Central New York Regional Transportation Authority

**Syracuse, NY**

ADA Complementary Paratransit Service

Compliance Review

April 23--26, 2007

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**With**

**TranSystems, Inc.**

**Final Report: March 5, 2008**

**CONTENTS**

1.  
2.  

[Purpose of the Review 1](#purpose-of-the-review)[Overview
3](#overview)[2.1 Pre-Review 3](#pre-review)

[2.2 On-Site Review 4](#on-site-review)

3.  

[Background 8](#background)[3.1 Description of ADA Complementary
Paratransit Service
11](#description-of-ada-complementary-paratransit-service)

[3.2 Call-A-Bus ADA Complementary Paratransit Performance Standards
12](#call-a-bus-ada-complementary-paratransit-performance-standards)

[3.3 Consumer Input 14](#consumer-input)

4.  
5.  

[Summary of Findings 20](#summary-of-findings) [ADA Complementary
Paratransit Service Criteria
28](#ada-complementary-paratransit-service-criteria)[5.1 Consumer
Comments 28](#consumer-comments)

[5.2 Service Area 28](#service-area)

[5.3 Days and Hours of Service 29](#days-and-hours-of-service)

[5.4 Fares 30](#fares)

[5.5 Findings 32](#findings)

[5.6 Recommendations 32](#recommendations)

6.  

[ADA Complementary Paratransit Eligibility
34](#ada-complementary-paratransit-eligibility)[6.1 Consumer Comments
34](#consumer-comments-1)

[6.2 Eligibility Determination Procedures and Practices
35](#eligibility-determination-procedures-and-practices)

[6.3 Determination Outcomes and Processing Time
42](#determination-outcomes-and-processing-time)

[6.4 No-Show Suspensions 46](#no-show-suspensions)

[6.5 Findings 48](#findings-1)

[6.6 Recommendations 51](#recommendations-1)

7.  

[Telephone Access 53](#telephone-access)[7.1 Consumer Comments
53](#consumer-comments-2)

[7.2 Phone Service Standards and Performance Monitoring
53](#phone-service-standards-and-performance-monitoring)

[7.3 Call Center Staffing 55](#call-center-staffing)

[7.4 Findings 58](#findings-2)

[7.5 Recommendations 58](#recommendations-2)

8.  

[Trip Reservations and Scheduling
60](#trip-reservations-and-scheduling)[8.1 Consumer Comments
60](#consumer-comments-3)

[8.2 Trip Reservations 61](#trip-reservations)

[8.3 Scheduling 68](#scheduling)

[8.4 Findings 71](#findings-3)

[8.5 Recommendations 73](#recommendations-3)

9.  

[Service Performance 75](#service-performance)[9.1 Consumer Comments
75](#consumer-comments-4)

[9.2 Service Policies 76](#service-policies)

[9.3 Trip Disposition 79](#trip-disposition)

[9.4 On-time Performance 80](#on-time-performance)

[9.5 Trip Duration 83](#trip-duration)

[9.6 Service Procedures and Practices
87](#service-procedures-and-practices)

[9.7 Findings 93](#findings-4)

[9.8 Recommendations 94](#recommendations-4)

10. 

[Resources 97](#resources)[10.1 Budget Process 97](#budget-process)

[10.2 Operating Resources 98](#operating-resources)

[10.3 Findings 101](#findings-5)

[10.4 Recommendations 101](#recommendations-5)

*Attachment A* CNYRTA Response

*Attachment B* On-Site Review Schedule

*Attachment C* Call-A-Bus -- A Brief History

*Attachment D* SCAT Service Description

*Attachment E* Call-A-Bus -- An Introduction

*Attachment F* Call-A-Bus Rider's Guide

*Attachment G* Call-A-Bus Service Standards

*Attachment H* Call-A-Bus (Onondaga County) Application Form

*Attachment I* Call-A-Bus (Onondaga County) Sample Eligibility
Determination Letters

*Attachment J* Utica and Rome (Oneida County) Application Forms

*Attachment K* Centro -- Call-A-Bus Eligibility Appeal Policy

*Attachment L* Call-A-Bus (Onondaga County) No-Show Materials

*Attachment M* Road Supervisor Worksheet Calculating Distance from Bus
Route

*Attachment N* Utica (Oneida County) Trip Denial Log

*Attachment O* Description of CNYRTA Funding

# Purpose of the Review

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 disabilities, 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 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 Federal grantees.

The primary purpose of these reviews is to assist the transit agency and
FTA in determining whether capacity constraints adversely affect
provision of ADA complementary paratransit services. The reviews examine
policies and standards related to service capacity, such as on-time
performance, on-board travel time, telephone hold times (also referred
to as time in queue), 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. The examination of patterns and practices
includes looking not just at service statistics, but also at basic
service records and operating documents, interviewing people responsible
for service delivery, 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 consumers.
Guidance is provided to assist the transit provider in monitoring
service for capacity constraints.

An on-site compliance review of ADA complementary paratransit service
provided by the Central New York Regional Transportation Authority's
(CNYRTA) Centro transit operation subsidiaries was conducted on April 23
to 26, 2007. Planners Collaborative, Inc., located in Boston,
Massachusetts, assisted by TranSystems, Inc., with offices in Medford,
Massachusetts, conducted the review for the FTA Office of Civil Rights.
As will be addressed further in section 3 of this report, CNYRTA is the
parent organization that oversees a number of divisions that provide
transportation services. The divisions that provide transit services are
known as Centro. In some cases responsibilities appear to be shared or
overlap between CNYRTA and its Centro divisions. This report attempts to
reference the responsible entity throughout the report, but its
objective is to assess service, regardless of what CNYRTA division is
actually providing the particular aspect of service. The review focused
on compliance of Centro's ADA complementary paratransit service with the
regulatory service criterion: "capacity constraints." Section 37.131(f)
of the regulations requires that ADA complementary paratransit services
be operated without capacity constraints. The review also included
observations of service criteria for eligibility, service area, hours of
operation, and fares.

This report summarizes the observations and findings of the on-site
review of Centro'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 Centro---fixed route bus and ADA complementary paratransit
service---is presented. All of the findings of the review are summarized
in Section 4. Section 5 includes observations on service area, hours,
and fares. Section 6 addresses observations on ADA complementary
paratransit eligibility. Observations and findings related to each
element of the capacity constraint criteria are then presented in
Sections 7 through 9. Adequacy of resources to provide service is
addressed in Section 10. Recommendations for addressing some of the
findings are also included for consideration by CNYRTA and Centro.

CNYRTA was provided with a draft copy of the report for review and
response. A copy of the correspondence received from CNYRTA on January
4, 2008, documenting its response to the draft report, is included as
Attachment A.

# Overview

This review focused on compliance with the ADA complementary paratransit
capacity constraints requirements of the DOT ADA regulations. These
regulations identify several possible types of capacity constraints.
These include "wait-listing" trips, having caps on the number of trips
provided, or recurring patterns or practices that result in a
significant number of trip denials, untimely pickups, or excessively
long trips. Capacity constraints also include other operating policies
or practices that tend to significantly limit service to persons who are
ADA complementary paratransit eligible.

To assess each type of capacity constraint, the review focused on
observations and findings regarding:

-   Trip denials and "wait-listing" of trips

-   On-time performance

-   Travel times

The review team also made observations and findings related to three
other areas of policies and practices that could affect access to ADA
complementary paratransit service:

-   Service area, service times, and fares

-   ADA complementary paratransit service eligibility process

-   Telephone capacity

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.

## Pre-Review

Prior to the on-site visit, the review team examined relevant service
information provided by CNYRTA. This information included:

-   A description of the organization of CNYRTA, Centro, and Centro's
    ADA complementary paratransit service

-   Public information describing the ADA complementary paratransit
    service

-   Copies of contracts with the service contractors

-   A description of Centro's standards for on-time performance, trip
    denials, travel times, and telephone service

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

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

-   Six months of service data, including the number of trips requested,
    scheduled, denied, and canceled, and the number of no-shows, missed
    trips, and trips provided by Call-A-Bus (CAB)

-   A breakdown of trips requested, scheduled, and provided by
    recognized geographic areas, communities, or zones

-   A listing of trips denied each month showing the customer's name,
    origin, requested destination, day and time, and if the person was
    ambulatory or used a wheelchair

-   On-time performance information

-   A listing of trips that exceeded the trip length standard showing
    the customer name, origin and destination, day and time, if the
    person was ambulatory or used a wheelchair, and the total time on
    board

-   Telephone call management records showing hold times by day and
    time, total call volume, and calls answered and abandoned

-   A list of complaints related to ADA complementary paratransit
    capacity constraints in the past year. The list was to include all
    complaints related to trip denials, trip limits, on-time
    performance, lengthy trips, phone capacity issues, etc. For each
    complaint, additional information was requested showing the
    customer's name, trip origin, date and type of complaint, carrier,
    and resolution (any corrective actions requested and taken)

## On-Site Review

An on-site review of the service was conducted from April 23 to 26,
2007. The on-site review began with an opening conference, held at 9
a.m. on Monday, April 23, 2007. In attendance were the following:

Frank Kobliski Executive Director CNYRTA

Steve Share Sr. Vice President, Finance & Administration CNYRTA

John Renock Sr. Vice President, Corporate Operations CNYRTA

Charles Acevedo CNYRTA

Joe DeGray CNYRTA

Sharon Keener Customer Service Supervisor CNYRTA

Betty Petrie Project Manager CNYRTA

David Ristau Director of Marketing CNYRTA

Leo Williams CNYRTA

Linda McKeown Manager, Specialized Transportation Call-A-Bus

James Bacon Call-A-Bus

Bill Hutson Centro of Cayuga

Ronald S. Bucciero General Manager Centro of Oneida

Maria Zongrone Manager of Operations Centro of Oneida

Kathy Kintz Centro of Oswego

Lettie Cardona Specialized Transportation Supervisor CNY
Centro--Syracuse

Don Kidston Lead Reviewer Planners Collaborative

Russell Thatcher Reviewer TranSystems

Tom Procopio Reviewer TranSystems

Participating by telephone was David Knight of FTA's Office of Civil
Rights. Mr. Knight thanked CNYRTA for its cooperation. He described the
purpose of the review and emphasized that it was intended to assist
CNYRTA in providing effective ADA complementary paratransit service.

Mr. Kobliski indicated that he looked forwarded to a dialogue with FTA
and its reviewers as a means to service improvement.

Don Kidston, team leader for the review, described the objective of the
review to identify significant impediments, if any, to people with
disabilities receiving the service to which they are entitled under ADA,
and to assist CNYRTA 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. He explained that the areas to be addressed included service
design criteria, eligibility, telephone access, reservations and
scheduling, operating procedures, practices and performance, and
adequacy of resources. He then presented the schedule for the on-site
review, including the elements of the operation that would be observed
for each day of the review. A copy of the review schedule is provided in
Attachment B.

Mr. Knight acknowledged the shared FTA and CNYRTA goal of good service.
He also noted that the review team would make every effort to avoid
interfering with Centro's efforts to provide service during the on-site
review.

The reviewers' activities during the week generally followed the
schedule in Attachment B. Modifications to the schedule were made to
focus on divisions with higher trip volumes. As a result, site visits to
CAB in Cayuga, Oswego, and Rome were canceled. Instead, one review team
member, Russell Thatcher, spent Tuesday afternoon in Utica reviewing
eligibility practices as well as operations. Tom Procopio observed Blue
Chip, a contract service provider in Syracuse, on Tuesday morning, and
Don Kidston visited Kelly, another contract provider, on Wednesday
morning. Other minor modifications to the schedule were made to
accommodate the availability of CNYRTA staff.

An exit conference was held at 1 p.m. on Thursday, April 26, 2007. In
attendance were the following:

Frank Kobliski Executive Director CNYRTA

Steve Share Sr. Vice President, Finance & Administration CNYRTA

John Renock Sr. Vice President, Corporate Operations CNYRTA

Charles Acevedo CNYRTA

Joe DeGray CNYRTA

Linda Dotter CNYRTA

Betty Petrie Project Manager CNYRTA

David Ristau Director of Marketing CNYRTA

Ronald S. Bucciero General Manager Centro of Oneida

Maria Zongrone Manager of Operations Centro of Oneida

Don Kidston Lead Reviewer Planners Collaborative

Russell Thatcher Reviewer TranSystems

Tom Procopio Reviewer TranSystems

David Knight and Jonathan Klein of FTA's Office of Civil Rights,
participated by telephone.

Mr. Knight opened the exit conference by thanking the CNYRTA staff for
their cooperation in the review. Mr. Klein provided CNYRTA with FTA
Office of Civil Rights contact information should there be any
questions. He then described the procedure for report preparation and
review and subsequent progress reporting. He identified late June 2007
as the time the draft report should become available for CNYRTA review
and comment and late August 2007 as the expected time the final report
would be completed. The actual dates when the draft and final reports
were made available were delayed from those described at the closing
conference. Mr. Klein also explained that the final report would become
a public document and be posted on FTA's website. Quarterly progress
reporting will be required until all report findings have been addressed
to FTA's satisfaction.

The review team members then presented an overview of the assessment and
initial observations and findings in each of the following areas:

-   Consumer input

-   Service design parameters

-   Eligibility determinations

-   Telephone access

-   Trip reservations and scheduling procedures

-   Service performance

    -   Trip denials

    -   On-time performance

    -   Trip duration

    -   Missed trips

-   Reservations observations

-   Trip scheduling

-   Dispatching and carrier operations

-   Operator interviews

-   Resources (vehicles, manpower, and financial resources)

In response to a description of some findings relating directly to the
capacity constraint or other requirements of the regulations and others
having an indirect or contributing relationship, Mr. Kobliski asked how
CNYRTA would be able to make the required distinctions. Mr. Kidston
replied that those policies, procedures, and practices that
significantly impede an individual who is eligible for ADA complementary
paratransit service from obtaining that service would be a regulatory
compliance concern.

Mr. Bucciero asked how quickly Centro would need to respond to findings
given limitations such as the need to reach agreement with labor unions.
Mr. Kidston replied that FTA would expect positive and expeditious
progress in addressing findings on issues that may be a regulatory
compliance concern, while recognizing the needs of CNYRTA and its Centro
subsidiaries to follow applicable contractual and administrative
procedures.

Mr. Knight and Mr. Kidston thanked CNYRTA for its cooperation and
positive approach to the review.

# Background

The Central New York Regional Transportation Authority (CNYRTA) was
formed in 1970 and began operation of public bus service on January 17,
1972.

CNYRTA is a public authority and a public benefit corporation of New
York State, created in 1970 by Title 11-D of Public Authorities Law. Its
legislated purpose is to continue, further develop, and improve
transportation and related services in the Central New York Regional
Transportation District, which originally included Onondaga County and
could include Cayuga, Cortland, Jefferson, Madison, Oneida, and Oswego
Counties by election of those legislative bodies. To date, Oswego and
Cayuga (both 1973) and Oneida (2005) Counties have joined Onondaga
County (1970) as members of the District.

CNYRTA provides transit services through public benefit subsidiary
corporations. Public transit service is provided through five subsidiary
bus operations in four counties of central New York. CNY Centro, Inc.
serves Onondaga County; Centro Oneida, Inc, Centro Oswego, Inc, and
Centro Cayuga, Inc. each serves the county for which it is named; and
CAB provides paratransit service in Onondaga County. Responsibilities of
each subsidiary are more fully described later in this section of the
report.

In 1993, Centro services expanded to absorb the operations of two
private bus operators, who provided subsidized public services in and
between Onondaga, Oswego, and Cayuga Counties. The private operators had
indicated their desire to discontinue operations. At the request of
local and state officials, and with their financial support, CNYRTA
absorbed these operations and was able to smoothly and efficiently
integrate them into Centro service.

In the early 2000s, both Utica Transit Authority (UTA) and City of
Rome's public transportation system (VIP) experienced difficulties to
the extent that they were considering discontinuation of service. In
late 2004, officials from these cities and Oneida County (where these
cities are located) and the state proposed that the transit services be
assumed by CNYRTA. As a result, the UTA operation was merged with CNYRTA
effective April 1, 2006. The City of Rome VIP program joined the
Authority on October 1, 2006.

CNYRTA also operates two subsidiaries that do not provide transit
service. A separate parking management subsidiary was formed in 1977 to
operate certain parking facilities. Another subsidiary was formed in
1995 for the purpose of owning, constructing, and operating an
intermodal transportation facility located in the City of Syracuse.

Centro Parking, Inc., manages, under contract, a state-owned two-level
parking garage and nearby ground lots in Syracuse for the State
University of New York (SUNY) Upstate Medical University. It also
operates monthly/daily public parking lots located under U.S. Interstate
81 in Syracuse, which are leased from the State of New York.

Intermodal Transportation Center, Inc. (ITC, Inc.) is a subsidiary
created in 1995 to build, own, and operate the William F. Walsh Regional
Transportation Center located on P&C Parkway near the Carousel Center in
Syracuse. This intermodal transportation facility provides a direct link
between Centro's local and regional mass transit services, intercity bus
carriers (Greyhound/Trailways), and intercity passenger rail (Amtrak).
Prior to the creation of this facility, there was no easy way for the
traveler to transfer among these modes of transportation. This facility
opened to the public in July 1999 for intercity bus service, with Amtrak
commencing service into the facility in November 1999.

CNYRTA and its subsidiaries are governed by a Board of Members
consisting of representatives from the four counties and the City of
Syracuse. A list of at least two persons for each position is created
and approved by the legislative bodies of the above entities, and is
then submitted to the Governor's Office. Members are appointed by the
Governor with the advice and consent of the New York State Senate. Terms
are for fixed staggered seven-year periods beginning July 1, with
members continuing to serve until their successors are appointed and
have qualified. Members may be reappointed for subsequent terms by the
same process. Officers of the Board (chairperson, vice-chairperson,
secretary, and treasurer) are elected by the Board of Members.

CNYRTA and all of its subsidiaries are headed by an executive director,
who is hired by and reports directly to the Board of Members.

The subject of this review is the ADA complementary paratransit service
provided by CAB in Syracuse and the CNYRTA Centro subsidiaries in
Cayuga, Oneida, and Oswego Counties.

CNY Centro provides fixed route public transit services in Onondaga
County in Syracuse and surrounding areas using approximately 161
full-sized transit buses. CNY Centro is by far the largest Centro
subsidiary and provides primary functions (heavy maintenance, planning,
scheduling, accounting, human resources, and many other administrative
and support functions) for all subsidiaries.

Centro of Oswego, Inc., provides fixed route public transit and ADA
complementary paratransit services in Oswego using approximately 11
large transit buses and five vans. It provides extensive service to and
within the SUNY Oswego campus, service within the cities of Oswego and
Fulton, service between Mexico, Fulton, and Oswego, and regional service
connection to the William F. Walsh Regional Transportation Center in
Syracuse. It operates out of a light maintenance/office facility in the
City of Oswego.

Centro of Cayuga, Inc., provides fixed route public transit and ADA
complementary paratransit services utilizing approximately 15 large
buses and one small vehicle. It provides service within the City of
Auburn, and commuter services between Auburn, Weedsport, Port Byron, and
employment centers and the Regional Transportation Center in Syracuse
using several different routes. Service is operated from a light
maintenance/office facility located in the City of Auburn. The primary
provider of ADA paratransit services in the Cayuga area is Senior
Citizen Aid to Transportation (SCAT), a private nonprofit organization.
SCAT serves Centro ADA customers as a Centro contractor. Centro
supplements SCAT service during hours when SCAT is not operating.

Centro of Oneida, Inc., is the newest addition to CNYRTA, joining the
Authority in 2005. This subsidiary provides fixed route public transit
and ADA complementary paratransit services with 34 large transit buses
and eight small buses. It provides services to two areas, one in the
vicinity of Utica and the other in the vicinity of Rome. Nearby
communities served include New Hartford, Whitesboro, and New York Mills.
Services include routes to SUNY and community college campus locations,
along with major employment sites such as Griffiss Technology Park.
Centro has customer information centers and transit hubs in the Utica
and Rome central business districts. The main administrative offices and
maintenance facility are located in Utica.

CAB provides demand responsive services and serves as Centro's ADA
complementary paratransit service provider in Onondaga County. CAB also
provides coordinated transportation services for senior citizens of
Onondaga County and provides rides for low-income residents of the
county seeking employment or re-employment in its Rides for Work
Program. CAB may provide service to clients using its own vehicles, CNY
Centro fixed route buses, and private transportation provider operators
and vehicles under contract. Its offices are housed within the main
Centro facility in Syracuse. Its fleet consists of 22 small buses, all
located and maintained in the main facility.

Centro serves 2,500 passenger trips per day on its fixed route services
and specialized services for the New York State Fair, Syracuse
University, and Oswego State University. Over the course of a year,
Centro provides approximately 12 million rides and 5.2 million miles of
service with a combined fleet of 258 large and small buses in four
counties (Onondaga, Oneida, Oswego, Cayuga). At the time of the on-site
review, 120 buses were powered by compressed natural gas (CNG), with
that number scheduled to increase during spring 2007. All buses have
wheelchair lifts or ramps. CNYRTA has over 670 full- and part-time
employees, including bus operators, bus mechanics and technicians,
facilities maintenance, and office staff.

Reporting directly to the executive director are five senior staff
members, including two senior vice presidents (for corporate operations
and finance/administration) who direct multiple functions, and three
directors (for marketing, human resources, and planning). The senior
vice president for corporate operations oversees the operations of all
bus subsidiaries, including CAB. He is responsible for building and
vehicle maintenance, labor relations, safety and security, and the
Regional Transportation Center.

Bus operators, mechanics, servicers, and building maintenance employees
at the Centro bus operations in Onondaga, Oswego, and Cayuga are
represented by Amalgamated Transit Union (ATU) Local 580. These same
employee classes in the City of Rome are also represented by ATU, but
have their own local (Local 582). The bus operators and mechanics of
Centro of Oneida's Utica Division are represented by the United Public
Service Employees Union (UPSEU).

## Description of ADA Complementary Paratransit Service

CNYRTA established a dial-a-ride system for the elderly and disabled in
the 1970s, before it became a requirement under the ADA. In 1992, CNYRTA
adopted its *ADA Service Plan*. A brief history of CAB appears in
Attachment C.

Central administrative responsibilities in each county are handled as
follows:

-   In **Onondaga County**, the specialized transportation manager has
    overall responsibility for CAB services.

-   Office staffing in **Oswego** **County** and **Cayuga County**
    consists of a manager and administrative coordinator with support
    from a Centro division supervisor during evenings and weekends.

-   In Utica in **Oneida County**, two dispatchers are responsible for
    ADA complementary paratransit operations with support from the
    Centro operations manager.

-   In Rome in **Oneida County**, one dispatcher with assistance of an
    operator/dispatcher is responsible for ADA complementary paratransit
    service.

The following paragraphs describe operator and vehicle operations in
each county:

In **Oswego County** and **Oneida County**, transportation service is
operated with Centro operators and vehicles.

In **Cayuga County**, between the hours of 7 a.m. and 3 p.m., service is
provided through a contract with SCAT, a private nonprofit
transportation service provider. The contract with SCAT specifies that
CNYRTA pay SCAT a fixed fee of \$5,000 per year plus an amount of \$2
for each trip provided to individuals who are registered as ADA
complementary paratransit customers. Centro operators and vehicles
provide service during the remaining hours of the service day.

A brief description of SCAT services taken from its website appears in
Attachment D. SCAT service is provided by two paid staff and volunteer
operators, using eight lift-equipped vans. According to CNYRTA managers,
many ADA eligible individuals contact SCAT directly to reserve trips.
*Call-A-Bus -- An Introduction* (Attachment E) and the *Call-A-Bus
Rider's Guide* (Attachment F) both direct ADA eligible customers to call
the Cayuga CAB office to schedule trips.

In **Onondaga County**, service is provided by Centro CAB operators and
vehicles supplemented by services of four contractors.

-   **Peace, Inc**., is a transportation service provider that provides
    services for Head Start and other programs. Ten Peace operators are
    assigned to Centro to operate CAB vehicles. Their regular work
    procedures are the same as those of Centro CAB operators.

-   **Blue Chip** **Transportation, Inc.,** provides operators and
    body-on-chassis vehicles to operate three weekday ADA runs and one
    weekend ADA run. Blue Chip also operates four blended runs on
    weekdays and two on Saturdays. The blended runs serve ride-to-work
    and elderly customers as well as ADA customers. Customer eligibility
    is tracked by fare and the same service standards that apply to ADA
    are used on these mixed runs. The vehicle schedules are provided by
    Centro. When operators are driving on the road they report to the
    Centro dispatcher. The three weekday runs total 24 to 30 operator
    hours per day. Weekend work consists of approximately 16 operator
    hours per day. Blue Chip is reimbursed at a rate of \$38/operator
    hour.

-   **Kelly** **Transportation, Inc.,** (also referred to as Kelly Bella
    Via and North Area) is a taxi company. Kelly is assigned two blended
    runs each weekday. The runs are operated using Centro pre-approved
    operators, who have been drug and alcohol certified, and
    pre-approved sedans. The sedans are not equipped with ramps. Centro
    pays Kelly an hourly rate for these runs. Kelly is also assigned
    trips to two additional runs on an as-needed basis. Many of these
    trips are assigned on the day of service. Reimbursement for these
    trips is on a per-passenger trip basis.

-   **Able Medical Transportation, Inc.**, operates two weekday split
    runs with raised-roof vans. The runs are primarily for ADA group
    trips with some ADA demand customers as well. The vans can
    accommodate only people who are ambulatory.

A fifth contractor, CNY Sedan Services, is available to provide service,
as needed, with one or two taxis. CNY Sedan is paid on an hourly basis
for these services.

The assistant manager of the Onondaga CAB program is responsible for the
ADA complementary paratransit eligibility process for Onondaga, Oswego,
and Cayuga Counties. In Oneida County, service eligibility is the
responsibility of the two dispatchers in Utica under the supervision of
the manager of operations. At the time of the review, a total of 5,464
individuals had been determined to be ADA paratransit eligible in
Onondaga, Oswego, and Cayuga Counties.

There are five call centers, one for each county with the exception of
Oneida, which has call centers in both Rome and Utica. Scheduling for
each of the five service areas is done at the respective call centers.

Pre-registered customers can call the appropriate CAB call center
between 8 a.m. and 5 p.m., seven days a week, to reserve trips from one
to 14 days before the day of travel. On weekdays, trip requests are
accepted by an operator between 8 a.m. and 5 p.m. On weekends and
holidays, all trip requests are taken by the answering machine.

## Call-A-Bus ADA Complementary Paratransit Performance Standards

Performance standards provided for CAB service by CNYRTA are presented
in Attachment G, *Call-A-Bus Service Standards -- Amendment to the ADA
Plan of 1992*.

With respect to service delivery, the performance standards address:

-   trip denials

-   missed trips

-   no-shows

-   on-time performance

-   trip length

-   telephone access

As described in Attachment G, "a **trip denial** is any event where an
eligible customer is denied an eligible ride if the request is made in
the appropriate timeframe." The definition of eligible customer is
further addressed in Section 6 of this report; eligible trip is further
discussed in Section 8. CNYRTA managers defined appropriate timeframe as
the beginning of Centro normal business hours 14 days before the travel
day to the end of Centro normal business hours on the day before the
travel day. Normal business hours for Utica are from 8:30 a.m. to 4:30
p.m. for Centro of Oneida and 8 a.m. to 5 p.m. for all other Centro
divisions. Reservation timeframes are further addressed in Sections 7
and 8 of this report.

A **missed trip** is an event where the vehicle fails to arrive for a
scheduled pickup. CNYRTA managers further defined a missed trip as
occurring when a trip is not completed and the vehicle fails to appear
at the pickup location between 5 minutes before and 25 minutes after the
time negotiated with the customer, or fails to wait for the customer for
5 minutes from the time of arrival or 5 minutes from the negotiated
time, whichever is later. The negotiated time is also the scheduled
time. The time period, 5 minutes before to 25 minutes after the
negotiated time, is commonly referred to as the pickup window and in
this report may be presented as "-5/+25." The CAB standard for maximum
number of missed trips is three for any operating division in one month.

CNYRTA managers described a **no-show** as occurring when the vehicle is
at the pickup location between the negotiated time and 25 minutes after
the negotiated time and the customer does not appear to board the
vehicle within 5 minutes of the negotiated time or arrival of the
vehicle, whichever is later. Managers described "cancel at door" as a
no-show for purposes of initiating customer suspension proceedings. A
"cancel at door" occurs when the vehicle is at the pickup location, in
the pickup window, and the customer declines the trip. No-shows can
result in suspension of service to the customer. Three no-shows in 30
days results in a warning; three additional no-shows in the next 30 days
may result in a customer suspension of service for 30 days with
notification by certified letter. One no-show in the 30 days following
service suspension may result in a six-month service suspension.

In materials provided to FTA before the review, Centro defines an
**on-time trip** as occurring when the vehicle arrives at the pickup
location any time in the pickup window (-5/+25). CNYRTA managers further
defined an on-time trip as the vehicle arriving before the end of the
pickup window (0/+25). The *Call-A-Bus Rider's Guide* on the CNYRTA
website describes an on-time trip (page 21) as arriving within the
on-time window and describes the window (page 19) as up to 25 minutes
after the scheduled pickup time (0/+25). This on-time definition is also
described in the Centro newsletter, *Accessible Transportation Matters*.
Centro's standard for on-time performance is 95 percent of trips on time
per month. In addition to limiting all late trips to 5 percent, Centro
also has a standard for late pickups for which the operator is the
cause---as opposed to late trips resulting from unforeseen conditions
over which CAB has no control. According to CNYRTA managers, late trips
caused by the operator are categorized as "Missed but Transported." The
CAB standard for missed but transported trips is three for any operating
division in one month.

CAB performance standards for **trip length** are: "Trips of five miles
or less shall be accomplished in 60 minutes or less. Trips greater than
five miles to less than 10 miles shall be accomplished in 90 minutes or
less. Trips greater than 10 miles shall be accomplished in 2 hours or
less. CAB shall maintain a 95% or better compliance rate per month,
measured at the division level."

The CAB standard for **telephone access** is that calls will not be left
on hold for more than 2 minutes and that this standard will be achieved
at least 85 percent of the time by each division.

## Consumer Input

Prior to 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. Team members reviewed a
formal complaint on file with FTA, conducted telephone interviews with
CAB customers and customer advocates, and reviewed customer CAB
complaints on file with Centro.

**Formal ADA Complaints Received by FTA**

On August 22, 2006, FTA received a formal complaint (No. 06-0273)
regarding Centro ADA complementary paratransit service. The complainant
indicated she had been a customer of the Onondaga County CAB service
since 2001. She alleged that the service was not the equivalent of
Centro's fixed route bus service. A second complaint was filed by the
same person on September 22, 2006. The complainant also identified
service issues in associated e-mails to FTA between the time of the
initial complaint and October 3, 2006. Specific issues related to
compliance with the ADA cited in the complaints and associated
correspondence included:

-   Public Information

1.  Disabled riders were denied informational tours of the CAB
    scheduling unit

2.  Riders were denied access to a Centro meeting with agency
    representatives

3.  Transportation coordinators refused to answer questions on how the
    system worked

-   Eligibility

1.  Transportation coordinators with no medical training determined ride
    eligibility based on medical diagnoses, not functional limitations

2.  Users of power wheelchairs were denied eligibility

3.  CAB applicants were not receiving responses within 21 days.

4.  Eligibility decisions were inappropriate

5.  People with psychiatric disabilities were not properly considered in
    the eligibility process

-   Reservations/Scheduling

1.  Hold times were as long as 10 minutes and there were periods when
    all lines were busy

2.  Rides were not confirmed at the time of request

3.  Ride times were not negotiated

4.  Rides were scheduled 1 hour from fixed route schedule times not
    customer requested times

5.  Trips were provided only one way, either for the going or return
    trip but not both

6.  ADA eligible ride orders were refused

7.  Rides for medical treatment were given priority

8.  Cancellation/Information Line was often busy or unanswered

-   Service

1.  Excessively long rides were frequent

2.  Operators failed to tie down wheelchairs at four points

3.  Late pickups and arrivals occurred

4.  Substandard vehicles were used

On October 5, 2006, FTA advised the complainant that issues raised in
the complaint that were related to compliance with the ADA would be
addressed as part of this review and that FTA would take no further
action directly in response to the complaint.

**Consumer Interviews**

Prior to the review team's site visit, team members conducted telephone
interviews with 12 customers and customer advocates of CAB, Centro's ADA
complementary paratransit service in Onondaga County. One additional
customer was interviewed after the site visit. One of those interviewed
lives outside of the service area and does not use CAB. He advocates
expansion of the service area. Two of the remaining 12 people
interviewed identified themselves as advocates for people with
disabilities. Eleven of those interviewed, including one of the
advocates, are users of the service. Four of those interviewed
identified themselves as blind or having vision impairments. The
interviews were used to gain a better insight into, and identification
of, issues to be addressed during the on-site review. Concerns raised in
the interviews are summarized in the following paragraphs.

**Eligibility Process.** Six of those interviewed cited problems with
eligibility. Of those who had problems, most described the process as
confusing. Other issues cited included inadequate consideration of path
of travel to bus stops, confusing criteria for considering a customer's
functional ability, particularly people with cognitive disabilities, and
unclear communication/ understanding of conditional eligibility and
courtesy rides.

Three interviewees mentioned that it took months to become eligible but
believed that performance has since improved. One customer who had
received notification that she could use the service was unable to
reserve a trip because her ID number was not in the system.

**Telephone Access.** Customers identified difficulty reaching trip
coordinators (also called "reservationists" or "call-takers") after 3
p.m., with some calls going unanswered. Most interviewees said that hold
times during these periods could range from 10 to 20 minutes. During
other times of day, customers indicated that hold times range from 0 to
5 minutes.

**Trip Reservations.** Almost all customers believed they had to call
back between 3 and 7 p.m. on the day before service to confirm their
trips. One indicated that he could not reserve a trip after 2:30 p.m.
One customer thought that the trip would not be guaranteed if he tried
to negotiate on the initial call. Three customers said that their trip
requests were not always honored and others cited confusion about
conditional eligibility and "courtesy trips." One customer indicated
that he was denied an evening trip at a time and in an area served by
fixed route. Several mentioned confusion about the pickup window. One
person said it was 10 minutes and another 45 minutes, but no one knew
the correct window. There were several comments that customers were
scheduled to a vehicle they were unable to board. Customers cited trips
for appointments being scheduled too early or too late. In general,
customers appeared to find the multiple calls and rules regarding trip
reservations confusing.

**On-time Performance.** Although no interviewees understood the on-time
pickup window, most indicated that pickups were usually made on time.
Four customers mentioned that some pickups occurred 20 to 30 minutes
early or late and operators had different pickup times in their
manifests from those given to customers.

Four respondents indicated that they were usually dropped off at
appointments on time. Four customers cited drop-offs that were 30 to 60
minutes early.

**Operator Knowledge.** Most customers were very complementary of
regular CAB operators. Five interviewees indicated that operators do a
good job with directions and use of equipment, and are sensitive. Five
others indicated that the regular operators did well but backup
operators and contract operators get lost. Problems with backup
operators' use of lifts and air conditioning, courtesy, and beeping
horns upon early arrival were also cited. One customer commended the
operators' ability to drive in snow.

Several interviewees cited problems with identifying the CAB vehicle.
One customer, who is unable to wait outside in winter, mentioned being
unable to see the vehicle from inside a building. Other customers
mentioned difficulty in identifying contractor vehicles and CAB vehicles
covered with shrink-wrap advertising.

One interviewee was concerned that Bella Via (Kelly) operators were not
properly screened and licensed.

**Long Trips.** Three customers had no problems with long trips, four
had occasional problems, and three cited long trips associated with
traveling long distances, circuitous routing, and vehicles filled with
as many as eight passengers.

**Complaint Resolution.** Six interviewees had filed complaints. They
indicated that the responses ranged from non-existent to very good.
Three interviewees said they thought customers were intimidated and
unwilling to make complaints.

**Other.** One interviewee said that a subcontractor, Blue Chip, was
using bungee cords as wheelchair tie downs, but that the problem had
been corrected. Another questioned the adequacy of Bella Via (Kelly)
taxis for paratransit service.

One customer was stuck on an inoperable lift and neither the operator
nor the road supervisor had the tool needed to operate the lift
manually. As a result, the customer was stuck on the lift for a long
time before a mechanic lowered it.

Several interviewees cited the need for better communication. One issue
identified by customers was that non-CAB vehicles were not readily
identifiable. On the other hand, several also noted recent service
improvement.

**Rider Comments on File at Centro**

In 2005, Centro instituted a central complaint management program. The
new program is managed as a customer service function under the
direction of the manager of marketing and communications. The program is
designed to encourage customer input as a means of identifying and
tracking customer concerns and, in turn, improving service. A
computerized complaint tracking and reporting system was established in
2005 with a separate track for CAB comments and complaints. In 2006,
monthly reports were developed that tracked four categories of CAB
complaints:

-   operator courtesy

-   bus running late

-   not letting customer off at requested stop

-   miscellaneous

In Centro's online *Call-A-Bus Rider's Guide*, a telephone number, an
e-mail address, and mailing address are provided for submittal of
comments, compliments, and complaints. The version of the guide mailed
to the review team by CNYRTA instructs customers to call the local
Centro Customer Service Office and provides a different e-mail address
than that on the website for customer comments. The *Accessible
Transportation Matters* newsletter provides the same contact information
as the website. The newsletter is distributed through social service
agencies. Centro is further soliciting customer complaints by
distributing flyers with the complaint telephone number in CAB vehicles.
Direct mailings to active CAB users are also under consideration once
the list of registrants is updated.

Since the last calendar quarter of 2006, all complaints and comments are
to be directed to CNYRTA's customer service supervisor. When complaints
or comments are received, Centro records a summary of the complaint in
the tracking system and assigns the complaint a number. A postcard
acknowledgement of the complaint with the complaint file number is
issued within one day of receiving the complaint. The complaint is
forwarded to the responsible department for investigation and response.
The department response is normally made in seven to 10 days, with a
target of responding to the customer within two weeks from receipt of
the complaint. Centro responds to customer complaints by letter or
e-mail. Notably, in order to better monitor service and safety, Centro
is installing audio and video surveillance equipment on all of its
passenger vehicles and telephone monitoring systems in all of its call
centers. This equipment should be helpful in investigating service
complaints.

**Centro File Observations**

CNYRTA managers provided summary monthly reports on CAB service for the
first three months of 2007. The reports are summarized in Table 3.1.

**Table 3.1 -- Summary of Call-A-Bus Complaints:** First Quarter of 2007

  ------------------------ ------------- -------------- ----------- -----------
                           **January**   **February**   **March**   **Total**

  **Complaint**                                                     

  Phone Access             1             1              0           2

  Reservations             3             1              4           8

  Not on Time              3             2              2           7

  Long Ride                0             0              1           1

  Wrong Stop               3             0              1           4

  Operator                 1             5              5           11

  Tie Downs                1             1              0           2

  Vehicle                  1             1              0           2

  Injury                   0             1              0           1

  **Total**                **13**        **12**         **13**      **38**

                                                                    

  **Operator               **1**         **1**          **0**       **2**
  Commendation**                                                    
  ------------------------ ------------- -------------- ----------- -----------

Complaints for the three western counties in the Centro service area
(Oswego, Cayuga, and Onondaga) are recorded collectively. Complaints for
Utica and Rome in Oneida County are kept separately. The review team
analyzed the complaint files for the western counties for the month of
January and Oneida County files for the year 2006. The results are
summarized in Table 3.2.

The review team also analyzed response times to customer complaints. Of
the 16 complaint files reviewed, there were six records of postcards in
the file. CNYRTA managers indicated that postcards were sent when each
complaint was received but were not always copied and placed in the
file. There were records of response for 10 of the 16 complaints. Of the
10 responses, there were seven written records and three notes of
response by telephone. CNYRTA should consider recording the dates of
postcard acknowledgements in the complaint file and also including a
written record (copy of letter or e-mail of the final response to all
complaints, including written record of follow-up of telephone
responses) in the file. This documentation can be helpful should
questions arise at a later date. CNYRTA managers indicated that they
would include such documentation in the files.

**Table 3.2 -- Review of Centro ADA Complementary Paratransit**
Complaint Files

  ------------------------- ----------------------- ------------ ----------
                            **Onondaga, Oswego, &   **Oneida**   
                            Cayuga Counties**                    

                                                    **Utica**    **Rome**

  **Complaint**             **January 2007**        **2006**     **2006**

  Eligibility               1                       0            0

  Phone Access              3                       0            0

  Reservations              6                       2            0

  Not on Time               2                       2            0

  Long Ride                 1                       0            0

  Wrong Stop                2                       0            0

  Operator                  2                       1            3

  Tie Downs                 3                       0            1

  Vehicle                   1                       1            0

  Injury                    0                       0            0

  **Total**                 **16**                  **6**        **3**

                                                                 

  **Operator Commendation** **2**                   **1**        **0**
  ------------------------- ----------------------- ------------ ----------

# Summary of Findings

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 CNYRTA. Recommendations are also included
in the body of the report for CNYRTA's consideration in developing
corrective actions.

## A. ADA Complementary Paratransit Service Criteria {#a.-ada-complementary-paratransit-service-criteria .unnumbered}

1.  At the time of the review team's visit, CAB was not serving certain
    locations that are within the ADA complementary paratransit service
    area. CAB's practice was to measure service area as the area within
    3/4-mile of a fixed route bus stop by way of the roadway system. The
    DOT ADA regulations define the service area as within 3/4-mile of
    any point on the fixed bus route, regardless of stop location or
    street configuration. The practice used by CAB resulted in a service
    area smaller than that required by the regulations. CAB indicated
    that it would immediately revise its practice to measure the
    3/4-mile service boundary as prescribed in the regulations.

2.  CAB may not be including core area islands in its service area. The
    regulations require these islands, which are described in the
    regulations as small areas within the core service area that are
    more than 3/4-mile from fixed route bus service but are surrounded
    by fixed route services, be included in the ADA complementary
    paratransit service area. By defining the service area on a
    route-by-route basis, CAB appears to be excluding these core service
    area islands from the service area.

3.  Reliance upon trip notes and the judgment of trip coordinators and
    road supervisors reviewing maps to determine whether locations are
    in the service area can lead to inconsistent determinations and a
    higher error rate than by using a predefined service area, which can
    be more easily enforced using maps or street addresses or other
    means.

4.  The practice of confirming service hours on a location-by-location,
    route-by-route basis appears to comply with the minimum requirements
    of the regulations. However, in service areas with multiple routes,
    this practice can be confusing to customers and can result in more
    inconsistent and incorrect decisions than using uniform ADA
    complementary paratransit service hours for such service areas. The
    latter method will result in service that meets or exceeds the ADA
    requirements.

5.  The CAB fares appear to comply with the requirement that ADA
    complementary paratransit fares be no greater than twice the full
    fare for a similar trip on the fixed route system.

6.  In the *Call-A-Bus Rider's Guide* on the Centro website, the ADA
    complementary paratransit fare for Oswego is cited as \$1.25, more
    than twice the fixed route fare of \$0.60 for the Oswego service
    area. This rate is inconsistent with the rate of \$1.20 cited in
    other public documents and appears to be the result of a typographic
    error. This apparently incorrect information can cause confusion
    among customers.

7.  Zone fares are apparently charged for CAB service in Onondaga
    County. These CAB zone fares are not described in any of the public
    information documents. The use of CAB zone fares, absent any
    description in public information documents, appears to be causing
    confusion among customers as to the correct fare.

## B. ADA Complementary Paratransit Eligibility {#b.-ada-complementary-paratransit-eligibility .unnumbered}

1.  The Centro CAB ADA complementary paratransit eligibility
    determination process and application form for Onondaga, Oswego, and
    Cayuga Counties do not appear to adequately address path-of-travel
    issues or the impacts of weather on travel abilities, and
    consequently paratransit eligibility appears to be improperly
    restricted. CAB has implemented an eligibility determination process
    that very strictly interprets ADA paratransit eligibility
    requirements. Determinations are primarily based on a paper
    application and do not appear to adequately consider all of the
    functional limitations that could affect applicants' ability to use
    the fixed route system. A review of 20 recent determinations
    identified several examples where applicants' abilities to use fixed
    route were likely affected by path-of-travel barriers or severe
    weather conditions. These issues were not included, however, in the
    conditions of eligibility in final determination letters.

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8.  One of the eight recent determinations of ineligibility (not
    eligible under any conditions) for ADA complementary paratransit
    service for Onondaga, Oswego, and Cayuga Counties is questionable.
    Seven of the eight findings seemed appropriate. In the questionable
    case, the applicant indicated that "I cannot walk to or from the bus
    stop," but the application had some inconsistencies. CAB staff
    indicated that there had been no telephone follow-up with the
    applicant or the verifying professional and that the file did not
    include any documentation of follow-up.

9.  One of five recent determinations of ineligibility for Oneida County
    is questionable. Four of the five determinations of ineligibility
    seemed appropriate. In the questionable case, the applicant and
    verifying professional indicated that the rider had received a hip
    replacement affecting the applicant's ability to travel significant
    distances or in snowy or icy conditions to a bus stop. A
    determination of conditional eligibility, perhaps on a temporary
    basis, might have been more appropriate.

10. The current eligibility process appears to make inappropriate
    determinations of conditional eligibility. The review of 10 recent
    determinations that resulted in conditional eligibility indicated
    that in six instances, a finding of unconditional eligibility ("In
    All Cases") probably would have been more appropriate, given the
    stated functional abilities of the applicants.

11. The current eligibility process appears to result in inappropriate
    determinations of conditional eligibility for applicants with
    cognitive disabilities. In two of the 10 recent conditional
    determinations that were examined as part of the review, applicants
    with dementia and Alzheimer's were granted eligibility to
    "unfamiliar locations." For these applicants, familiarity with a
    destination did not appear to address the applicants' limitations,
    as they were likely to become confused while traveling, regardless
    of the location. The issue in these cases appeared to be an
    inability to travel alone to any destination. Unconditional
    eligibility ("In All Cases") appeared to be more appropriate.

12. Eligibility determinations do not appear to authorize travel with
    personal care attendants in all cases where warranted. Current
    application forms do not appear to obtain adequate information about
    the need for personal care attendants. As a result, only 11 percent
    of all riders in Onondaga, Oswego, and Cayuga Counties are
    authorized to travel with personal care attendants. A review of 25
    application files identified several cases where applicants appeared
    to require personal care attendant services sometimes, but travel
    with a personal care attendant was not authorized in the final
    determination letters.

13. The letters of determination sent to applicants in Onondaga, Oswego,
    and Cayuga Counties provide confusing descriptions of conditions of
    eligibility. Brief phrases such as "walk up to one block," or "stand
    up to 2 minutes" are used to explain conditions of eligibility.
    These phrases do not clearly explain conditions of eligibility to
    applicants. Several riders contacted in advance of the review
    indicated that they were confused about conditional eligibility.
    These phrases also do not provide sufficient information to permit
    an applicant to make an informed appeal of the determination.

14. Eligibility letters do not clearly indicate the date of expiration
    of eligibility. The expiration date is included as a handwritten
    note at the end of the letter and is worded in a way that could lead
    an applicant to think it is an internal administrative note (e.g.,
    "Re-Evaluate on October 4, 2007").

15. With the exception of issues described in Findings 10 and 11, the
    no-show suspension practices in Onondaga, Oswego, and Cayuga
    Counties appear to be consistent with regulatory requirements that
    indicate that service should be suspended only when there is
    documentation of a "pattern or practice of missing scheduled trips"
    (§ 37.125(h)). The efforts to contact and counsel riders about
    no-shows and to work out issues those riders may be having with the
    service are commendable. Suspensions are proposed for small numbers
    of riders, and only after a substantial record of missing scheduled
    trips, is accumulated.

16. The administrative process related to no-show suspensions appears to
    sometimes charge riders with no-shows for non-ADA trips that they
    may not know have been scheduled. Some conditionally eligible riders
    whose trips are not initially scheduled are charged with no-shows if
    the trip is later scheduled. This can happen even if riders do not
    call back to confirm that they have accepted the ride.

17. No-show suspensions become effective almost immediately upon receipt
    of the no-show suspension letters. Time is not allowed for riders to
    request an appeal before the suspension takes effect. The current
    practice also appears to reinstate service on a case-by-case basis
    if an appeal is requested. DOT ADA regulations (§ 37.125(h) (3))
    require that service continue to be provided until any requested
    appeals are heard and decided.

18. It appears that ADA complementary paratransit service is provided to
    eligible applicants when CAB takes longer than 21 days to make an
    eligibility determination. Although more time is often required by
    CAB, service appears to be provided as long as a completed
    application has been received.

19. While it does not limit ADA eligible customers from obtaining
    service, Centro took more than 21 days to process 48 percent of a
    sample of 159 applications received during early 2007 in Onondaga,
    Oswego, and Cayuga Counties.

20. Participation by the Oneida County general manager in the six-person
    committee that hears formal ADA complementary paratransit
    eligibility appeals in Oneida County appears to violate the DOT ADA
    regulatory requirement that there be separation of functions between
    those hearing appeals and those making the initial eligibility
    decision. The regulations require that, to the extent practicable,
    the person hearing the appeal not be a supervisor of the original
    decision maker.

21. The appeals process in Onondaga, Oswego, and Cayuga Counties does
    not appear to be fully developed. In particular, the individuals and
    number of persons who would hear and decide formal appeals are not
    defined in the current written policy. Staff did not appear to know
    how the appeals panel would be constituted.

22. ADA complementary paratransit service eligibility does not appear to
    be adversely affected by Centro CAB's appeals process. Centro CAB
    appears to resolve most appeals of eligibility determinations
    informally. Only about one formal appeal a year is heard in Oneida
    County. No formal appeals appear to have been scheduled or heard in
    Onondaga, Oswego, and Cayuga Counties in recent years.

## C. Telephone Access {#c.-telephone-access .unnumbered}

1.  For the sample month (March 2007), 83 percent of calls were answered
    in less than 2 minutes. This is slightly below the Centro standard
    of answering 85 percent of calls in less than 2 minutes.

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23. Between 4 and 5 p.m., 30 percent of callers were on hold for more
    than 2 minutes. Seven percent of callers were still on hold after 4
    minutes, and 4 percent after 5 minutes. The number of long hold
    times during late afternoon hours could limit customers' ability to
    reserve trips and use the service.

24. From 5 to 6 p.m., 29 percent of calls to confirm trips were on hold
    for more than 4 minutes and 20 percent of calls were on hold for
    more than 5 minutes. As explained in Section 6, some riders for
    non-ADA trips are effectively required to call back to confirm trips
    because they have no other way of finding out that the trip has been
    scheduled and no-shows for such trips are counted against the
    riders' ADA eligibility.

25. According to CAB public information materials, call center hours for
    trip reservations are from 8 a.m. to 5 p.m. CNYRTA managers
    indicated that reservation hours in Rome are 8:30 to 4:30 p.m. DOT
    ADA regulations require that reservation service be available during
    at least normal business hours of the transit agency, which appear
    to extend to at least 5 p.m. for all CAB service areas.
    Additionally, the public information materials are inconsistent with
    the reservation hours for Rome and Utica and potentially confusing
    to customers.

26. Available staffing for phone coverage in Syracuse steadily decreases
    after 3 p.m. even though call volumes are highest between 3 and 5
    p.m. This leads to longer telephone hold times.

## D. Trip Reservations and Scheduling {#d.-trip-reservations-and-scheduling .unnumbered}

1.  In Onondaga County, all requests for trips identified by trip
    coordinators as ADA eligible appear to be accommodated. Team members
    did not observe denials of eligible trips during the trip
    reservation process. CAB also reports no trip denials.

2.  In Utica, there appear to be a small number of ADA trip denials, at
    the rate of about one round-trip every two days. Staff indicated
    that they planned to eliminate these trip denials by having fixed
    route extra-board operators perform trips that cannot otherwise be
    provided. Negotiations with the fixed route operators union were
    underway at the time of the review to allow this practice to be
    implemented.

3.  In both the Onondaga County and Utica operations, distance in street
    miles from the fixed route system is used to determine if requested
    pickup and drop-off locations are within the ADA service area. The
    regulations indicate that the 3/4-mile minimum ADA service area
    corridors are defined using straight-line distance (see Section
    37.131 Appendix D of 49 CFR Part 37). Some trips in the service area
    appear to have been mistakenly categorized as not eligible based on
    this incorrect method of measuring the service area corridors.

4.  The methods used by trip coordinators in the Onondaga operation to
    interpret and apply rider conditions of eligibility appear to be
    inconsistent and, in some cases, inappropriate. It is likely that
    the current method of performing trip-by-trip eligibility has
    resulted in some trips that are eligible being categorized as not
    ADA eligible. Also, as indicated in Section 6 of this report, the
    conditions of eligibility that are being used do not appear to
    consider all of the possible travel limitations that apply to
    riders.

5.  The procedures used to book trips in Onondaga County do not
    accurately capture actual requested trip times. The requested times
    stated by riders appear to be changed by 5 to 10 minutes in many
    cases to accommodate the current trip scheduling process. As a
    result, the times requested by customers are not clearly and
    consistently recorded. This limits the ability to measure
    performance against requested times and potentially leads to
    confusion in communications.

6.  The procedures used in Utica to record and schedule trips do not
    appear to provide for a complete record of trip requests. Initial
    trip request times are not recorded; only the final negotiated times
    are recorded. Moreover, if a trip is rescheduled or canceled, the
    original record is erased and only the new trip time is preserved.
    As a result, it is not possible to measure the responsiveness of
    trip offers to customer requests or to track trip cancellations.

7.  The Onondaga County Division uses the time fields in Trapeze in a
    manner that fosters miscommunication in scheduling and serving
    trips. Trip coordinators enter the times requested by customers in
    the "early" time field, rather than the "requested" time field. When
    customers call to confirm trip times on the afternoon before
    service, they are provided "scheduled" times---while operators are
    given the "estimated" vehicle arrival time at the time the manifests
    are printed. The potential for different times promotes
    miscommunication and increases the possibility of inappropriate
    no-shows or missed trips.

8.  During interviews with Centro operators, they cited instances of
    receiving unclear or incorrect information about riders, such as
    customers' inability to board certain vehicles or being accompanied
    by a PCA. They also cited occasional problems of incorrect locations
    or addresses printed on manifests.

9.  For the majority of Onondaga County customers who choose not to
    schedule their trips live, the scheduler assigns trip times within
    the allowable window of -60/+60 minutes. No negotiation takes place
    with the customers before the trip is scheduled. Moreover, providing
    customers with a scheduled time when they call to confirm trips on
    the afternoon before service may place implicit pressure on the
    customers to accept the ride times as-scheduled. This procedure does
    not appear to be true negotiation of a pickup time.

10. Printing manifests before the end of the reservation period on the
    day before service potentially increases the number of manual
    changes that must be made to each run before service. The number of
    potential changes likely increases as trip volume increases. Adding
    a large number of trips after the schedules have been completed can
    contribute to late and missed trips.

11. Few recurring trips are prescheduled as subscription trips at the
    Onondaga operation. Prescheduling subscription trips can reduce the
    time required to schedule trips, improve efficiency of runs, and
    reduce call volumes associated with trip requests.

12. In Oneida County, trip information on canceled trips is not being
    retained. A record of the cancellation can be helpful, should the
    change in trip status be questioned after the fact. For example, the
    information can be helpful in documenting late cancellations or
    disputed cancellations.

## E. Service Performance {#e.-service-performance .unnumbered}

1.  No trip denials or missed trips in Onondaga County were identified
    from a review of CAB data for Wednesday, February 7, 2007.

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1.  The Oneida County Division had an average capacity denial rate of
    approximately 0.7 percent of all requests, ranging from 0.3 percent
    to 1.4 percent during the period of October 2006 to March 2007.

2.  The Onondaga County Division does not have a substantial number of
    significantly late drop-offs. Analysis of trip records for February
    7, 2007, indicated that 3.6 percent of trips (5 of 138) with
    scheduled appointment times were dropped off late. All of those
    trips were late by 5 minutes or less.

3.  The Onondaga County Division has a significant number of early
    drop-offs. On the sample day, 17 percent of trips with appointment
    times were dropped off more than 30 minutes early. Significantly
    early drop-offs can result in long waits until customer appointments
    and can be a constraint to use of CAB service.

4.  The Onondaga County Division may have a substantial number of
    significantly early pickups. On February 7, 2007, 25 percent of
    trips provided (92 of 365) were picked up more than 5 minutes before
    the scheduled time. Of the 92 early trips, 23 (6 percent of all
    trips provided) were more than 15 minutes early. Consumers
    interviewed expressed concern about early pickups. When agreed to by
    the customer, early pickups are acceptable and can improve operating
    efficiency and customer service. However, it is not acceptable to
    pressure customers into accepting early pickups when they are not
    prepared or do not wish to board. When customers are encouraged, or
    pressed, to accept pickups that are significantly before the
    scheduled time, those pickups could be considered untimely. During
    interviews, operators appeared to be aware that they are not to
    arrive for pickups too early. Display of estimated times rather than
    scheduled times on operator manifests may, however, contribute to
    early pickups as a result of misunderstanding of the pickup time.

5.  A review of "long trips" (more than 60 minutes) for two sample days
    indicates that the Onondaga County Division does not have a
    substantial number of significantly long trips.

6.  The Oneida County Division, Rome office reported 31 percent of its
    trips exceeded 45 minutes. Staff indicated that this was due to a
    large number of group trips. Staff stated that these group trips had
    subsequently been split up on different runs to reduce the travel
    times.

7.  Centro does not have a standard for on-time drop-offs for CAB. For
    many trips, such as medical, work, school, and business
    appointments, on-time drop-offs are more important to the customer
    than on-time pickups.

8.  Reconciliation of trip data did not start until February 2007. A
    review of the reconciled data for the sample day found a 12 percent
    error rate.

9.  CAB in Onondaga appears to have sufficient numbers of vehicles and
    operators to cover all assigned runs.

10. Centro Utica in Oneida County does not have a sufficient number of
    operators available to cover all ADA runs when assigned operators
    are absent. CNYRTA is negotiating with the operator's labor union to
    make fixed route extra-list operators available for assignment to
    ADA complementary paratransit runs when needed.

11. Contract carriers often have difficulty communicating with the
    Onondaga CAB dispatcher. Operators (using cell phones) communicate
    with dispatch through one telephone line that is also used to handle
    advance cancellations and information requests from customers.
    Answering customer calls diverts dispatchers from their primary
    responsibility of tracking service, identifying problems, and
    assisting operators to avoid service delays.

12. The Onondaga dispatcher does not actively track the status of
    operators' schedule adherence. The dispatcher discovers that
    operators are running late only when they report that they are
    running late or request a no-show approval. This reactive method
    prevents the dispatcher from identifying and addressing service
    delays before they occur.

13. Contractors do not notify the Onondaga dispatcher when they receive
    trip cancellations from customers. As a result, CAB personnel are
    unaware of the change in trip status.

14. Operators sometimes change the sequence of stops on their routes
    without notifying the dispatcher.

15. Operators believe that the estimated time shown on the manifest is
    the same as the scheduled time told to the customer. The estimated
    time can be different from the time scheduled with the customer. As
    a result, operators may arrive for pickups at the wrong time. This
    can result in early, late, and missed trips or inefficient use of
    the operator's time. It can also delay other customers and confuse
    customer communications.

16. Customers expressed concern about new operators and contract
    operators, including operators getting lost and operator
    sensitivity. Additionally, during interviews, operators seemed
    unclear regarding some procedures and concepts, including times on
    manifests, changing their schedules, and on-time performance.

## F. Resources {#f.-resources .unnumbered}

1.  CNYRTA appears to have adequate financial resources to meet current
    demand for ADA complementary paratransit service.

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1.  CNYRTA appears to have effective procedures for making changes
    during the year to address ADA complementary service passenger
    demand and financial needs.

2.  It is anticipated that overall CAB service demand will increase,
    largely because of increasing demand from Medicare recipients and
    modifications to eligibility procedures. Consequently, CAB will need
    corresponding increases in resources in order to sustain existing
    service levels.

3.  Minor increases in reservationist (trip coordinator) staffing may be
    needed to improve late afternoon telephone response times if
    improvements cannot be achieved through adjusting reservation and
    scheduling procedures and/or revising the schedules of current
    reservationist staff.

4.  Additional budget resources may be needed to fund additional
    preliminary training for all Centro ADA complementary paratransit
    service operators.

5.  Additional dispatch telephone capacity may be needed to eliminate
    impediments to communication between the dispatcher and contractor
    operators if the problem cannot be adequately addressed by revising
    dispatch procedures.

# ADA Complementary Paratransit Service Criteria

The review team compared Centro's ADA complementary paratransit service
with its fixed route service to determine whether it is comparable with
respect to three of the DOT ADA service criteria related to service
design, as cited:

-   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 Centro policies regarding service area,
days and hours, and fares, and interviewed CNYRTA staff.

## Consumer Comments

As discussed in Section 8 of the report, Centro relies on reservation
call-takers, called trip coordinators, to make trip-by-trip
determinations of trip eligibility with respect to service area and
hours. Accordingly, customer comments related to trip reservations may
reflect issues with service area and hours.

Among the comments in the FTA complaint that might relate to service
criteria was that ADA eligible ride orders were refused.

Of the consumers interviewed, three said their trip requests were not
always honored and others cited confusion about conditional eligibility
and "courtesy trips." One customer described being denied an evening
trip at a time and in an area served by fixed route buses.

## Service Area

The DOT ADA regulations require that ADA complementary paratransit
service be available within 3/4-mile of all bus routes and rail
stations, except for routes and stations exclusively for commuter and
inter-city service (49 CFR §§ 37.121 and 37.131(a)). The review team
assessed Centro's policies and practices with respect to service area to
ensure compliance with the regulations.

It is Centro's policy to serve all ADA complementary paratransit trip
requests for trip origins and destination locations within 3/4-mile of
Centro fixed route bus service. This service area definition is
presented in Centro's public information materials. The public
information materials also indicate that CAB service is not available on
commuter routes.

CAB trip coordinators implement the service area policy on a
trip-by-trip basis when entering trip requests. The trip coordinators
accept trips to and from common destinations that they know to be within
the service area. Locations clearly outside the service area will not be
accepted. If the trip coordinator is uncertain whether the location is
within the 3/4-mile service area, the coordinator reviews the location
using the system route map in the Trapeze scheduling software and makes
a determination based on that review. If the trip coordinator is still
uncertain, it is the CAB practice to accept the trip request and refer
the location to the road supervisor for determination of whether or not
it is within 3/4-mile of the fixed route service. The road supervisor
measures the odometer distance from the customer's address to the
nearest fixed route bus stop and uses this distance to determine whether
the trip is eligible as an ADA complementary paratransit trip. If the
location is finally determined to be in the service area, it is
scheduled. If it is outside the service area, it is scheduled, but the
customer is advised that future trip requests for the location will not
be accepted. A record of whether or not the location is within the
service area is entered into the customer's file in Trapeze for
reference in the future when customers call to request trips to or from
this location. This practice is more fully discussed in Section 8.2 of
this report.

As described in the appendix to 49 CFR § 37.131, the service area for
fixed route is defined as 3/4-mile measured in a straight line from any
point on the fixed route. A service area measured in this fashion will
include a substantially greater area than the area defined by Centro.
Consequently, the practice used by Centro to determine whether locations
are in the service area is likely improperly denying trips that are
within the service area as defined by the DOT ADA regulations.

At the time of the review, this problem was brought to the attention of
the road supervisor and CAB manager, who revised the practice for using
maps---either in the Trapeze software or printed---to identify the
service area using straight line distances.

The appendix to 49 CFR § 37.131 also requires that small areas within
the "core service area" that are more than 3/4-mile from fixed route bus
service but are surrounded by fixed route services be included in the
ADA complementary paratransit service area. Centro's practice of
considering each trip end in isolation likely results in incorrect
identification of "core area" locations as outside the service area.

To reduce the potential for error by trip coordinators in determining
whether trip locations are in the ADA service area, CAB should follow
the guidance provided in the appendix to 49 CFR § 37.131 and develop a
map to define the ADA complementary paratransit service area for each of
the five fixed route operating divisions. To facilitate clear
communication, both internally and with customers, and to minimize
confusion, CAB should consider using well-understood landmarks as
service area boundaries---such as community boundaries, bodies of water,
or roads that are outside of but near to the 3/4-mile distance from
fixed routes. This is a practice commonly used by other ADA
complementary service providers.

## 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)). As indicated in the brochure *Call-A-Bus
-- An Introduction* and page 6 of the *Call-A-Bus Rider's Guide*, the
CAB service hours are the same as non-commuter fixed route service as
determined on a route-by-route basis.

The method used by CAB to apply this standard is to review bus route
schedules during the process of accepting trip requests. As a more
simplified approach, the review team examined the bus schedules for
fixed route operation in each of the Centro service areas to identify
the earliest and latest service hours for each service area by day of
the week. These service hours are presented below in Table 5.1

Table 5.1 -- Fixed Route Operating Times

+---------+---------+---------+---------+---------+---------+---------+
| **C     | **We    |         | **Sat   |         | **S     |         |
| ounty** | ekday** |         | urday** |         | unday** |         |
+---------+---------+---------+---------+---------+---------+---------+
|         | **      | **End** | **      | **End** | **      | **End** |
|         | Start** |         | Start** |         | Start** |         |
+---------+---------+---------+---------+---------+---------+---------+
| O       | 4:50    | 1:20    | 5:30    | 12:30   | 5:55    | 12:30   |
| nondaga | a.m.    | a.m.    | a.m.    | a.m.    | a.m.    | a.m.    |
|         |         |         |         |         |         |         |
|         | (Route  | (Route  | (Route  | (Routes | (Route  | (Routes |
|         | 23)     | 52)     | 23)     | 52, 70, | 23)     | 52, 70, |
|         |         |         |         | 123)    |         | 74,123) |
+---------+---------+---------+---------+---------+---------+---------+
| Cayuga  | 5:43    | 11:24   | 8:04    | 8:10    | No      |         |
|         | a.m.    | p.m.    | a.m.    | p.m.    | Service |         |
|         |         |         |         |         |         |         |
|         | (Route  | (Route  | (Route  | (Route  |         |         |
|         | 4)      | 4)      | 1-3)    | 4-2)    |         |         |
+---------+---------+---------+---------+---------+---------+---------+
| Oswego  | 6:05    | 12:17   | 8 a.m.  | 6:27    | 12:14   | 6:04    |
|         | a.m.    | a.m.    |         | p.m.    | p.m.    | p.m.    |
|         |         |         | (both   |         |         |         |
|         | (Laker  | (City   | routes) | (City   | (both   | (both   |
|         | S       | Route)  |         | Route)  | routes) | routes) |
|         | huttle) |         |         |         |         |         |
+---------+---------+---------+---------+---------+---------+---------+
| Oneida/ | 5:20    | 11:15   | 6:20    | 6:55    | No      |         |
| Utica   | a.m.    | p.m.    | a.m.    | p.m.    | Service |         |
|         |         |         |         |         |         |         |
|         | (Route  | (Routes | (Route  | Route   |         |         |
|         | 24)     | 14, 24) | 24)     | 24)     |         |         |
+---------+---------+---------+---------+---------+---------+---------+
| Oneida/ | 6 a.m.  | 6:10    | 9:15    | 6:10    | No      |         |
| Rome    |         | p.m.    | a.m.    | p.m.    | Service |         |
|         | (Routes |         |         |         |         |         |
|         | 2, 4,   | (Route  | (Routes | (Route  |         |         |
|         | 5, 6)   | 5)      | 2, 4,   | 5)      |         |         |
|         |         |         | 5, 6)   |         |         |         |
+---------+---------+---------+---------+---------+---------+---------+

As one reviewer observed during reservations, a trip-by-trip review can
be time consuming, can lead to errors as alleged by one of the customers
who was interviewed, and can create confusion in communication with
customers. The current practices for confirming days and hours of
service appear to comply with the requirements of the regulations.
However, CNYRTA should consider establishing uniform ADA complementary
paratransit service hours for service zones in Onondaga and other large
Centro service districts. Such an approach will make it easier to
communicate service hours to customers and simplify the trip reservation
process.

## Fares

The 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)).

The full adult fare for Centro fixed route bus service is \$1.00 in
Onondaga County, \$0.60 in Cayuga County, \$0.60 in Oswego County,
\$1.25 in Utica, and \$0.75 in Rome.

Transfers are free and the "extension zone" fare is 25 cents. The Centro
website discusses extension zone fares:

> *Extension Zone Fares*
>
> *Additional zone fares are required on extended portions of the routes
> traveling to the following locations:*
>
> *Auburn*
>
> *Baldwinsville*
>
> *Camillus*
>
> *Central Square*
>
> *Elbridge*
>
> *Electronics Park*
>
> *Fayetteville-Manlius*
>
> *Liverpool*
>
> *Minoa*
>
> *North Syracuse*
>
> *Oswego*
>
> *Solvay*
>
> *Tully-Lafayette*

The *Call-A-Bus* brochure and the *Call-A-Bus Rider's Guide* mailed to
the review team present Centro ADA complementary paratransit services
CAB fares as follows:

-   Onondaga County \$1.25

-   Cayuga County \$1.20

-   Oswego County \$1.20

-   Oneida County/ Utica \$2.00

-   Oneida County/ Rome \$1.50

The *Call-A-Bus Rider's Guide* on the Centro website presents the same
information with the exception that the Oswego fare is cited as \$1.25.
The Oswego bus schedules also identify the adult base fare as \$0.60,
indicating that the \$1.25 is probably a typographic error.

With the exception of the \$1.25 fare for Oswego County presented in the
website version of the *Call-A-Bus Rider's Guide*, the base CAB fare is
twice or less than twice the adult base fare.

Customers and CAB mangers mentioned charging customers zone fares even
though it is not referenced in any of the customer information materials
available to the reviewers. As described above, CAB charges a \$0.25
zone fare on some routes. A paratransit zone fare of up to \$0.50 would
be compliant with the DOT ADA regulations. Failure to clearly
communicate to customers the requirement to pay zone fares can create
confusion for customers and lead to problems for operators attempting to
collect the additional fare. If CAB wishes to continue to charge zone
fares to its customers, it should make this point clear in the customer
information materials and describe when the zone charge applies.

## Findings

1.  At the time of the review team's visit, CAB was not serving certain
    locations that are within the ADA complementary paratransit service
    area. CAB's practice was to measure service area as the area within
    3/4-mile of a fixed route bus stop by way of the roadway system. The
    DOT ADA regulations define the service area as within 3/4-mile of
    any point on the fixed bus route, regardless of stop location or
    street configuration. The practice used by CAB resulted in a service
    area smaller than that required by the regulations. CAB indicated
    that it would immediately revise its practice to measure the
    3/4-mile service boundary as prescribed in the regulations.

2.  CAB may not be including core area islands in its service area. The
    regulations require these islands, which are described in the
    regulations as small areas within the core service area that are
    more than 3/4-mile from fixed route bus service but are surrounded
    by fixed route services, be included in the ADA complementary
    paratransit service area. By defining the service area on a
    route-by-route basis, CAB appears to be excluding these core service
    area islands from the service area.

3.  Reliance upon trip notes and the judgment of trip coordinators and
    road supervisors reviewing maps to determine whether locations are
    in the service area can lead to inconsistent determinations and a
    higher error rate than by using a predefined service area, which can
    be more easily enforced using maps or street addresses or other
    means.

4.  The practice of confirming service hours on a location-by-location,
    route-by-route basis appears to comply with the minimum requirements
    of the regulations. However, in service areas with multiple routes,
    this practice can be confusing to customers and can result in more
    inconsistent and incorrect decisions than using uniform ADA
    complementary paratransit service hours for such service areas. The
    latter method will result in service that meets or exceeds the ADA
    requirements.

5.  The CAB fares appear to comply with the requirement that ADA
    complementary paratransit fares be no greater than twice the full
    fare for a similar trip on the fixed route system.

6.  In the *Call-A-Bus Rider's Guide* on the Centro website, the ADA
    complementary paratransit fare for Oswego is cited as \$1.25, more
    than twice the fixed route fare of \$0.60 for the Oswego service
    area. This rate is inconsistent with the rate of \$1.20 cited in
    other public documents and appears to be the result of a typographic
    error. This apparently incorrect information can cause confusion
    among customers.

7.  Zone fares are apparently charged for CAB service in Onondaga
    County. These CAB zone fares are not described in any of the public
    information documents. The use of CAB zone fares, absent any
    description in public information documents, appears to be causing
    confusion among customers as to the correct fare.

## Recommendations

1.  CNYRTA should develop service area maps and/or other comprehensive
    means of defining the ADA complementary transit service area for use
    by customers and trip coordinators. The defined service area should
    include all locations within 3/4-mile of all points on all Centro
    fixed bus routes and all small islands beyond the 3/4-mile distance
    but surrounded by the Centro fixed bus route service area. Use of
    such a tool by trip coordinators during the trip reservation process
    should result in more consistent and reliable service area
    information, facilitate customer communications, and reduce call
    times.

2.  CNYRTA should establish uniform ADA complementary paratransit
    service hours for service zones in Onondaga and other large Centro
    service districts. Use of this information by call-takers when
    accepting trip requests can improve the consistency and accuracy of
    information shared with customers with respect to service hours. One
    graphic tool that can assist in identifying different service hours
    is a service area map with coded zones for different service hours.

3.  CNYRTA should review all of the CAB and Centro public information
    media to ensure that fare information is presented accurately,
    consistently, and comprehensively. Materials should be revised to
    provide a consistent and accurate fare for Oswego service and to
    advise customers on zone fares.

# ADA Complementary Paratransit Eligibility

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. This portion of the review also examined policies, procedures,
and practices associated with suspensions of service for a pattern or
practice of riders missing scheduled trips (no-shows). In order to meet
these objectives, review team members:

-   Interviewed customers regarding the eligibility process

-   Interviewed Centro and CAB staff who oversee the ADA paratransit
    eligibility determination process

-   Collected and reviewed materials used in the certification process

-   Reviewed a sample of 25 completed applications and their respective
    eligibility determinations

-   Reviewed recent statistics related to eligibility processing time
    and determinations

-   Interviewed CAB staff who manage no-show suspensions

-   Reviewed no-show suspension policies and materials

-   Reviewed recent no-show suspension records and documentation

## Consumer Comments

The review team gathered information about the concerns of riders who
use Centro ADA complementary paratransit service through telephone
interviews with riders and professionals who work with riders and
through review of written and telephone complaints to CNYRTA and one
formal complaint filed with FTA.

The FTA complainant raised the following issues associated with
eligibility:

-   Transportation coordinators with no medical training made
    eligibility determinations based on medical diagnoses, not
    functional limitations

-   Users of power wheelchairs were denied eligibility

-   ADA complementary paratransit service applicants were not receiving
    responses within 21 days

-   Eligibility decisions were inappropriate

-   People with psychiatric disabilities were not properly considered in
    the eligibility process

In the telephone interviews of 12 ADA complementary paratransit service
riders and consumer advocates, 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. Six
of those interviewed cited problems with eligibility. Of those who had
problems, most described the process as confusing. Among the issues
cited were inadequate consideration of path of travel to bus stops;
confusing criteria for considering an applicant's functional ability,
particularly for people with cognitive disabilities; and unclear
communication/understanding of the terms of conditional eligibility and
courtesy rides.

Three interviewees mentioned that it took months to become eligible but
believed that this has improved. One customer who had received
notification that she could use the service said that she was unable to
reserve a trip because her ID number was not in the system.

Of 18 customer comments and complaints filed in January 2007 regarding
Centro ADA complementary paratransit services in Onondaga, Oswego, and
Cayuga Counties and nine complaints filed during 2006 in Oneida County,
one related to eligibility. The complainant raised a number of related
concerns that affected service. One of those concerns was being
categorized as conditionally eligible for ADA complementary paratransit
service.

## Eligibility Determination Procedures and Practices

##  {#section .unnumbered}

ADA paratransit eligibility determinations are managed from two
locations in the CNYRTA system. CAB staff in the Syracuse office manages
determinations for riders in Onondaga, Oswego, and Cayuga Counties.
Centro staff in the Utica office manages determinations for riders in
Oneida County.

At the time of the review, the two processes were somewhat different.
The application forms used in each process were different, and
conditional eligibility was treated differently in determination
outcomes. CNYRTA staff indicated that they were working on making the
processes more uniform throughout the region. Because the processes and
outcomes are different, they are presented separately in each section
below.

**Application Process and Materials**

**Onondaga, Oswego, and Cayuga Counties**

Individuals in Onondaga, Oswego, and Cayuga Counties apply for ADA
paratransit eligibility by first requesting an application form from
Centro CAB. The CAB staff in the Syracuse office takes calls from
individuals seeking eligibility and sends out applications upon request.
Along with application forms, CAB staff also send information about the
CAB ADA complementary paratransit service---particularly describing the
service area and purpose of serving individuals with disabilities who
are not always able to use the fixed route service.

The application form is five pages long. The application packet also
includes two upfront pages that provide a summary of the ADA regulatory
eligibility criteria and the application process and instructions. Two
pages of the application form are completed by the applicant. The last
three pages are to be completed by a "licensed, certified, or degreed
health care professional or rehabilitation professional, or physician"
familiar with the applicant (hereafter, "verifying professional").
Attachment H presents a copy of the application form.

Applicants are asked to:

-   Provide general information (name, address, phone number, etc.)

-   Indicate the nature of their disability in the general categories of
    "visual," "physical," or "mental impairment"

-   Indicate if the disability is permanent or temporary and, if
    temporary, the expected duration

-   Indicate how far they can travel without the assistance of another
    person (with the possible answers starting at "one block" and
    extending to "over 3/4-mile)"

-   Indicate if they can climb three 12-inch steps without assistance

-   Indicate if they can wait outside without support for 10 minutes

-   Indicate if they are eligible for paratransit service on another
    transit system

The three pages to be completed by verifying professionals ask those
persons to:

-   Indicate the capacity in which they know the applicant

-   Explain their qualifications to be able to "verify the transit
    disability of the applicant"

-   Indicate if, in their opinion, the applicant can use fixed route
    service for all trips, some trips, or no trips

-   Indicate functional abilities of the applicant, including how far
    the applicant can independently travel; how long he/she can "wait
    outside"; whether he/she can climb three 12-inch steps; whether
    he/she can get on a bus lift without assistance; whether he/she can
    get in and out of an automobile; and whether he/she has the
    cognitive ability to recognize landmarks and destinations, give
    address and phone number on request, and "ask for and follow
    directions"

-   Describe any mobility aids used by the applicant

-   Indicate if, in their opinion, the applicant would benefit from
    travel training

-   Provide any other information which the professional feels is
    appropriate and which might be useful in making the determination

The application does not include any questions about path of travel,
street crossing, or impacts of weather on travel. This information is
only captured if it is entered as additional comments in the
application.

It was also noted that there is no specific question about the need for
or use of a personal care attendant (hereafter "PCA," except in findings
and recommendations). Some of the questions in the portion of the
application completed by a verifying professional ask if certain
functions can be performed only with a PCA, but as mentioned in the
"Determination Outcomes" below, the answers to this question did not
seem to be consistently used to determine if a person should be
authorized to travel with a PCA.

Finally, it was noted that the applicant was not asked about mobility
aids used. The only question about mobility aids used was included in
the section to be completed by a verifying professional.

Completed application forms are returned to the Syracuse CAB office. One
of the two people who review applications, date-stamps the application
upon receipt, and enters information about each application into a log
book. The log book is used to track the review progress of each
application and to capture the time required to process applications.
Each application is then checked for completeness. If there are minor
omissions, staff members call the applicant and get the missing
information over the phone. If there are major omissions, such as no
information from a verifying professional, the application is returned
along with a letter noting that the application is incomplete. When
applications are returned for incompleteness, it is noted as such in the
log.

Letters are sent to all applicants who submit completed applications.
The letters indicate that the application is being reviewed, that a
decision should be made within 21 days, and that paratransit service
will be provided in the interim, if needed. If an applicant calls and
indicates that interim transportation is needed, the eligibility staff
members enter him/her into the Trapeze system as a temporary rider.
Riders given temporary eligibility while applications are being
processed do not get a final rider ID number. When they call for
service, trip coordinators must look up their file by name rather than
ID number.

The two eligibility staff members divide applications between themselves
and conduct most reviews independently. If the initial review indicates
that the applicant is not eligible, each staff member will typically
check with his or her counterpart to see if there is concurrence. They
also may check with their supervisor to see if the denial seems
appropriate.

Staff indicated that they make decisions mainly based on information in
the paper application form. Follow-up calls are sometimes made to get
additional information, but this is not typical. They indicated that
they make follow-up calls 10 percent of the time or less.

When a final decision is made, a letter of determination is drafted.
Letters sent to applicants determined unconditionally eligible,
conditionally eligible, or ineligible all included the five pieces of
information required by § 37.125(e) of the DOT ADA regulations:

1.  Name of the eligible individual

2.  Name of the transit provider

3.  Telephone number of the entity's paratransit coordinator

4.  Expiration date for eligibility

5.  Any conditions or limitations on the individual's eligibility

While all required information is included in the determination letters
sent to applicants, the conditions of eligibility are worded in a
potentially confusing way. Attachment I includes a copy of a sample
letter of determination, plus the first page of a second letter showing
the conditions of eligibility. Each letter includes the statement, "The
conditions we will consider when you request Call-A-Bus trips are..."
The first letter then includes the phrase, "Walk up to 1 block." The
phrase "Walk up to 1 block" is intended to tell the applicant that trips
on CAB will be eligible if he/she has to walk more than one block to get
to or from a fixed route bus stop.

The second letter includes the phrases, "Walk up to the curb," "Stand up
to 2 minutes," and "Trips during cold/wet weather." These phrases are
intended to indicate that trips will be eligible on CAB if the applicant
has to walk beyond the curb to get to or from a fixed route bus stop,
has to stand for more than 2 minutes at a bus stop while using the fixed
route system, or is making trips during cold or wet weather. For many
applicants, though, the cryptic phrases included in these letters
probably do not adequately explain the conditions under which they will
be eligible to request ADA complementary paratransit service.

In addition, as noted below in the discussion on determination outcomes,
some of the conditions being set for eligibility seem to be
unreasonable. In the second letter in Attachment I, the applicant was
found to be unable to travel beyond the curb. The applicant also could
not stand unassisted for more than 2 minutes. So, to use the fixed route
system, the buses would need to stop at the curb at both the origin and
destination and buses would have to arrive within 2 minutes of the
applicant's arrival at the stop. The number of fixed route trips where
this would be the case is likely to be extremely small. The applicant
therefore has functional limitations that would typically lead to
unconditional eligibility. Staff at CAB set these or similar conditions
of eligibility in many of the determinations examined.

Finally, the expiration date for eligibility was included as a
handwritten note at the end of the letter. As worded, the handwritten
note could be misunderstood by the reader. As shown on page 2 of the
first letter in Attachment I, the handwritten note "Re-Evaluate October
4, 2007" is included. Staff indicated that this meant that the person's
eligibility expired on October 4, 2007. To the applicant receiving this
letter, this handwritten phrase could be interpreted as an internal
administrative note, and inadvertently disregarded.

**Oneida County**

The eligibility determination process in Oneida County also is based on
a brief paper application form. Individuals in Oneida County who are
interested in applying for ADA complementary paratransit service
eligibility can request an application form by calling the operations
centers in Utica or Rome.

The application forms used by Utica and Rome are almost identical. The
titles are different and one question has different wording. Copies of
the Utica and Rome applications are included in Attachment J.

Both the Utica and Rome applications have three parts. The first part,
which is to be completed by the applicant, asks for the following
information:

-   General information (name, address, etc.)

-   An indication of the distance from the applicant's home to the
    nearest bus stop

-   Whether the applicant is applying for "permanent" or "temporary"
    eligibility (the Utica application also asks if the applicant is
    applying for eligibility only "during the winter months from
    November 1 to April 1")

-   If the applicant currently uses the Centro fixed route service

-   If not, a description of the "medical conditions" that prevent use
    of the fixed route service

-   Any other information about the applicant's disability or medical
    conditions

-   Whether the applicant has completed any form of fixed route travel
    training

-   Types of mobility aids used by the applicant

-   Current means of transportation

-   Whether the applicant needs information and materials in
    alternative, accessible formats

-   Emergency contact information

-   If another person assisted with the application

The second part of each application is a Health Insurance Portability
and Accountability Act (HIPAA) release form that is to be signed by the
applicant to allow CAB staff to contact and get information from the
verifying professional who completes the third part of the application.
The third part of each application seeks information from a "primary
physician." Both applications require that these sections be completed
by a primary physician rather than another type of professional who
might be familiar with the applicant. This section of each application
requests the following information:

-   Description of the applicant's disability or health condition

-   Whether the condition is temporary and, if so, the expected duration

-   Whether the condition is "likely to become worse"

-   Whether the applicant can walk "200 feet" or "1/4 of a mile" without
    assistance and whether this can only be done "with great difficulty"

-   Whether the applicant can climb three 15\" steps that have a
    handrail

-   Whether the applicant can wait outside alone for 10 minutes

-   Whether the applicant has a vision impairment and, if so, detailed
    information about the field of vision, visual acuity, and other
    conditions is requested

-   Types of mobility aids used by the applicant

-   Whether the applicant has cognitive limitations (i.e., inability to
    give name and address upon request, recognize streets and bus
    numbers, deal with unexpected situations, and ask for and understand
    directions)

-   Other pertinent information

As with the Onondaga, Oswego, and Cayuga application, the Utica and Rome
applications did not request any information about path-of-travel
issues. Also, the Rome and Utica applications did not ask the applicant
about the need for or use of a PCA. Information about the need for a PCA
was only requested as part of the question about general mobility aids
in the portion of the application completed by the primary physician.

Applicants are asked to send completed application forms to Centro staff
at the Utica office. Applications from both Utica and Rome are reviewed
by one of the CAB dispatchers, as well as by the Utica assistant general
manager.

Application forms are first checked for completeness. If key information
is missing, the forms are returned to applicants with a letter asking
that the missing information be provided. Completed applications are
reviewed and a determination is made. Staff at Utica indicated that
decisions are based solely on the information in the paper application
form. Follow-up calls for additional information are not typical.

A determination letter is then sent to the applicant. The letters
contain most of the information required by the regulations (i.e., name
of the applicant, name of the transit agency, telephone number of the
transit agency, expiration date, and any conditions of eligibility). The
one exception is that conditional eligibility is not detailed. While the
Utica staff may determine some applicants to be conditionally eligible,
they do not set or use specific conditions of eligibility or apply
conditional eligibility in daily operations. Letters which indicate
conditional eligibility simply state that the applicant has been
determined conditionally eligible without giving any detailed conditions
that describe what would make a trip eligible or ineligible.

**Recertification**

**Onondaga, Oswego, and Cayuga Counties**

Customers, other than those with temporary eligibility, in Onondaga,
Oswego, and Cayuga Counties are asked to reapply for eligibility every
three years. The length of temporary eligibility is typically one year
or less and depends on the information provided in the application form
about the expected duration of the health condition or disability. The
same application form and process for initial eligibility are used when
riders reapply.

Staff indicated that if trip coordinators note that a rider's
eligibility is about to expire, they will send the person a new
application form. There is no formal process, though, for identifying
riders whose eligibility is about to expire and for sending out letters
reminding riders to reapply. Staff indicated that if a rider's
eligibility expires and this is discovered during the trip booking
process, the term of eligibility is extended, a new application form
sent, and eligibility is continued until a new determination is made.

**Oneida County**

Customers in Oneida County, other than those with temporary eligibility,
are asked to reapply for eligibility every two years. Temporary
eligibility is granted for a shorter period based on the expected
duration of the disability or health condition indicated in the
application form. Staff at the Utica office also noted that there were
plans to standardize the eligibility processes for all Centro CAB
operations and that the term of eligibility would likely be extended to
three years to be consistent with recertification policies in other
counties.

Staff in the Utica office indicated that they regularly track riders'
eligibility and identify those riders whose eligibility is about to
expire. A letter reminding riders to reapply, along with a new
application form, is typically sent 30 to 90 days before the expiration
date.

**Appeals Process**

**Onondaga, Oswego, and Cayuga Counties**

As noted above, applicants who are denied eligibility or who are granted
only conditional eligibility are informed that they have the right to
appeal this decision. A copy of the "Centro Call-A-Bus Appeal Policy and
Procedure" is attached to all denial and conditional eligibility
letters. Attachment K includes a copy of the appeals policy. As
indicated, applicants are asked to make written requests for appeals and
to send those requests to the vice president of operations at Centro.
The policy also encourages applicants to "contact Call-A-Bus to discuss
any issues or problems first, to see if a mutually agreed upon solution
can be found prior to requesting an appeal."

If applicants call or write to request a formal appeal, the matter is
referred to the vice president of operations. An informal review of the
initial determination is then conducted. Staff indicated that when this
is done, the initial determination is typically revised and the
applicant granted eligibility. It was noted that every attempt is made
to resolve eligibility disputes without going to a formal appeal. Staff
members could not remember the last formal appeal and indicated Centro
has not had a formal appeal in the past two years.

Because the formal appeals process does not appear to be used, the
details of the process are somewhat vague. The "Appeal Policy and
Procedure" indicates that an Appeal Committee would hear any formal
appeals and that the committee would consist of "member(s) of the
disability community, organizations representing the disabled or elderly
community and one representative from Centro." The exact make-up and
size of the committee was unclear. Staff indicated that they would
likely ask members of the consumer advisory committee to participate in
an appeal hearing, but were not sure of exactly how many individuals
would be asked to hear the appeal. If there were to be an appeal
hearing, the policy does clearly indicate that transportation to and
from the committee hearing would be provided at no cost to the
appellant.

**Oneida County**

If applicants in Utica or Rome disagree with initial determinations, the
application files are reviewed again by the assistant general manager.
Any additional information presented by the applicant is considered as
part of this informal review. In most cases, the informal review will
resolve the issue.

If the applicant is still not satisfied following the informal review, a
formal appeal hearing will be arranged. Formal appeals are heard by a
committee of six people, which includes Centro's Oneida County general
manager, a representative of the local Association for the Blind, a
representative of the local center for independent living, and three
persons with disabilities (two of whom use the ADA complementary
paratransit service). The DOT regulations (49 CFR § 37.125(g) (2))
require separation of functions between those hearing appeals and those
making the initial eligibility decision. This means that, to the extent
practicable, the person reviewing the appeal should not be the
supervisor or subordinate of the person making the initial
determination. Applications from both Utica and Rome are reviewed by one
of the CAB dispatchers as well as by the Utica assistant general
manager---both of whom are subordinates of the Oneida general manager,
who is a member of the appeals committee.

As in Onondaga County, free transportation is provided to and from the
appeal hearing if needed. Staff in the Utica office indicated that one
formal appeal had been heard in calendar year 2006 and one in calendar
year 2005.

**No-Show Suspension Policies**

CNYRTA has adopted a single no-show suspension policy used in all of the
service areas and operations. Page 24 of the *Call-A-Bus Rider's Guide*
indicates that a rider can be suspended for 30 days for three or more
no-shows or cancels at the door in a 30-day period. Riders can be
suspended for a six-month period for a second occurrence of three or
more no-shows or cancels at the door in a 30-day period. CNYRTA does not
consider "late cancellations," apart from cancels at the door, in its
no-show policy.

## Determination Outcomes and Processing Time

**Determination Outcomes**

**Onondaga, Oswego, and Cayuga Counties**

At the time of the review, a total of 5,464 individuals had been
determined to be ADA paratransit eligible in Onondaga, Oswego, and
Cayuga Counties. In these areas, CAB staff confer eligibility in one of
the four categories:

-   "In All Cases": these riders are unconditionally eligible

-   "In All Cases with Attendant": these riders are unconditionally
    eligible and are also eligible to travel with a PCA

-   "Conditional": these riders are eligible for some trips; the
    conditions of their eligibility are detailed in the letters of
    determination.

-   "Conditional with an Attendant": these riders are eligible for some
    trips and are also eligible to travel with a PCA

CAB does not have a separate category of eligibility for riders who are
granted temporary eligibility. These riders are eligible under one of
the categories above and are simply given a date of expiration for their
eligibility that is sooner than the standard term of eligibility.

Table 6.1 presents the number of persons who were eligible in each
category as of April 2007. As shown, 18 percent of eligible riders were
eligible "In All Cases." Eighty-two percent of riders were given
"Conditional" eligibility. This is a very high percentage of conditional
eligibility relative to other transit agencies. The experience of other
transit agencies, including those with model in-person functional
assessment processes, is that about 25 to 35 percent of applicants are
conditionally eligible.

**Table 6.1 -- ADA Paratransit Eligible Riders in Onondaga, Oswego, and
Cayuga** Counties by Eligibility Category

  --------------------------- --------------------- ---------------------
  **Type of Eligibility       **\# of Customers**   **% of All
  Granted**                                         Customers**

  In All Cases                543                   10%

  In All Cases with PCA       463                   8%

  Conditional                 4,302                 79%

  Conditional with PCA        156                   3%

  **TOTAL**                   5,464                 100%
  --------------------------- --------------------- ---------------------

As shown in Table 6.1, only 11 percent of eligible riders have been
granted the ability to travel with a PCA. This is a very low percentage
relative to other transit properties and is probably related to the
absence of a specific question in the application form about the need
for or use of a PCA.

CAB records also indicated that seven applicants had been denied ADA
paratransit eligibility from January 1 to March 31, 2007. During this
time, there were a total of 261 completed applications submitted. This
yields an eligibility denial rate for this period of 2 percent.

Twenty recent determinations were examined in detail as part of the
review. This included two applicants determined "In All Cases" eligible,
10 applicants granted "Conditional" eligibility, and eight applicants
who had been denied eligibility (including all seven applicants denied
from January through March 2007). This review found the two
determinations where applicants were granted eligible "In All Cases" to
be appropriate. Seven of the eight denials of eligibility seemed
appropriate; the eighth denial was questionable. In this one case, the
applicant indicated "I cannot walk to or from the bus stop." The
verifying professional indicated that the applicant had "severe
arthritis" and checked the box on the application form indicating that
the applicant is "Unable to get to curb to board bus without
assistance." However, in the section of the form where the professional
indicates functional abilities and limitations, the professional
indicated that the applicant was able to perform all of the tasks
listed. This application clearly had some inconsistencies. CAB staff
stated that there had been no telephone follow-up with the applicant or
the verifying professional and the file did not include any
documentation of follow-up. For this one application, it would have been
helpful to follow up with the professional to question him about the
inconsistencies in his application and get more detailed information
about the applicant's functional abilities.

The review of the 10 determinations that found applicants conditionally
eligible raised several questions. In six of the 10 cases, it appeared
that applicants had very little ability to use fixed route services.
Determinations granting "In All Cases" eligibility probably would have
been more appropriate. A summary of the key information in these six
files is provided below.

-   In one case, the applicant was a 91-year-old man who was in
    end-stage renal failure and who participated in dialysis treatments.
    The applicant indicated he could walk only one block. The verifying
    professional indicated he could only walk to the curb and
    recommended paratransit service exclusively. The determination made
    was for conditional eligibility, with the condition that he was
    eligible for paratransit if he had to walk more than one block to
    use the fixed route service.

-   In a second case, the applicant was an 84-year-old man with
    "moderate Alzheimer's." The verifying professional indicated that he
    could not do any of the things listed in the application concerning
    cognition (e.g., ask for and follow directions, recognize
    landmarks). The professional also indicated he could not travel
    beyond the curb and recommended paratransit service in all cases.
    The determination was for conditional eligibility if the rider had
    to travel beyond the curb to use the fixed route service.

-   In a third case, the applicant was a man with dementia who also used
    a quad cane. The verifying professional indicated issues with
    cognitive abilities, indicated the man could not stand to wait for a
    bus for more than 5 minutes, and indicated he could only get to and
    from the curb. The determination was for conditional eligibility
    with the conditions: (1) if the rider had to travel beyond the curb
    to use the fixed route service; (2) if he had to wait more than 15
    minutes when using the bus; and (3) if he was traveling to
    unfamiliar locations.

-   In a fourth case, the applicant indicated legal blindness and
    "advanced age." The verifying professional, an orientation and
    mobility (O&M) specialist who had apparently attempted to work with
    the individual, indicated that she could not be instructed to
    recognize landmarks to travel independently. The O&M specialist also
    indicated in the application that the woman had cognitive
    limitations and could not perform many of the tasks required to use
    fixed route service. Finally, the professional indicated that the
    woman could not travel beyond the curb and recommended paratransit
    service in all cases. The determination was for conditional
    eligibility if: (1) the rider had to travel beyond the curb to use
    the fixed route service; or (2) was traveling to unfamiliar
    locations.

-   In a fifth case, the applicant was legally blind, used a walker, and
    was not able to travel beyond the curb---which was verified by the
    professional. The determination was for conditional eligibility
    when: (1) the rider had to go beyond the curb to use the fixed route
    service; or (2) was traveling to unfamiliar locations.

-   In the sixth case, the applicant was 90 years old, used a walker
    (and sometimes a wheelchair), and indicated an ability to travel one
    block at the most. The verifying professional indicated that she
    could travel no distance and was "not able to move easily." The
    determination was for conditional eligibility when: (1) the rider
    had to go beyond the curb to use the fixed route service; and (2) if
    there were "environmental/ physical barriers" that prevented travel
    by fixed route.

While each of the above applicants clearly could have benefited from a
PCA, none were granted the right to travel with an attendant. All were
granted "Conditional" eligibility rather than "Conditional with PCA"
eligibility.

The review of these cases indicates that CAB is applying conditional
eligibility too strictly. In other transit systems, if applicants are
only able to travel to the curb, this becomes a reason for unconditional
eligibility rather than a condition of eligibility. Also, a finding that
applicants with dementia or Alzheimer's are only eligible for ADA
complementary paratransit service when traveling to "unfamiliar
locations," is inappropriate. The issue in these cases is not that the
applicants are familiar or unfamiliar with certain destinations, but
that they can become confused and lost when traveling independently by
fixed route---regardless of their familiarity with the route or
destination.

**Oneida County**

At the time of the on-site review, a total of 960 individuals had been
found ADA paratransit eligible in Oneida County. Staff in the Utica
office granted eligibility in the following categories:

-   "Permanent": These riders are unconditionally eligible and can take
    all trips on paratransit. Although called "permanent," these riders
    must renew their eligibility every two years.

-   "Conditional": These riders are able to use fixed route service some
    of the time and are eligible to use paratransit for some trips.

-   "Temporary": These riders have a temporary disability or health
    condition and are given eligibility for a time period shorter than
    the standard two years.

While some riders are granted conditional eligibility, the letters of
determination do not detail the conditions under which the riders are
expected to use fixed route and when they are eligible to use the ADA
complementary paratransit service. The letters simply state that the
riders are conditionally eligible. In practice, the Utica and Rome
operations also do not apply conditional eligibility. Persons determined
conditionally eligible are allowed to book any and all trips on the ADA
complementary paratransit service.

Table 6.2 presents the number of persons who were eligible in each
category as of April 2007. As shown, 92 percent of all eligible riders
have been granted "permanent" eligibility. Four percent of riders have
been granted "conditional" eligibility. And 4 percent have been granted
"temporary" eligibility.

**Table 6.2 -- ADA Paratransit Eligible Riders in Oneida County** by
Eligibility Category

  --------------------------- --------------------- ---------------------
  **Type of Eligibility       **\# of Customers**   **% of All
  Granted**                                         Customers**

  Permanent                   821                   92%

  Conditional                 36                    4%

  Temporary                   35                    4%

  **TOTAL**                   892                   100%
  --------------------------- --------------------- ---------------------

Records in Oneida County indicated that about 20 to 30 completed
applications are received each month. Of these, about three to five
applicants are typically denied eligibility. This yields a denial rate
of about 15 percent.

Five recent denials from Oneida County were examined in detail as part
of the review. The information in the files and the final determinations
were reviewed with staff. Four of the five denials of eligibility seemed
appropriate. In one case, however, the applicant and verifying
professional indicated that the rider had received a hip replacement.
The applicant expressed concern about traveling in snowy or icy
conditions and the verifying professional indicated that the applicant
could be expected to travel only up to 1/4-mile. In this case, it seemed
that a finding of conditional eligibility, perhaps on a temporary basis,
might have been more appropriate. If the applicant's abilities improved
over time, the eligibility could be re-evaluated.

**Processing Time**

As noted above, CAB staff in the Syracuse office maintain a log that
indicates when applications are received, if and when they are sent back
for being incomplete, and when final determinations are made on
completed applications. This log was examined as part of the on-site
review to determine the typical application processing times. The
processing times, associated with 159 completed applications received
between January 25, 2007 and March 27, 2007, were examined. Table 6.3
presents the processing times for these applications. As shown, 24
percent of all completed applications were processed within 14 days.
Another 28 percent were processed in 15 to 21 days: a total of 52
percent of all applications processed within 21 days. Forty percent of
all applications during this period took between 22 and 30 days to
process. Eight percent took more than 30 days.

While a significant percentage of all applications during this period
took more than 21 days to process, riders have been able to receive
service in the interim. As noted above, if riders need service before a
final decision is made, they can call and request interim service. This
is indicated in the letters sent to riders when a completed application
is received. As long as a completed application is in process, Centro
provides paratransit service.

**Table 6.3 -- Processing Times for 159 Completed Applications
Received**

Between January 25 and March 27, 2007

  --------------------------- --------------------- ---------------------
  **\# of Days Required to    **\# of Completed     **% of Completed
  Make Eligibility            Applications**        Applications**
  Determinations**                                  

  1--7 Days                   6                     4%

  8--14 Days                  32                    20%

  15--21 Days                 45                    28%

  22--30 Days                 63                    40%

  31+ Days                    13                    8%

  **TOTAL**                   **159**               **100%**
  --------------------------- --------------------- ---------------------

## No-Show Suspensions

The review team interviewed staff members in the Syracuse and Utica
offices who track no-shows and send no-show warning and suspension
letters. Recent no-show suspension records were also reviewed.

**Onondaga, Oswego, and Cayuga Counties**

No-shows are very actively tracked and managed in the Syracuse office
for customers in Onondaga, Oswego, and Cayuga Counties. Each week, staff
members prepare a list of customers who no-showed or cancelled at the
door during the prior week. Copies of this list are then distributed to
all staff members who make trip reservations. If a rider on the list
calls for another ride, a staff member discusses the prior no-show with
the customer and attempts to determine the customer's reason for the
cancellation or failure to appear for the ride.

A special effort is made for new customers. Staff members call the
customer after the first no-show to make sure the customer is familiar
with the on-time pickup window and the vehicle wait time policy.
Attempts are made to resolve any issues the customer may have with
effectively using the service.

The staff person in the Syracuse office who manages the no-show process
regularly prepares a complete list of customers who have no-shows for
the prior 30-day period, sorted by rider name. At the time of the onsite
review, she noted that the list only contains no-shows. It does not
include cancels at the door or late cancellations. This list is used to
send warning and suspension letters. A first warning letter is sent to
riders who have two no-shows in the 30-day period. This first warning
letter informs riders of the no-show policy and states, "At this time,
you are in jeopardy of having your service suspended." The letter also
encourages riders to call and cancel any trips they no longer plan to
take. A second warning letter is sent to riders who are listed as having
three no-shows during a 30-day period. This second letter states, "You
are in jeopardy of losing your Call-A-Bus service. If you have one more
no-show within 30 days, your service will be suspended." Both warning
letters list all of the no-shows on the rider's record with the date of
the trip and the scheduled pickup time. Attachment L presents copies of
first and second warning letters.

The staff person who manages the process indicated that second warning
letters are also sent to riders who have four or five no-shows in a
30-day period. A review of warning and suspension letters in 2006 and
2007 confirmed this. The sample second warning letter provided in
Attachment L is an example of a warning letter for which the rider had
recorded five no-shows during a 30-day period.

Staff indicated that suspension letters are typically only sent to
riders who have an ongoing record of three or more no-shows for several
discrete 30-day periods. They noted that most riders are given the
benefit of the doubt and that the process is used to identify the small
number of riders who clearly abuse the service. Suspension letters are
typically sent following several warning letters. They document the most
recent no-show (e.g., "On December 28, 2006 you received your 7th
no-show with Call-A-Bus.") and note that as a result of this latest
no-show, the rider is being suspended. The length of the suspension and
the date the suspension will start are indicated. The letters also
inform riders that they can appeal the decision and a copy of the
"Centro Call-A-Bus Appeal Policy and Procedure" is attached. A copy of a
suspension letter is also provided in Attachment L.

The first warning letter and the suspension letters contain the
statement, "If you have any questions regarding this matter, feel free
to contact us at 442-3434, Monday through Friday between 9:00 AM and
3:00 PM." Some of the second warning letters examined did not contain
this statement. The staff person in the Syracuse office indicated that
no-shows are removed from a rider's record if he or she provides an
acceptable reason for the no-show. A reason for the no-show might be
given when trip coordinators are counseling riders about no-shows the
previous week, when staff members call new riders about their first
no-show, or when riders call after receiving a warning or suspension
letter. The reason provided by the rider will be included in the
"Tracker Notes" associated with the no-show in the Trapeze system. The
Syracuse office staff person said that any reasonable excuse is
accepted.

The staff person also indicated that she conducts a thorough review of
each no-show before sending out warning or suspension letters. Her
review includes looking at scheduled and actual arrival times, vehicle
wait times, and any "Tracker Notes" associated with the no-show.

A review of the warning and suspension letters for calendar year 2006
and the first three months of 2007 showed that a total of 111 first and
second warning letters had been sent. Only three riders had been
suspended from service, all for a 30-day period. Records indicated that
one suspended rider had recorded seven no-shows in a seven-day period
and had received several warning letters. The second rider also had
accumulated seven no-shows in a seven-day period and had a prior history
of repeated no-shows. The third rider had five no-shows during the month
that she was suspended and had no-showed three or more times in two
previous 30-day periods.

The review of no-show suspension letters indicated that suspensions are
scheduled to begin as soon as riders receive the letters. For example, a
rider suspended in December 2006 was sent a suspension letter dated
December 6 and the suspension was scheduled to be effective from
December 9, 2006, through January 9, 2007. When asked about policies
regarding appeals, CAB staff indicated that service might be reinstated
pending an appeal, but that this was at the discretion of the
supervisor. There did not appear to be a policy of automatically
reinstating service when an appeal is requested. Section 37.125(h) (3)
of the DOT ADA regulations requires that, in the case of proposed
no-show suspensions, the suspension be "stayed pending the outcome of an
appeal."

The review of no-show suspensions also indicated that some riders who
are conditionally eligible are charged with no-shows for non-ADA trips,
which are not scheduled at the time that the rider calls to make the
request, but are subsequently scheduled *but not confirmed with the
rider*. As detailed later in this report, if a trip request is
determined not ADA eligible because the rider is conditionally eligible
and it is felt that he or she can make the trip by fixed route, the
rider is told that the trip is not eligible and is not being scheduled
at the time of the request. The rider is told that the trip might be
scheduled if there is space and to call back the afternoon before the
day of service to see if the trip has been scheduled. The trip is then
coded as a "DNC" trip (Did Not Confirm) in the Trapeze system. On the
afternoon before the day of service, the trip is scheduled if there is
space. Riders are not automatically called back, but if they call in,
they are told the trip has been scheduled. However, if they do not call
in, the trip remains scheduled and a vehicle is sent. It therefore is
possible for a rider to be told at the time that he or she requests a
ride that the trip is ineligible, to not call back to see if it has been
scheduled, and to not expect that a ride has been scheduled, but then to
be recorded as a no-show if a vehicle is sent.

The above sequence of events appears to have taken place for one of the
three riders suspended in 2006. The record shows that all seven of the
trips recorded as no-shows were "DNC" trips. The individual trip records
also indicated that this rider never called back to see if the denied
trips had actually been scheduled. A copy of the trip record for this
rider indicating that all of the trips were "DNC" trips is provided in
Attachment L.

**Oneida County**

Staff members at the Utica office who manage eligibility records for
riders in Oneida County (Utica and Rome) indicated that no-shows are
regularly tracked but that warning letters and suspension letters were
not being sent as of the time of the on-site review. They indicated that
contact may be made with some riders who no-show regularly to make sure
that they are aware of the no-show policy and to determine if there are
accommodations that might need to be made to assist the rider. The
no-show suspension policy has not, however, been enforced to this point.

## Findings

1.  The Centro CAB ADA complementary paratransit eligibility
    determination process and application form for Onondaga, Oswego, and
    Cayuga Counties do not appear to adequately address path-of-travel
    issues or the impacts of weather on travel abilities, and
    consequently paratransit eligibility appears to be improperly
    restricted. CAB has implemented an eligibility determination process
    that very strictly interprets ADA paratransit eligibility
    requirements. Determinations are primarily based on a paper
    application and do not appear to adequately consider all of the
    functional limitations that could affect applicants' ability to use
    the fixed route system. A review of 20 recent determinations
    identified several examples where applicants' abilities to use fixed
    route were likely affected by path-of-travel barriers or severe
    weather conditions. These issues were not included, however, in the
    conditions of eligibility in final determination letters.

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1.  One of the eight recent determinations of ineligibility (not
    eligible under any conditions) for ADA complementary paratransit
    service for Onondaga, Oswego, and Cayuga Counties is questionable.
    Seven of the eight findings seemed appropriate. In the questionable
    case, the applicant indicated that "I cannot walk to or from the bus
    stop," but the application had some inconsistencies. CAB staff
    indicated that there had been no telephone follow-up with the
    applicant or the verifying professional and that the file did not
    include any documentation of follow-up.

2.  One of five recent determinations of ineligibility for Oneida County
    is questionable. Four of the five determinations of ineligibility
    seemed appropriate. In the questionable case, the applicant and
    verifying professional indicated that the rider had received a hip
    replacement affecting the applicant's ability to travel significant
    distances or in snowy or icy conditions to a bus stop. A
    determination of conditional eligibility, perhaps on a temporary
    basis, might have been more appropriate.

3.  The current eligibility process appears to make inappropriate
    determinations of conditional eligibility. The review of 10 recent
    determinations that resulted in conditional eligibility indicated
    that in six instances, a finding of unconditional eligibility ("In
    All Cases") probably would have been more appropriate, given the
    stated functional abilities of the applicants.

4.  The current eligibility process appears to result in inappropriate
    determinations of conditional eligibility for applicants with
    cognitive disabilities. In two of the 10 recent conditional
    determinations that were examined as part of the review, applicants
    with dementia and Alzheimer's were granted eligibility to
    "unfamiliar locations." For these applicants, familiarity with a
    destination did not appear to address the applicants' limitations,
    as they were likely to become confused while traveling, regardless
    of the location. The issue in these cases appeared to be an
    inability to travel alone to any destination. Unconditional
    eligibility ("In All Cases") appeared to be more appropriate.

5.  Eligibility determinations do not appear to authorize travel with
    personal care attendants in all cases where warranted. Current
    application forms do not appear to obtain adequate information about
    the need for personal care attendants. As a result, only 11 percent
    of all riders in Onondaga, Oswego, and Cayuga Counties are
    authorized to travel with personal care attendants. A review of 25
    application files identified several cases where applicants appeared
    to require personal care attendant services sometimes, but travel
    with a personal care attendant was not authorized in the final
    determination letters.

6.  The letters of determination sent to applicants in Onondaga, Oswego,
    and Cayuga Counties provide confusing descriptions of conditions of
    eligibility. Brief phrases such as "walk up to one block," or "stand
    up to 2 minutes" are used to explain conditions of eligibility.
    These phrases do not clearly explain conditions of eligibility to
    applicants. Several riders contacted in advance of the review
    indicated that they were confused about conditional eligibility.
    These phrases also do not provide sufficient information to permit
    an applicant to make an informed appeal of the determination.

7.  Eligibility letters do not clearly indicate the date of expiration
    of eligibility. The expiration date is included as a handwritten
    note at the end of the letter and is worded in a way that could lead
    an applicant to think it is an internal administrative note (e.g.,
    "Re-Evaluate on October 4, 2007").

8.  With the exception of issues described in Findings 10 and 11, the
    no-show suspension practices in Onondaga, Oswego, and Cayuga
    Counties appear to be consistent with regulatory requirements that
    indicate that service should be suspended only when there is
    documentation of a "pattern or practice of missing scheduled trips"
    (§ 37.125(h)). The efforts to contact and counsel riders about
    no-shows and to work out issues those riders may be having with the
    service are commendable. Suspensions are proposed for small numbers
    of riders, and only after a substantial record of missing scheduled
    trips, are accumulated.

9.  The administrative process related to no-show suspensions appears to
    sometimes charge riders with no-shows for non-ADA trips that they
    may not know have been scheduled. Some conditionally eligible riders
    whose trips are not initially scheduled are charged with no-shows if
    the trip is later scheduled. This can happen even if riders do not
    call back to confirm that they have accepted the ride.

10. No-show suspensions become effective almost immediately upon receipt
    of the no-show suspension letters. Time is not allowed for riders to
    request an appeal before the suspension takes effect. The current
    practice also appears to reinstate service on a case-by-case basis
    if an appeal is requested. DOT ADA regulations (§ 37.125(h) (3))
    require that service continue to be provided until any requested
    appeals are heard and decided.

11. It appears that ADA complementary paratransit service is provided to
    eligible applicants when CAB takes longer than 21 days to make an
    eligibility determination. Although more time is often required by
    CAB, service appears to be provided as long as a completed
    application has been received.

12. While it does not limit ADA eligible customers from obtaining
    service, Centro took more than 21 days to process 48 percent of a
    sample of 159 applications received during early 2007 in Onondaga,
    Oswego, and Cayuga Counties.

13. Participation by the Oneida County general manager in the six-person
    committee that hears formal ADA complementary paratransit
    eligibility appeals in Oneida County appears to violate the DOT ADA
    regulatory requirement that there be separation of functions between
    those hearing appeals and those making the initial eligibility
    decision. The regulations require that, to the extent practicable,
    the person hearing the appeal not be a supervisor of the original
    decision maker.

14. The appeals process in Onondaga, Oswego, and Cayuga Counties does
    not appear to be fully developed. In particular, the individuals and
    number of persons who would hear and decide formal appeals are not
    defined in the current written policy. Staff did not appear to know
    how the appeals panel would be constituted.

15. ADA complementary paratransit service eligibility does not appear to
    be adversely affected by Centro CAB's appeals process. Centro CAB
    appears to resolve most appeals of eligibility determinations
    informally. Only about one formal appeal a year is heard in Oneida
    County. No formal appeals appear to have been scheduled or heard in
    Onondaga, Oswego, and Cayuga Counties in recent years.

## Recommendations

1.  CNYRTA should consider developing a more thorough application form
    and eligibility determination process in order to obtain all
    information needed to set detailed conditions of eligibility. The
    form and process should obtain information about path-of-travel
    barriers as well as the effects of severe weather on travel
    abilities. Many transit systems that set and implement conditions of
    eligibility use an in-person process with interviews and functional
    assessments as needed to more completely identify all travel issues.
    CNYRTA should also review eligibility determination guidance
    developed by Easter Seals Project ACTION on this topic: "Determining
    ADA Paratransit Eligibility: An Approach, Guidance and Training
    Materials." This report is available free of charge from Project
    ACTION.

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16. CAB should employ a more workable approach to setting conditions of
    eligibility that ensures that eligibility is not unlawfully denied
    to legally entitled individuals. Applicants who indicate an ability
    to travel only very limited distances (to the curb or only one
    block), or applicants with similar serious travel limitations,
    should be granted unconditional rather than conditional eligibility

17. CAB should not grant conditional eligibility for "unfamiliar
    locations" to applicants who are not able to safely travel alone due
    to cognitive issues. These applicants should be granted
    unconditional eligibility if they can only travel on fixed route
    service with a personal care attendant or someone else assisting
    them.

18. CNYRTA should include specific questions about the possible need for
    and use of personal care attendants in its application form and
    should more thoroughly consider when applicants should be authorized
    to travel with a personal care attendant.

19. CNYRTA should revise the wording of conditions of eligibility in its
    determination letters to more clearly communicate to riders the
    circumstances when they are eligible for CAB services and when they
    are expected to use the fixed route system. For example, instead of
    using the phrase "Walk up to 3 blocks," determination letters could
    state that applicants are "eligible to use the Call-A-Bus service
    for trips that would require walking more than 3 blocks to get to
    and from fixed route bus stops."

20. CNYRTA should clearly state the expiration dates of eligibility in
    determination letters. For example, the determination letters could
    indicate that "Your eligibility for Call-A-Bus service will expire
    on October 24, 2010, by which time you will need to reapply to
    continue to use the service." To make sure that riders understand
    the expiration date, the sentence could be bolded or written in
    capital letters. It also is recommended that the process of sending
    notices of pending expirations of eligibility now used in Oneida
    County be extended to Onondaga, Oswego, and Cayuga Counties.

21. CAB should check to be sure that no-shows are not charged to riders
    for "DNC" trips that were not confirmed with riders.

22. CAB should allow at least 15 days between the receipt of a notice of
    a proposed suspension of service due to no-shows and the proposed
    date on which the suspension becomes effective. If suspensions are
    appealed, CAB should also continue to provide service and should
    delay the suspension until the appeal is decided.

23. In revising its eligibility determination procedures, CNYRTA should
    consider establishing a goal of making determinations within 21 days
    of receipt of a completed application.

24. CNYRTA should change its eligibility appeals committee for Oneida to
    avoid participation by a superior of the staff making the initial
    eligibility determination or document why it is impractical to do
    so.

25. CNYRTA should clarify the participants who would be called upon to
    hear and decide appeals of eligibility for all of its service areas.

# Telephone Access

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 greatly limit
peoples' ability to use the service and could therefore be a capacity
constraint. For this portion of the review, the team collected
information about telephone access to Centro's ADA complementary
paratransit service. The review team also conducted the following
activities:

-   Reviewed consumer input

-   Reviewed performance standards

-   Reviewed the design of the phone system

-   Reviewed phone system monitoring reports

-   Reviewed call center staffing

-   Observed call center personnel handling calls

## Consumer Comments

The review team gathered information about the concerns of riders who
use CAB service through several methods. The review team conducted
telephone interviews with riders and professionals who work with riders.
They also reviewed records of written and telephone complaints to CNYRTA
and one formal complaint filed with FTA.

With respect to telephone access for the purpose of making trip
reservations, the FTA complainant indicated that hold times are as long
as 10 minutes and that there are periods when all lines are busy. The
complainant also indicated that calls to the cancellation/information
line often received busy signals or went unanswered.

Telephone interviews with 12 customers and customer advocates indicated
difficulty accessing trip coordinators after 3 p.m. Some interviewees
said that calls went unanswered. Most said hold times ranged from 10 to
20 minutes. Customers indicated that hold times ranged from 0 to 5
minutes during other times of the day.

Of 18 customer comments and complaints filed in January 2007 regarding
CAB services in Onondaga, Oswego, and Cayuga Counties and nine
complaints filed during 2006 in Oneida County, three cited telephone
access as an issue.

## Phone Service Standards and Performance Monitoring

The CAB standard for telephone access as provided in the *Call-A-Bus
Service Standards -- Amendment to the ADA Plan of 1992* is that calls
will not be left on hold for more than 2 minutes, and that this standard
will be achieved at least 85 percent of the time by each division.

**Phone Service Design**

The DOT ADA regulations (49 CFR § 37.131(b)(1)) require transit
providers to make reservation services available on all days before a
service day, during at least during normal weekday business hours of the
transit agency. CNYRTA managers described normal business hours for
Utica and for Centro of Oneida as 8:30 a.m. to 4:30 p.m., and 8 a.m. to
5 p.m. for all other Centro divisions. In *Call-A-Bus -- An
Introduction* and the *Call-A-Bus Rider's Guide,* Centro identifies 8
a.m. to 5 p.m. as its uniform business hours.

Trip reservations are made through call centers at each of the five CAB
operating sites. The hours that trip reservations are accepted and how
they are accepted vary by operating area as set forth in Table 7.1

**Table 7.1** -- Call Center Coverage

+--------+--------+---------+--------------+------------+------------+
| **Co   | **S    | **S     | **Call       |            |            |
| unty** | ervice | taffed/ | Center       |            |            |
|        | Ce     | Voice   | Hours**      |            |            |
|        | nter** | Mail**  |              |            |            |
+--------+--------+---------+--------------+------------+------------+
|        |        |         | **Weekday**  | **         | **Sunday** |
|        |        |         |              | Saturday** |            |
+--------+--------+---------+--------------+------------+------------+
| Oneida | Utica  | Staffed | 8:30         | 12         | n/a        |
|        |        |         | a.m.--4:30   | n          |            |
|        |        |         | p.m.         | oon--4p.m. |            |
+--------+--------+---------+--------------+------------+------------+
|        |        | Voice   | n/a          | 8 a.m.--12 | 8 a.m.--5  |
|        |        | Mail    |              | noon       | p.m.       |
|        |        |         |              |            |            |
|        |        |         |              | 4 p.m.--5  |            |
|        |        |         |              | p.m.       |            |
+--------+--------+---------+--------------+------------+------------+
|        | Rome   | Staffed | 8:30         | 9          | n/a        |
|        |        |         | a.m.--4:30   | a.m.--4:30 |            |
|        |        |         | p.m.         | p.m.       |            |
+--------+--------+---------+--------------+------------+------------+
|        |        | Voice   | n/a          | n/a        | 8 a.m.--5  |
|        |        | Mail    |              |            | p.m.       |
+--------+--------+---------+--------------+------------+------------+
| Oswego | Oswego | Staffed | 7 a.m.--5    | n/a        |            |
|        |        |         | p.m.         |            |            |
+--------+--------+---------+--------------+------------+------------+
|        |        | Voice   | n/a          | 8 a.m.--5  | 8 a.m.--5  |
|        |        | Mail    |              | p.m.       | p.m.       |
+--------+--------+---------+--------------+------------+------------+
| On     | Sy     | Staffed | 6 a.m.--8    | 12 a.m.--4 | 12 a.m.--4 |
| ondaga | racuse |         | p.m.         | p.m.       | p.m.       |
+--------+--------+---------+--------------+------------+------------+
|        |        | Voice   | n/a          | 8 a.m.--12 | 8 a.m.--12 |
|        |        | Mail    |              | noon       | noon       |
|        |        |         |              |            |            |
|        |        |         |              | 4 p.m.--5  | 4 p.m.--5  |
|        |        |         |              | p.m.       | p.m.       |
+--------+--------+---------+--------------+------------+------------+
| Cayuga | Auburn | Staffed | 8 a.m.--5    | 7 a.m.--5  | n/a        |
|        |        |         | p.m.         | p.m.       |            |
+--------+--------+---------+--------------+------------+------------+
|        |        | Voice   | n/a          | n/a        | 8 a.m.--5  |
|        |        | Mail    |              |            | p.m.       |
+--------+--------+---------+--------------+------------+------------+
|        | SCAT   | Staffed | 8 a.m.--3    | n/a        | n/a        |
|        |        |         | p.m.         |            |            |
+--------+--------+---------+--------------+------------+------------+

As shown, trip reservation phone lines are typically staffed weekdays.
Reservation lines are also staffed part of the weekend in Onondaga
County, Cayuga County, and Oneida County. When trip reservation lines
are not staffed on the weekends, riders can leave requests on voice mail
systems. CNYRTA staff also indicated that in the near future they
planned to staff the reservation lines from 8 a.m. to 5 p.m. on weekends
in Onondaga County.

Centro managers indicated that full-time call-takers are planned for
Saturdays and Sundays at the Syracuse call center and Saturdays at the
Rome call center. As noted in Table 7.1, actual reservation service for
Rome and Utica on weekdays and Saturdays is not available during all the
weekday business hours described in the customer guides.

**Telephone Service Performance Monitoring**

The review team further assessed the telephone system used for
reservations at the Syracuse call center. CNYRTA provided the review
team with a report that presented the number of calls answered and in
queue for each one hour period of the day, for the entire month. The
numbers of calls are reported in reference to half-minute increments
(representing the number of calls still in queue after 0.5 minutes, 1.0
minutes, 1.5 minutes etc.). The data from the report covers the month of
March 2007 and is presented in Table 7.2.

A number of observations regarding customers' ability to make trip
reservations can be made from the reported data. For the month, 83
percent of calls to trip coordinators were answered in less than 2
minutes. This is slightly below the Centro standard of answering 85
percent of calls in less than 2 minutes. The data also indicates that
there were 228 callers (5 percent) on hold for more than 4 minutes and
146 callers (3 percent) on hold for more than 5 minutes. The longest
call queue time for the month was 17 minutes. While the regulations do
not provide exact numbers for what constitutes a substantial number of
calls in queue for a significantly long time, 5 percent of calls on hold
for more than 4 or 5 minutes at best meets only minimum telephone
performance requirements.

The phone reports also indicate patterns of potentially long hold times.
CAB encourages its customers to place trip requests and then call back
after 3 p.m. to confirm their scheduled times. Call volumes are highest
between 3 and 4 p.m. Telephone performance during reservation hours is
at its worst between 4 and 5 p.m., with only 70 percent of calls
answered within 2 minutes. During this hour, 6 percent of callers were
on hold for more than 4 minutes, and 4 percent for more than 5 minutes.
Call volume is still high after 5 p.m. because of customers confirming
their scheduled trips. From 5 to 6 p.m., 51 percent of calls were on
hold for less than 2 minutes; 29 percent of calls were on hold for more
than 4 minutes; and 20 percent of calls were on hold for more than 5
minutes.

During team member observations of reservations between 3:20 and 5 p.m.
on April 23, there were not significant numbers of calls in the
telephone queue. For much of the time, there were no calls at all on
hold.

## Call Center Staffing

Staffing levels at CAB were reviewed for adequacy in answering telephone
calls. The CAB office staff consists of 11 people. Of this number, seven
staff members are available to respond to customer calls, as well as
support scheduling and dispatch. Most office staff members work Monday
through Friday, with the road supervisor and one other staff member
working Sunday through Thursday, and one staff member working Tuesday
through Saturday. Based on these work schedules, Table 7.3 presents a
chart of telephone coverage for a typical weekday.

The table presents the number of call-takers ("trip coordinators") who
are available to take calls by hour of day. The table also identifies
the average number of calls answered by trip coordinators by hour of
day. The period of highest call volume is 3 to 5 p.m. Many of these
calls are to confirm next-day trip times and generally take less time
than calls for tasks such as scheduling trips. As a result, call-takers
may be able to respond to more calls during these time periods than
other hours of the day. Nonetheless, as discussed in Section 7.1,
percentage of calls answered in less than 2 minutes is at its worst
during the period of 4 to 5 p.m., and the percentage of calls on hold
after 4 and 5 minutes during this period is above average.

  ------------ ------- --- -------- ---------- ------ ---------- ------ ---------- ------ ---------- --------- ---------- ------ ---------- ------ ---------- ------ ---------- -------- ---------- ------ ---------- ------ ---------
  **Table                                                                                                                                                                                                                    
  7.2--                                                                                                                                                                                                                      
  Call-A-Bus                                                                                                                                                                                                                 
  Telephone                                                                                                                                                                                                                  
  Queue Report                                                                                                                                                                                                               
  for March                                                                                                                                                                                                                  
  2007**                                                                                                                                                                                                                     

                                    Interval                                                                                                                                                                                  
                                    in Minutes                                                                                                                                                                               

                                    \< 0.5            0.5--1.0          1.0--1.5          1.5--2.0             2.0--2.5          2.5--3.0          3.0--3.5          3.5--4.0            4.0--4.5          4.5--5.0          

   Calls                                                                                                                                                                                                                     Maximum
  Answered                                                                                                                                                                                                                   

  Time Period               Total   Num        Cum%   Num        Cum%   Num        Cum%   Num        Cum%      Num        Cum%   Num        Cum%   Num        Cum%   Num        Cum%     Num        Cum%   Num        Cum%   Minutes

  8:00 a.m.    9:00        385      269        70%    67         87%    22         93%    11         96%       3          97%    6          98%    6          100%   0          100%     1          100%   0          100%   4
               a.m.                                                                                                                                                                                                          

  9:00 a.m.    10:00       344      243        71%    46         13%    22         90%    11         94%       12         97%    5          99%    4          100%   0          100%     0          100%   1          100%   5
               a.m.                                                                                                                                                                                                          

  10:00 a.m.   11:00       294      217        74%    37         13%    18         93%    12         97%       2          97%    2          98%    1          98%    0          98%      2          99%    1          99%    6
               a.m.                                                                                                                                                                                                          

  11:00 a.m.   12:00       207      172        83%    20         10%    5          95%    6          98%       2          99%    2          100%   0          100%   0          100%     0          100%   0          100%   3
               noon                                                                                                                                                                                                          

  12:00 noon   1:00        227      167        74%    27         12%    10         90%    8          93%       6          96%    3          97%    2          98%    0          98%      1          99%    1          99%    6
               p.m.                                                                                                                                                                                                          

  1:00 p.m.    2:00        263      192        73%    27         10%    19         90%    3          92%       3          93%    1          93%    3          94%    1          95%      1          95%    4          97%    **17**
               p.m.                                                                                                                                                                                                          

  2:00 p.m.    3:00        350      184        53%    47         13%    25         73%    16         78%       9          80%    9          83%    8          85%    7          87%      6          89%    10         92%    12
               p.m.                                                                                                                                                                                                          

  3:00 p.m.    4:00        1,140    404        35%    238        21%    192        73%    113        83%       79         90%    49         94%    27         97%    16         98%      5          99%    3          99%    15
               p.m.                                                                                                                                                                                                          

  4:00 p.m.    5:00        651      216        33%    105        16%    86         63%    47         70%       61         79%    39         85%    29         90%    27         94%      11         95%    4          96%    11
               p.m.                                                                                                                                                                                                          

  5:00 p.m.    6:00        281      55         20%    24         9%     37         41%    28         51%       19         58%    18         64%    10         68%    8          71%      14         76%    11         80%    13
               p.m.                                                                                                                                                                                                          

  6:00 p.m.    7:00        165      67         41%    28         17%    17         68%    11         75%       12         82%    4          84%    7          88%    8          93%      5          96%    1          97%    11
               p.m.                                                                                                                                                                                                          

  7:00 p.m.    8:00        9        4          44%    0          0%     0          44%    1          56%       0          56%    0          56%    0          56%    2          78%      0          78%    0          78%    10
               p.m.                                                                                                                                                                                                          

                                                                                                                                                                                                                              

  Total                    4,317    2,191      51%    666               453               267                  208               138               97                69                  46                36                17

  Cumulative                                          2,857      66%    3,310      77%    3,577      **83%**   3,785      88%    3,923      91%    4,020      93%    4,089      95%      4,135      96%    4,171      97%     
  Total                                                                                                                                                                                                                      

                                                                                                                                                                                                                              

    Calls in                                          1,460      34%    1,007      23%    740        17%       532        12%    394        9%     297        7%     228        **5%**   182        4%     146        3%      
  Queue                                                                                                                                                                                                                      
  ------------ ------- --- -------- ---------- ------ ---------- ------ ---------- ------ ---------- --------- ---------- ------ ---------- ------ ---------- ------ ---------- -------- ---------- ------ ---------- ------ ---------

**Num**: number of calls answered within time interval

**Cum%**: percentage of calls answered up to and including time interval

  ------------------------ ------- ------ --- ------ --- ------ ------- ------- ------- ------- ------- ------- ------- ------- ------- ------- ------- ------- ------- -------- ------- -------- ------- -------- --- -------- --- ------ ---
  **Table 7.3 -- CAB                                                                                                                                                                                                                       
  Telephone Coverage for a                                                                                                                                                                                                                 
  Typical Weekday**                                                                                                                                                                                                                        

                                   6:00       7:00       8:00           9:00            10:00           11:00           12:00           1:00            2:00            3:00             4:00             5:00         6:00         7:00   

                                                                                                                                                                                                                                            

  **Trip Coordinator                                                                                                                                                                                                                        
  Shifts**                                                                                                                                                                                                                                 

  ** **                    ** **                                                                                                                                                                                                            

  ** **                    ** **                                                                                                                                                                                                            

  ** **                    ** **                                                                                                                                                                                                            

  ** **                    ** **                                                                                                                                                                                                            

  ** **                    ** **                                                                                                                                                                                                           

  ** **                    ** **                                                                                                                                                                                                           

  ** **                    ** **                                                                                                                                                                                                            

  **Phone Coverage**                      0   2      2   4      **5**   **5**   **5**   **5**   **5**   **7**   **7**   **7**   **7**   **7**   **7**   **7**   **7**   **6**    **6**   **4**    **4**   **2**    1   1        1   1      1

  ** **                    ** **                                                                                                                                                                                                            

  **Monthly Call                                         385            344             294             207             227             263             350             1,140            651              281          165          9      
  Volumes **                                                                                                                                                                                                                               

  **Calls/Coordinator **                                 43             34              29              15              16              19              25              **95**           **81**           **94**       **83**       5      

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

During the period from 3 to 6 p.m., the number of available trip
coordinators decreases each hour: from seven at 3 p.m., down to one at
5:30 p.m. Meanwhile, the two busiest hours for incoming calls are from 3
to 5 p.m. These results indicate that CAB should revise its staff
schedules to improve telephone service performance during these late
afternoon hours.

Other means of reducing reservation call hold times include reducing the
total number of customer calls, reducing the concentration of call
volume, and reducing the average time needed on each call. The number of
calls and peaking of calls in late afternoon could be reduced by more
extensive use of live scheduling, in which the trip is assigned to a
route at the time of the customer request and where all customer
communication is addressed in one call without further communication to
confirm the trip. Reducing the number of conditionally eligible ADA
complementary paratransit customers (discussed in Section 6) would
likely also reduce the time spent on each trip request. These procedures
are further discussed in Section 8 of this report.

## Findings

1.  For the sample month (March 2007), 83 percent of calls were answered
    in less than 2 minutes. This is slightly below the Centro standard
    of answering 85 percent of calls in less than 2 minutes.

2.  Between 4 and 5 p.m., 30 percent of callers were on hold for more
    than 2 minutes. Seven percent of callers were still on hold after 4
    minutes, and 4 percent after 5 minutes. The number of long hold
    times during late afternoon hours could limit customers' ability to
    reserve trips and use the service.

3.  From 5 to 6 p.m., 29 percent of calls to confirm trips were on hold
    for more than 4 minutes and 20 percent of calls were on hold for
    more than 5 minutes.

4.  According to CAB public information materials, call center hours for
    trip reservations are from 8 a.m. to 5 p.m. CNYRTA managers
    indicated that reservation hours in Rome are 8:30 to 4:30 p.m. DOT
    ADA regulations require that reservation service be available during
    at least normal business hours of the transit agency, which appear
    to extend to at least 5 p.m. for all CAB service areas.
    Additionally, the public information materials are inconsistent with
    the reservation hours for Rome and Utica and potentially confusing
    to customers.

5.  Available staffing for phone coverage in Syracuse steadily decreases
    after 3 p.m. even though call volumes are highest between 3 and 5
    p.m. This leads to longer telephone hold times.

## Recommendations

1.  Centro should take measures to reduce hold times during afternoon
    hours, particularly after 3 p.m. This could be accomplished through
    a combination of several changes, including increasing staffing
    during these hours, increasing live scheduling and thereby reducing
    customer call backs, and simplifying the procedures for determining
    trip eligibility and thereby reducing call times.

2.  All call centers should accept trip requests from 8 a.m. to 5
    p.m.---as indicated in Centro publications---or the publications
    should be revised to reflect the hours of operation. Reservation
    hours for all Centro ADA complementary service providers should
    equal or exceed Centro business hours.

3.  CAB should make all reservations through a single phone call and not
    require riders to call back to confirm trips.

# Trip Reservations and Scheduling 

The on-site review team evaluated reservations and scheduling of trip
requests for Centro's ADA complementary paratransit service. The purpose
of this portion of the review was to identify procedures or practices
that might limit service performance. Information reviewed and
observations of scheduling included:

-   Consumer comments

-   Centro reservations and scheduling procedures

-   Scheduling software

-   Interviews with Centro and CAB managers, schedulers, trip
    coordinators, and dispatchers

## Consumer Comments

As described in Section 3.3, the review team gathered information about
the concerns of riders who use CAB service through several methods. The
review team conducted telephone interviews with riders and professionals
who work with riders. They also reviewed records of written and
telephone complaints to CNYRTA and one formal complaint filed with FTA.

With respect to telephone access for the purpose of making trip
reservations, the FTA complainant indicated that hold times are as long
as 10 minutes and there are periods when all lines are busy. The
complainant also indicated that calls to the cancellation/information
line often receive busy signals or go unanswered.

The FTA complainant identified the following concerns regarding
reservations and scheduling:

-   Rides were not confirmed at the time of request

-   Ride times were not negotiated

-   Rides were scheduled 1 hour from the time that a fixed bus is
    scheduled to pass near the customers trip origin, not the times
    requested by the customer

-   Trips were scheduled only one way

-   ADA eligible ride requests were denied

-   Rides for medical treatment were given priority

Telephone interviews with 12 customers and customer advocates indicated
a number of potential compliance and service issues concerning trip
reservations and scheduling. Almost all customers believed that they had
to call back between 3 and 7 p.m. on the day before service to confirm
their trip. In general, customers appeared to find the multiple calls
and rules regarding trip reservations confusing. Other comments
included:

-   One customer indicated that he could not reserve a trip after 2:30
    p.m.

-   One customer thought that the trip would not be guaranteed if she
    tried to negotiate on the initial call.

-   Three customers said their trip requests were not always honored and
    others cited confusion about conditional eligibility and "courtesy
    trips."

-   One customer indicated he was denied an evening trip at a time and
    in an area served by fixed route.

-   Several customers mentioned confusion about the pickup window. One
    customer said it was 10 minutes and another 45 minutes, but no one
    knew the proper window.

-   There were several comments that customers were scheduled to a
    vehicle they were unable to board.

-   Customers cited trips for appointments being scheduled too early or
    too late.

Of 18 customer comments and complaints filed in January 2007 regarding
CAB services in Onondaga, Oswego, and Cayuga Counties and nine
complaints filed during 2006 in Oneida County, eight included issues
related to trip reservations. Several related to incorrect pickup
addresses and assignment of vehicles that the riders were unable to
board. One identified problems with confirming a trip.

## Trip Reservations

Team members observed the procedures for making trip reservations at two
of the call centers, the Syracuse call center in Onondaga County and the
Utica call center in Oneida County. Centro service policies allow CAB
customers to place trip requests up to 14 days in advance at all call
centers.

**Onondaga County**

The on-site review team members observed CAB call-takers accept trip
reservations in the 200 Cortland Street office on April 23 from 2:50 to
5:00 p.m. and on April 24 from 9:15 to 10:30 a.m. There did not appear
to be many calls on hold during the observations, and at 4:10 p.m. on
April 23 there were no calls on hold.

A total of 36 call observations were recorded. Only seven of the calls
involved trip requests by ADA riders. Nearly half (17) of the calls were
made by customers to confirm trips. The rest of the calls had a range of
purposes, including early cancellations, eligibility inquiries, trip
requests by non-ADA riders, and "Where's my ride?" (estimated time of
arrival) questions. In general, the trip coordinators were observed to
be courteous and professional in addressing customer requests.

The Onondaga operation uses Trapeze to assist with the trip reservation,
scheduling, and dispatching processes. Trip coordinators in Onondaga
County appeared to be fairly consistent in procedures and to capture all
of the key information needed to accurately book trips. For the typical
trip booking process, the trip coordinator takes the following steps:

-   Enters the name of the rider

-   Enters the day of the trip

-   Enters the pickup address; if the trip is originating from the
    rider's home, verifies home address

-   Enters the destination address

-   Asks the caller, "Do you want to confirm the trip (live schedule)
    \[see Section 7.3\] now with a 30 minute window, or do you prefer to
    call back the day before?"

-   Asks the caller if he/she has an appointment time. Depending on the
    response, the trip coordinator enters various times in Trapeze.

-   Asks for the return pickup time

-   Checks the fixed routes and fixed route hours of operation in the
    origin and destination areas, as needed, to ensure that the origin
    and destination are both within the ADA service area and that the
    fixed route service is operating at the times requested.

-   Checks to see if the rider is "conditionally eligible" and if the
    conditions exist for the trip requested \[explained in more detail
    below\]. If the trip is determined to be an eligible request, the
    trip is coded as a "DEM" (demand) trip. If the rider is
    conditionally eligible and it is determined that he/she could use
    fixed route service for the trip requested, the trip is entered as a
    "DNC" (did not confirm) trip---also explained in more detail below.

-   Informs the rider of the fare for the trip.

-   Verifies the mobility aid that the rider will be using if the record
    indicates multiple mobility aids.

-   Asks the caller about a PCA or companion for the trip.

After entering the trip information, the trip coordinators also do a
final verification of key trip information with the rider.

During interviews with Centro operators, they cited instances of
receiving unclear or incorrect information about riders, for instance
concerning customers' inability to board certain vehicles or being
accompanied by a PCA. They also cited occasional problems of incorrect
locations or addresses printed on manifests. It is not immediately clear
at what point in the scheduling process these miscommunications occur.
To minimize this type of miscommunication during the reservation
process, however, Centro should consider developing a checklist or
script for the trip coordinators to ensure that all relevant trip
information is confirmed with customers when booking trips.

**Trip-by-Trip Verification**

As the above process indicates, trip coordinators check trip requests
against the fixed route system to ensure that they are in the ADA
paratransit service area and that fixed route buses are running on the
days and times requested. Information about fixed route services is
contained in the Trapeze system and trip coordinators can call up route
and schedule information during the trip booking process. If there is
any question about whether the origin and destination are within
3/4-mile of a fixed route, the trip coordinator will enter the trip as
"presumptively eligible" and refer the trip information to a road
supervisor to be evaluated. Road supervisors then go to the origin
and/or destination and measure the distance to the nearest fixed route.
Notably, the presumptively eligible trips are always scheduled and
delivered, and determinations of trip ineligibility are not applied
until the next request.

A team member interviewed a road supervisor about the procedures used to
evaluate whether origins and destinations are within the service area.
Specifically, the road supervisor was asked how the distance to the
nearest bus route was measured. As described in Section 5, the road
supervisor indicated that he drives from the requested pickup or
drop-off location to the nearest bus route. A review of a recent
determination for a presumptively eligible trip request confirmed that
street miles are the basis for these determinations. Attachment M
contains the paperwork for a determination completed on April 19, 2007.
The paperwork shows that the requested pickup location was at the
intersection of Mott Road and Spyglass Lane in Fayetteville. The road
supervisor measured the street distance to the nearest bus route (the
East Genesee route) as 0.8 miles and had determined that the trip would
not be eligible. The location was then called up on a computer map and
the straight-line to the bus route was measured using a distance
measurement feature available on the computer. The straight-line
distance was only 0.17 miles. This suggests that the trip is well within
the ADA service area and should be eligible.

As noted in the trip booking procedures above, the trip coordinators in
the Onondaga operation also were actively applying any conditions of
eligibility to trip requests. Two trip coordinators described how they
checked the most common eligibility conditions:

-   **Distance Conditions.** If the rider's file indicates conditional
    eligibility based on a maximum walking distance, trip coordinators
    use the "Find Closest Wizard" in Trapeze to locate the bus stops
    nearest the origin and destination. The distance displayed on the
    map is then compared with the rider's maximum walking distance.

-   **"Extreme Weather."** Some riders have eligibility based on
    "extreme weather." Trip coordinators indicated that they interpret
    this to mean snow and ice and consequently base their decisions
    about eligibility on the season and possible weather conditions on
    the day of travel.

-   **Specific Weather Conditions.** Some riders are eligible only when
    specific weather conditions apply---for example, when the
    temperature is less than 40 degrees or more than 80 degrees. Trip
    coordinators indicated that in these cases they rely on their
    knowledge of the current and forecasted weather. They noted there is
    no official posting in the operations center of the upcoming weather
    forecasts.

-   **"Can't Climb Hill."** A few riders have eligibility based on an
    inability to negotiate steep terrain. In these cases, trip
    coordinators indicated that they rely on their knowledge of the
    area. If there are questions, they may ask a road supervisor to do a
    field assessment.

-   **"Unfamiliar Locations."** A number of riders are eligible for
    travel only to "unfamiliar locations." There was some inconsistency
    in how this condition was applied. One trip coordinator indicated
    that she looks at a rider's prior travel history on CAB. If the
    rider has previously traveled to the requested location on CAB, the
    location is considered "familiar" and the trip is not eligible.
    Another trip coordinator indicated CAB service is provided until a
    road supervisor travel trains the person to use fixed route service.

-   **"Wait 'X' Minutes."** A number of riders are eligible if they have
    to wait more than a defined number of minutes when transferring
    routes. Trip coordinators indicated that they consider the fixed
    routes that would be used for the trip and determine whether a
    transfer of buses is involved. If a transfer is involved, they look
    to see what the connection times would be. If the scheduled
    connection times are greater than the maximum time the person can
    stand and wait, the trip is considered to be eligible. Trip
    coordinators do not consider possible wait times for comparable
    fixed route trips requiring only one bus route or the possibility of
    longer wait times where buses are running late.

-   **"Physical Barriers."** A few riders have the general condition of
    "physical barriers," referring to obstacles that the rider
    encounters in the path of travel to and from transit. There was some
    uncertainty about how these types of conditions are checked. One
    trip coordinator indicated that she would ask a road supervisor to
    do a field assessment.

A number of issues are raised by the current method for implementing
trip-by-trip eligibility. First, as noted in Section 6 of this report,
many of the conditions of eligibility are quite vague. The conditions
also can be interpreted differently by different trip coordinators.

Second, the procedure used by at least one trip coordinator regarding
"unfamiliar locations" is not appropriate. The fact that a rider has
previously used CAB to travel to a location does not mean that the rider
is familiar with how to use the fixed route bus to get to that location.
One trip coordinator properly interpreted that this meant there had to
be evidence that the rider had been successfully trained to use the
fixed route service. His response that road supervisors would train
riders raised another issue: it did not appear that road supervisors
were trained travel trainers, travel instructors, or orientation and
mobility specialists. Consequently, it may not be appropriate for them
to be attempting to teach riders with cognitive or vision disabilities
(the riders to whom this condition is most often applied) to use the
fixed route service.

Considering wait times for transfers between fixed route buses, but not
considering possible waits at bus stops for one-route trips or late
buses is not appropriate. Many of the same issues that will prevent use
of the fixed route service and make an individual eligible for
paratransit service will arise when waiting for any bus. In particular,
many riders with "Wait 'X' Minutes" eligibility appear to have
conditions that allow maximum waits of only 2 or 5 minutes.

With respect to physical barriers, a team member observed a phone call
involving a customer who uses a power wheelchair. The trip coordinator
reviewed the fixed route schedule connections for the trip and
determined, based on her personal knowledge of path of travel for the
trip, that the requested trip was not ADA eligible. When questioned on
the particular path of travel, the trip coordinator indicated
uncertainty of its accessibility. The trip coordinator then changed the
status of the request from standby to a regular ADA trip. The trip
coordinator referred the path-of-travel information to the road
supervisor to verify accessibility of path of travel for application to
future requests for this trip.

If a trip coordinator determines that, based on the conditions of
eligibility in a rider's file, that the requested trip could be made on
fixed route, the trip is entered into Trapeze as DNC. The rider is told
that the trip is not ADA eligible but that he or she can call back three
to seven days before the date of the trip to see if it can be scheduled.
These non-ADA trips are not guaranteed; they are served on a space
available basis. It was noted, though, that CAB schedules and provides
most DNC trips. For example, a review of DNC trips for the week of
February 4 to 10, 2007, indicated that CAB scheduled all 120 DNC trips.

**Trip Requests: "Live Scheduling" and Call Backs**

CAB customers in Onondaga County can place trip requests in two ways.
They can ask that the trip be scheduled onto a run while they are on the
phone (known as "live scheduling" ---explained in Section 7.3).
Alternatively, customers can leave their request, have the trip
scheduled by CAB staff the day before the trip, and then call back after
3 p.m. (the day before service) to get their scheduled pickup time.

The *Call-A-Bus Rider's Guide* encourages customers to leave requests
and call back rather than ask for "live scheduling." On page 15, the
guide states, "If your trip is scheduled at the time of your request, we
will only be able to give you a broad estimate of your pickup time. If
you call back the day before your travel day, we will be able to provide
you with a more defined pickup and drop-off time." Team members also
observed that if riders asked for "live scheduling," the trip
coordinators would say something like, "It will be a 30 minute window if
I live schedule now. Is that clear?"

When this was discussed further with CAB staff, they explained that if
trips are live scheduled, riders are told that the pickup can take place
any time within the 30 minute on-time window. If they simply place the
request and call back the day before, riders are given the exact
scheduled pickup time. However, all trips are scheduled to the 30 minute
on-time window, whether they are live scheduled or the customers choose
to call back. As a consequence, there is no apparent advantage in using
either method for the customer with respect to how close the pickup time
will be to the time requested by the customer. In fact, if riders "live
schedule," they are made aware of the scheduled time and pickup window
while they are on the phone and can negotiate a better time if the trip
time offered is not convenient. If the customer simply leaves a request
and calls back the day before, there is less opportunity to negotiate.
Customers who live schedule can still call on the afternoon before the
service day for a more precise estimated vehicle arrival time---the same
as the customer who schedules using the call back method.

In addition, since the pickup window is based on the requested time, the
customer can be confident the vehicle will arrive within 25 minutes of
the requested time. When a pickup time is provided to a customer who
uses the call back method, the on-time window is measured from the
scheduled time provided the customer---and not the originally requested
time, meaning that the pickup time could be more than 25 minutes from
the requested pickup time.

CAB riders in Onondaga County can make trip requests based on a
requested pickup time or an appointment/desired drop-off
time---whichever is more appropriate for the trip. The *Rider's Guide*
encourages riders to provide trip coordinators with an appointment time
if they need to be at their destination by a specific time. A fairly
elaborate set of procedures has been created to record trip information
in the Trapeze system, with different steps depending on whether or not
the trip is live scheduled and if an appointment time is requested. The
procedures are described in the following paragraphs.

**Live Scheduled Trips.** If the customer provides an appointment time:

1.  The trip coordinator enters the stated appointment time in the "LT"
    (latest time) field in the "Destination" tab of the trip booking
    screen.

```{=html}
<!-- -->
```
1.  The trip coordinator checks the trip distance. If the trip is less
    than 10 miles, the trip coordinator enters the appointment time
    minus 60 minutes in the "ET" (earliest time) field in the "Origin"
    tab of the trip booking screen, enters the appointment time minus 55
    minutes in the "Req" (requested time) field of the "Origin" tab, and
    enters the appointment time minus 30 minutes in the LT field in the
    Origin tab of the trip booking screen.

2.  If the trip distance is 10 or more miles, the trip coordinator
    enters the stated appointment time minus 90 minutes in the ET field,
    the appointment time minus 85 minutes in the Req field, and the
    appointment time minus 60 minutes in the LT field all in the Origin
    tab.

3.  Finally, the trip coordinator enters information about the trip
    request in the "Comment" field (e.g., "arr 9:00 rtn 11:00" for a
    requested 9 a.m. appointment and 11 a.m. return trip).

If the customer provides a requested pickup time:

1.  The trip coordinator enters the requested pickup time in the ET
    field of the Origin tab.

```{=html}
<!-- -->
```
4.  The trip coordinator enters the requested pickup time plus 5 minutes
    in the Req field of the Origin tab.

5.  The trip coordinator enters the requested pickup time plus 30
    minutes in the LT field in the Origin tab.

For either a requested pickup or appointment, the trip coordinators is
supposed to provide the customer with an expected pickup time of 5
minutes before to 25 minutes after (hereafter referenced as -5/+25) the
requested pickup time. It is unclear whether the "requested" time is the
time actually requested by the customer or the time entered into Trapeze
(time requested by customer plus 5 minutes).

**Call Back Trips.** If the customer provides an appointment time:

1.  The trip coordinator enters the stated appointment time in the LT
    field in the "Destination" tab of the trip booking screen.

```{=html}
<!-- -->
```
1.  The trip coordinator then checks the trip distance. If the trip is
    less than 10 miles, the trip coordinator enters the appointment time
    minus 60 minutes in the Req field of the Origin tab.

2.  If the trip distance is 10 or more miles, the trip coordinator
    enters the stated appointment time minus 90 minutes in the Req field
    in the Origin tab.

If the customer provides a requested pickup time:

1.  The trip coordinator enters the requested pickup time in the ET
    field of the Origin tab.

```{=html}
<!-- -->
```
3.  The trip coordinator enters the requested pickup time plus 10
    minutes in the Req field of the Origin tab.

These procedures appear to be designed to provide the scheduler with
information to assist with the scheduling process (which, as explained
later in Section 8.3, is largely a manual process) and to ensure that
times are not moved outside of the on-time pickup window given to
riders. It was also noted, though, that these procedures have the effect
of entering times in the requested field in Trapeze that differ by 5 or
10 minutes from the times actually requested by the customer.

One call-taker was observed entering scheduled times in the estimated
field for trips assigned to taxi operators so that manifests will show
only one time.

CAB makes little use of subscription service. Staff noted that new
subscription service has not been granted for several years. A few
riders were granted subscription service in the 1990s and still use the
system. Most riders who travel regularly are instructed to call every
two weeks and book all of their trips for the next two-week period. A
review of trip records for a sample future weekday (Tuesday, May 8)
found that there were only five people (10 one-way trips) on the system
as "Reg" riders (regular subscription riders) on that day.

**Utica**

Team members also observed and reviewed the trip reservation procedures
used in Utica. The Utica operation uses a customized database (Jakeware)
to manage client records and trip records. Jakeware is used to maintain
a master rider file and to generate statistical reports. It does not
include a trip booking module or scheduling algorithm. Trip reservations
and scheduling in Utica are performed manually.

Five vehicles are operated daily in Utica for CAB service. Five
clipboards---one for each vehicle---are used to record and schedule trip
requests. Each clipboard has a sheet for each day of service. CAB riders
in Utica may book trips 14 days in advance, consequently each clipboard
has a page for each of the days of service for the next two weeks.

Each clipboard page displays times of day in 15 minute intervals. As
trip requests are received, they are manually recorded on the
appropriate page. If a time slot is already taken, the next closest 15
minute time slot is used to schedule the trip.

Trips from a Utica home are typically scheduled based on the stated
appointment time, as opposed to a requested pickup time. Depending on
the trip distance, Utica staff allows 15, 30, or 45 minutes of travel
time. Return trips are scheduled to the requested pickup times. Trip
times are negotiated up to 60 minutes from the requested time. For
return trips, the negotiation considers only the hour after the
requested return pickup time. Riders are not asked to leave appointments
before the requested return time.

Utica operations staff indicated that they always offer a trip option,
even if it is not within 60 minutes of the requested time. If a time
slot is not available within 60 minutes of the requested time, though,
staff records the request as a denial. This information is recorded
whether or not the rider accepts the trip time offered. Trip denials are
recorded manually in a notebook.

A review of recent trip denial records showed that from January 1, 2007,
through March 31, 2007, a total of 29 round trips (58 one-way trips)
were denied or could not be accommodated within 1 hour of the requested
time. A copy of the trip denial log for this period is provided in
Attachment N. The records indicate an average of about four to five
one-way trip requests per week, or about one round trip every two days.
Utica staff noted that they were hoping to be able to accommodate this
small number of denied trips by having fixed route "extra-list"
(extra-board or spare) operators available to perform these trips. They
were in negotiation with the operators union at the time of the on-site
review and hoped to begin using extra-list operators within a few
months.

CAB riders in Utica also are able to schedule subscription service as
needed. There is no formal policy on what qualifies for subscription
service. Any type of trip made on a regular basis can be scheduled as a
subscription trip. Utica staff noted that they have no waiting lists for
subscription service.

Schedule changes are made manually on the clipboard sheets. For example,
if a scheduled trip is canceled, the trip is either erased from the
clipboard sheet or covered with white-out. It also was noted that there
is no formal record of actual requested trip times. The negotiated time
is recorded on the clipboards, but the actual requested time is not
recorded in any way.

Utica CAB service is only provided at times when fixed route service is
in operation and in corridors around the fixed routes. Operations staff
indicated that, given the limited size of the area, they have a good
working knowledge of the service area and the fixed route schedules. If
there are any questions, they look the trip location up on "MapQuest"
and compare the location with the fixed route maps. If this still does
not provide a conclusive answer about the eligibility of a trip, they
may ask a road supervisor to conduct a field evaluation. As was done in
Onondaga, staff indicated that road supervisors check proximity to fixed
routes by measuring the street distance rather than the straight-line
distance.

Unlike the Onondaga operation, Utica does not set specific conditions of
eligibility and does not do any type of trip-by-trip eligibility
determination.

## Scheduling

As with reservations, the CAB scheduling procedures were reviewed for
two operating divisions, Syracuse in Onondaga County and Utica in Oneida
County.

**Onondaga County**

The Onondaga County operation schedules between 350 and 400 ADA trips
per weekday. Passenger trips are assigned to CAB vehicles, dedicated
subcontractor vehicles, or non-dedicated subcontractor vehicles. The
scheduler is able to use operators from the fixed route extra-list to
cover any uncovered runs. To be eligible, the extra-list operators must
be trained and determined to be certified to drive for CAB. There are a
total of 38 daily runs (25 during the peak period) available for
scheduling trips on weekdays. In addition, trips can be assigned to CNY
Sedan Services

There is one primary scheduler who uses Trapeze software to assist in
the scheduling of rides. Other CAB staff members are cross-trained to
fill in when the scheduler is not available. Work on a given day's
schedule starts two to three days before the day of service, but the
final scheduling of trips is essentially done by the morning of the day
before service. According to the scheduler, any additional trip requests
for the next day are scheduled by the trip coordinators as they receive
the next-day trip requests. Any requests that the trip coordinators
cannot schedule are referred to the scheduler. All requested trips are
scheduled to runs; no trips are left unscheduled at the end of the day
to be assigned during the service day.

The scheduler starts with non-ADA trips already assigned to vehicle
runs. These include trips for senior citizens, rides for work, and
Medicaid trips. Notably, there are few subscription ADA trips for
Onondaga County. The schedules are built manually using the "drag and
drop" feature in Trapeze. Using this method, the scheduler drags a
requested trip from an unassigned list and drops the trip into an
available route or run. The scheduler indicated that he uses this
technique until the schedule has "more form" (i.e., when most of the
vehicle runs have general outlines of their geographic tours).

When the schedule has more form, he uses the "Schedule Booking Wizard"
in Trapeze to either place trips on runs or provide suggestions where
the trip can be manually placed. Based on the time, origin, and
destination of the requested trip, the schedule booking wizard examines
each run and identifies runs with available ("slack") time that can
effectively serve the trip. According to the scheduler, he schedules the
trips within the pickup window of 5 minutes before to 25 minutes after
(-5/+25) the requested time. As noted in the reservations discussion,
the trip coordinators are entering the time requested by the customer in
the early field and the actual requested time plus 5 or 10 minutes in
the requested field. Differences between the time requested by the
customer and the time entered into the requested time field used in
Trapeze may lead to scheduling errors and miscommunication with
customers.

If it is necessary to move a trip outside of the -5/+25 pickup window,
the scheduler is supposed to call the customer to ask if the suggested
time is acceptable. A review of 77 trips on February 7, 2007, found that
10 trip requests had scheduled times outside of the pickup window. One
of those trips was scheduled 30 minutes after the requested time. The
other nine were scheduled between 8 and 15 minutes before the requested
time.

It appears that most customers choose not to schedule live. This means
they do not negotiate their trip times at the time of the initial call.
According to the ADA regulations minimum requirements (and Centro
practice), their trips may be scheduled, through negotiation, up to 60
minutes before to 60 minutes after the requested time. The review team
did not observe any scheduled times that were outside of the allowable
negotiation window. However, customers who call after 3 p.m. to learn
their "negotiated" pickup times may feel an implicit pressure to accept
the ride as offered or risk not getting the rides---even if the times
offered are not convenient. In the view of the complainant to FTA, this
practice is not a true negotiation of a pickup time.

Since manual scheduling is used, the scheduler must be aware of mobility
needs or other conditions pertaining to the customer's travel needs.
This is handled in one of two ways. For customers who are non-ambulatory
or use a mobility aid, the scheduler uses the "Alert" feature in
Trapeze. This feature allows the name of the customer to appear in a
different color and enables the scheduler to know, by looking at the
color of the name, whether the customer needs a lift-equipped vehicle.
If a customer has some other special need, that need is included in the
last name field (e.g., "'no van' Smith"). This visual cue should alert
schedulers of any special needs, but customers commented that Centro has
occasionally scheduled them to vehicles they were unable to board. While
Trapeze has the capability to account for mobility needs of customers,
the scheduler can override these needs (intentionally or not) when using
the "drag and drop" technique of scheduling.

As the scheduler creates the daily schedule, his first priority is to
schedule rides to Centro vehicles, then to vendor vehicles where Centro
purchases blocks of time (dedicated runs), and lastly to vendors paid
per trip or by meter. CAB managers indicated that the vendors are
sometimes given longer trips based on the passenger and vehicle
requirements. Vendors generally run the schedules as created by Centro,
but may move trips between dedicated runs if necessary. If a vendor
makes a change, it is supposed to notify the Centro office. While
observing dispatch operations, team members did not see any instances of
dedicated carriers moving trips between dedicated runs, or back to CAB
runs.

The operator manifests are printed between 3:30 and 4 p.m. the day
before service. However, the transportation coordinators continue to
take trip requests for the next day until 5 p.m. Any trip requests
scheduled after the manifests are printed are still entered into the
system. On the day of service, the dispatchers are responsible for
noting any additional trips, cancellations, or other changes on the
drivers' manifests; they inform operators when they pick up their
vehicle assignments. In the event a significant change has been made, a
new operator's manifest may be printed out on the day of service. If
there is a change to a vendor manifest, the Centro dispatcher is
responsible for notifying the vendor dispatcher.

Notably, the pickup time printed on the operator manifests is the
*estimated time* of vehicle arrival. In Trapeze, there are three
distinct times related to a pickup:

-   requested time

-   scheduled time

-   estimated time

The requested time is the time when the customer asked to be picked up.
The scheduled time is the negotiated time agreed upon by the customer
and transit system (the "0" of the pickup window); the scheduled time
may be identical to the requested time. The estimated time is the time
Trapeze anticipates the pickup will occur based on other pickup and
drop-off points and times, travel speeds, and time spent at stops for
customers.

As trips are added or canceled, the estimated times may change, but the
scheduled time remains fixed. As noted above, the scheduled time, as
negotiated with the customer, may be different from the estimated time
that the operator has on the manifest. Furthermore, since the manifests
are printed before scheduling is complete, even the estimated time may
have changed. This creates the potential that different times are
provided to customers and operators for pickups. As a result, the
operator may arrive earlier than the time given to the customer (i.e.,
before the stated pickup window). This could lead to improperly recorded
passenger no-shows or carrier missed trips. Reported examples of such
occurrences are discussed further in Section 9 of this report.

**Oneida County Division**

The review team observed the scheduling process for Oneida County, Utica
Division. As discussed earlier in this section, the Oneida County
operation does not have scheduling software; reservations and scheduling
are done manually.

Approximately 100 trips per weekday are scheduled to five runs for the
division. As described above, five clipboards are placed in the
reservations area, one for each run. Each clipboard has 14 sheets of
paper, one for each of the 14 days (13 in advance) that trip requests
are scheduled. Each page is divided into 15 minute increments. Any
standing orders are pre-printed on the daily sheets. As customers call,
the run sheets are scanned to find a time when the customer's trip can
be placed on a run. Oneida County's policy is that trips are scheduled
from 15 minutes before to 15 minutes after the requested time. When an
appropriate run and time are found, the customer's name and other trip
information are recorded on the sheet. On the day of service, the
completed sheet serves as the operator manifest for the day.

When a customer calls to cancel a trip, the trip is stricken from the
run. Staff members are able to determine the number of cancels, but no
other information about canceled trips is retained.

## Findings

1.  In Onondaga County, all requests for trips identified by trip
    coordinators as ADA eligible appear to be accommodated. Team members
    did not observe denials of eligible trips during the trip
    reservation process. CAB also reports no trip denials.

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17. In Utica, there appear to be a small number of ADA trip denials, at
    the rate of about one round-trip every two days. Staff indicated
    that they planned to eliminate these trip denials by having fixed
    route extra-board operators perform trips that cannot otherwise be
    provided. Negotiations with the fixed route operators union were
    underway at the time of the review to allow this practice to be
    implemented.

18. In both the Onondaga County and Utica operations, distance in street
    miles from the fixed route system is used to determine if requested
    pickup and drop-off locations are within the ADA service area. The
    regulations indicate that the 3/4-mile minimum ADA service area
    corridors are defined using straight-line distance (see Section
    37.131 Appendix D of 49 CFR Part 37). Some trips in the service area
    appear to have been mistakenly categorized as not eligible based on
    this incorrect method of measuring the service area corridors.

19. The methods used by trip coordinators in the Onondaga operation to
    interpret and apply rider conditions of eligibility appear to be
    inconsistent and, in some cases, inappropriate. It is likely that
    the current method of performing trip-by-trip eligibility has
    resulted in some trips that are eligible being categorized as not
    ADA eligible. Also, as indicated in Section 6 of this report, the
    conditions of eligibility that are being used do not appear to
    consider all of the possible travel limitations that apply to
    riders.

20. The procedures used to book trips in Onondaga County do not
    accurately capture actual requested trip times. The requested times
    stated by riders appear to be changed by 5 to 10 minutes in many
    cases to accommodate the current trip scheduling process. As a
    result, the times requested by customers are not clearly and
    consistently recorded. This limits the ability to measure
    performance against requested times and potentially leads to
    confusion in communications.

21. The procedures used in Utica to record and schedule trips do not
    appear to provide for a complete record of trip requests. Initial
    trip request times are not recorded; only the final negotiated times
    are recorded. Moreover, if a trip is rescheduled or canceled, the
    original record is erased and only the new trip time is preserved.
    As a result, it is not possible to measure the responsiveness of
    trip offers to customer requests or to track trip cancellations.

22. The Onondaga County Division uses the time fields in Trapeze in a
    manner that fosters miscommunication in scheduling and serving
    trips. Trip coordinators enter the times requested by customers in
    the "early" time field, rather than the "requested" time field. When
    customers call to confirm trip times on the afternoon before
    service, they are provided "scheduled" times---while operators are
    given the "estimated" vehicle arrival time at the time the manifests
    are printed. The potential for different times promotes
    miscommunication and increases the possibility of inappropriate
    no-shows or missed trips.

23. During interviews with Centro operators, they cited instances of
    receiving unclear or incorrect information about riders, such as
    customers' inability to board certain vehicles or being accompanied
    by a PCA. They also cited occasional problems of incorrect locations
    or addresses printed on manifests

24. For the majority of Onondaga County customers who choose not to
    schedule their trips live, the scheduler assigns trip times within
    the allowable window of -60/+60 minutes. No negotiation takes place
    with the customers before the trip is scheduled. Moreover, providing
    customers with a scheduled time when they call to confirm trips on
    the afternoon before service may place implicit pressure on the
    customers to accept the ride times as-scheduled. This procedure does
    not appear to be true negotiation of a pickup time.

25. Printing manifests before the end of the reservation period on the
    day before service potentially increases the number of manual
    changes that must be made to each run before service. The number of
    potential changes likely increases as trip volume increases. Adding
    a large number of trips after the schedules have been completed can
    contribute to late and missed trips.

26. Few recurring trips are prescheduled as subscription trips at the
    Onondaga operation. Prescheduling subscription trips can reduce the
    time required to schedule trips, improve efficiency of runs, and
    reduce call volumes associated with trip requests.

27. In Oneida County, trip information on canceled trips is not being
    retained. A record of the cancellation can be helpful, should the
    change in trip status be questioned after the fact. For example, the
    information can be helpful in documenting late cancellations or
    disputed cancellations.

## Recommendations

1.  CNYRTA should continue with its proposed plan to use fixed route
    extra-board operators to eliminate trip denials in Utica. Should
    this approach be unsuccessful, CNYRTA should develop an alternative
    means of providing flexible service capacity to eliminate denials

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28. CAB should use computer mapping systems to determine straight-line
    distance between requested pickup or drop-off locations and the
    nearest fixed routes. Road supervisors could still be used to
    determine the exact locations of pickup and drop-off addresses, but
    once these locations are known and accurately identified on a
    computer map, straight-line distances should be calculated using
    computer mapping technology. Alternatively, as suggested in Section
    5, CAB could use commonly known boundaries or features to define a
    service area that meet or exceed the regulatory requirements. This
    approach, while including more locations in the service area, is
    more easily understood and communicated.

29. More specific and consistent approaches to applying eligibility
    conditions should be developed and implemented if CNYRTA continues
    to do trip-by-trip eligibility determinations. If trip-by-trip
    determinations continue to be performed, a more thorough
    determination of all the conditions of eligibility also should be
    performed. CNYRTA should develop an alternate approach for
    determining trip-by-trip eligibility outside of the reservation and
    scheduling processes. Most transit systems that use trip-by-trip
    eligibility have trained staff members conduct field assessments for
    frequently made trips. The eligibility of each trip in question is
    then entered into the reservations and scheduling system or a
    supplemental database. Trip coordinators then only need to check the
    list of assessed trips to determine if a requested trip is eligible
    or not. If a requested trip has not yet been assessed and is not in
    the system, it is provided until an assessment is completed. This
    approach reduces customer uncertainty and confusion regarding trip
    eligibility, simplifies the trip coordinator's job, reduces call
    times, and can reduce potential errors in trip determinations.

30. CAB should develop procedures to accurately capture and record
    actual trip request times. Trip coordinators should enter requested
    pickup times into the proper "Req" (requested time) fields in
    Trapeze (rather than entering adjusted times). System parameter
    settings should then be used to apply these times properly in the
    scheduling process.

31. Centro should develop procedures for capturing and preserving
    complete trip request and final service records in the Utica
    operation. CAB staff can use a "Trip Request" form in Utica to
    supplement the current manual trip booking and scheduling process.
    This form could capture the original rider requested trip times,
    which if entered into the database, along with information from the
    clipboard sheets, would provide a more complete record of requested
    times as well as final scheduled times. The resultant data would
    permit comprehensive monitoring of service performance against the
    criteria in the DOT ADA regulations.

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27. The Onondaga County Division should standardize the time given to
    customers and operators to be consistent with the time fields in
    Trapeze. All times requested by the customer for pickups should be
    entered into the requested field. All pickup times derived from
    requested appointment times using CAB procedures should be entered
    into the requested time field. Pickup times agreed to by the
    customer should be entered as negotiated times. Scheduled times
    should be the same as negotiated times. Scheduled pickup and
    appointment times should be printed on all operator manifests so
    that operators have the same pickup and appointment times as those
    given to customers.

28. To minimize miscommunication during the reservation process, Centro
    should consider developing a checklist or script for the trip
    coordinators to ensure that all relevant trip information is
    confirmed with customers when booking trips.

29. The Onondaga County Division should consider live scheduling all
    trips with customers. Doing so would permit customers to negotiate
    scheduled trip times and reduce call volume, eliminating the need
    for call backs. Live scheduling is typically done by using a pickup
    window for all trip requests. The window provides the operator some
    flexibility in scheduling trips in response to requests.

30. To simplify communication of the pickup information, trip
    coordinators should give customers a time range (the pickup window),
    rather than a specific time, when confirming trips. The window
    should be as simple as possible to understand (e.g., 0 to 25
    minutes) and as short as possible, while providing sufficient
    flexibility to schedule efficiently and accommodate unpredictability
    of daily service and traffic conditions.

31. CAB should print manifests after all reservations, including all
    negotiations of trip times, have been completed.

32. CAB should develop guidelines for allowing customers to schedule
    subscription service in Onondaga County. Centro should encourage
    subscription service where practical, helping both the customers and
    CAB.

33. CAB should consider increasing the use computer-assisted scheduling
    in Onondaga County. In particular CAB should consider live
    scheduling trip requests, in combination with pre-scheduling
    subscription trips, and batch scheduling more than two days before
    the service day.

34. CAB should develop procedures for documenting trip information for
    canceled trips for Oneida County. Among other uses, the
    documentation can be helpful if the trip status is later questioned.

35. CAB should post notices of the weather forecasts for the next few
    days, in order to facilitate decisions for conditional eligibility.

# Service Performance 

Section 37.131(f) of the DOT ADA regulations prohibits transit entities
from having operational patterns or practices that significantly limit
the availability of complementary paratransit service to ADA paratransit
eligible individuals, including, but not limited to:

-   Substantial numbers of trip denials or missed trips

-   Substantial numbers of untimely pickups

-   Substantial numbers of trips with excessive trip lengths

This section of the report addresses CAB service performance policies as
expressed in service criteria and standards, service procedures, and
practices that may contribute to service performance. The covered areas
include assignment of operators, equipment, and dispatchers, operator
operations, and performance in serving requested trips on time and with
reasonable trip duration.

## Consumer Comments

As described in Section 3.3, the review team used several methods to
gather information about the concerns of riders who use CAB service. The
review team conducted telephone interviews with riders and professionals
who work with riders. They also reviewed records of written and
telephone complaints to CNYRTA and one formal complaint filed with FTA.

The FTA complainant raised the following issues associated with service
delivery:

-   Frequent excessively long rides

-   Operators fail to tie down wheelchairs at four points

-   Late pickups and arrivals

-   "Sub-standard" vehicles

In telephone interviews with 12 CAB riders and consumer advocates,
review team members asked the interviewees questions regarding late
trips, long trips, and operator performance. Most interviewees indicated
that pickups were usually on time. Notably, however, none understood the
on-time pickup window. Four customers mentioned pickups from 20 to 30
minutes early or late and operators having different pickup times from
customers. Four respondents indicated that they were usually dropped off
at appointments on time. Four customers cited drop-offs that were 30 to
60 minutes early.

Most interviewees were very complimentary of regular CAB operators. Five
interviewees indicated that operators are sensitive to the needs of
riders, do a good job with directions, and know how to use lifts and
wheelchair tie-downs. One customer commended the operators' ability to
drive in snow. Five others indicated that the regular operators did
well, but backup operators and contract operators get lost. They also
cited other problems with backup operators, including their use of
lifts, their use of air conditioning, their lack of courtesy, and their
beeping horns upon early arrival.

Several interviewees cited problems identifying the CAB vehicles. One
customer who is unable to wait outside in winter mentioned being unable
to see the vehicle from the building. Other customers mentioned
difficulty in identifying contractor vehicles and CAB vehicles covered
with shrink-wrap advertising.

One interviewee was concerned that Bella Via operators were not properly
screened and licensed.

Three interviewees said that they had not experienced problems with long
trips. Four had occasional problems. Three interviewees cited problems,
including being on the vehicle for a long time as the result of long
trip distances, circuitous routing, and vehicles filled with as many as
eight passengers.

Of 18 customer comments and complaints filed in January 2007 regarding
CAB services in Onondaga, Oswego, and Cayuga Counties and nine
complaints filed during 2006 in Oneida County, 17 related to service
delivery. Three complaints concerned the use of wheelchair tie-downs,
and three related to late or long trips. Three complaints concerned
operators.

## Service Policies

As indicated earlier in the report, Centro has adopted standards for CAB
services with respect to trip denials, missed trips, customer no-shows,
on-time performance, and trip duration.

-   **Trip Denial.** Centro describes a **trip denial** as "any event
    where an eligible customer is denied an eligible ride if the request
    is made in the appropriate timeframe."

-   **Missed Trip.** A **missed trip** is an event where the vehicle
    fails to arrive for a scheduled pickup.

-   **No-Shows.** A **no-show** is described in CAB service policy as
    customer "failure to board a reserved Call-A-Bus."

-   **On-Time Performance.** Centro defines an **on-time trip** as "the
    vehicle arriving at the pickup location any time from 5 minutes
    before the scheduled pickup time to 25 minutes after the scheduled
    pickup time..." The standard for on-time performance is "95% or
    better compliance rate per month measured at the division level."

-   **Travel Time.** CAB performance standards for trip length are
    "trips of five miles or less shall be accomplished in 60 minutes or
    less. Trips of greater than five miles to less than 10 miles shall
    be accomplished in 90 minutes or less. Trips of greater than 10
    miles shall be accomplished in 2 hours or less. Call-A-Bus shall
    maintain a 95% or better compliance rate per month, measured at the
    division level."

For **trip denials**, the definition of eligible customer has been
addressed in Section 6 of this report. In general, the findings of the
eligibility review in Section 6 indicate that CNYRTA determines
individuals who are unable to use fixed route service as the result of a
physical or mental impairment eligible to use Call-a-Ride for at least
some trips. CNYRTA defines an eligible ride as having an origin and
destination within the ADA service area. As discussed in Section 5,
CNYRTA had incorrectly defined the ADA service area as a roadway
distance of 3/4‑mile from each transit stop, rather than the larger area
defined by the straight-line distance of 3/4‑mile from all points on the
bus route. Application of the incorrect standard has had the effect of
denying trips that have an origin and destination in the larger zone
defined by the regulations rather than the smaller zone used by CAB.

Additionally, as discussed in Section 6, many passengers are granted
conditional eligibility with trip coordinators making determinations of
trip eligibility for each trip request made by the conditionally
eligible customer. Trip coordinators often do not have sufficient
information to make such determinations. For example, customers with
conditional eligibility may not be able to travel to boarding locations
or destinations because of conditions related to their disabilities
and/or architectural or environmental barriers. Absent access to a
survey of each path between origins/destinations and fixed route stops,
trip coordinators were observed relying on their own knowledge of the
area and judgment. Trip coordinators are supposed to refer
path-of-travel questions to a road supervisor to assess the path of
travel in question, treat the initial trip as an eligible trip, and
apply ineligible trip determinations only to subsequent trips. However,
trip coordinators do not always follow this procedure, with the result
that they may be incorrectly determining trips to be ineligible. Such
incorrect determinations could be considered trip denials.

The regulatory trip denial definition does not specifically address
negotiation of trip times or explain what constitutes a responsive trip
offer from CAB in response to a customer's request. Section 8 of this
report addresses concerns with the Onondaga CAB operation's procedure
for negotiating trip times.

CNYRTA managers further defined a **missed trip** as occurring when a
trip is not completed and the vehicle fails to appear at the pickup
location during the -5/+25 pickup window negotiated with the customer,
fails to wait for the customer for 5 minutes from the time of arrival or
5 minutes from the negotiated time, whichever is later. For purposes of
measuring missed trips and other service performance indicators, the
negotiated time used by CNYRTA is also the scheduled time. Centro CAB's
definition of a missed trip, as described by CNYRTA managers, is
consistent with FTA's application of the DOT ADA regulations. The
contracts with CNY Sedan Services and Able Medical Transportation define
a missed trip as an event in which the contractor's vehicle fails to
arrive to transport the customer or arrives more than 15 minutes beyond
the scheduled time and the customer is transported by another CAB
vehicle. The contract with Blue Chip similarly describes a missed trip
as a trip assigned to Blue Chip that is served by a non-Blue Chip
vehicle but specifies no limit on the Blue Chip vehicle time of arrival.
There is no definition of missed trip in the contract with SCAT.

CNYRTA managers described a **no-show** as occurring when the vehicle is
at the pickup location between the negotiated time and 25 minutes after
the negotiated time and the customer does not board the vehicle within 5
minutes of the negotiated time or arrival of the vehicle---whichever is
later. The contracts with CNY Sedan Services, Able Medical
Transportation, and Kelly Transportation define a no-show in similar
fashion and require the contractor to notify the CAB dispatcher at the
time of the no-show. The contract with Blue Chip also requires the
operator to notify the CAB dispatcher at the time of the no-show but
does not specify 5 minutes after the scheduled trip time. No-shows are
not addressed in the contract with SCAT.

Managers described "**Cancel at Door**" as a no-show for purposes of
initiating customer suspension proceedings. A cancel at door occurs when
the vehicle is at the pickup location in the pickup window and the
customer declines the trip. The definition of a customer no-show and/or
cancel at door provided by CNYRTA managers is consistent with FTA's
application of the DOT ADA regulations. However, since a customer can
face service suspensions for no-shows, it is important that the
customer's obligations be clearly presented to the customer in advance.
The obligation of the customer to board the vehicle within 5 minutes of
the scheduled time or arrival of the vehicle and the customer's
obligation to be ready to board any time up to 25 minutes after the
scheduled time should be clearly presented to the customer. The
*Call-A-Bus Service Standards* do not identify either of these customer
requirements. Both the *Call-A-Bus Rider's Guide* on the CNYRTA website
and the hardcopy version provided to the review team by CNYRTA identify
the customer requirement to board the vehicle within 5 minutes, but
neither identifies the customer's obligation to be prepared to board
from the scheduled time until 25 minutes after the scheduled time. Both
versions of the *Call-A-Bus Rider's Guide* advise customers that if they
cancel trips less than 2 hours from their pickup time, they may be
subject to service suspensions. Such **late cancellations** appear to be
the equivalent of customer no-shows with respect to service impact;
consequently, treating them as no-shows for purposes of service
suspensions to customers is consistent with FTA's application of the DOT
ADA regulations.

In materials provided to FTA before the review, and as cited above,
Centro defines an **on-time trip** as a vehicle arrival at the pickup
location any time in the pickup window (-5/+25). The *Call-A-Bus Rider's
Guide* posted on the CNYRTA website (page 21) describes an on-time trip
as where the vehicle arrives within the on-time window and describes the
window (page 19) as up to 25 minutes after the scheduled pickup time
(0/+25). This on-time definition is also described in the Centro
newsletter, *Accessible Transportation Matters*. Centro's standard for
on-time performance is 95 percent of trips on time per month.

In addition to limiting all late trips to 5 percent, Centro also has a
standard for late pickups for which the operator is the cause, as
opposed to late trips resulting from unforeseen conditions over which
CAB has no control. According to CNYRTA managers, late trips caused by
the operator are categorized as "Missed but Transported." The CAB
maximum standard for such trips is three for any division per month. The
CAB on-time performance standard for pickups appears to be reasonable in
accounting for travel conditions beyond the control of the operator and
the challenges of service operation. While recognizing Centro's CAB
standard as acceptable, FTA recommends that transit providers set a goal
of serving 100 percent of trips on time as a means of encouraging
operators to strive for ideal performance.

Centro does not have a standard for on-time drop-offs (appointments) for
CAB. For many trips, such as medical appointments, work, school, and
business appointments, on-time drop-offs are more important to the
customer than on-time pickups. Similarly, the amount of time by which
drop-offs are late can have greater consequence than for late pickups. A
late drop-off could cause an appointment or class to be missed, or, if
late drop-offs are recurring, could jeopardize employment. In
consultation with the disability community, Centro should develop a
standard for on-time drop-offs and a standard for significantly late
drop-offs. In establishing an on-time drop-off window, consideration
should also be given to avoiding drop-offs that are too early. Dropping
off a customer too early could result in the customer waiting outdoors
in inclement weather for a facility to open. Paratransit services often
use on-time drop-offs windows, such as 30 minutes before the appointment
time, to prevent such occurrences.

The CAB standard for long trips measures trip duration by distance.
Using this standard may be helpful in identifying long trips but will
likely fail to identify all long trips, as measured by FTA's application
of the DOT ADA regulations. FTA uses the travel time on fixed route
service as the basis for comparison in determining whether an ADA
complementary paratransit trip is significantly long.

Use of the CAB standard for long trips, more than five or 10 miles, can
result in failure to identify some significantly long trips. For
example, if a six mile trip could be completed in 30 minutes or an 11
mile trip could be completed in 1 hour using fixed route service, FTA
might consider paratransit trips with similar origins and destinations
to be significantly long if they took 80 minutes and 110 minutes,
respectively. Neither of these trips would be identified as long trips
applying Centro's standard.

The contract service providers have limited control over service
performance. The schedules that they use are provided by CAB and
operators are under the supervision of CAB dispatchers once they leave
the bus yard. The contract operators are responsible for providing
reports on performance to CAB.

The contract for SCAT services for Cayuga County requires the contractor
to comply with the ADA but otherwise includes no specific service
performance provisions with respect to on-time performance or trip
duration.

## Trip Disposition

**Onondaga County**

The review team analyzed trip records for Wednesday February 7, 2007, to
assess service performance. For this sample day, there were a total of
570 trip requests in the system, of which 376 were classified as "DEM,"
meaning they were ADA trips. Another 23 were classified as "DNC,"
meaning they were trips for persons who were given conditional
eligibility. The remaining trips were categorized as:

-   Arrived: completed trip

-   No-Show: operator unable to locate the customer

-   Cancel at Door: operator arrived and customer canceled the ride

-   Canceled: customer called in advance of trip to cancel

-   Missed but Transported: ride was provided, but the pickup was
    outside (late) of the 30 minute pickup window specified in Centro's
    policy

Trip refusals and trip denials were not specifically identified in the
data. A trip denial occurs when the service provider fails to negotiate
a trip within 1 hour of a customer's request. A trip refusal occurs when
a trip coordinator makes a responsive trip offer and the customer
declines the offer.

To identify potential trip denials, the review team computed the
difference between the requested times and scheduled times for 77 trip
requests made on February 7. Out of the 77 trip requests reviewed, all
were scheduled within 1 hour of the requested time. However, the
scheduled pickup times for 10 of the 77 requests (13 percent) were
scheduled outside of the -5/+25 minute pickup window stated in Centro
policy. Of these 10, only one was scheduled later than the requested
time, and that was by 30 minutes. The other nine were all scheduled
between 8 and 15 minutes early.

Of the 399 total ADA trip requests for February 7, 34 were canceled
prior to the provision of service. Of the 365 scheduled and dispatched
runs, nine were classified as no-shows and two were classified as cancel
at door, yielding 354 trips that were completed.

**Oneida County**

For the period between October 2006 and March 2007, the review team's
analysis of trip records indicated that Oneida County, Utica Division
averaged 19 denials per month or 0.7 percent of total requests. Denied
trips ranged from 0.3 percent in March 2007 to a high of 1.4 percent in
February 2007.

It appears that the percentage of trips denied is overstated in Centro's
reports. Centro calculated the percentage using total passenger
trips---rather than trip requests---as the denominator. Between October
2006 and March 2007, the Oneida County Division reported an average of
about 1 percent capacity denials per month, ranging from 0.4 percent in
March 2007 to 2.2 percent in February 2007, as opposed to the findings
of the review team.

## On-time Performance

**Onondaga County**

The review team assessed Centro of Onondaga's on-time performance by
reviewing completed trips in Trapeze data. For Onondaga, Centro defines
an on-time pickup as a vehicle arrival between the scheduled pick-up
time and 25 minutes after the scheduled time (0/+25). Centro and its
carriers do not have mobile data terminals, so the times in Trapeze were
entered by CAB staff from the handwritten operator manifests. The review
team used Wednesday, February 7 as a representative day for the
analysis. CAB staff ran the on-time report for the day. The vehicle runs
included both ADA and non-ADA trips, but the review team calculated
on-time performance for only ADA trips.

The review team assessed the reliability of the data entered by CAB
during the trip reconciliation process. To do this, the team used a 20
percent sample of randomly selected ADA trips (77 out of 365 scheduled).
The team retrieved the operator manifests for these trips and compared
what the operators had written on the manifests with what was entered
into Trapeze. CAB had initiated a process of entering operator manifest
data into Trapeze in February 2007. The 77 trips represent 154 separate
entries for time and odometer (one for pickups and one for drop-offs).
Errors were found with nine of the trips (12 percent), and one entry
error affected the on-time performance calculation.

Table 9.1 presents the on-time performance reported for all trips on
that day and the on-time performance calculated for ADA trips only.

**Table 9.1 -- On-Time Performance for CAB** Onondaga County: February
7, 2007

+--------------------------+----------+----------+---------+----------+
|                          | **CAB    |          | **ADA   |          |
|                          | Trapeze  |          | Trips   |          |
|                          | Report** |          | Only**  |          |
|                          |          |          |         |          |
|                          | **(All   |          |         |          |
|                          | Trips)** |          |         |          |
+--------------------------+----------+----------+---------+----------+
| ** **                    | **       | **P      | **N     | **P      |
|                          | Number** | ercent** | umber** | ercent** |
+--------------------------+----------+----------+---------+----------+
| **All Trips**            |          |          |         |          |
+--------------------------+----------+----------+---------+----------+
| Scheduled Trips          | 596      | 100%     | 365     | 100%     |
+--------------------------+----------+----------+---------+----------+
| Completed Trips          | 596      | 100%     | 354     | 97%      |
+--------------------------+----------+----------+---------+----------+
| Early or within On-time  | 573      | 96%      | 347     | 95%      |
| Window                   |          |          |         |          |
+--------------------------+----------+----------+---------+----------+
| Within Pickup Window     | 519      | 87%      | 255     | 70%      |
+--------------------------+----------+----------+---------+----------+
| Early Pickups            | 54       | 9%       | 92      | 25%      |
+--------------------------+----------+----------+---------+----------+
| 1 to 15 minutes          | n/a      | n/a      | 69      | 19%      |
+--------------------------+----------+----------+---------+----------+
| 16 to 30 minutes         | n/a      | n/a      | 21      | 6%       |
+--------------------------+----------+----------+---------+----------+
| \> 30 minutes            | n/a      | n/a      | 2       | 1%       |
+--------------------------+----------+----------+---------+----------+
| Late Pickups             | 23       | 4%       | 7       | 2%       |
+--------------------------+----------+----------+---------+----------+
| 1 to 15 minutes          | n/a      | n/a      | 4       | 1%       |
+--------------------------+----------+----------+---------+----------+
| 16 to 30 minutes         | n/a      | n/a      | 3       | 1%       |
+--------------------------+----------+----------+---------+----------+
| \> 30 minutes            | n/a      | n/a      | 0       | 0        |
+--------------------------+----------+----------+---------+----------+
| **Trips with Appointment |          |          |         |          |
| Times**                  |          |          |         |          |
+--------------------------+----------+----------+---------+----------+
| Completed Trips          | 195      | 100%     | 138     | 100%     |
+--------------------------+----------+----------+---------+----------+
| Early Drop-offs          | n/a      | n/a      | 23      | 17%      |
+--------------------------+----------+----------+---------+----------+
| 31 to 45 minutes         | n/a      | n/a      | 21      | 15%      |
+--------------------------+----------+----------+---------+----------+
| \> 45 minutes            | n/a      | n/a      | 2       | 1%       |
+--------------------------+----------+----------+---------+----------+
| Late Drop-offs           | 10       | 5%       | 5       | 4%       |
+--------------------------+----------+----------+---------+----------+
| 1 to 15 minutes          | n/a      | n/a      | 5       | 4%       |
+--------------------------+----------+----------+---------+----------+
| \> 15 minutes            | n/a      | n/a      | 0       | 0        |
+--------------------------+----------+----------+---------+----------+
| On-time Drop-off         | 185      | 95%      | 110     | 80%      |
+--------------------------+----------+----------+---------+----------+

n/a: data not provided

The data shows that 25 percent of the trips scheduled by pickup time
experienced pickups more than 5 minutes before the scheduled time. Of
the trips picked up early, 25 percent were more than 15 minutes early.
Arriving before the customer expects the pickup may cause the customer
to feel pressured to board the vehicle in fear of missing the trip.
Significantly early pickups without free agreement of the customer could
be considered untimely pickups.

As previously noted, both the customer and operator interviews indicated
widespread misunderstanding of the concept of the pickup window.
Moreover, even those who understood the concept did not know the correct
window. A lack of clear customer and operator understanding of the
responsibilities associated with pickup times can further contribute to
the implicit pressure on customers to accept early pickups.

The review team also analyzed on-time performance for trips scheduled
with appointment times. The analysis showed that on the sample day, 3.6
percent of the trips (five) were dropped off late. All of those trips
were 5 minutes late or less. The analysis of early drop-offs showed that
16.7 percent (23 trips) were dropped off more than 30 minutes before the
appointment time. Almost all of those trips (21 out of 23) were dropped
off between 31 and 45 minutes early. The remaining two trips were
dropped off more than 45 minutes early. Drop-offs more than 30 minutes
before appointment times can result in customers waiting long periods
for facilities to open or programs to begin and can be a constraint on
use of the service for the customer.

Trips that have been dispatched and not completed can be caused by the
failure of the customer or the carrier. The customer may not notify the
carrier of a cancellation in a timely manner or may not appear for the
ride within 5 minutes of the vehicle arriving within the pickup window.
A vehicle may arrive outside of the on-time window, or may not wait the
appropriate amount of time after arriving for a pickup. A potential
cause of many no-shows for Centro was the fact that different times were
being used by the customer (scheduled) and the operator (estimated).

Operators who were interviewed indicated that they are required to call
the dispatcher to request that a trip be categorized as a no-show. The
review team observations in dispatch confirmed that this was taking
place. Team members also observed that when a dispatcher received a
request for a no-show, the dispatcher routinely asked what time the
operator had on his or her manifest, checked Trapeze to determine what
the scheduled time was, and made sure the operator waited 5 minutes past
that time.

The review team reviewed 37 no-show records for the period January 2 to
8, 2007. Of the 37 no-shows, 28 were on Centro-operated runs and nine
were on vendor-operated runs. The review team checked to make sure that
the trips coded as no-shows were proper by comparing the scheduled time,
confirmed vehicle arrival time, and the estimated time for each no-show.
In each case, the no-show was properly recorded and the operator had
waited at least 5 minutes past the scheduled time. Review of this data
appears to confirm that CAB practices are consistent with no-show
policies. However, the current practice can result in unnecessary calls
from operators to the dispatcher when estimated times are earlier than
scheduled times and require the dispatcher to determine what time the
operator had on the manifest and compare it with the scheduled time that
was confirmed with the customer.

**Oneida County**

The review team also reviewed on-time performance for the Utica Division
in Oneida County. The Centro of Oneida Division has an on-time window of
15 minutes before the scheduled pickup to 15 minutes after the scheduled
pickup (-15/+15). The team relied upon analysis made by Centro of Oneida
staff in preparation for the review. The Utica Division reported that
for the week of January 22 through 27, there were four trips out of 498
that were late. To confirm this level of performance, the review team
sampled trips for one day, April 19, 2007. On that day there were 93
trips; one was late and five were early. This yields a performance of 99
percent early or on time. Considering only trips within the pickup
window, the performance was 94.5 percent. When looking at trips
scheduled by appointment time, two trips out of 53 were late, yielding
an on-time performance of 96 percent. It should be noted that one of the
two late trips was only 1 minute late. The sample day review confirms
that the data as reported by CAB appears to be representative of service
provided in Utica.

## Trip Duration

The review team analyzed Centro's ADA complementary paratransit service
trip length (travel time) performance by comparing travel times for long
ADA complementary paratransit trips with comparable trips made using
fixed route service. Trips for both Onondaga County and Oneida County
divisions were reviewed.

**Onondaga County**

The review team analyzed Centro data for the Onondaga County service
area to determine if there were a substantial number of significantly
long ADA complementary paratransit trips relative to trips made on the
Centro fixed route system.

The review team selected completed trips from two service days, Tuesday,
February 6, and Wednesday, February 7, 2007. The review team selected a
sample of trips with on-board travel times greater than 60 minutes. The
60 minute threshold was selected because trips of shorter duration are
unlikely to be significantly longer than comparable trips made using
fixed route service. If CAB trips are significantly longer than
comparable fixed route trips, they are also more likely to be trips that
are longer than 60 minutes.

Approximately 700 ADA trips were completed on the sample days. Of that
number, 31 had travel times in excess of 60 minutes. The review team,
with the assistance of Centro staff, took the origin, destination, and
time of each of those long trips and identified the fixed route
itinerary for a corresponding trip. The fixed route itineraries and
travel times were created using the estimated times in the trip planner.
These trip planner times represent the time from boarding the bus at the
originating stop to alighting the bus at the final destination stop. It
should be noted that all 31 trips involved a transfer on the fixed route
system. The transfer time was included in the travel time. Centro staff
reviewed the fixed route solutions presented to verify that the proposed
itineraries were valid. One of the fixed route solutions would have
resulted in the customer arriving to work 20 minutes late. This trip was
retained in the analysis since the objective was to compare travel times
for the same trip on each mode of travel.

To make the fixed route comparable to a "curb-to-curb" CAB trip, the
review team added 20 minutes to the fixed route travel times generated
by Centro staff to account for the following travel elements:

-   5 minutes to access the Centro bus stop from the trip origin

-   10 minutes to wait for the first Centro bus

-   5 minutes to reach a destination after alighting from the Centro bus

Although the use of a 20 minute allowance for access and wait time may
overestimate the actual travel time for some trips and underestimate it
for others, the 20 minutes approximates the door-to-door fixed route
travel time for a typical user.

For purposes of the analysis, a CAB trip that was more than 30 minutes
longer than the comparable fixed route trip is designated as a
potentially significantly long trip. After adding the 20 minute
travel/waiting time to the computed fixed route travel time, one out of
the 31 trips (3.2 percent) was identified as significantly longer than
comparable fixed route travel time (see [Table 9.2]{.mark}). That trip
was 32 minutes longer than the comparable fixed route trip and is
identified by **bold** type.

Notably, 13 out of the 31 trips reviewed (42 percent) had CAB trip times
that were less than the comparable fixed route itinerary. Based on this
analysis, it does not appear that in the Onondaga service area, Centro
has a substantial number of significantly long ADA complementary
paratransit trips.

**Oneida County**

Using data compiled by Oneida County staff, the review team analyzed
trip duration in Oneida County. The trip length policy for both the
Utica and Rome divisions of Oneida County is that no rider should be on
board a vehicle for more than 45 minutes. Oneida County staff sampled
runs from October through February for both divisions. The review team
performed a count of trips that exceeded 45 minutes in each division.
The purpose of the analysis was to determine the number and percentage
of trips that exceeded Centro of Oneida ride time policies. CAB trip
times were not compared with corresponding fixed route itineraries. If
all trips are completed within 45 minutes in accordance with Centro of
Oneida's policy goal, there should be no significantly long ADA
complementary paratransit trips relative to fixed route service.

For the Utica Division, 391 trips were sampled. Of that number, 27, or 7
percent, had rides times in excess of 45 minutes. Staff should continue
to monitor ride times and try to reduce the number of trips on board
greater than 45 minutes. In the Rome Division, 442 trips were sampled.
Of that number, 136, or 31 percent, had ride times in excess of 45
minutes. Staff indicated that the reason for this was the large number
of customers on grouped trips to centers. They indicated that these
trips were recently split onto different runs to reduce the ride times
for the affected customers. Staff should continue to sample the runs and
determine the effect the change has had on trips in excess of 45
minutes. Staff should continue to modify trip scheduling to avoid
significantly long trips.

**Table 9.2 -- Comparison of Travel Times of Call-A-Bus Trips vs. Fixed
Route for Selected Onondaga Trips (February 6 and** 7, 2007)

+---------------+-------+-------+---------+--------+-------+---------+
| **Pickup      | **P   | **Dro | **Com   | **Call | **    | **Dif   |
| Address**     | ickup | p-off | parable | -A-Bus | Fixed | ference |
|               | T     | T     | Fixed   | Travel | Route | Call-   |
| **Drop-Off    | ime** | ime** | Route   | Time   | T     | A-Bus - |
| Address**     |       |       | Trip**  | (hrs:m | ravel | Fixed   |
|               |       |       |         | ins)** | Time  | Route** |
|               |       |       |         |        | (h    |         |
|               |       |       |         |        | rs:mi | **(hrs: |
|               |       |       |         |        | ns)** | mins)** |
+===============+=======+=======+=========+========+=======+=========+
| 100 Spaulding | 7:25  | 8:40  | Rte 10, | 1:15   | 0:58  | 0:17    |
| Ave           | a.m.  | a.m.  | Rte 74  |        |       |         |
|               |       |       |         |        |       |         |
| 600 S Wilbur  |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 100 Spaulding | 7:30  | 8:45  | Rte 10, | 1:15   | 0:58  | 0:17    |
| Ave           | a.m.  | a.m.  | Rte 74  |        |       |         |
|               |       |       |         |        |       |         |
| 600 S Wilbur  |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 400 Wavel St  | 2:15  | 3:50  | Rte 20, | 1:35   | 1:14  | 0:21    |
|               | p.m.  | p.m.  | Rte 10  |        |       |         |
| 100 Spaulding |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 400 Wavel St  | 2:15  | 3:34  | Rte 20, | 1:19   | 1:08  | 0:11    |
|               | p.m.  | p.m.  | Rte 72  |        |       |         |
| 1             |       |       |         |        |       |         |
| Presidential  |       |       |         |        |       |         |
| Plaza         |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 400 Wavel St  | 2:15  | 3:26  | Rte 20, | 1:11   | 1:03  | 0:08    |
|               | p.m.  | p.m.  | Rte 10  |        |       |         |
| 2000 State St |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 6300 S Salina | 3:45  | 4:46  | Rte 10, | 1:01   | 1:29  | (0:28)  |
| St            | a.m.  | a.m.  | Rte 46  |        |       |         |
|               |       |       |         |        |       |         |
| 3600 Gaskin   |       |       |         |        |       |         |
| Rd            |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| **2600 S      | *     | **    | **Rte   | **     | **0   | *       |
| Salina St**   | *8:54 | 10:15 | 10, Rte | 1:21** | :49** | *0:32** |
|               | p     | p     | 76**    |        |       |         |
| **600         | .m.** | .m.** |         |        |       |         |
| Hazelwood     |       |       |         |        |       |         |
| Ave**         |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 1700 Milton   | 8:24  | 9:36  | Rte 74, | 1:12   | 1:06  | 0:06    |
| Ave           | p.m.  | p.m.  | Rte 40  |        |       |         |
|               |       |       |         |        |       |         |
| 700 Ivy Ridge |       |       |         |        |       |         |
| Rd            |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 200 School Rd | 3:34  | 4:51  | Rte     | 1:17   | 1:08  | 0:09    |
|               | p.m.  | p.m.  | 246,    |        |       |         |
| 300 Noble Ave |       |       | Rte 52  |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 600 Madison   | 3:35  | 4:30  | Rte 30, | 0:55   | 0:51  | 0:04    |
| St            | p.m.  | p.m.  | Rte 10  |        |       |         |
|               |       |       |         |        |       |         |
| 100 Gary Ave  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 1 Warren St   | 1:50  | 3:03  | Rte 10, | 1:13   | 0:58  | 0:15    |
|               | p.m.  | p.m.  | Rte 74  |        |       |         |
| 100 Munro Dr  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 1 Warren St   | 2:32  | 3:35  | Rte 10, | 1:03   | 0:58  | 0:05    |
|               | p.m.  | p.m.  | Rte 74  |        |       |         |
| 100 Munro Dr  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 4600          | 2:32  | 3:35  | Rte 86, | 1:03   | 1:25  | (0:22)  |
| Crossroads    | p.m.  | p.m.  | Rte 60  |        |       |         |
| Park Dr       |       |       |         |        |       |         |
|               |       |       |         |        |       |         |
| 400 N Orchard |       |       |         |        |       |         |
| Rd            |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 4600          | 3:03  | 4:16  | Rte 86, | 1:13   | 1:04  | 0:09    |
| Crossroads    | a.m.  | a.m.  | Aub/Ska |        |       |         |
| Park Dr       |       |       |         |        |       |         |
|               |       |       |         |        |       |         |
| 4500 Onondaga |       |       |         |        |       |         |
| Blvd          |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 1500 Caleb    | 7:45  | 8:40  | Rte 58, | 1:05   | 1:04  | 0:01    |
| Ave           | a.m.  | a.m.  | Rte 74  |        |       |         |
|               |       |       |         |        |       |         |
| 600 S Wilbur  |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 1500 Caleb    | 7:47  | 8:58  | Rte 58, | 1:11   | 1:04  | 0:07    |
| Ave           | a.m.  | a.m.  | Rte 74  |        |       |         |
|               |       |       |         |        |       |         |
| 600 S Wilbur  |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 211 Lafayette | 7:50  | 8:57  | Rte 72, | 1:07   | 0:52  | 0:15    |
| Rd            | a.m.  | a.m.  | Rte 74  |        |       |         |
|               |       |       |         |        |       |         |
| 600 S Wilbur  |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 500 S Crouse  | 7:56  | 9:00  | Rte 76, | 1:04   | 0:59  | 0:05    |
| Ave           | a.m.  | a.m.  | Rte 46  |        |       |         |
|               |       |       |         |        |       |         |
| 4000 Long     |       |       |         |        |       |         |
| Branch Rd     |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 100 Spaulding | 7:20  | 8:55  | Rte 10, | 1:35   | 1:34  | 0:01    |
| Ave           | a.m.  | a.m.  | Rte 52  |        |       |         |
|               |       |       |         |        |       |         |
| 4000 Wavel    |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 2000 State St | 7:46  | 8:56  | Rte 72, | 1:10   | 1:13  | (0:03)  |
|               | a.m.  | a.m.  | Rte 52  |        |       |         |
| 400 Wavel St  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 180 Parkway   | 7:59  | 9:00  | Rte 26, | 1:01   | 1:15  | (0:14)  |
| Dr            | a.m.  | a.m.  | Rte 52  |        |       |         |
|               |       |       |         |        |       |         |
| 400 Wavel St  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 400 S Avery   | 7:58  | 9:02  | Rte 74, | 1:04   | 1:15  | (0:11)  |
| St            | a.m.  | a.m.  | Rte 52  |        |       |         |
|               |       |       |         |        |       |         |
| 400 Wavel St  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 100 Kasson Rd | 10:51 | 12:12 | Rte 36, | 1:21   | 1:26  | (0:05)  |
|               | a.m.  | p.m.  | Rte 20  |        |       |         |
| 1000          |       |       |         |        |       |         |
| Sunnycrest Rd |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| Shoppingtown- | 7:45  | 8:46  | Rte 76, | 1:01   | 1:03  | (0:02)  |
| Erie Blvd E   | p.m.  | p.m.  | Rte 10  |        |       |         |
|               |       |       |         |        |       |         |
| 200 Borden    |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 3400 Erie     | 11:48 | 1:00  | Rte 68, | 1:12   | 1:21  | (0:09)  |
| Blvd E        | a.m.  | p.m.  | Rte 74  |        |       |         |
|               |       |       |         |        |       |         |
| 200 Myron Rd  |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 40 Silver St  | 4:08  | 5:10  | Rte 23, | 1:02   | 1:34  | (0:32)  |
|               | a.m.  | a.m.  | Rte 74  |        |       |         |
| 1700 Milton   |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+
| 300 Palmer    | 7:00  | 8:10  | Rte 26, | 1:02   | 0:37  | 0:25    |
| Ave           | a.m.  | a.m.  | Rte 84  |        |       |         |
|               |       |       |         |        |       |         |
| 300 Prospect  |       |       |         |        |       |         |
| Ave           |       |       |         |        |       |         |
+---------------+-------+-------+---------+--------+-------+---------+

Note: Addresses have been rounded to nearest 100 block.

## Service Procedures and Practices

**Run Coverage: Runs, Operators, and Vehicles**

The number of dispatch staff and stations, vehicles, and operators
needed each day is determined by the number of vehicle runs (routes)
operated each day, and in particular, the number of runs operated during
the peak periods. The number of runs operated is developed by schedulers
in response to the demand for service.

**Vehicles.** Centro owns a fleet of 38 vehicles for CAB service.
Vehicles are scheduled for retirement after four years in service. As of
2007, the fleet's average vehicle age was approximately 3.2 years.

Syracuse has 19 vans assigned to CAB and three to fixed route service.
Of these 19, 16 are needed for peak service, leaving three spares. If
additional buses are needed, the vans assigned to fixed route can be
reassigned for use by CAB.

Cameras with time-stamped recordings have been installed on all CAB
vehicles. The cameras can be used to investigate accidents, customer
complaints, or other incidents involving the vehicles. The cameras have
been installed at a cost of \$8,000 per vehicle and can be moved from
vehicle to vehicle as they are retired. Recordings are saved for
approximately seven days, with recordings of incidents saved as long as
needed.

CAB vehicles are maintained with the fixed route fleet at each of the
Centro divisions, with the exception of Syracuse. At this site, there
are two dedicated paratransit mechanics. Centro is considering the
addition of a third mechanic. The Centro paratransit mechanics perform
most vehicle maintenance functions in-house. Additionally, the vehicle
lifts are cycled each day before the vehicle is used in service.

CNYRTA's contracts with private operators require that the private
operators provide "clean, properly maintained, NYS \[New York State\]
inspected vehicles, which are in safe operating condition, in a manner
consistent with state and local laws, rules and regulations regarding
motor vehicles." In response to this requirement, Kelly Transportation
and CAB have developed an approved vehicle list. The CAB road supervisor
conducts spot-checks of vehicles being used for CAB service to confirm
that they are approved vehicles.

Table 9.3 provides data on the vehicles used for CAB service by the
contractors.

Table 9.3 -- Contractor Vehicles Used for CAB Service

+-------------------------------+---------------+---------------------+
| **Contractor**                | **Vehicles    | **Average Age**     |
|                               | Available**   |                     |
|                               |               | **(years, as of     |
|                               |               | 2007)**             |
+-------------------------------+---------------+---------------------+
| Able Medical Transportation   | 3             | (data not provided) |
+-------------------------------+---------------+---------------------+
| Blue Chip                     | 7             | 4.6                 |
+-------------------------------+---------------+---------------------+
| CNY Sedan Services            | 5             | 5.8                 |
+-------------------------------+---------------+---------------------+
| Kelly                         | 8             | 8.8                 |
+-------------------------------+---------------+---------------------+

Based on customer comments and reservations observations, customers
appear to have difficulty recognizing contractor vehicles as CAB
vehicles. CAB managers indicated that they have tried to use magnetic
signs, affixed to the vehicles, to better identify CAB vehicles, but
that the signs failed to stay on the vehicles. CAB was exploring the use
of decals installed inside the vehicle windows as a means of improving
vehicle identification.

**Operators**

Most CAB operators are regular Centro bus operators. Operators choose
their assigned runs each quarter. CAB runs are selected from among all
Centro runs by operators based on seniority. As a result of operator
self-selection, many Centro CAB operators appear to be well-suited to
the requirements of paratransit service.

In addition to regular Centro operators, CAB in Syracuse uses contractor
operators on Centro vehicles. As of April 2007, Peace, Inc., provided
nine operators to operate Centro CAB vehicles. Tenure for Peace
operators ranged from 1.2 to 23.2 years, with an average of 9.3 years.

CAB in Utica had six operators to cover six weekday runs, with no backup
operators. When there is a planned absence, a run is dropped and the
passenger trips are assigned to the remaining runs. Unexpected absences
are addressed through a combination of reassignments of passenger trips
and use of office and maintenance staff as backup operators. To better
address this operator shortage, Centro is negotiating with the operators
union to use Centro fixed route extra-list operators as both fixed route
and CAB extra-list operators (discussed in Section 8).

All CAB contracts with private carriers require that operators be drug
and alcohol tested and that they be appropriately licensed and trained
to provide CAB service. Because Kelly Transportation has operators who
do not provide CAB service, Kelly provides Centro with a list of
operators that meet the contract requirements each quarter. The Kelly
operators are periodically checked against the list by the CAB road
supervisor during spot-checks. Kelly Transportation has 10 regular
operators. The average tenure for current Kelly operators is 1.2 years.

CNY has six operators, including three employees and three independent
operators. Blue Chip has eight operators assigned to CAB services. Two
of the operators have been employed for less than one year and two for
over seven years. The average tenure for Blue Chip operators is 3.6
years. Able has three operators assigned to CAB, with four alternate
operators. All three assigned operators have been employed for less than
two years, with an average tenure of 1.4 years. In addition to
indicating that operators are inexperienced, this low average tenure may
indicate that many operators are not well suited for the job. Both
inexperience and operator unsuitability may result in performance issues
and customer relations issues.

**Vehicle Dispatch**

The review team observed the dispatch operation at the Onondaga County
Division to identify procedures or practices that might affect
performance. There is one dispatcher in service for the entire CAB
operation. He is responsible for 25 to 27 runs per day. The runs consist
of both directly operated and contracted service. Additionally, the
dispatch office is located adjacent to the transportation coordinators
and the scheduler work area. This arrangement of space allows for
effective communication among the staff.

Before the morning pull-out, the CAB operators report to the fixed route
dispatcher to pick up their schedule manifests. They then report to the
CAB dispatcher to get any trip cancellations or add-ons, to get their
vehicle assignments, and to pick up the keys to their assigned vehicles.
The maximum in-house pull-out is 20 vehicles, including non-ADA runs.
There are 22 vehicles available for pull-out. In the event that there
are not enough spare vehicles, the dispatcher is allowed to reassign a
vehicle from a non-ADA run to a CAB run and the non-ADA run is assigned
a vehicle from the fixed route fleet. Although the spare ratio of 10
percent can be considered tight, the fact that non-ADA runs can use
other fleet resources mitigates the potential problem.

In the event that an assigned CAB operator calls in sick, the dispatcher
may use an operator from the fixed route extra-list to cover the run.

All passenger trip requests have been scheduled to runs the before the
day that customers are scheduled to travel so that the dispatcher does
not need to assign any unscheduled trips at the beginning of the day.
The dispatcher does have the responsibility to enter trip cancellations
as well as respond to calls requesting information or applications. When
answering a call for information, if the dispatcher cannot answer the
question posed, he gets a phone number from the caller and has an
appropriate staff person return the call. The telephone line used for
information and cancellations is also used by the dedicated vendor
operators to contact CAB dispatch. Vendor operators have reported
problems getting through to CAB dispatch.

The dispatcher is in contact with CAB operators via radio, and is in
touch with dedicated (Blue Chip and Able) subcontractor operators via
cell phone. Contact with CNY Sedan is through the CNY Sedan dispatcher.
Operators are required to call in if they are running more than 10
minutes late. If an operator calls in that he or she is running late,
the dispatcher changes the estimated time. This causes Trapeze to
recalculate subsequent estimated times on the run. When this occurs, the
dispatcher checks to see who is running late. He looks to see if there
is a place in the schedule where the operator can "recover." If not, he
may reassign trips as needed.

When an operator calls to request authorization for a customer no-show,
the dispatcher attempts to contact the customer if a telephone number is
available. He also asks the operator what time is indicated on the
manifest for the pickup, compares that time with the current estimated
time in the computer, and verifies the scheduled time confirmed with the
customer indicated in the record for the trip. The dispatcher indicated
that he does not authorize the no-show until the operator has waited 5
minutes past the scheduled time given to the customer.

The review team observed dispatch during the afternoon peak (3 to 5 p.m.
on Wednesday, April 24) to assess the dispatch operation. During that
time there was little dispatch interaction with the operators. There
were no calls to dispatch requesting assistance or indicating that an
operator was running late. There was one call requesting a no-show and
some operators came into the office to get their vehicles for the
evening or return keys as they came out of service. Despite this light
workload, the number of peak runs that the dispatcher is responsible for
appears to be appropriate.

The CAB dispatch operation seemed to be mostly reactive. The dispatcher
discovers that operators are running late only when they report that
they are running late or request a no-show approval. The dispatcher
appeared to focus more attention on answering customer calls for advance
cancellations and information, rather than tracking the status of each
vehicle run. This is not the best use of a dispatcher. The primary
responsibility of a dispatcher should be to monitor activities in the
field and make adjustments as needed to provide timely service.
Reassigning customer call responsibilities to another staff member would
allow the dispatcher to identify and address service issues or potential
issues during the course of the day. This would also reduce the problems
that vendor operators have in contacting CAB dispatch.

**Carrier Operations**

Reviewers visited two contract carriers and interviewed their managers.
The purpose of these visits was to learn about the carriers' operating
procedures and practices, and to evaluate the adequacy of resources
related to on-time performance and avoidance of missed trips. Reviewers
visited Kelly Transportation and Blue Chip Transportation.

**Kelly Transportation**

Kelly Transportation operates two to four CAB routes each day. Two runs
(Kelly 1 and Kelly 2) are dedicated to CAB customers. Passenger trips on
the other two routes, Kelly 3 and Kelly 4, may be assigned to CAB as
needed. One of the two dedicated routes is operated as a single 8 hour
shift. The other dedicated route is a 12 hour split shift operated by
two operators.

Before beginning service, operators report to work and review the
schedules for the day. The Kelly manager noted a few problems with the
schedules:

-   Schedules are sometimes tight and do not appear to allow sufficient
    time for passenger boarding and alighting

-   As few as three passengers on one vehicle can cause problems with
    vehicle loading

-   The addresses of pickups are sometimes unclear

-   Road construction delays are not reflected in the schedules

-   More information on customers' travel aids would be helpful such as
    "blind---using cane" rather than the vague information currently
    provided, like "mobility aid"

-   The schedule time on the manifest is sometimes different from the
    time given to the customer

Kelly personnel use a Centro form to provide feedback on schedule
issues. Kelly dispatchers do not actively monitor service; they react as
issues arise. Dispatchers address vehicle problems, and if operators
report that they are late, dispatchers reassign passenger trips among
other Kelly operators. Operators generally call the dispatcher if
running 15 to 30 minutes behind schedule. In addition to reassigning
passenger trips among operators, dispatchers assign the one to 10 add-on
trips they receive each day from CAB dispatchers.

Customer-related communications, including customer no-shows, are not
addressed by the Kelly dispatcher but instead directed to CAB. The Kelly
dispatcher is not allowed to telephone the customer or unilaterally
authorize a no-show. Managers noted that Kelly operators and the Kelly
dispatcher often have difficulty getting through to the CAB dispatcher
to address customer no-shows. If unable to reach CAB, ultimately the
Kelly dispatcher will release the operator from waiting. According to
the Kelly manager, this difficulty in communicating with CAB, combined
with confusion regarding the pickup times (the manifest times are often
different from the negotiated times given to the customers), results in
trips being incorrectly treated as customer no-shows. The end result is
that many customer trips are missed or delayed, and additional vehicles
have to be dispatched to pickup locations.

The Kelly manager indicated that if Kelly receives a cancellation from a
customer, Kelly does not notify CAB. As a result, it is unclear whether
the cancellation is recorded as an early or late cancellation or a
customer no-show.

**Blue Chip Transportation**

On the day of the site visit, Blue Chip was in the process of moving its
office and garage into a new facility where all functions would be
located. The initial meeting took place at the office's current
location. The review team then toured the new garage and office
facility.

Operations staff at Blue Chip indicated that CAB usually creates
schedules for three runs, although there is no guarantee for the number
of hours. The staff members indicated that on days that more than three
runs are needed, the CAB scheduler calls them before scheduling the
additional runs. Blue Chip appears to have the equipment necessary to
carry out the requirements of the contract.

Once on the road, operators are in direct contact with the CAB
dispatcher via cell phone. Office staff reported that operators have
indicated occasional problems getting through to the CAB dispatcher. As
noted earlier, this may be due to the fact the CAB dispatcher handles
information calls and advance cancellations. The phone number used by
the operators to contact the CAB dispatcher is the published information
number for CAB.

All operators are to follow the manifest as created by CAB. Office staff
indicated that some operators say that there is not enough time to
complete the runs. The one operator interviewed at Blue Chip did not
identify this as a problem. There was, however, confusion about the
on-time pickup window. The operator and office staff had different and
incorrect information on the window.

In the event changes need to be made to a run, the operator contacts CAB
dispatch. The only time a Blue Chip operator contacts the Blue Chip
dispatcher is in the event of a breakdown. The operator contacts the
company dispatcher to arrange for a replacement vehicle. If, as a result
of the breakdown customers need to be transferred to another vehicle,
CAB dispatch is also notified.

Operators are required to be certified by the New York State Department
of Transportation (NYSDOT) and to have a commercial operator's license
(CDL) with passenger endorsement. Training is conducted by Blue Chip
using the CDL Handbook and material from Montauk Bus Company. Operators
are certified in wheelchair securement and receive refresher training
two times per year. In addition, new hires ride along with experienced
operators for their first 15 days of service.

The new facility appears to have adequate parking for the fleet and an
indoor maintenance bay. An inspection of a vehicle used in CAB service
showed the vehicle to be clean inside and out. It appeared to be in good
working condition. The vehicle had the necessary straps for wheelchair
securement.

**Operator Interviews and Training**

During the site visit, team members interviewed nine operators,
including four Centro operators assigned to Onondaga and two assigned to
Utica; two Peace contract operators assigned to Centro of Onondaga; and
one contract operator working for Blue Chip. Peace operators are
contracted by CAB and operate CAB vehicles. Blue Chip operators work for
Blue Chip and drive Blue Chip vehicles. In general, the operators
appeared professional, with positive attitudes towards customer service.
They indicated that vehicles and support services were very good. Issues
of concern that emerged from the interviews were a lack of clear,
consistent understanding of operating procedures and, associated with
that, the adequacy of operator training.

**Procedures**

The operator interviews raised several procedural issues that could
affect service.

-   The times printed on manifests are estimated times and are sometimes
    different from the times negotiated with customers. As a result,
    trips are sometimes missed and a second vehicle has to be dispatched
    to the pickup location.

-   Operators will sometimes change the sequence of stops on their route
    without notifying the dispatcher. By comparison, if the dispatcher
    is notified, he or she is able to concur in the change or reject it,
    taking into consideration all relevant factors, including many of
    which the operators may be unaware. Dispatchers can record changes
    in the scheduling software, allowing dispatchers to track operators'
    locations, more efficiently reschedule trips, respond to customer
    ride status inquiries, and improve overall efficiency of schedules.

-   Operators generally indicated that they must be at the pickup
    location by the scheduled time on their manifests. Most did not,
    however, know the correct on-time pickup window.

-   Contractors who rely on telephones to reach CAB dispatchers are
    often unable to do so in a timely fashion. As a result, customers
    may be incorrectly identified as no-shows if they are near or at the
    pick-up location but cannot be located, since only CAB dispatchers
    may contact customers directly.

**Training**

The initial training provided to Centro operators assigned to CAB is the
same training provided to all Centro fixed route operators. By contrast,
contract operators train their own operators. For Centro CAB operators,
a half day refresher training was provided by the fixed route trainer
during June and July 2006. At the time of the onsite review, Centro
planned to hold the training again with the CAB road supervisor
conducting the half-day class, but it is not clear when or how
frequently future trainings will occur.

Initial training includes two weeks of classroom training. The training
includes a half day of instruction on ADA procedures and CAB operations
by the manager of specialized transportation and a second day covering
operation of CAB vehicles and lifts, including role-playing. Materials
used for ADA-related training include excerpts from the DOT ADA
regulations related to provision of fixed route service, and discussion
of treatment of customers with service animals, different wheelchair
types, appropriate terminology, customer rights and responsibilities,
and how disabilities affect transit use. In addition to the initial
training, when Centro bus operators pick CAB or extra-list runs, they
are given a half day of orientation in operation of the CAB vehicles and
procedures.

## Findings

1.  No trip denials or missed trips in Onondaga County were identified
    from a review of CAB data for Wednesday, February 7, 2007.

```{=html}
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32. The Oneida County Division had an average capacity denial rate of
    approximately 0.7 percent of all requests, ranging from 0.3 percent
    to 1.4 percent during the period of October 2006 to March 2007.

33. The Onondaga County Division does not have a substantial number of
    significantly late drop-offs. Analysis of trip records for February
    7, 2007, indicated that 3.6 percent of trips (5 of 138) with
    scheduled appointment times were dropped off late. All of those
    trips were late by 5 minutes or less.

34. The Onondaga County Division has a significant number of early
    drop-offs. On the sample day, 17 percent of trips with appointment
    times were dropped off more than 30 minutes early. Significantly
    early drop-offs can result in long waits until customer appointments
    and can be a constraint to use of CAB service.

35. The Onondaga County Division may have a substantial number of
    significantly early pickups. On February 7, 2007, 25 percent of
    trips provided (92 of 365) were picked up more than 5 minutes before
    the scheduled time. Of the 92 early trips, 23 (6 percent of all
    trips provided) were more than 15 minutes early. Consumers
    interviewed expressed concern about early pickups. When agreed to by
    the customer, early pickups are acceptable and can improve operating
    efficiency and customer service. However, it is not acceptable to
    pressure customers into accepting early pickups when they are not
    prepared or do not wish to board. When customers are encouraged, or
    pressed, to accept pickups that are significantly before the
    scheduled time, those pickups could be considered untimely. During
    interviews, operators appeared to be aware that they are not to
    arrive for pickups too early. Display of estimated times rather than
    scheduled times on operator manifests may, however, contribute to
    early pickups as a result of misunderstanding of the pickup time.

36. A review of "long trips" (more than 60 minutes) for two sample days
    indicates that the Onondaga County Division does not have a
    substantial number of significantly long trips.

37. The Oneida County Division, Rome office reported 31 percent of its
    trips exceeded 45 minutes. Staff indicated that this was due to a
    large number of group trips. Staff stated that these group trips had
    subsequently been split up on different runs to reduce the travel
    times.

38. Centro does not have a standard for on-time drop-offs for CAB. For
    many trips, such as medical, work, school, and business
    appointments, on-time drop-offs are more important to the customer
    than on-time pickups.

39. Reconciliation of trip data did not start until February 2007. A
    review of the reconciled data for the sample day found a 12 percent
    error rate.

40. CAB in Onondaga appears to have sufficient numbers of vehicles and
    operators to cover all assigned runs.

41. Centro Utica in Oneida County does not have a sufficient number of
    operators available to cover all ADA runs when assigned operators
    are absent. CNYRTA is negotiating with the operator's labor union to
    make fixed route extra-list operators available for assignment to
    ADA complementary paratransit runs when needed.

42. Contract carriers often have difficulty communicating with the
    Onondaga CAB dispatcher. Operators (using cell phones) communicate
    with dispatch through one telephone line that is also used to handle
    advance cancellations and information requests from customers.
    Answering customer calls diverts dispatchers from their primary
    responsibility of tracking service, identifying problems, and
    assisting operators to avoid service delays.

43. The Onondaga dispatcher does not actively track the status of
    operators' schedule adherence. The dispatcher discovers that
    operators are running late only when they report that they are
    running late or request a no-show approval. This reactive method
    prevents the dispatcher from identifying and addressing service
    delays before they occur.

44. Contractors do not notify the Onondaga dispatcher when they receive
    trip cancellations from customers. As a result, CAB personnel are
    unaware of the change in trip status.

45. Operators sometimes change the sequence of stops on their routes
    without notifying the dispatcher.

46. Operators believe that the estimated time shown on the manifest is
    the same as the scheduled time told to the customer. The estimated
    time can be different from the time scheduled with the customer. As
    a result, operators may arrive for pickups at the wrong time. This
    can result in early, late, and missed trips or inefficient use of
    the operator's time. It can also delay other customers and confuse
    customer communications.

47. Customers expressed concern about new operators and contract
    operators, including operators getting lost and operator
    sensitivity. Additionally, during interviews, operators seemed
    unclear regarding some procedures and concepts, including times on
    manifests, changing their schedules, and on-time performance.

## Recommendations

1.  CNYRTA should continue with its plans to provide increased capacity
    in Oneida County to cover for absenteeism as a means for eliminating
    service denials.

2.  The Onondaga County Division of CAB should regularly monitor early
    drop-offs and adjust procedures to reduce the number of
    significantly early drop-offs. Distance-based parameters for
    scheduling trips for appointments should be reviewed and modified as
    appropriate.

3.  CNYRTA should, in consultation with its consumer advisory group,
    develop a performance standard for on-time drop-offs for trips with
    appointment times that would include an earliest time and a latest
    time.

4.  To avoid significantly early pickups, operator manifests should be
    revised to show the scheduled times negotiated with the customer.
    The scheduled time, rather than the estimated time, should be used
    by the operator for determining when to approach the customer.

5.  CNYRTA should continue to reconcile service performance data and
    produce performance reports. CNYRTA should establish a quality
    control procedure to ensure that the reconciled data is
    representative of the service actually provided.

6.  CNYRTA should consider setting a standard for all divisions for
    maximum allowable on-board time.

7.  CNYRTA should continue with its plans to provide backup operators
    for Utica ADA complementary paratransit service by negotiating with
    the operator's labor union to make fixed route extra-list operators
    available for assignment to ADA complementary paratransit runs when
    needed.

8.  CAB should limit the incoming phone calls to the dispatcher to
    contractor operators. CAB should also add one or more additional
    dispatch phone lines to allow multiple operator access to the
    dispatcher at any time and facilitate telephone access by dedicated
    vendor operators.

9.  CAB should reassign the responsibility for advance cancellations and
    information calls in Onondaga from the dispatcher to other CAB
    personnel. This would allow the dispatcher to focus on managing
    service on the street.

10. Dispatcher procedures should be revised to track schedule status of
    all runs at each stop on the run. This would enable dispatchers to
    identify service problems in advance and address delays in advance
    by reassigning trips. Such procedural changes could reduce the
    number of late and missed trips.

11. All Onondaga operators, including contract operators, should be
    required to notify the CAB dispatcher of changes in trip status.
    This would enable the dispatcher to identify the schedule status of
    each run in real time and identify slack time in operator runs that
    can be used to serve new trip assignments.

12. CAB should establish procedures to enable operators to review their
    manifests before pull-out and, if appropriate, propose changes in
    the sequence of their stops to the CAB dispatcher. Changes should be
    made only with the approval of the dispatcher, using Trapeze. The
    scheduler should periodically review operator-initiated schedule
    changes as a means of improving scheduling. Such procedures would
    permit the dispatcher to track the operator on the run and improve
    schedule efficiency.

13. CAB should change operator manifests to include scheduled (not just
    estimated) pickup and appointment times. Operators should be
    instructed to operate their routes to meet the scheduled times
    safely.

14. CAB should consider increasing supplemental training to all
    operators, including all newly assigned ADA operators and extra-list
    and contract operators, at the time of their initial assignment.
    This training should include the use of lifts and securements, as
    well as map reading and directional orientation; customer
    sensitivity (including provision for heating and air conditioning
    needs); and operating procedures (such as reading and using the
    manifest, on-time performance, and dispatcher communications).

# **Resources**

The on-site review team assessed CNYRTA equipment staffing and funding
information to identify potential limits in capacity to provide ADA
complementary paratransit service.

## Budget Process

By law, the fiscal year of CNYRTA and its subsidiaries is identical to
that of New York State, April 1 to March 31. The annual budget process
begins in September with a review of the prior six months' actual costs.
These actual costs are adjusted to reflect factors that will influence
future costs, such as increases in travel demand. The manager of CAB,
senior director of operations, and planning staff all participate in
development of demand and budget projections. Straight-line projections
are used as a basis for demand forecasting, with adjustments for factors
such as increases in travel by Medicaid recipients in recent years.
Biweekly meetings of department heads provide a forum for budget
discussion and development. The budget is reviewed by the executive
director in November, presented to the Board of Directors in December,
and submitted to the State Authority Budget Office and the State
Legislature by December 31. Between January and March, the budget is
reviewed and adjusted by the state. In March, the resultant budget is
adopted by the Board of Directors. An overview of CNYRTA's finances and
budget is provided in Attachment O.

As reflected in Table 10.1, there has been significant growth in CAB
trips in recent years. There have also been substantial funding
increases, although much of the overall increase appears to be directed
to the addition of service in Oneida County.

CNYRTA uses a continuous process to monitor and revise its budget. In
addition to the annual budget, the general manager reports quarterly to
the Board of Directors on the status of the budget and other service
measures, including trip volumes. In addition, department heads and
senior managers meet biweekly to report on changes in passenger volumes,
expenditures, and needed adjustments. Staffing levels and other
resources are increased and funds are reallocated to the CAB budget as
needed to serve CAB demand and avoid denials of trip requests. The
reallocation of resources is reflected in Table 10.1, with annual CAB
expenditures exceeding budgeted amounts.

Increases in use of CAB services in recent years by Medicaid clients
have been reflected in the FY 2007 budget. Further increases in travel
demand may result from suggested changes to the application of
conditional eligibility and the service parameters used in trip
scheduling. Although these increases may not be large, they should be
considered during the budget process.

CNYRTA staff also works with NYSDOT staff throughout the year, and
NYSDOT in turn works with the New York State Division of Budget to
determine the amount of funding to include in the executive budget each
year. The state budget process considers financial and operating
results, capital programs, and other concerns for the most recently
completed year, the current year, and the subsequent year.

**Table 10.1 -- Review of CAB** Budgets

  --------------- ------------ ----------- ------------------------ ------------- ------------- ---------- -------------
  **Year**                                                          **FY 2005 -   **FY 2006**              **FY 2007 -
                                                                    B**                                    A**

  **Demand**                                                                                               

                               Passenger                                                                   
                               Trips                                                                       

                                           Onondaga                 77,052        92,605                   108,232

                                           Oswego                   1,750         2,713                    2,004

                                           Cayuga                   20            98                       32

                                           Sub-total                78,822                                 

                                           Oneida - B               26,976        37,548                   33,408

                                           Total                    105,798       132,964                  143,676

                               \% Change                                          26%                      8%

  **Budget**                                                        \$2,471,600   \$3,118,366              \$3,456,416

  Operating                                                                                                
  Expenditures                                                                                             

                  Centro                                                                                   
                  (excluding                                                                               
                  Oneida)                                                                                  

                                           Amount                   \$2,882,460   \$2,851,395              \$2,842,995

                                           \% Change                              -1%                      0%

                  Centro                                                                                   
                  Totals                                                                                   

                                           Amount                   \$2,822,460   \$3,540,446              \$4,068,244

                                           \% Change                              25%                      15%

  **Cost/Trip**                                                                                            

                  Amount                                            \$35.81       \$26.63                  \$28.32

                  \% Change                                                       -26%                     6%

  A - 2007                                                                                                 
  numbers                                                                                                  
  prorated from                                                                                            
  available data                                                                                           
  for part of the                                                                                          
  year                                                                                                     

  B - 2005 Oneida                                                                                          
  not included in                                                                                          
  budget or cost                                                                                           
  calculations                                                                                             

  Fiscal Year                                                                                              
  ends on March                                                                                            
  31                                                                                                       
  --------------- ------------ ----------- ------------------------ ------------- ------------- ---------- -------------

CNYRTA has been successful in funding its services. A source of local
CNYRTA funding is a 0.25 percent mortgage tax. The tax generates about
\$7 to 8 million annually towards funding its total FY 2008 budget of
approximately \$52 million. This tax source has the potential advantage
of high rates of long-term growth since real estate values, and in turn
mortgage volumes, generally exceed the growth in the cost of living. A
disadvantage, as described in Attachment O, is that real estate markets
can fluctuate significantly in the short term, making year-to-year
prediction of funding from this source difficult. In response, CNYRTA
budgets these funds flexibly, using them for local match for grants and
for operating reserves. CNYRTA does not use bond funding as a source of
capital funding.

## Operating Resources

**Reservations Resources**

As addressed in Section 7 of this report, telephone hold times during
late afternoon hours were observed to be sufficiently long to be a
potential impediment to service. These long hold times could be reduced
by changing reservations and scheduling procedures, as addressed in the
report. They also could be addressed by changing staffing schedules. If
neither change results in reduced long hold times, consideration should
be given to additional staffing.

**Scheduling Resources**

Staffing for scheduling appeared to be adequate at all of the CNYRTA
transit subsidiaries. The CAB scheduler for Onondaga County schedules
approximately 350 to 400 ADA trips per weekday. This is generally
considered to be near the upper volume of trips that can be scheduled
using the manual "drag and drop" scheduling. CAB could increase its
upper limit to about 500 trips per day by scheduling subscription trips
in advance and by using the automated scheduling features of the Trapeze
software.

**Transportation Resources**

Centro and CAB generally appear to have sufficient operator and vehicle
resources to serve current demand for ADA complementary paratransit
service.

**Vehicles.** In addition to fleet size, fleet age can be a factor in
service performance. Older fleets tend to be less reliable and have a
higher percentage of the fleet unavailable for service at any given
time. The condition of the vehicle with respect to passenger comfort
tends to decline with age as well. The age of the CAB fleet of vehicles,
including CAB-owned vehicles and contractor vehicles, is presented in
Table 10.2.

**Table 10.2 -- CNYRTA Paratransit Fleet Age**

  -------------- ---------- ----------- ------------ ----------- ------------
  ** Carrier**   **CAB**    **Able**    **Blue       **Kelly**   **CNY
                                        Chip**                   Sedan**

  Year                                                            

  1996                                               2            

  1997                                               3            

  1998                                                            

  1999           1                                   2           2

  2000                                  1                         

  2001                                  2                        1

  2002           4                      2                         

  2003           13                                              1

  2004           6                                               1

  2005           11                     1            1            

  2006           3                      1                         

                                                                 

  **Total**      38         3           7            8           5

  **Avg Age      **3.2**    **N/A**     **4.6**      **8.8**     **5.8**
  (years)**                                                      
  -------------- ---------- ----------- ------------ ----------- ------------

The table indicates that the contractor vehicles tend to be older, with
Kelly vehicles assigned to CAB service having the highest average age.
During interviews, customers expressed concern with some of the
contractor vehicles; one customer commented specifically about the age
of the Kelly vehicles. It is CNYRTA's policy to schedule CAB passenger
vehicles for retirement after four years in service. A corresponding
requirement in service contracts that limits contractors to using only
vehicles that are four years old or less (or even five or six years)
might help to minimize issues with respect to contractor vehicles.

Another vehicle-related problem identified during the review was
customer difficulty in identifying contractor vehicles. Magnetic decals
were previously tried, unsuccessfully, to address this issue. According
to CAB and contractor staff, the decals had to be placed very
carefully---otherwise they would fall off of the vehicles. At the time
of the onsite review, CAB staff indicated that they are pursuing the use
of window decals to make the vehicles more readily identifiable.

**Operators.** As discussed in Section 9 of this report, Centro and CAB
appear to have enough operators to adequately cover all runs and meet
demand with the exception of operators for ADA services in Utica for the
Oneida Division. At the time of the on-site review, there were
insufficient extra-list operators, causing trip denials and negatively
affecting service. CNYRTA was addressing this problem by negotiating
with the Utica operators union to use Centro of Utica operators as
extra-list operators for ADA services.

Operator tenure can be an indicator of quality of operator performance.
The core operators for ADA services are Centro operators and Peace
operators. Based on information provided by CAB managers on hire dates
for 24 Centro operators assigned to CAB, the average tenure of Centro
CAB operators is 3.7 years. Nine of the operators have been employed by
Centro for less than one year. This in all likelihood results in a high
proportion of extra-list operators among CAB operators. Removing these
nine operators from the calculation increases the average tenure of
Centro operators to 5.9 years. By comparison, the average tenure for
Peace operators is 9.3 years, and the average tenure for contract
operators ranges from 1.2 years for Kelly to 3.6 years for Blue Chip.

The disparate operator tenure rates for the different providers appear
to correspond to customer comments regarding operator performance for
the providers. For transit providers in general, customers tend to be
more satisfied with rides that are provided by more experienced
operators. Similarly, the impression of Centro customers is that
dedicated Centro operators and Peace operators provide superior service
to contract operators and extra-list operators.

Notably, rides are typically assigned first to CAB operators and
contractors that have higher tenure rates. This practice should mitigate
the limitations of the newer operators. Additional training for new
operators, as addressed in Section 9, could also improve performance of
new operators.

**Dispatch.** As discussed in Section 9, it is common for paratransit
dispatchers to monitor and direct 20 to 30 runs. CAB has one dispatcher
for CAB's 25 to 27 daily runs, which appears appropriate and to not be a
constraint on service.

However, the procedures for communicating with contract operators by
cell phone appear to impede service delivery. Inability of contract
operators to get through on the dispatch phone line was cited by
contractors as a cause of late and missed trips. This service impediment
could be adequately addressed by altering dispatch procedures as
discussed in Section 9. If not, additional dispatch phone lines may be
required.

## Findings

1.  CNYRTA appears to have adequate financial resources to meet current
    demand for ADA complementary paratransit service.

2.  CNYRTA appears to have effective procedures for making changes
    during the year to address ADA complementary service passenger
    demand and financial needs.

3.  It is anticipated that overall CAB service demand will increase,
    largely because of increasing demand from Medicare recipients and
    modifications to eligibility procedures. Consequently, CAB will need
    corresponding increases in resources in order to sustain existing
    service levels.

4.  Minor increases in reservationist (trip coordinator) staffing may be
    needed to improve late afternoon telephone response times if
    improvements cannot be achieved through adjusting reservation and
    scheduling procedures and/or revising the schedules of current
    reservationist staff.

5.  Additional budget resources may be needed to fund additional
    preliminary training for all Centro ADA complementary paratransit
    service operators.

6.  Additional dispatch telephone capacity may be needed to eliminate
    impediments to communication between the dispatcher and contractor
    operators if the problem cannot be adequately addressed by revising
    dispatch procedures.

## Recommendations

1.  During regular senior management meetings, CNYRTA should monitor
    performance and needs for changes in service demand, call center
    performance and dispatching, training of newly assigned ADA
    complementary paratransit operators, and dispatch telephone access.

**Attachment A**

**CNYRTA Response**

**Attachment B**

On-Site Review Schedule

+--------+--------------------------------------+--------+------------+
| **     | **Activity**                         | *      | **Where**  |
| Time** |                                      | *Who** |            |
+--------+--------------------------------------+--------+------------+
| **M    |                                      |        |            |
| onday, |                                      |        |            |
| April  |                                      |        |            |
| 23,    |                                      |        |            |
| 2007** |                                      |        |            |
+--------+--------------------------------------+--------+------------+
| 9 a.m. | -   Opening Conference               | All    | 200        |
|        |                                      |        | Cortland   |
+--------+--------------------------------------+--------+------------+
| 9:30   | -   Review information requested &   | All    |            |
| a.m.   |     policies & procedures with       |        |            |
|        |     Centro managers                  |        |            |
+--------+--------------------------------------+--------+------------+
| 11     | -   Tour facility                    | All    |            |
| a.m.   |                                      |        |            |
+--------+--------------------------------------+--------+------------+
| 1 p.m. | -   Review scheduling procedures and | Pr     |            |
|        |     performance reporting            | ocopio |            |
|        |                                      |        |            |
|        | -   Review customer                  | K      |            |
|        |     comments/complaints              | idston |            |
|        |                                      |        |            |
|        | -   Review eligibility process and   | Th     |            |
|        |     records                          | atcher |            |
+--------+--------------------------------------+--------+------------+
| 3 p.m. | -   Observe call-takers; record trip | All    |            |
|        |     request information              |        |            |
+--------+--------------------------------------+--------+------------+
| **Tu   |                                      |        |            |
| esday, |                                      |        |            |
| April  |                                      |        |            |
| 24,    |                                      |        |            |
| 2007** |                                      |        |            |
+--------+--------------------------------------+--------+------------+
| 8 a.m. | -   Observe call-takers              | K      | 200        |
|        |                                      | idston | Cortland   |
|        | -   Review eligibility process and   |        |            |
|        |     records                          | Th     |            |
|        |                                      | atcher |            |
|        | -   Interview operators              | Pr     |            |
|        |                                      | ocopio |            |
+--------+--------------------------------------+--------+------------+
| 10     | -   Review of budget and resources   | K      |            |
| a.m.   |                                      | idston |            |
|        | -   Continue review of eligibility   |        |            |
|        |     process and records              | Th     |            |
|        |                                      | atcher |            |
|        | -   Interview schedulers             |        |            |
|        |                                      | Pr     |            |
|        |                                      | ocopio |            |
+--------+--------------------------------------+--------+------------+
| 12     | -   Site visit: Rome                 | K      | Rome       |
| noon   |                                      | idston |            |
|        | -   Site visit: Cayuga               |        | Auburn     |
|        |                                      | Pr     |            |
|        | -   Review telephone system, taped   | ocopio |            |
|        |     calls                            |        |            |
|        |                                      | Th     |            |
|        |                                      | atcher |            |
+--------+--------------------------------------+--------+------------+
| 3 p.m. | -   Site visit: Utica                | K      | Utica      |
|        |                                      | idston |            |
|        | -   Site visit: Oswego               |        | Oswego     |
|        |                                      | Th     |            |
|        | -   Review trip disposition          | atcher | 200        |
|        |                                      |        | Cortland   |
|        |                                      | Pr     |            |
|        |                                      | ocopio |            |
+--------+--------------------------------------+--------+------------+
| **Wedn |                                      |        |            |
| esday, |                                      |        |            |
| April  |                                      |        |            |
| 25,    |                                      |        |            |
| 2007** |                                      |        |            |
+--------+--------------------------------------+--------+------------+
| 8 a.m. | -   Document & analyze service area, | K      | 200        |
|        |     hours & fares                    | idston | Cortland   |
|        |                                      |        |            |
|        | -   Observe dispatch                 | Th     |            |
|        |                                      | atcher |            |
|        | -   Review on-time performance       |        |            |
|        |                                      | Pr     |            |
|        |                                      | ocopio |            |
+--------+--------------------------------------+--------+------------+
| 1 p.m. | -   Operator interviews              | Th     | 200        |
|        |                                      | atcher | Cortland   |
|        | -   Analysis of resources & budget   |        |            |
|        |                                      | K      |            |
|        | -   Continue review of on-time       | idston |            |
|        |     performance                      |        |            |
|        |                                      | Pr     |            |
|        |                                      | ocopio |            |
+--------+--------------------------------------+--------+------------+
| 3 p.m. | -   Operator interviews              | K      |            |
|        |                                      | idston |            |
|        | -   Observe call-takers              |        |            |
|        |                                      | Th     |            |
|        | -   Conduct trip length analysis     | atcher |            |
|        |                                      |        |            |
|        |                                      | Pr     |            |
|        |                                      | ocopio |            |
+--------+--------------------------------------+--------+------------+
| **Thu  |                                      |        |            |
| rsday, |                                      |        |            |
| April  |                                      |        |            |
| 26,    |                                      |        |            |
| 2007** |                                      |        |            |
+--------+--------------------------------------+--------+------------+
| M      | -   Complete preliminary data        | All    | 200        |
| orning |     analysis & remaining detail work |        | Cortland   |
|        |                                      |        |            |
|        | -   Prepare materials for debriefing |        |            |
|        |     session                          |        |            |
+--------+--------------------------------------+--------+------------+
| 1 p.m. | -   Exit Conference                  | All    | 200        |
|        |                                      |        | Cortland   |
+--------+--------------------------------------+--------+------------+

**Attachment C**

**Call-A-Bus -- A Brief History**

1973 START OF Call-A-Bus

> \- 2 year Federal demonstration grant

\- Service to seniors and people with disabilities

\- First Elderly and Disabled Advisory Committee (later called the
CALL-A-BUS Advisory Committee) established

1975 CALL-A-BUS TAKES DELIVERY ON FIRST BODY ON CHASSIS VANS (4) WITH
WHEELCHAIR LIFTS

-Averaging 200 rides per day

1976 CALL-A-BUS services recognized nationally as "most innovative" and
RECOGNIZED locally with an award from the CNY Rehabilitation Association

1977 CALL-A-BUS SERVICE TO RURAL AREAS

\- Feeder Trips to Fixed Route

1978 DEMAND RESPONSE PARTNERSHIPS

-   Shared Resources with PEACE, Inc and the MCOA

-   Centralized Scheduling / Dispatch

-   Training

-   Outreach

1978 PRIORITY SEATING ESTABLISHED ON FIXED ROUTE BUSES

> \- Partnership with local Council on Aging results in retrofitting a
> 45 passenger transit bus into a group transport vehicle for people who
> use wheelchairs.

1982 25 NEW LIFT ACCESSIBLE TRANSIT BUSES JOIN FLEET

> \- Board approves policy that personal care attendants shall ride for
> free.

1983 DEVELOP W/C LIFTS FOR FIXED ROUTE SERVICE

> \- Wheelchair lifts on new buses fail dramatically due in part to
> environmental exposures. CNYRTA initiates internal design, repair and
> retrofitting of lifts on new and older buses that becomes the national
> standard (the "Syracuse Standard").

1983 CUSTOM COMPUTER SOFTWARE INSTALLED TO HELP MANAGE THE SIGNIFICANT
INCREASES IN CALL-A-BUS WORKLOADS.

1985 ADDED TAXI SERVICE TO CALL-A-BUS

1989 COMSIS SOFTWARE INSTALLED

\- Interactive Scheduling

1992 LOCAL ADA PLAN IS DEVELOPED AND ADOPTED

\- One of the first plans to be accepted by the FTA

1996 FUNDING REDUCTIONS

> -Medicaid Partnering
>
> a\) Became a Vendor
>
> b\) Developed transportation needs application for DSS
>
> -Brokered medical transportation for HMO

1999 TRAPEZE SOFTWARE INSTALLED

-   Batch Schedules

-   Billing

-   Reports

-   ADA trip by trip eligibility coding

2001 MOBILITY MANAGEMENT CENTER ESTABLISHED

-Additional contractors in place to provide service to low income
residents (including those with disabilities) to access jobs.

2005 CNYRTA IS RECIPIENT OF THE USDOT [UNITED WE RIDE]{.underline}
LEADERSHIP AWARD.

2006 ACCESSIBLE TRANSPORTATION ADVISORY COUNCIL ESTABLISHED.

**Attachment D**

**SCAT Service Description**

+----------------+-----------------------------------------------------+
| ![](media      | **Transportation Project for Cayuga County**\       |
| /image1.jpeg){ | The Willard Memorial Chapel-Welch Building\         |
| width="0.72847 | 17 Nelson St, Auburn, NY 13021\                     |
| 22222222222in" | Phone: (315) 253-0996                               |
| he             |                                                     |
| ight="1.166666 |                                                     |
| 6666666667in"} |                                                     |
+----------------+-----------------------------------------------------+
| Kathy          |                                                     |
| Shutter -      |                                                     |
| Director       |                                                     |
| (253-3548)\    |                                                     |
| \              |                                                     |
| (315) 626-2732 |                                                     |
| Cato\          |                                                     |
| (315) 497-2652 |                                                     |
| Moravia\       |                                                     |
| (315) 889-7255 |                                                     |
| Union Springs\ |                                                     |
| (315) 253-0996 |                                                     |
| Weedsport      |                                                     |
|                |                                                     |
| **Mission:**   |                                                     |
| The            |                                                     |
| Transportation |                                                     |
| Project for    |                                                     |
| Cayuga County  |                                                     |
| provides       |                                                     |
| specialized    |                                                     |
| transportation |                                                     |
| for the        |                                                     |
| elderly (60+)  |                                                     |
| and disabled   |                                                     |
| of Cayuga      |                                                     |
| County through |                                                     |
| the operation  |                                                     |
| of the SCAT    |                                                     |
| (Senior        |                                                     |
| Citizen Aid to |                                                     |
| T              |                                                     |
| ransportation) |                                                     |
| vans. The      |                                                     |
| service is     |                                                     |
| available to   |                                                     |
| those elderly  |                                                     |
| and            |                                                     |
| handicapped    |                                                     |
| persons who do |                                                     |
| not have       |                                                     |
| access to, or  |                                                     |
| cannot access  |                                                     |
| public         |                                                     |
| t              |                                                     |
| ransportation. |                                                     |
| The service    |                                                     |
| will transport |                                                     |
| any eligible   |                                                     |
| person to any  |                                                     |
| needed         |                                                     |
| destination    |                                                     |
| such as        |                                                     |
| medical        |                                                     |
| appointments,  |                                                     |
| physical       |                                                     |
| therapy,       |                                                     |
| dental,        |                                                     |
| shopping,      |                                                     |
| nutrition and  |                                                     |
| work sites, or |                                                     |
| simply to      |                                                     |
| visit a        |                                                     |
| friend.        |                                                     |
|                |                                                     |
| **Services:**  |                                                     |
| Eight vehicles |                                                     |
| are equipped   |                                                     |
| with           |                                                     |
| wheelchair     |                                                     |
| lifts and are  |                                                     |
| available      |                                                     |
| throughout the |                                                     |
| county.        |                                                     |
| Door-to-Door   |                                                     |
| service is     |                                                     |
| provided.      |                                                     |
| Persons        |                                                     |
| requiring      |                                                     |
| assistance     |                                                     |
| from their     |                                                     |
| homes or to    |                                                     |
| their          |                                                     |
| destination    |                                                     |
| must provide   |                                                     |
| their own      |                                                     |
| escort. The    |                                                     |
| SCAT vans      |                                                     |
| operate on a   |                                                     |
| modified       |                                                     |
| d              |                                                     |
| emand-response |                                                     |
| basis (first   |                                                     |
| come, first    |                                                     |
| serve).        |                                                     |
| Suggested fees |                                                     |
| are \$2.00 in  |                                                     |
| Auburn and     |                                                     |
| \$3.00 in the  |                                                     |
| county. Group  |                                                     |
| trips          |                                                     |
| available      |                                                     |
| during         |                                                     |
| evenings and   |                                                     |
| weekends.      |                                                     |
|                |                                                     |
| **Other        |                                                     |
| Services:**    |                                                     |
| CAM (Cayuga    |                                                     |
| Medical) Van   |                                                     |
| Service is     |                                                     |
| available to   |                                                     |
| persons who    |                                                     |
| need           |                                                     |
| transportation |                                                     |
| to Syracuse    |                                                     |
| for medical    |                                                     |
| appointments.  |                                                     |
| Under age 60,  |                                                     |
| there is a     |                                                     |
| \$22.00 fee    |                                                     |
| and for those  |                                                     |
| over 60, there |                                                     |
| is a suggested |                                                     |
| donation of    |                                                     |
| \$12.00.       |                                                     |
| Reservations   |                                                     |
| require a      |                                                     |
| week\'s        |                                                     |
| notice.        |                                                     |
|                |                                                     |
| **R            |                                                     |
| eservations:** |                                                     |
| Reservations   |                                                     |
| may be made by |                                                     |
| calling the    |                                                     |
| nearest office |                                                     |
| five working   |                                                     |
| days in        |                                                     |
| advance. Calls |                                                     |
| should be made |                                                     |
| between 9:00   |                                                     |
| am - 12:00     |                                                     |
| noon, Monday - |                                                     |
| Friday.        |                                                     |
|                |                                                     |
| **Office       |                                                     |
| Hours:**       |                                                     |
| Mon-Fri. 8:00  |                                                     |
| am-3:00pm.     |                                                     |
|                |                                                     |
| **Referral:**  |                                                     |
| All community  |                                                     |
| agencies,      |                                                     |
| friends,       |                                                     |
| relatives, and |                                                     |
| s              |                                                     |
| elf-referrals. |                                                     |
|                |                                                     |
| **Support:**   |                                                     |
| Cayuga County  |                                                     |
| Office for the |                                                     |
| Aging, United  |                                                     |
| Way, Cayuga    |                                                     |
| County         |                                                     |
| townships and  |                                                     |
| villages, City |                                                     |
| of Auburn and  |                                                     |
| donations.     |                                                     |
+----------------+-----------------------------------------------------+

**Attachment E**

**Call-A-Bus -- An Introduction**

**Attachment F**

**Call-A-Bus Rider's Guide**

**Attachment G**

**Call-A-Bus Service Standards**

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height="9.244444444444444in"}

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height="2.640277777777778in"}

**Attachment H**

**Call-A-Bus (Onondaga County) Application Form**

**Attachment I**

**Call-A-Bus (Onondaga County)**

**Sample Eligibility Determination Letters**

**Attachment J**

**Utica and Rome (Oneida County) Application Forms**

**Attachment K**

**Centro -- Call-A-Bus Eligibility Appeal Policy**

**Attachment L**

**Call-A-Bus (Onondaga County) No-Show Materials**

**Attachment M**

**Road Supervisor Worksheet**

**Calculating Distance from Bus Route**

**Attachment N**

**Utica (Oneida County) Trip Denial Log**

**Attachment O**

**Description of CNYRTA Funding**

The following is an CNYRTA staff document provided to the FTA ADA review
team by CNYRTA managers.

[Fiscally sound]{.underline}

At present, the Authority is financially sound, with a strong balance
sheet and no debt, either short or long term. The CNYRTA is in this
position due to sound policies developed by the Board of Members, a
strong internal control environment, conservative business practices,
credibility with New York State DOT and DOB and the FTA, and support
from elected officials at all levels.

[Funding and Finances]{.underline}

[Capital Funding Programs]{.underline}

The CNYRTA takes full advantage of available capital grant programs from
federal and state sources, primarily the Federal Transit Administration
(FTA) and the New York State Department of Transportation (NYSDOT).
Generally, capital projects are funded with 80% FTA dollars, 10% NYSDOT
dollars, and 10% CNYRTA dollars (from mortgage tax revenues). Local
share for that year's grant application are set aside in the CNYRTA
operating budget. From time to time, special grants may be available
from NYSDOT which cover 100% of certain capital projects, primarily in
the smaller Oswego and Cayuga subsidiaries. In addition, the CNYRTA has
been the recipient of special grants from the New York State Energy
Research & Development Authority (NYSERDA) to offset certain costs of it
alternative fueled bus procurements.

[Funding Operating Costs]{.underline}

The CNYRTA subsidiaries charge fares and fees for various transportation
services provided, and earn a small amount of miscellaneous revenues
from other transit-related activities. These user and other fees
typically cover 25% or less of the operating costs of the bus
operations. The balance of the net cost of service is made up of other
operating subsidies:

-   Significant operating assistance from the NYSDOT under its Statewide
    Mass Transportation Operating Assistance (STOA) program.

-   State-mandated match by participating counties for a certain portion
    of the state operating assistance funding

-   federal capital grants which allow preventive maintenance-related
    costs to be recouped, treated as operating revenues

-   voluntary aid from municipalities

-   miscellaneous local grants

-   transfers of funds from the CNYRTA as needed and available

[Special Service Operating Assistance]{.underline}

To the maximum extent possible, the Authority applies for funding for
special programs such as welfare-to-work transportation from a variety
of sources, such as the federal Jobs Access Reverse Commute (JARC) and
Community Solutions for Transportation (CST). Such funding must be used
for specifically defined purposes rather than as general operating
subsidies.

[Dedicated Funding]{.underline}

In the counties which participate in the Central New York Regional
Transportation District (currently Onondaga, Oneida, Oswego and Cayuga),
a mortgage recording fee of 1/4 of 1% (.25%) is payable by the mortgagee
to the recording officer of the county in which the mortgaged property
is located (there is a small exemption for single or two-family
dwellings). This is known as the "additional" mortgage tax payable to
transportation authorities. This funding is remitted by the county
clerks' offices to the CNYRTA on a monthly basis. The revenue is used
for the local matching share of capital grants, to establish necessary
insurance, capital and general fund reserves, to pay off debt, to
subsidize any operating deficits of the bus operating subsidiaries and
for Authority expenditures. The amount of revenue received is highly
dependent on mortgage interest rates and other factors, such as selling
prices of housing and commercial structures, the health of and
confidence in the local economy on the part of individuals and
businesses and activity of local industrial development agencies (IDA's,
which can exempt development projects from mortgage and other taxes).
Therefore, the amount of revenue is difficult to predict and can
fluctuate greatly from year to year. For example, it fell 58% between
SFY-1994 and SFY-1995 and increased 71% between SFY-2001 and SFY-2002,
largely as a result of fluctuating interest rates strongly influenced by
federal monetary policy.

[Relationships with federal, state and local elected
officials]{.underline}

Under the STOA program for state operating assistance, counties
participating in the CNYRTA are required to match certain funds with
local operating assistance. Because of that requirement and the fact the
CNYRTA serves constituents of county elected officials, the CNYRTA staff
meets periodically with committees of the respective legislatures
assigned to transportation issues. One county may require monthly
attendance while another may be once per year- we are responsive to the
desires of the counties involved. Staff may also meets upon request by
the County Executive or a designee on any issue with transit-related
issue.