Metropolitan Atlanta Rapid Transit Authority

(MARTA)

**Atlanta, Georgia**

Assessment

of

ADA Complementary Paratransit Service

Capacity Constraints

September 10-14, 2001

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**with**

**Multisystems, Inc.**

**Final Report: March 19, 2002**

**CONTENTS**

**I. Purpose of the Assessment** 1

**II. Overview of the Assessment** 3

**III. Background** 7

**IV. Summary of Findings** 9

**V. Observations Regarding ADA Complementary Paratransit Eligibility**

**Determinations** 14

**VI. Observations Regarding Telephone Access** 22

**VII. Observations Regarding the Handling and Scheduling of Trip
Requests** 28

**VIII. Observations Regarding Service Provision** 35

**On Time Performance** 39

**ADA Complementary Paratransit Service Travel Times** 40

**IX. Resources and Overall Level of Service** 47

**Attachment A. MARTA Response**

**Attachment B. On-Site Assessment Schedule**

**Attachment C. Paratransit Customer's Guide**

**Attachment D. Summary of ADA Complementary Paratransit Complaints on
File at MARTA, September 2000 through August 2001**

**Attachment E. MARTA ADA Complementary Paratransit Eligibility
Application and Materials**

**Attachment F. MARTA Daily Service Summary Reports - June-August 2001**

**Attachment G. Long Ride Report for August 1-13, 2001**

# Purpose of the Assessment

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

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

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

An on-site compliance assessment of ADA Complementary Paratransit
service provided by the Metropolitan Atlanta Rapid Transit Authority
(MARTA) in Atlanta, Georgia was conducted from September 10 through 14,
2001. Planners Collaborative, Inc., located in Boston, Massachusetts,
and Multisystems, Inc., located in Cambridge, Massachusetts, conducted
the assessment for the FTA Office of Civil Rights. The assessment
focused on compliance of MARTA's ADA Complementary Paratransit service
with one specific regulatory service criterion: the "capacity
constraints" criterion. Section 37.131(f) of the regulations requires
that ADA Complementary Paratransit services be operated without capacity
constraints.

This report summarizes the observations and findings of the on-site
assessment of MARTA's ADA Complementary Paratransit service. First, a
description of the approach and methodology used to conduct the
assessment is provided. Then, a description of key features of the ADA
Complementary Paratransit service is provided. The major findings of the
assessment are then summarized. Observations and findings related to
each element of the capacity constraint criterion are then presented.
Recommendations for addressing some of the findings are also provided.

MARTA was provided with a draft copy of the report for review and
response. A copy of the correspondence received from MARTA documenting
the transit agency's response to the draft report is included as
Attachment A.

# Overview of the Assessment

This assessment focused on compliance with the ADA Complementary
Paratransit capacity constraints requirements of the regulations.
Several possible types of capacity constraints are identified by the
regulations. These include "wait listing" trips, having caps on the
number of trips provided, or recurring patterns or practices that result
in a substantial number of trip denials, untimely pick-ups, or
significantly long trips. Capacity constraints also include other
operating policies or practices that tend to significantly limit the
amount of service to persons who are ADA Complementary Paratransit
eligible.

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

-   Trip denials and "wait listing" of trips;

-   Trip caps;

-   On-time performance; and

-   Travel times.

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

-   Determinations of ADA Complementary Paratransit eligibility, and

-   Telephone capacity.

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

**Pre-Assessment**

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

-   A description of how the ADA Complementary Paratransit service is
    structured;

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-   A copy of the passenger guide, which details service policies to
    customers; and

-   A description of MARTA's standards for on-time performance, trip
    denials, travel times, and telephone service, if any.

It was requested that additional information be available during the
on-site visit. This information included:

-   Copies of completed driver manifests for recent months;

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

-   A breakdown of trips requested, scheduled, and provided;

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

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

-   Telephone call management records; and

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

In addition to the review of data and direct observations, the
assessment team conducted telephone interviews with nine customers and
consumer representatives. The assessment team also reviewed four
complaints on file with FTA. These complaints were filed between July
1999 and February 2001.

**On-Site Assessment**

The on-site compliance assessment began with an opening conference, held
at 1:00 PM on Monday, September 10, 2001. MARTA representatives
attending the meeting included:

Philip Carroll, Deputy General Manager for Operations; Jerome Beasley,
Assistant General Manager for Bus Operations; Rosalyn Green, Assistant
General Manager for Diversity and Equal Employment; Richard Jones,
General Superintendent of Paratransit; and Knox O'Callaghan, FTA
Coordinator. Also attending for MARTA were Sheila Cozine, Michael
Bushell,

David Golder, Cheryl Turner, Mike Fredericks, and John Jefferson.
Russell Thatcher and Rosemary Mathias of Multisystems, Inc., and Brian
Barber of Planners Collaborative represented the FTA assessment team.
Frank Billue, the Civil Rights Officer for Region IV, represented FTA.
Roger Peralta and Mary Elizabeth Peters of FTA's Office of Civil Rights
in Washington, D.C. also participated in the opening conference via
telephone.

[]{.mark}

Roger Peralta opened the meeting by thanking MARTA for their cooperation
in the assessment. He reviewed the purpose of the assessment and
emphasized that it was intended to assist MARTA in providing effective
ADA Complementary Paratransit service. Mr. Peralta explained that:

-   Preliminary findings and an opportunity to respond would be provided
    at a closing meeting on Friday.

-   A report would be drafted and provided to MARTA for review and
    comment before being finalized as a public document.

Russell Thatcher then described the schedule for the on-site assessment.
A copy of the assessment schedule is provided in Attachment B.

Mr. Philip Carroll indicated that MARTA staff would be available to
provide any assistance and information needed during the course of the
assessment.

Following the opening conference, the assessment team met with MARTA
staff to review the service structure and standards and the information
available on-site. In the late afternoon, the assessment team sat with
three reservationists and observed the trip reservations and initial
scheduling process. The assessment team members sat with different call
takers and listened to calls as they were received. Basic information
(e.g., date and time requested, trip origin and destination addresses,
mobility aids used by the rider, whether the request was accepted, and
the negotiated trip time) was recorded for each call observed.
Information on staffing, phone system design and capacity, and the
available fleet was also collected.

In the morning on Tuesday, September 11, the assessment team again
observed and recorded information in the reservations area. The team
also met with MARTA staff to review ADA Complementary Paratransit
service complaints and telephone service records. An analysis of trip
length was also initiated with the assistance of MARTA customer service
staff. In the afternoon, the team met with MARTA's eligibility
coordinator and collected information about the ADA Complementary
Paratransit eligibility determination process and outcomes. Finally,
completed manifests for a sample day were requested and an estimate of
on-time performance was developed based on actual recorded pick-up and
drop-off times.

On Wednesday, September 12, the assessment team observed the pull out
process in the dispatch area. Information about the number of runs and
the availability of operators was collected. The process used to make
same day changes to runs and schedules was observed and dispatchers were
interviewed about the processes used to manage the delivery of service.
The assessment team also met with the chief scheduler to review the
processes used to prepare final run manifests.

On Thursday, September 13, the assessment team met with MARTA staff to
review the budgeting process for ADA Complementary Paratransit service
and to collect information about budget and expenditures for recent
years. Work also continued on calculating on-time performance from
randomly selected manifests and on comparing travel time on the ADA
Complementary Paratransit system to travel time by fixed route service.

The assessment team spent Friday morning, September 14, tabulating and
organizing the information collected. The exit conference was held at
11:00 AM. Attending the exit conference for MARTA were Jerome Beasley,
Rosalyn Green, Richard Jones,

Knox O'Callaghan, Sheila Cozine, Catherine Morris, Dave Golder, Ken
McDonald, and

John Jefferson. Attending for the assessment team were Russell Thatcher,
Rosemary Mathias, and Brian Barber. Cheryl Hershey, Roberta Wolgast, and
Mary Elizabeth Peters participated via telephone for FTA.

Cheryl Hershey opened the exit conference by thanking MARTA for their
cooperation in the assessment, particularly given the events that had
unfolded during the week. She then reviewed the process and timing for
developing a draft and final report. The assessment team members then
presented initial findings in each of the following areas:

-   Customer comments and issues;

-   Eligibility determination;

-   Telephone access;

-   Handling of trip requests and trip denials;

-   On-time performance;

-   Trip duration; and

-   Vehicle, manpower, and financial resources.

Mr. Beasley closed the conference by pledging MARTA's continued
cooperation in responding to any issues identified and indicated MARTA's
commitment to provide service in compliance with the DOT ADA
regulations.

# Background

MARTA provides public transit services in the Atlanta metropolitan area,
which includes the City of Atlanta and adjoining Fulton and DeKalb
Counties. MARTA provides rapid rail, fixed route bus and ADA
Complementary Paratransit service. About 1,241,000 people live in the
MARTA service area, which covers about 804 square miles.

The rapid rail system consists of 48 route miles, 248 rail cars, and 38
stations. The rail system operates weekdays from 4:23 AM until 2:02 AM.
In FY2000, the rail system served 83,796,696 one-way passenger trips.

Fixed route bus service is provided with a fleet of 710 buses operating
on 154 routes. Bus service is provided weekdays from 4:03 AM until 3:01
AM. In FY2000, the bus system served 83,118,954 one-way passenger trips.

In January 2001, the basic fixed route fare was raised from \$1.50 to
\$1.75 per ride. Free transfers are provided between bus and rail as
well as to neighboring transit systems, such as Cobb Community Transit.

**Description of the ADA Complementary Paratransit Service**

MARTA employees operate the entire ADA Complementary Paratransit, known
locally as

L-Van, in-house. ADA Complementary Paratransit service is provided in
all areas within ¾ of a mile of fixed route rail or bus services. As of
the time of the assessment, MARTA was also preparing to operate limited
ADA Complementary Paratransit service for Clayton County Transportation
(CTran), along two routes that run to the MARTA Airport rail station.

ADA Complementary Paratransit service is provided seven days a week, 365
days a year. Weekday service is provided from about 4:00 AM until 2:00
AM (with first pick-ups at about 4:30 AM and last return pick-ups at
about 1:30 AM). On weekends and holidays, the service operates generally
from 5:00 AM until 1:30AM.

The one-way fare for ADA Complementary Paratransit is \$3.50, twice the
full adult fixed route fare. A copy of the "Paratransit Customer's
Guide" is included as Attachment C.

MARTA uses the Trapeze automated reservations, scheduling, and dispatch
system to manage the ADA Complementary Paratransit operation. Real-time
reservations and scheduling is performed, with riders given pick-up
times when they call to request rides.

About 2,811 people are registered with MARTA as ADA Complementary
Paratransit eligible. In FY 2001 (July 2000 through June 2001), a total
of 166,858 one-way passenger trips were provided by the ADA
Complementary Paratransit service using a fleet of 94 body-on-chassis
minibuses.

**FY2001 Triennial Review**

An FTA Triennial Review was conducted at MARTA between January and May
of 2001. The draft report prepared in May 2001 noted two deficiencies
related to the ADA Complementary Paratransit service. First, it was
noted that the ADA Complementary Paratransit service did not operate
during all of the hours when fixed route service was available. MARTA
was asked to adjust the ADA Complementary Paratransit hours and provide
evidence of the change to FTA. Second, the review noted that MARTA was
regularly denying a percentage of ADA Complementary Paratransit trip
requests. A plan for eliminating trip denials was requested.

**Consumer Comments**

Prior to the assessment, in order to identify potential areas of
concern, the team interviewed ten consumers and consumer representatives
and reviewed four complaints filed with FTA from

July 1999 through February 2001.

In addition, during the field assessment, the team reviewed MARTA
complaint records for the period from September 2000 through August
2001. A tabulation of these complaints is provided in Attachment D.

Customer comments and complaint information for the issues assessed is
summarized in each section of this report.

# Summary of Findings

The following summarizes the findings made as a result of the
assessment. The bases for these findings are addressed in other sections
of this report. The findings should be used as the basis for any
corrective actions proposed by MARTA. Recommendations are also included
in the report for MARTA's consideration in developing corrective
actions.

**Findings Regarding ADA Complementary Paratransit**

**Eligibility Determinations**

1.  The eligibility determination process used by MARTA does not appear
    to limit access to ADA Complementary Paratransit service. MARTA
    staff appears to have a very good understanding of ADA Complementary
    Paratransit eligibility and appear to make determinations that are
    thorough and appropriate in most cases.

2.  Eligibility determinations appear to be made in a timely way.
    Ninety-eight percent (98%) of the determinations examined were made
    in less than 21 days. The longest processing time identified was 37
    days, which was for a recertification of eligibility that did not
    affect the person's ongoing use of the service.

3.  Information provided in the paper application form sometimes fails
    to accurately represent the applicant's situation. Denials of
    eligibility based solely on information in the application form and
    professional certification form may not always be appropriate. When
    additional information is presented during the appeals process, many
    initial determination decisions are changed. Of the 91 applicants in
    the past three years who were initially denied eligibility and who
    appealed, 88 (97%) were determined eligible through the appeal. A
    review of recent denials of eligibility also indicated that
    additional information might have been helpful. MARTA should obtain
    additional clarifying information before denying eligibility based
    on inconsistent or unclear information in application forms.

4.  MARTA staff makes an effort to provide applicants with information
    about all transportation options available to them. This includes
    information about the fixed route service as well as other human
    services transportation options. This additional information is
    particularly helpful to applicants who may have difficulty paying
    the \$3.50 MARTA ADA Complementary Paratransit fare or who need
    immediate service while their application is being processed. MARTA
    should take care, however, to ensure that applicants are not given
    the impression that they are being referred to other services, away
    from the ADA Complementary Paratransit program, when this
    information is provided. It appears that this information is
    currently being appropriately conveyed as additional rather than
    alternative service. MARTA should ensure that this additional
    service information continues to be provided in this way.

5.  The letters of determination to applicants determined conditionally
    eligible or eligible for only feeder service do not include
    information about the appeals process. The letters that provided
    trip-by-trip eligibility also do not explain exactly what this means
    in terms of which trips the person may request on the ADA
    Complementary Paratransit system. MARTA should revise its
    determination letters to provide individuals whose eligibility is
    conditioned in any way with a clearer understanding of when they can
    request ADA Complementary Paratransit and what type of service they
    can expect. The letters should also indicate that the person has a
    right to appeal this limitation on his or her eligibility. And,
    until clearer information and an opportunity for an appeal is
    provided, MARTA should not limit service to any person who is
    conditionally eligible.

**Findings Regarding Telephone Access**

1.  The current standard of handling 95% of all calls in eight minutes
    does not provide an acceptable level of service. A tighter and more
    definitive standard is needed.

2.  Often the main reservations line appears to have excessively long
    hold times. A significant percentage of callers (33%) end up
    abandoning their calls because of the long hold times. The poor
    level of phone service that was observed and documented could be
    considered a constraint on the service that could deter customers
    from requesting trips and using the service.

3.  There did not appear to be adequate staff to handle trip reservation
    calls during the busiest call times of the day.

4.  The inability to handle calls in a timely way appears to be creating
    additional work that further reduces staff's capacity to handle
    incoming calls. About 100 callbacks appear to be made per day to
    contact people who have left messages after being on hold for ten
    minutes. Twenty-five percent of the time these callbacks are
    unsuccessful in reaching customers.

5.  Referring callers who are on hold and who need immediate assistance
    to the ADA Complementary Paratransit and general customer service
    numbers and then transferring these calls back to the reservation
    line (placing them back at the beginning of the queue) add further
    to customer frustration in trying to make a trip request.

6.  Leaving callers on hold for up to five minutes without music or any
    other indication that the call is still in the queue could be
    causing many people to abandon their calls.

7.  The lack of information about the main dispatch number appears to be
    causing some riders to call the main reservation number for same day
    service issues rather than reservations. The dispatch number is not
    listed on the cover of the "Paratransit Customer's Guide", and there
    is no indication in the Guide that the 4212 number should be called
    to check on the status of a ride. The number is only listed for late
    night or same day cancellations (page 18) and for lost articles
    (page 38).

**Findings Regarding the Handling and Scheduling of Trip Requests**

1.  MARTA does not appear to employ trip caps in the operation of its
    ADA Complementary Paratransit service.

2.  MARTA does appear to wait list some trips. Observations suggest that
    as many as 6.5% of all requests might be initially denied. By
    continuing to search for options after riders have been denied
    trips, schedulers appear able to eventually accommodate about 60-70%
    of initial denials.

3.  Reported trip denials appear to be undercounted. Trips that are
    initially denied, but are subsequently scheduled are changed from
    "Capacity Denials" to scheduled trips in the system. Customers who
    are initially denied a trip may make alternate plans because of the
    uncertainty of service and should be accounted for separately. This
    procedure could be considered the equivalent of wait listing trips.

4.  Trip denials also appear to be undercounted by counting denials of
    one leg of a trip by a customer who wishes to make a round trip
    using ADA Complementary Paratransit service, as one rather than two
    "Capacity Denials."

5.  Between July 1999 and August 2001, MARTA denied from 0.1% to 6.3% of
    monthly trip requests and from 0.2% to 13.1% of demand trip
    requests.

6.  MARTA does not appear to have the capacity to provide reliable next
    day service. Eleven of the 29 next day requests observed by
    assessment team members (38%) were initially denied. While
    schedulers continued to look for options and many individuals were
    called back later and offered rides, these observations suggest
    riders cannot be reasonably sure that requests made one day in
    advance will be served.

7.  There appear to be patterns to the trip denials that would make the
    rate for certain requests higher than the system-wide average. The
    denial rate during afternoon and early evening hours appears to be
    1.5-2.6 times higher than the average rate of denial.

**Findings Regarding Service Provision**

1.  MARTA appears to be using drafted and extra board drivers to cover
    regular runs created to accommodate trip requests. This causes a
    shortage of extra board drivers to cover call-outs on the day of
    service.

2.  Without adequate driver back-up capability, runs are regularly
    "split-up" on the day of service and trips are reassigned to covered
    runs. These add-ons on the day of service appear to negatively
    affect on-time performance and ride times.

3.  Scheduler time appears to be diverted away from a thorough review of
    all runs and creation of the best possible schedules by the constant
    need to handle "unscheduled trips" and "capacity denials."

4.  Schedulers do not maintain a log of callbacks to riders when
    negotiated pick-up times are changed. It is therefore not possible
    to confirm that riders are notified of time changes.

5.  Dispatchers appear to spend a significant amount of time reassigning
    trips from uncovered runs, which may be distracting them from
    proactively managing drivers. With little or no back-up service
    capacity, though, there are often no other options for proactively
    handling same day problems and issues.

6.  Drivers do not appear to be given scheduled breaks. As a result, it
    appears that some drivers may perform some trips early and the next
    trip late in order to create break times in their runs.

7.  Poor on-time performance appears to be a capacity constraint in the
    MARTA ADA Complementary Paratransit service. In July and August
    2001, on-time performance was below 85% for the month. On-time
    performance was below 80% for 12 days during this two-month period.
    Poor on-time performance appears to be related to efforts to
    minimize trip denials without additional driver and service
    capacity.

8.  Some ADA Complementary Paratransit trips appear to be excessively
    long. Of the 24 trips analyzed in detail, 13 appeared to have
    significantly longer travel times by ADA Complementary Paratransit
    than by fixed route. The most frequent ADA Complementary Paratransit
    ride time issues appear to be related to medium length trips (16-30
    miles long) rather than the longest trips in the system.

**Findings Regarding Resources**

1.  MARTA appears to have an adequate number of vehicles to meet the
    current expressed demand for ADA Complementary Paratransit service.
    However, the fleet may be insufficient to serve increased passenger
    volumes resulting from improved service.

2.  The ADA Complementary Paratransit training program for operators
    seems quite extensive and adequate.

3.  The number of approved ADA Complementary Paratransit operator
    positions and the level of staffing in ADA Complementary Paratransit
    reservations do not, however, appear adequate to meet the demand for
    service. By holding the number of approved operator positions
    constant over the past five years, MARTA appears to have constrained
    ADA Complementary Paratransit service capacity. Failure to increase
    reservations staffing when reservations hours were expanded, had a
    significant adverse impact on telephone service.

4.  The lack of an adequate number of approved operator positions also
    appears to significantly affect MARTA's ability to cover scheduled
    runs, to respond to same day operator call-outs, and to respond to
    same day service issues. This lack of run coverage appears to have
    significantly affected MARTA's ability to provide an acceptable
    level of ADA Complementary Paratransit service. On-time performance
    and ride times, in particular, have been negatively impacted.

5.  During the first eight months of 2001 MARTA had a monthly average of
    2.4% denials of demand trips. The process used by MARTA to develop
    ADA Complementary Paratransit operating budgets does not appear to
    include any consideration of prior trip denials, latent demand, or
    the projected growth in demand for service. The budget process
    starts by looking at the expenses related to the number of approved
    positions for the operation. Since operator positions have been
    constant since FY97, the ADA Complementary Paratransit budget has
    essentially allowed for only inflationary increases and some
    additional overtime. FTA's interpretation of the capacity
    constraints provision regarding denials is that transit service
    providers must plan and budget for zero denials. It does not appear
    that MARTA develops its budget to meet the demand for ADA
    Complementary trips without denials.

6.  The existence of capacity constraints, including trip denials,
    untimely service, and long ride times appears to have depressed
    demand for ADA Complementary Paratransit service in the MARTA area.
    MARTA has far fewer ADA Complementary Paratransit riders per capita
    and far fewer trips per capita than other systems of its size. While
    some of this lower demand may be due to the high fare charged, the
    difference is greater than would be expected due to differences in
    fares.

# Observations Regarding ADA Complementary Paratransit Eligibility Determinations

The process used to determine ADA Complementary Paratransit eligibility
was assessed to be sure that determinations are being made in a way that
accurately reflects the functional ability of applicants. The timeliness
of the processing of requests for eligibility was also reviewed. The
assessment was completed as follows:

-   Input about the eligibility determination process was obtained
    through interviews with riders and advocates.

-   An understanding of the handling and review of applications was
    developed through interviews of MARTA staff and a review of
    application materials.

-   Eligibility determination outcomes were reviewed.

-   Ten recent denials of eligibility were reviewed with staff.

-   Records for applications reviewed in the past three months were
    examined, and the processing time for each was determined.

**Consumer Comments**

Most of the riders and advocates contacted did not have concerns about
the accuracy and thoroughness of the eligibility determination process.
There was general agreement, though, that MARTA encouraged persons with
disabilities to use the fixed route system. Several commenters noted
that the fixed route system did not always work well for people with
disabilities -- particularly persons with vision disabilities. A lack of
stop announcements was noted as a problem.

Two riders expressed dissatisfaction with the fact that they had been
granted only temporary eligibility. One noted that, on appeal, her
eligibility had been changed from temporary to full-term. Another rider
indicated that the appeal process was cumbersome.

A review of formal complaints on file with FTA and ADA Complementary
Paratransit complaints on file at MARTA for the past year failed to
identify eligibility determination as subject of consumer concern.

**Overview of the Eligibility Determination Process and Materials**

MARTA determines ADA Complementary Paratransit eligibility based on a
paper application process. When individuals call and inquire about
registering for the service, the Paratransit Eligibility Specialist or
one of the Paratransit Service Agents explains the program to callers,
takes their name and address and sends them a cover letter and brief,
four page application form. Assistance with completing the application
form is also offered. If the person indicates that they would like
assistance, the staff reviews the application form with them over the
phone and fills out as much of the application as possible. The
applicant is then sent the completed form with a cover letter asking him
or her to check the information entered by the staff, complete any
information not addressed over the phone, and sign and return the
completed application. If individuals do not want help completing the
application, they are sent a blank application form and standard cover
letter asking them to complete and return the form.

In addition to explaining the ADA Complementary Paratransit service and
offering assistance with the completion of the form, staff also lets
callers know that MARTA provides accessible fixed route service and a
discounted fixed route fare for persons with disabilities. If the caller
is interested, the number for the Half-Fare program is provided. ADA
Complementary Paratransit staff also explain that the ADA Complementary
Paratransit fare is \$3.50 each way and note that there are other
service options with free or lower fares. Again, if the person is
interested, information about these other services is provided.

A copy of the four-page application form and the two types of cover
letters is provided in Attachment E. The application form requests the
following information:

-   General information such as name, address, phone number, etc.;

-   A description of the applicant's disability and whether the
    disability is temporary;

-   Statements about how the disability affects use of fixed route bus
    service and train service;

-   Whether environmental conditions or architectural barriers (such as
    hills, a lack of sidewalks, or a lack of curb-cuts) affect travel;

-   Whether the applicant is able to wait outside for a fixed route bus;

-   The maximum distance the applicant can walk unassisted;

-   The types of mobility aids used by the applicant;

-   The need for a personal care attendant;

-   Whether the applicant can climb steps and hold onto handrails for
    support;

-   How the applicant now travels and whether they have used the fixed
    route bus or train;

-   If the applicant has received training to use the bus or train; and

-   If the applicant could use the bus or train if ADA Complementary
    Paratransit took them to and from stops/station.

Finally, applicants are asked to identify a health care professional who
can verify their disability and need for the service. The name, phone
number and fax number of the professional is requested and applicants
are asked to sign a release statement to allow the professional to
provide medical information.

When a completed application is received, MARTA staff sends a cover
letter and two-page "Health Care Professional Certification for ADA
Complementary Paratransit Eligibility" form to the professional named by
the applicant. The fax cover and the cover letter ask the professional
to please respond within three days. A copy of a sample fax cover, cover
letter and professional certification form is also provided in
Attachment E.

The application form is referred to as "Part A" by MARTA staff. The
professional verification form is referred to as "Part B." When both
parts have been completed, the ADA Complementary Paratransit Eligibility
Specialist reviews the information and makes a determination of
eligibility. In some cases, telephone calls are made to applicants
and/or professionals to clarify information in the application or to get
additional information about the applicant's functional abilities.

Letters of determination are then sent to applicants. There are fourteen
different types of letters that are sent depending on the outcome of the
process. This includes a "not eligible" letter if the applicant is found
to be able to use fixed route service all of the time. It also includes
a letter conferring temporary eligibility if the disability or health
condition is expected to last for less than a year. If the condition is
not temporary, eligibility is granted for a two-year period. For
applicants determined eligible for a full two-years of service, the
outcome variables include: the regulatory category under which
applicants qualify (Category 1, 2, 3); if they are eligible for full
service, feeder service only, or "trip-by-trip" service; if they qualify
to have a personal care attendant (PCA) ride with them at no fare; and
if they qualify for only temporary eligibility. The 10 different letters
for two-year service provide one of the following types of eligibility:

-   Unconditional eligibility under regulatory Category 1 not authorized
    for a PCA;

-   Unconditional eligibility under regulatory Category 1 authorized for
    a PCA;

-   Unconditional eligibility under regulatory Category 1 for feeder
    service only and not authorized for a PCA;

-   Unconditional eligibility under regulatory Category 1 for feeder
    service only and authorized for a PCA;

-   Conditional eligibility under regulatory Category 2 for feeder
    service only and not authorized for a PCA;

-   Conditional eligibility under regulatory Category 2 for feeder
    service only and authorized for a PCA;

-   Conditional trip-by-trip eligibility under regulatory Category 3 not
    authorized for a PCA;

-   Conditional trip-by-trip eligibility under regulatory Category 3
    authorized for a PCA;

-   Conditional trip-by-trip eligibility under regulatory Category 3 for
    feeder service only and not authorized for a PCA; and

-   Conditional trip-by-trip eligibility under regulatory Category 3 for
    feeder service only and authorized for a PCA.

Finally, if applicants indicate in the application form that they live
outside the ADA Complementary Paratransit service area, a special
determination letter is sent to them indicating that they cannot be
picked-up at their residence address but can use the service if they are
traveling within the service area.

While several different types of eligibility are granted, MARTA staff
indicated that all persons determined eligible are essentially treated
as unconditionally eligible. Regardless of the type of eligibility
granted, all trip requests are honored as long as the trip is within the
defined service hours and area.

Determination letters to persons found to be "not eligible" detail the
specific reasons why it was determined that the person did not qualify
for ADA Complementary Paratransit. They also provide information about
how to initiate an appeal of the decision.

Letters conferring limited eligibility (trip-by-trip or feeder service)
do not detail the specific circumstances under which applicants can or
cannot use the fixed route service. This information (e.g., need
curb-cuts and sidewalks, can only walk a limited distance, need an
accessible bus, etc.) is maintained in a separate database in the
Trapeze computer system but is not detailed in the determination
letters. Also, letters granting limited eligibility do not include
information on the appeal process.

Determination letters indicate that eligible individuals must have a
photo identification card made before they can begin to use the service.
To get a card, applicants must travel to the ADA Complementary
Paratransit administrative offices and have a photo taken. Free ADA
Complementary Paratransit service is provided to the office for the
photo ID. The standard \$3.50 fare is collected if an ADA Complementary
Paratransit ride back home from the office is scheduled. MARTA staff
indicated that eligible riders often do not visit the office and that
they are still entered into the "client file" in the computer system and
they receive service without the ID.

If applicants appeal the initial determination, the Paratransit
Eligibility Specialist first reviews the decision. This often involves a
follow-up telephone conversation with the applicant to explain and
discuss the decision. If this does not satisfy the applicant, an appeal
before five members of the Elderly and Disabled Advisory Committee
(EDAC) is scheduled. Different members of the committee hear appeals and
serve on the Appeals Subcommittee on a rotating basis. Finally, if the
applicant is still not satisfied with the outcome, he or she can appeal
to a three-member panel made up of MARTA's Assistant General Manager of
Operations, Assistant General Manager of Diversity and Equal
Opportunity, and Assistant General Manager of Customer Service.

**Determination Outcomes**

At the time of the assessment, there were 2,811 persons registered to
use the MARTA ADA Complementary Paratransit service. Records indicated
that MARTA eligibility staff review about 120-140 applications per
month.

MARTA tracks type of eligibility by regulatory category. Of the 2,811
registered riders, 843 have been granted unconditional "Category 1"
eligibility; 319 have conditional "Category 2" eligibility; 1,645 have
conditional "Category 3" eligibility; and 4 riders did not have an
eligibility code in their files. As indicated above, while riders are
given an eligibility code, no distinction is made in actual operation.
Persons determined "trip-by-trip" eligible or only "feeder" eligible
could still request and receive any trips on ADA Complementary
Paratransit.

Records for the past three fiscal years indicated that a total of 4,708
applications were submitted and reviewed. Of these, 4,182 applicants
(89%) were approved for some type of eligibility and 526 applicants
(11%) were determined not eligible.

Ninety-one (91) of the persons determined not eligible appealed the
decision. The Paratransit Eligibility Specialist handled eighty-six of
these appeals through follow-up conversations with the applicant. Only
five appeals were heard by the EDAC or by the MARTA appeal board. Of the
91 applicants who appealed, 88 were eventually granted eligibility of
some type.

**Review of Recent Denials of Eligibility**

Ten recent denials of eligibility were randomly selected and reviewed as
part of the assessment. The full files were reviewed and discussed with
the Paratransit Eligibility Specialist. The assessment team noted
reasons for the determination that the applicant could always use fixed
route service.

Of the ten files reviewed, the determinations appeared to be clear-cut
and appropriate in seven cases. In three instances, the information in
the application form and the professional certification was not
consistent. There was an indication in all three cases that the
applicants had or could use bus or train service. There was also an
indication in each case, however, of possible problems getting to and
from bus stops or train stations. Follow-up with the applicant and/or
professional to clarify these inconsistencies would have been helpful.

**Review of Application Processing Times**

The ADA regulations require that transit agencies provide presumptive
eligibility to applicants if determinations cannot be made within 21
calendar days of the receipt of a completed application. In the MARTA
process, an application is not considered complete until information
confirming the applicant's disability is received from the named
professional.

MARTA date stamps applications when they are received and enters the
date into a tracking database. The date that information is received
from named professionals is also logged. Finally, the date that a
determination is made and a letter is sent to the applicant is entered
into the tracking system.

Tracking records for 237 determinations made between June 28 and
September 5, 2001, were reviewed. Table 1 below shows the processing
times for each of these determinations. As shown, 98% of all
determinations were made in 21 days or less. About half (48%) of all
determinations were made in 14 days or less. Of the five applications
that took longer than 21 days to process, three were for persons who
were already eligible and who were seeking to be recertified. Therefore
service access for these persons was not affected. One new application
took 30 days to process and a second new application was processed in 35
days.

**Table 1. Time Required to Make Determinations of ADA Complementary
Paratransit Eligibility**

**Determinations made from 6/28/01 to 9/7/01**

  --------------------------------- ------------------- ------------------
  **Days Elapsed between request    **Number of         **Cumulative
  for Interview and Actual          Applicants**        Percent**
  Interview Date**                                      

  7 days or less                    19                  8%

  8-14 days                         94                  48%

  15-21 days                        119                 98%

  More than 21 days                 5                   100%

  TOTAL                             237                 100%
  --------------------------------- ------------------- ------------------

**Findings**

1.  The eligibility determination process used by MARTA does not appear
    to limit access to ADA Complementary Paratransit service. MARTA
    staff appears to have a very good understanding of ADA Complementary
    Paratransit eligibility and appear to make determinations that are
    thorough and appropriate in most cases.

2.  Eligibility determinations appear to be made in a timely way.
    Ninety-eight percent (98%) of the determinations examined were made
    in less than 21 days. The longest processing time identified was 37
    days, which was for a recertification of eligibility that did not
    affect the person's ongoing use of the service.

3.  Information provided in the paper application form sometimes fails
    to accurately represent the applicant's situation. Denials of
    eligibility based solely on information in the application form and
    professional certification form may not always be appropriate. When
    additional information is presented during the appeals process, many
    initial determination decisions are changed. Of the 91 applicants in
    the past three years who were initially denied eligibility and who
    appealed, 88 (97%) were determined eligible through the appeal. A
    review of recent denials of eligibility also indicated that
    additional information might have been helpful. MARTA should obtain
    additional clarifying information before denying eligibility based
    on inconsistent or unclear information in application forms.

4.  MARTA staff makes an effort to provide applicants with information
    about all transportation options available to them. This includes
    information about the fixed route service as well as other human
    services transportation options. This additional information is
    particularly helpful to applicants who may have difficulty paying
    the \$3.50 MARTA ADA Complementary Paratransit fare or who need
    immediate service while their application is being processed. MARTA
    should take care, however, to ensure that applicants are not given
    the impression that they are being referred to other services, away
    from the ADA Complementary Paratransit program, when this
    information is provided. It appears that this information is
    currently being appropriately conveyed as additional rather than
    alternative service. MARTA should ensure that this additional
    service information continues to be provided in this way.

5.  The letters of determination to applicants determined conditionally
    eligible or eligible for only feeder service do not include
    information about the appeals process. The letters that provided
    trip-by-trip eligibility also do not explain exactly what this means
    in terms of which trips the person may request on the ADA
    Complementary Paratransit system. MARTA should revise its
    determination letters to provide individuals whose eligibility is
    conditioned in any way with a clearer understanding of when they can
    request ADA Complementary Paratransit and what type of service they
    can expect. The letters also should indicate that the person has a
    right to appeal this limitation on his or her eligibility. And,
    until clearer information and an opportunity for an appeal is
    provided, MARTA should not limit service to any person who is
    conditionally eligible.

**Recommendations**

1.  MARTA should consider making it standard procedure to make follow-up
    calls to applicants and/or named professionals if denial of
    eligibility is being considered. This will allow any incorrect
    information to be corrected and considered and potentially avoid the
    need for some appeals.

2.  MARTA should more thoroughly consider the ability of applicants to
    get to and from fixed route stops/stations throughout the service
    area. Some denials appeared to be made on the basis that the
    applicant could use fixed route service some of the time and was
    close to bus stops. Several applicants may, however, have had
    difficulty traveling long distances to get to or from other stops
    that were not in close proximity. Eligibility determinations should
    consider these "most limiting situations."

3.  To ensure that the provision of optional service information does
    not inhibit people from applying for ADA Complementary Paratransit
    service, MARTA should consider providing limited information about
    other services when a general inquiry is made (only if the caller
    indicates a need for immediate service or would clearly benefit
    immediately from knowing about other services) and then including
    more complete information about other services when the application
    is mailed to the person.

4.  MARTA should consider implementing an in-person interview process to
    determine ADA Complementary Paratransit eligibility. Since MARTA
    requires approved applicants to come to the ADA Complementary
    Paratransit office to get a photo ID, it would add little cost to
    the process to have all applicants come to the office for an
    interview and bring the completed application with them. At the time
    of the interview, the photo could be taken for an ID. The photo ID
    could then be mailed to approved applicants after information is
    obtained from a medical professional and a decision is made. The
    opportunity to speak with applicants in-person has been found in
    other systems to strengthen the eligibility process. A major change
    of this type should be developed with EDAC and community input.

5.  The use of regulatory "Category 1, 2, or 3" in final determination
    letters may not be the clearest way to explain eligibility to
    riders. MARTA should consider determining applicants either
    unconditionally eligible (meaning they are not able to use fixed
    route service under any conditions; conditionally eligible (meaning
    they can use fixed route under some conditions but need ADA
    Complementary Paratransit service for some trips); or not eligible
    (meaning they are able to use fixed route service for any potential
    trip they may want to make throughout the area). Then, if
    conditional eligibility is granted, the specific conditions under
    which ADA Complementary Paratransit service is needed should be
    clearly explained (e.g., "when you would need to travel more than 3
    blocks to get to or from a bus stop or train station," or "when the
    bus you would need to use is not equipped with a lift," or "if there
    are intersections that you are unable to cross to get to or from bus
    stops or train stations\")." The specific conditions of eligibility
    should reflect each applicant's functional abilities and travel
    limitations. Persons determined conditionally eligible should also
    be given information on how to appeal the determination.

6.  It is recommended that MARTA not make riders solely "feeder
    eligible." Feeder service should be considered for certain trips for
    persons who are conditionally eligible, based on their specific
    travel limitations (rather than for all trips for certain
    individuals).

# Observations Regarding Telephone Access

The assessment team collected information about telephone access to the
service for this part of the assessment. 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, without significant delays, to
place trip requests or to check on rides could discourage people from
using the service and could therefore be considered a form of capacity
constraint.

The following information was collected:

-   Consumer input on this issue was obtained through telephone
    interviews with riders, advocates and agencies, and through a review
    of recent customer comments and complaints received by MARTA;

-   MARTA's standards for performance in this area were reviewed;

-   Design of the phone system and the staffing of phones was reviewed;

-   Handling of calls in both reservations and dispatch was observed;
    and

-   Available telephone service reports showing hold times and the
    number of abandoned calls were reviewed.

**Consumer Comments**

Several of the riders, advocates and local agency staff contacted by
phone as part of the assessment, mentioned phone service as a problem.
These individuals specifically mentioned facing long hold times when
calling to make trip reservations or calling to make changes to
scheduled trips. Long hold times were also mentioned in recent public
meetings concerning the ADA Complementary Paratransit service.

Phone service was not cited as an issue, though, in formal complaints
filed with FTA. It was also only mentioned in one of the internal
complaints submitted to MARTA's customer service department over the
past year.

**MARTA's Phone Service Design, Staffing, and Standards**

There are several different telephone numbers used by ADA Complementary
Paratransit riders depending on their needs. For application
information, individuals are instructed to call

404-848-5399. For general information or to comment on the service,
riders can call either the ADA Complementary Paratransit Customer
Service number (404-848-5389) or the general MARTA Customer Service
number (404-848-4800). To place a reservation on weekdays, or to cancel
or change a scheduled trip one or more days in advance, riders are
instructed to call the main reservations number (404-848-5826). To place
advance reservations on the weekend, riders are instructed to call
404-848-6400. This weekend number is served by voice mail and riders
calling on the weekend can only request trips one day in advance.

To make same day inquiries about the status of a trip or to make same
day cancellations, riders can call the main dispatch number at
404-848-4212. It was noted, however, that the main dispatch number is
not identified for this purpose in the "Paratransit Customer's Guide"
and reservationists reported getting many calls on the 848-5826 line for
same day trip information.

The main trip reservation number is staffed Monday through Friday from 8
AM until 10 PM and on weekends and holidays from 10 AM to 4 PM. On
weekdays, the main reservations office takes trip reservation calls.
Three call takers plus a supervisor cover the phones on weekdays from 8
AM to 5 PM. Two additional reservationists are scheduled to work the
weekday afternoon and evening shift (one reports at 1 PM and the second
at 2 PM). On weekends, calls made to the main reservations number are
automatically routed to the 848-6400 voice mail line. Data specialist
and scheduling staff are on duty on the weekends return messages.

It was noted that the weekday reservation hours were extended in March
2000. Prior to that time, reservations were taken from 8 AM to 5 PM on
weekdays. The weekday hours were extended to 10 PM in response to
comments from riders who work and who indicated that making calls during
working hours was an inconvenience and hardship. The extension in hours
was implemented without any additional reservations staffing. There were
five reservationist positions and a supervisor position authorized prior
to March 2000 and no change has been made in this staffing level to
date. Prior to March 2000, there were five reservationists and a
supervisor available to handle calls from 8 AM to 5 PM. Now, there are
only three reservationists and a supervisor on duty from 8 AM to 1 PM.
Call records also showed that the morning hours are the busiest call
times.

The main reservations number has a central queue. When riders call, they
are greeted by an automated message and then routed to an available
agent. If all agents are assisting callers, the call is placed in a
central queue until an agent is free to accept another call. After
several minutes, a message informs the callers on hold that all agents
are still busy. The message states that if the caller needs immediate
assistance they can call 848-5389 (Paratransit Customer Service),
848-4212 (Paratransit dispatch), or 848-4800 (general MARTA Customer
Service). When the customer service and dispatch staff was asked how
they handle calls from persons wanting to book a trip, they said that
they transfer them back to the main reservations line (which then puts
the person back into the beginning of the queue). If the person remains
on hold and does not try one of these other numbers, they get repeat
messages letting them know that all lines are busy. After 8 minutes, the
system is supposed to route the call to voice mail (a message lets the
caller know all lines are busy and asks them to leave a message after
the tone). The actual experience of the assessment team (based on
several calls to the line and times on hold) was that the voice mail was
not actually activated until after about 10 minutes on hold.

The main dispatch number (848-4212) is a direct line to one phone at the
main "window dispatch" station. This phone has two incoming lines and
one outgoing line. If the main window dispatcher is serving a caller on
the 4212 line, the next call is routed to the second line on this phone
(848-4390). The dispatcher can therefore put one call on hold and serve
up to two callers at a time. If both of the lines on the main window
dispatch phone are in use, calls are routed to a third dispatch line
(848-4234), which is located at the second window dispatch station. A
fourth dispatch line (848-4330) is also programmed at this second
station, but this line is forwarded back to the first station. So, as
currently designed, a maximum of three same day service calls can be
handled by the two window dispatchers. When all three lines are in use
and a fourth person calls, the fourth caller gets a busy signal.

MARTA reported that its telephone service standard is to answer 95% of
all calls within eight (8) minutes.

**First-Hand Observations of the Call Handling Process**

Assessment team members observed call takers and dispatchers for several
hours on Monday, Tuesday, and Wednesday, September 10-12. Calls to the
main reservations and dispatch lines were also made on these days.

During the week of the assessment, one full-time reservationist was
absent. It was reported that this person was on long-term leave.
Therefore, only two call takers and a supervisor staffed the main
reservations line from 8 AM until 1 PM. Often, one of these three people
would be away from their station (sometimes taking messages to dispatch
or the supervisor would be performing other administrative duties) and
only two people would staff the reservations function. To cover for
staffing shortages, the Supervisor worked from 8 AM until 10 PM on the
days that the team was on-site. It was observed that calls to the main
reservations line are often placed on hold in the central queue for
several minutes. Several times when assessment team members called
during peak call times, they were kept on hold for the maximum time
(noted as 10 minutes) and then transferred to voice mail.

The main dispatch line (4212) did not appear to be very busy. Every time
assessment team members made calls to this number -- even during the
peak afternoon times -- the call was answered in a few rings by the
dispatcher. During the hours of observation, the team members did not
see all three of the dispatch lines in use at the same time.

It was noted that when calls to the main reservations number are placed
on hold there is no music to let the caller know that they are still in
the queue. Assessment team members noted being on hold, with silence on
the phone, for up to five minutes before a message would come on saying
that all agents were still busy.

**Review of Phone Performance Records**

MARTA is able to generate daily telephone service performance reports
for the main reservations number (848-5826). The Reservations Supervisor
receives telephone performance reports on a regular basis. By dialing a
special code, she is also able to get the number of callers in the queue
and the longest hold time for callers in the queue, in real-time.

Because dispatch and customer service have direct lines and are not on a
central queuing system, MARTA does not have similar performance reports
for these numbers.

The main reservations phone service performance records for two randomly
selected weeks (May 14-18 and August 20-24) were reviewed. Key
information from these reports is summarized in Table 2 below. As shown,
many calls are on hold for long periods and a large percentage of calls
are abandoned or go to voice mail. For the five weekdays from August
20-24, for example, only 59% of the 2,399 calls received were answered.
A third of all calls (801 total) were abandoned by the caller. One
hundred and eighty-four callers (8% of all callers) waited on hold the
full ten minutes and then were routed to voice mail. Average hold times
were as long as 4 minutes and thirty-eight seconds, which means that
many calls were likely holding for twice this amount of time.

**Table 2. Key Phone Performance Information for Line 848-5826
(Reservations),**

**May 14-18 and August 20-24, 2001**

  ----------------------------------- ------------------ -----------------
                                      **May 14-18**      **August 20-24**

  Total Calls Received                2234               2399

  Calls Answered                      1468 (66%)         1414 (59%)

  Calls Abandoned                     618 (28%)          801 (33%)

  Calls Routed to Voice Mail          148 (6%)           184 (8%)

  Average Hold Time for Answered      1:40 -- 4:18       1:36 -- 4:38
  Calls                                                  

  Average Hold Time for All Calls     3:04 -- 4:20       3:00 -- 4:28
  ----------------------------------- ------------------ -----------------

**Review of Callback Logs**

As noted above, after being on hold for 10 minutes, calls to the main
reservations number are routed to a voice mail system. Call takers
regularly check this voice mail and callbacks are made when time
permits. Each reservationist then maintains a callback log indicating
the outcome of efforts to reach the customer.

Callback logs for all reservationists for Monday, September 10, 2001,
were reviewed. These records showed that a total of 107 calls were
picked-up off of the voice mail. A total of 100 callbacks were made
(there were no entries for seven of the calls). Of the 100 callbacks
made, the log showed that the customer was reached and the trip booked
(or issue resolved) in 68 instances. Twenty times, reservationists
indicated that they left a message for the customer. In four cases the
line was busy and additional attempts to callback were not indicated. In
one instance, it was noted that the number left was not in service.

## Findings {#findings .unnumbered}

1.  The current standard of handling 95% of all calls in eight minutes
    does not provide an acceptable level of service. A tighter and more
    definitive standard is needed.

2.  Often the main reservations line appears to have excessively long
    hold times. A significant percentage of callers (33%) end up
    abandoning their calls because of the long hold times. The poor
    level of phone service that was observed and documented could be
    considered a constraint on the service that could deter customers
    from requesting trips and using the service.

3.  There did not appear to be adequate staff to handle trip reservation
    calls during the busiest call times of the day.

4.  The inability to handle calls in a timely way appears to be creating
    additional work that further reduces staff's capacity to handle
    incoming calls. About 100 callbacks appear to be made per day to
    contact people who have left messages after being on hold for ten
    minutes. Twenty-five percent of the time these callbacks are
    unsuccessful in reaching customers.

5.  Referring callers who are on hold and who need immediate assistance
    to the ADA Complementary Paratransit and general customer service
    numbers and then transferring these calls back to the reservation
    line (placing them back at the beginning of the queue) add further
    to customer frustration in trying to make a trip request.

6.  Leaving callers on hold for up to five minutes without music or any
    other indication that the call is still in the queue could be
    causing many people to abandon their calls.

7.  The lack of information about the main dispatch number appears to be
    causing some riders to call the main reservation number for same day
    service issues rather than reservations. The dispatch number is not
    listed on the cover of the "Paratransit Customer's Guide" and there
    is no indication in the Guide that the 4212 number should be called
    to check on the status of a ride. The number is only listed for late
    night or same day cancellations (page 18) and for lost articles
    (page 38).

## Recommendations {#recommendations .unnumbered}

1.  MARTA should consider a standard that would define a maximum average
    hold time for any hourly period of the day. Typically, standards
    call for average hold times to be no more than two minutes for any
    hourly period of the day.

2.  MARTA needs to ensure that there is adequate staffing to meet a
    higher performance standard such as the one suggested above. MARTA
    should minimize or eliminate reliance on voice mail and callbacks
    since this process is time-consuming and unreliable.

3.  Music or informational messages should be added to the system so
    that callers on hold know they are still in the queue.

4.  MARTA should not refer callers who are on hold to the customer
    service numbers for immediate assistance. The message should be
    changed to only refer callers who have questions about trips on that
    day to the dispatch number (848-4212).

5.  The 848-4212 number should be added to the cover of the "Paratransit
    Customer's Guide" and there should be a section of the guide that
    tells riders to call this number if their ride is late, if they want
    to make same day changes to trip reservations, or if they want to
    call on the day of service to inquire about a scheduled trip.

6.  Better advertising and use of 4212, the dispatch number, should
    lessen the burden on the main reservations line. It will, however,
    increase the volume of calls to dispatch. Currently, MARTA is not
    able to measure and track performance on the dispatch line because
    it does not use a central queue. MARTA should consider changing this
    line to a central queue or should find a way to closely monitor
    performance on the line so that if call volume increases performance
    can be tracked.

# Observations Regarding the Handling and Scheduling of Trip Requests

In this portion of the assessment, the team examined how trip requests
from riders were handled. Particular attention was given to whether
MARTA uses any form of trip caps or waiting lists and whether there was
a pattern or practice of denying a significant number of trip requests.
The following information was gathered and analyzed:

-   Input from customers and advocates was obtained through telephone
    interviews and through a review of comments and complaints on file
    at FTA and MARTA;

-   Reservations and scheduling policies, practices, and performance
    standards were reviewed;

-   Service reports prepared by MARTA showing the number of trips
    requested, scheduled and denied were examined; and

-   First-hand observations of the handling of trips at both contractor
    sites were made, and staff was interviewed about the ability to
    accommodate trip requests.

**Consumer Comments**

Riders, advocates and agency representatives contacted prior to the
assessment did not identify trip denials as a significant problem. The
review of ADA Complementary Paratransit service complaints received by
MARTA between September 2000 and August 2001 also showed little rider
concern about trip denials. This type of complaint was not significant
enough to be separated out as a type of complaint (see complaint
tabulation in Attachment D).

One of the four formal ADA complaints filed with FTA alleged that MARTA
wait lists trips and requires riders to call back to see if rides are
available. This complaint also noted that there are some outright
denials of trip requests.

**Reservations and Scheduling Policies, Practices and Performance
Standards**

As noted in the "background" section of this report, ADA Complementary
Paratransit requests are accepted Monday through Friday from 8 AM until
10 PM. On weekends and holidays, trip requests are taken from 10 AM
until 4 PM. On weekdays, reservation calls are handled directly by
reservationists. On the weekends and on holidays, callers are asked to
leave a voice mail message and weekend staff call back to get detailed
trip information and to book the trip. Most days, trips can be requested
up to 7 days in advance. On weekends and holidays, however, riders can
only request trips for the next day (i.e., on Saturday only Sunday trips
are taken and on Sunday only trips for Monday are taken). The policy
regarding advance reservations was changed in March 2001. Prior to that
time, requests were accepted up to 14 days in advance. Since March 17,
2001, requests are accepted a maximum of 7 days in advance.

Reservationists and schedulers negotiate trip times with callers to
efficiently group trips, but are instructed to schedule trips within one
hour of the time requested. Trips which cannot be scheduled or which can
only be scheduled more than an hour from the requested time are recorded
as "capacity denials." Trips that are offered within an hour of the
requested time but not accepted by the caller are recorded as "refused"
trips.

MARTA reported that it has no formal goal regarding trip denials and
strives to accommodate all trip requests. MARTA tracks and analyzes trip
denials on a monthly basis. The number and percentage of trip requests
that are denied is examined for the system as a whole. ADA Complementary
Paratransit management has also written special reports to look at trip
denials by time of day and by the number of days in advance that
requests are made.

MARTA records and schedules trip requests using the Trapeze automated
reservations, scheduling, and dispatch system. Reservationists place
trip requests directly onto runs that have been created in the Trapeze
system. Reservationists first enter all trip information, including the
date and requested pick-up or drop-off time, the origin and destination
addresses, and other information such as companions, PCAs, mobility
aids, etc. Once all trip information has been entered, the
reservationists search for available trip options. The system will then
identify runs that can accommodate the request and will offer specific
pick-up times that fit on that run. This search considers all runs that
can accommodate the trip within an hour of the requested pick-up time.
The reservationists will then offer the rider a time that best meets
their needs. If the offered time is accepted, the trip is booked.

MARTA allows riders to place requests based either on a desired arrival
time or a desired

pickup time. If the caller indicates that they have an appointment and
need to be dropped-off no later than that time, the reservationist
enters the appointment into the system as the "latest drop-off time."
The parameters in the system are set to ensure that changes will not be
made to violate that latest drop-off time.

Prior to March 2001, if the Trapeze system did not offer a scheduling
option, reservationists informed callers that the trip could not be
accommodated and the request was recorded as a "Capacity Denial." Since
March 17, if the trip is requested two or more days in advance, the
reservationist will confirm the trip with the caller as requested and
will enter it on an open run. The caller is told that they have a trip
at the time requested. Schedulers then scan the open "Unscheduled" run
file and continuously try to place these requests on actual runs. This
is often possible as advance cancellations are received. In some cases,
the schedulers may eventually need to adjust the requested times of
"Unscheduled" trips to get them to fit on runs. If the time is changed,
schedulers are instructed to call the rider to give them the new trip
times. It was reported that all trip requests made two or more days in
advance and initially entered as unscheduled trips are eventually placed
on runs and served.

If a trip request is made only one day in advance and the reservationist
finds no run option, or if the only options found are more than an hour
from the requested time, the reservationist is instructed to code that
trip as a "Capacity Denial." The caller is told that the trip cannot be
accommodated. They are also told, though, that they can check back later
in the day to see if space becomes available and are also told that
schedulers will continue to work on the request to try to accommodate
it. Schedulers then periodically scan the "Capacity Denial" file and
work to place these trips on scheduled runs. If space is found on an
existing run, the scheduler will call the rider back and offer the trip.
If the person has not already made alternate plans and still wants to
use the service, the trip will be booked and changed from a "Capacity
Denial" to a scheduled trip.

One exception to the above use of the "Unscheduled" run file is for trip
requests made on Friday for Monday or on a day prior to a holiday for
the day after the holiday. Since MARTA has only a skeleton staff on
weekends and holidays, these trip requests are not placed in the
"Unscheduled" file.

**Reported Handling of Trip Requests**

Monthly service reports developed by MARTA for the period July 1999
through August 2001, which include the number of trips requested, the
number of trips provided, and the number of requests denied, were
reviewed as part of the assessment. Table 3 below provides this
information.

It is important to note that the denial rates included in regular
monthly service reports and shown in the middle column of Table 3 are
based on all trips requests, including both subscription trips and
"demand" trips. Since subscription trips are automatically scheduled,
trip denials really only relate to "demand" requests. To get a better
estimate of the number of "demand" trip requests that were denied, Table
3 also includes the % of total trips that were non-subscription "demand"
trips for each month. This percentage is then divided into the total
trip denial rate to estimate a "demand" trip denial rate (shown in the
last column of Table 3).

It is also important to note that the final reported count of trip
denials does not include requests that were scheduled after they were
initially denied. As noted below in the "Observations of the
reservations and scheduling process" section of this report, about 6.5%
of trip requests appear to be initially denied.

Additionally, if a customer who wishes to make a round trip has one leg
of the round trip denied and, as a result declines or does not request
the other leg of the round trip, MARTA records this as one "Capacity
Denial" although the result is two one-way trips not made by the
customer. This procedure further understates the number of "Capacity
Denials."

As shown, the rate of denials of all trips and "demand" trips has
fluctuated over this period. From September to December 1999, about 500
to 1,000 trip requests per month were denied. This represented between
3.2% and 6.3% of all trip requests and is estimated as between 7% and
13.1% of all non-subscription "demand" trip requests. Since January
2000, total trip denials have numbered about 200-400 per month, or about
1-2% of all requests and about 2-4% of "demand" requests. In June and
July of this year, a much smaller number of denials were recorded (15 in
June and 64 in July). Staff noted that a concerted effort to eliminate
trip denials was made following an FTA Triennial Review conducted
earlier in the year. The Triennial Review indicated that all trip
requests had to be served. Staff noted, however, that this effort
resulted in an increase in untimely and "missed" trips. In August, the
effort to serve all requests was discontinued and 282 trips (about 2.6%
of demand requests) were denied.

**Table 3. Reported Transit Plus Trip Denials, January 2000 -- June
2001**

  ----------- ------------- ----------- ----------- ----------- -----------
  **Month,    **Total Trips **Trips     **% of      **%         **Est. %
  Year**      Requested**   Denied**    Total Trip  "Demand"    "Demand"
                                        Requests    Trips**     Requests
                                        Denied**                Denied**

  July, 1999  12,602        162         1.3%        47%         **2.8%**

  August      15,978        107         0.7%        52%         **1.3%**

  September   16,876        670         4.0%        46%         **8.7%**

  October     16,096        1,020       6.3%        48%         **13.1%**

  November    15,615        508         3.2%        46%         **7.0%**

  December    15,661        549         3.5%        47%         **7.4%**

  Jan., 2000  14,276        283         2.0%        47%         **4.2%**

  February    15,388        424         2.8%        56%         **5.0%**

  March       18,222        432         2.4%        75%         **3.2%**

  April       16,897        263         1.6%        61%         **2.6%**

  May         18,467        210         1.1%        72%         **1.5%**

  June        17,611        258         1.5%        58%         **2.6%**

  July        17,511        204         1.2%        58%         **2.1%**

  August      19,324        261         1.4%        72%         **1.9%**

  September   18,364        305         1.7%        75%         **2.3%**

  October     19,548        354         1.8%        46%         **3.9%**

  November    16,471        156         1.0%        48%         **2.1%**

  December    18,610        307         1.6%        56%         **2.8%**

  Jan., 2001  19,539        428         2.2%        49%         **4.5%**

  February    17,932        379         2.1%        50%         **4.2%**

  March       19,459        212         1.1%        51%         **2.2%**

  April       18,289        342         1.9%        55%         **3.4%**

  May         19,279        169         0.9%        51%         **1.8%**

  June        18,829        15          0.1%        51%         **0.2%**

  July        18,466        64          0.4%        57%         **0.7%**

  August      19,520        282         1.4%        54%         **2.6%**
  ----------- ------------- ----------- ----------- ----------- -----------

***Trip Denials by Time of Day***

The assessment team also reviewed reported denials for August 2001 in
more detail to determine if there were any patterns based on time of
day. The total number of demand trips and denials by the hour of day
were examined for this sample month.

This analysis indicated that the pattern of denials is more significant
at certain times of the day. Table 4 below shows the periods of the day
that had the greatest rate of trip denials in August 2001.

**Table 4. Peak Periods of Trip Denials in August 2001**

  --------------------------------- -------------------------------------
  **Time of Day**                   **Rate of Demand Trip Denials**

  1:00 to 2:00 PM                   1.1 times the average

  2:00 to 3:00 PM                   1.25 times the average

  3:00 to 4:00 PM                   2.6 times the average

  4:00 to 5:00 PM                   1.5 times the average

  6:00 to 7:00 PM                   2.0 times the average

  7:00 to 8:00 PM                   2.1 times the average

  11:00 PM to midnight              2.9 times the average
  --------------------------------- -------------------------------------

The most significant rates of denials appear to occur in the afternoon
and early evening, from 3:00 to 8:00 PM. During these times, the rates
of demand trip denials are 1.5 to 2.6 times the average. In the late
evening, when very few vehicles are in operation to cover the entire
service area, the rate of denial was 2.9 times the average.

This analysis suggests that in August 2001, for example, when 2.6% of
all demand trip requests were denied, the rate of denials during the
afternoon and early evening hours was about 4-7%.

***Trip Denials by Advance Notice Provided***

Finally, the assessment team analyzed trip denials from March 17, 2001,
to August 31, 2001, to determine if there was a difference in the rate
of denials based on the amount of advance notice given by riders. Table
5 below provides information about trip denials for trips placed 1-7
days in advance are shown.

**Table 5. Denial Rates by Days Advance Notice Provided,
3/17/01-8/31/01**

  ------------------------- ---------------------------------------------
  **Advance Notice**        Rate of Denial of Demand Trip Requests

  7 days                    0.03%

  6 days                    0.02%

  5 days                    0.1%

  4 days                    0.1%

  3 days                    1.8%

  2 days                    1.8%

  1 day                     4.2%
  ------------------------- ---------------------------------------------

For this period of time, 1.1% of all trip requests were reported as
denied. As shown in Table 5, trip requests placed 4 or more days in
advance are almost always accommodated. Requests made 2-3 days in
advance were denied 1.8% of the time (1.6 times more than on average).
This reflects the practice of denying trips made on Friday for Monday
rather than leaving them unscheduled. If riders called for next day
trips, they were denied 4.2% of the time (almost 4 times higher than the
average).

**Observations of the Reservations and Scheduling Process**

First-hand observations of the reservation and scheduling process were
conducted on Monday and Tuesday, September 10-12. Assessment team
members sat with reservationists at each operation center, listened in
on phone calls, and recorded information about trip requests and trip
times offered and scheduled.

The assessment team observed handling of a total of 199 trip requests.
No scheduling options were found for 13 of these requests and they were
entered into the computer system as capacity denials. While options may
have been found later by schedulers for these requests, these first-hand
observations suggest that as many as 6.5% of all requests may initially
be denied.

Observations also confirmed a high percentage of denials for next day
requests. Almost all of capacity denials observed (11 of 13) were for
next day requests. Of the 199 trip requests observed, a total of 29 were
for next day trips. Of these, 11 (or 38%) were denied.

While observing the reservations process, all three assessment team
members also heard reservationists tell callers who were asking for next
day rides that they "shouldn't wait to the day before to call" or that
they "should call farther in advance."

**Findings**

1.  MARTA does not appear to employ trip caps in the operation of its
    ADA Complementary Paratransit service.

2.  MARTA does appear to wait list some trips. Observations suggest that
    as many as 6.5% of all requests might be initially denied. By
    continuing to search for options after riders have been denied
    trips, schedulers appear able to eventually accommodate about 60-70%
    of initial denials.

3.  Reported trip denials appear to be undercounted. Trips that are
    initially denied, but are subsequently scheduled are changed from
    "Capacity Denials" to scheduled trips in the system. Customers who
    are initially denied a trip may make alternate plans because of the
    uncertainty of service and should be accounted for separately. This
    procedure could be considered the equivalent of wait listing trips.

4.  Trip denials also appear to be undercounted by counting denials of
    one leg of a trip by a customer who wishes to make a round trip
    using ADA Complementary Paratransit service, as one rather than two
    "Capacity Denials."

5.  Between July 1999 and August 2001, MARTA denied from 0.1% to 6.3% of
    monthly trip requests and from 0.2% to 13.1% of demand trip
    requests.

6.  MARTA does not appear to have the capacity to provide reliable next
    day service. Eleven of the 29 next day requests observed by
    assessment team members (38%) were initially denied. While
    schedulers continued to look for options and many individuals were
    called back later and offered rides, these observations suggest
    riders cannot be reasonably sure that requests made one day in
    advance will be served.

7.  There appear to be patterns to the trip denials that would make the
    rate for certain requests higher than the system-wide average. The
    denial rate during afternoon and early evening hours appears to be
    1.5-2.6 times higher than the average rate of denial.

**Recommendations**

1.  MARTA should count trip requests that are initially denied and later
    scheduled separately from scheduled trips.

2.  When customers decline one leg of a round trip after being denied
    the other leg of the round trip MARTA should consider each leg of
    the round trip as a "Capacity Denial."

3.  MARTA should increase the number of drivers, runs and, if needed,
    vehicles, to be able to accommodate next day service requests.
    Capacity during the afternoon peak travel time is needed in
    particular.

4.  MARTA should consider developing some "flexible capacity" so that it
    can cost-effectively accommodate the small number of trip denials
    that cannot be cost-effectively served by adding additional runs.
    For example, MARTA could develop subcontracts with existing local
    van companies for the provision of rides on a per trip basis. This
    would probably be a more cost-effective way of meeting the small
    number of daily trip denials than creating additional dedicated 4-8
    hour runs. Over time, additional runs could be created if the number
    and pattern of trips purchased on a per trip basis increases to the
    point where set runs would become efficient.

#  Observations Regarding Service Provision

The regulations for ADA Complementary Paratransit service indicate that
capacity constraints can be created if poor quality service is provided.
Specifically, they note that the provision of untimely trips or
excessively long rides can constitute capacity constraints. On-time
performance and on-board ride times were therefore examined as part of
the assessment. These aspects of service provision were assessed as
follows:

-   Consumer input was obtained through telephone interviews and through
    a review of complaints filed with FTA and with MARTA;

-   MARTA's service policies, procedures, and standards in these areas
    were reviewed;

-   The scheduling and dispatch functions were observed, and schedulers
    and dispatchers were interviewed;

-   Drivers were interviewed about schedules provided and dispatch
    support received;

-   MARTA on-time performance and travel time reports were reviewed;

-   Actual times reported on completed manifests for a randomly selected
    day were tabulated; and

-   Travel times on the MARTA ADA Complementary Paratransit service were
    compared to fixed route travel times for comparable trips.

**Consumer Comments**

All of the riders and agency representatives contacted in preparation
for the assessment cited

on-time performance as a major service issue. The most significant
concern expressed was late pick-ups, particularly during the afternoons.
A few riders also noted that drivers sometimes arrive very early in
order to keep on schedule.

Several riders indicated problems with the scheduling process. They said
that trip times were sometimes changed and they were not notified of the
change. They also said that rides were often added to driver schedules
in the afternoon causing their trip to be late.

Several of the riders contacted also noted that ride times were
excessive. They said that ride times were sometimes more than two hours
long. Again, the afternoons were cited as a problem. The addition of new
riders to the schedules seemed to them to cause rides to be long.

Several of the riders contacted also expressed concerns about missed
trips and no-shows. They indicated that vehicles would not show up, and
when they called dispatch to check on the ride they would be told that
the driver was there and had recorded them as a no-show.

The proper handling of trip reservations was cited as a major issue in
three of the four formal ADA complaints filed by local riders with the
FTA. Three complainants noted that negotiated pick-up times change and
said that call-backs are not made to inform riders of the changed times.
Two people indicated that these problems result in late pick-ups.

One formal complaint filed with the FTA noted long travel times as a
problem. This complaint provided documentation of trips that took over
two and a half hours each way.

Of the 484 recent complaints on file at MARTA that were reviewed as part
of the assessment, 168 (or 35%) relate to on-time performance. Late
pick-ups were the most frequent type of complaint received, accounting
for 149 (or 31%) of all complaints. Nineteen people cited early pick-ups
(4% of all complaints).

In August 2001, MARTA began identifying "changes in trip times without
notice" as a specific category of complaint (this category was not
tracked prior to this time). In August, six of the 65 total complaints
received noted problems with changing trip times.

Missed trips (vehicle no-shows) were also a frequent complaint.
Eighty-two complaints (17% of the total) received over a one-year period
claimed that vehicles had failed to show-up for scheduled pick-ups.

Only three complaints (less than 1% of the total) cited long ride times
as a problem.

**MARTA Service Standards and Policies**

***On-Time Performance Policies and Standards***

MARTA uses a 30-minute pick-up "window" to determine on-time
performance. Pick-ups are considered on time if pick-ups are made from
15 minutes before the time negotiated with the customer to 15 minutes
after the negotiated time.

MARTA's goal is to provide 95% of all scheduled trips on time.

The current on-time performance policy does not address on-time
arrivals.

***Travel Time Policies and Standards***

MARTA has established a ride time service standard that calls for all
trips (100%) to take no more than 90 minutes.

**Observations of Scheduling and Dispatching**

***Scheduling***

MARTA has one lead scheduler and two other support schedulers. The lead
scheduler and one support scheduler, work from 8:30 AM until 5:30 PM.
The third scheduler works from 2:00 PM to 10:00 PM.

Each day, the lead scheduler places subscription trips on runs eight
days in advance and prepares the automated system to begin accepting and
scheduling trips a week in advance. She and the other schedulers then
spend a considerable amount of time handling "unscheduled trips." They
first search existing runs to try to place these trips. If no options
can be found on existing runs, they may create new runs if there are
drivers available. Then, if the requested pick-up times have to be
adjusted, the schedulers call riders to inform them of the new pick-up
time. No callback log is maintained.

Next, the schedulers try to find options for trips that have been
recorded as "capacity denials." If options are developed, the rider is
called and offered the trip. Some riders will accept the offer. Others
may have identified other travel alternatives after initially being
denied the trip and will decline the offer. Again, no callback log is
maintained.

The lead scheduler noted that she often has to use all available
drivers, including draft and extra board drivers to cover the runs
created. This means that, on many days, there is no extra board to cover
same day callouts.

In between placing unscheduled trips and capacity denials, the
schedulers review and "clean-up" the runs created by the automated
reservations and scheduling system. They run a long trip report each day
to identify trips that are scheduled to be on-board for more than 90
minutes. If possible, adjustments are made to lower ride times. They
also constantly scan trips in the system to be sure that all trips have
been "negotiated" and that a negotiated time as well as a requested and
scheduled time is indicated. This protects trip times from being changed
in the automated scheduling process. The late afternoon/evening
scheduler completes the job of reviewing and cleaning-up runs for the
next day of service.

The lead scheduler also noted that the current driver contract does not
call for any breaks during the day. Drivers must take lunch and other
breaks when time is available in their schedule.

***Dispatch***

MARTA has six full-time dispatchers and two part-time dispatcher/drivers
who provide coverage as needed. Dispatch coverage is maintained 24 hours
a day. Most weekdays, there are two dispatchers available during the
morning peak and three during the afternoon peak. One or two dispatchers
provide off-peak coverage. One dispatcher is available during all
weekend hours.

Dispatchers manage and oversee the completion of runs, handle "Where's
my ride?" inquiries, and respond to in service issues and incidents.
They also reassign trips between runs if a run is not covered or if
problems develop on a run.

MARTA separates the handling of "Where's my ride?" calls from regular
dispatch. Two "window dispatchers," who are located in a room adjacent
to the main dispatch room, take "Where's my ride?" calls and request
estimated times of arrival from the full dispatchers. The "window
dispatchers" also check-in and check-out drivers and provide them with
manifests. These two staff people also are responsible for
reconciliation of completed manifests and enter information from
completed manifests into the Trapeze system.

Dispatchers noted that little if any extra board remains on the day of
service to cover driver absences. They also noted problems with coverage
of afternoon runs given the latest driver pick. Dispatchers indicated
that they typically must reassign trips on uncovered runs and add them
to existing runs. It is not unusual to have to "split-up" and reassign
trips on up to four scheduled afternoon runs.

Drivers do not typically call-in every pick-up and drop-off. They
contact dispatch if they have a problem or if they see problems
developing on the schedule. Dispatchers therefore rely on drivers and
"Where's my ride?" calls to identify problems. During peak hours,
dispatchers are often distracted by trip reassignments and are unable to
remain as current on the status of all runs as they would like.

Dispatchers also noted that because drivers do not have scheduled breaks
during the day, adding trips during downtime sometimes causes friction.
Drivers look at downtime as their opportunity for a break. If
dispatchers fill this time, they may go through the day without
reasonable breaks. It was also noted that some drivers will show up
early for one trip and late for a subsequent trip in order to create
break time in the schedule.

It was noted that the manifests provided to drivers only indicate the
estimated pick-up time generated by the automated scheduling system. The
manifests do not show the pick-up time negotiated with the riders or the
pick-up window within which the driver should perform the trip. It was
noted that the negotiated time and the pick-up window used to be shown
on the manifest but that it was recently removed. Managers felt that
some of the drivers were using the "window" information to create break
time.

**Driver Interviews**

Interviews were conducted with several drivers. Drivers were asked about
the feasibility of the schedules provided and about dispatch support.
Most drivers indicated that schedules are very tight and that as the day
progresses they will begin to run behind schedule. They confirmed that
there are typically a lot of add-ons throughout the day, particularly in
the afternoon and that these add-ons can cause on-time performance
problems.

The majority of drivers also noted that they liked having the on time
"window" on the manifest. They said that pick-up times are changed in
scheduling and that the time they get is often inconsistent with the
pick-up times that riders note they were given.

Drivers also noted that dispatch support is spotty. Adequate support is
provided by dispatchers some of the time, but is not consistent.

**Reported On-Time Performance**

MARTA records negotiated and actual pick-up times for all trips.
Negotiated pick-up times (pick-up times given to riders) are created in
the reservations and scheduling process and are captured and maintained
in the Trapeze system as trips are booked and as scheduled runs are
created. Drivers manually record actual pick-up times on run manifests.
Staff then enters actual pick-up times from completed run manifests into
the Trapeze system. Other information recorded by drivers on the run
manifests (no-shows, cancellations, etc.) is also checked against
information in the system to develop a final record for each trip
scheduled.

MARTA then runs daily and monthly reports that calculate on-time
performance from the trip data entered into the Trapeze system. These
reports tabulate the number and percentage of completed trips that had
actual pick-ups no more than 15 minutes before and no more than 15
minutes after the negotiated time.

Table 6 below shows on-time performance reported by MCTS for the period
from January through August 2001. As shown, systemwide on-time
performance was between 82.6% and 92.0% for this time period.

**Table 6. MARTA Reported On-Time Performance,**

**January-August, 2001**

  --------------------------------- -------------------------------------
  **Month**                         **Reported Average On-Time
                                    Performance**

  January, 2001                     91.8%

  February                          92.0%

  March                             91.1%

  April                             92.0%

  May                               90.6%

  June                              85.4%

  July                              82.6%

  August                            84.5%
  --------------------------------- -------------------------------------

Reported on-time performance was between 90.6% and 92.0% from January
through May. A significant drop in performance was noted from June
through August. MARTA staff indicated that this drop was due to efforts
to try to lower trip denials. This effort was made without additional
driver positions or resources. As a result, trips that were formerly
denied were scheduled onto runs covered by back-up drivers. Trips were
also squeezed into existing runs.

"Daily Service Summaries" for June, July, and August 2001 are provided
in Attachment F. These summaries show on-time performance by day for
these months. As these summaries show, there were several days when
on-time performance fell below 80% and on-time performance as low as
73.6% (on Monday, July 9, 2001) was recorded. In June, four of the 30
operating days showed on-time performance below 80%. In July, on-time
performance was below 80% on nine days. And in August, there were three
days when on-time performance was reported to be below 80%.

**Calculated On-Time Performance for a Sample Day**

The assessment team reviewed the accuracy of on-time performance
reported by MARTA by calculating on-time performance from the original
run manifests for one randomly selected day -- Wednesday, May 23, 2001.
Only pickup times were reviewed, since MARTA typically does not report
on-time arrivals. The assessment team recorded rides as being early, on
time or late according to MARTA's 30-minute pick-up window.

For May 23, the assessment team analyzed the negotiated and actual
pickup times for 667 rides. The results of the analysis are presented in
Table 7 below. As shown, 89.4% of all pick-ups were made either early or
on time. A total of 10.6% of all trips were late, with the majority of
late trips being 1-15 minutes after the pick-up window. About 3.3% of
all pick-ups were 16-30 minutes late and only one pick-up (0.1%) was
recorded as more than 30 minutes late.

These results were then compared to the on-time performance reported by
MARTA (see May Daily Service Report in Attachment F). The reported
on-time performance for this day was 89.3%, which suggests that the data
reconciliation and reporting by MARTA is representative of the
information recorded on the manifests.

**Table 7. Calculated On-Time Performance from Original Manifests**

May 23, 2001

  -------------------------------------- ---------------- ----------------
                                         Number of Trips  Percentage

  31 or more minutes before the pick-up  3                0.5%
  window                                                  

  16-30 minutes before the pick-up       19               2.9%
  window                                                  

  1-15 minutes before the pick-up window 123              18.4%

  Within the on-time window (15 minutes  451              67.6%
  before to 15 minutes after the                          
  negotiated time)                                        

  1-15 minutes after the pick-up window  48               7.2%

  16-30 minutes after the pick-up window 22               3.3%

  31 or more minutes after the pick-up   1                0.1%
  window                                                  

  TOTALS                                 667              100%
  -------------------------------------- ---------------- ----------------

While pick-ups made early were considered on time (as many riders might
be ready early and may even call for an earlier pick-up), it is worth
noting that over 30% of all pick-ups were made early. This suggests that
drivers are routinely making pick-ups before the window. It is likely
that some early pick-ups are made so that drivers can perform all trips
on time. Some early

pickups could also be made to create break times in their runs.

###### ADA Complementary Paratransit Travel Times {#ada-complementary-paratransit-travel-times .unnumbered}

As noted above, MARTA has adopted a goal of performing all ADA
Complementary Paratransit trips in 90 minutes or less. Special data
tabulations of rides, which took more than 90 minutes to complete, were
prepared for the assessment team by MARTA staff. These special reports
were run for the months of March through July 2001 as well as for August
1-13, 2001, the most recent period that was reconciled. A copy of the
August 1-13 report is provided as Attachment G.

These reports were then used to determine the percentage of trips with
travel times of more than 90 minutes and also to assess the distribution
of travel times for long trips for the August 1-13, 2001 period. Table 8
below shows the percentage of trips that exceeded 90 minutes for the
months of March through August 2001. Table 9 shows the distribution of
trips by travel time for August 1-13, 2001.

As shown, an average of 3.4% of all trips provided took more than 90
minutes to complete during the period from March 1 to August 13, 2001.
The percentage of long trips also increased significantly in June, July,
and August. Again, this appears to be due to efforts to minimize trip
denials without increasing driver capacity. In June, about 4.6% of all
trips took more than 90 minutes to complete.

**Table 8. ADA Complementary Paratransit Trips Taking More than 90
Minutes,**

**March -- August, 2001**

  ----------------- ----------------- ----------------- -----------------
  **Month**         **Total Trips     **Trips Longer    **% of Trips
                    Provided**        than 90 Minutes** Longer than 90
                                                        Minutes**

  March, 2001       14,924            508               3.4%

  April             14,299            436               3.0%

  May               15,134            541               3.6%

  June              15,135            702               4.6%

  July              14,821            599               4.0%

  August 1-13       6,333             276               4.4%

  **TOTALS**        **80,646**        **3,062**         **3.4%**
  ----------------- ----------------- ----------------- -----------------

Table 9. Distribution of Travel Times for August 1-13, 2001

  ----------------------- ---------------------- ------------------------
  **Travel Time**         **Total Trips**        **Percentage of Trips**

  90 minutes or less      6,057                  95.6%

  91-120 minutes          216                    3.4%

  121-150 minutes         50                     0.8%

  151 or more minutes     10                     0.2%

  **TOTALS**              **6,333**              **100.0%**
  ----------------------- ---------------------- ------------------------

As shown in Table 9, most long trips have travel times of between 91 and
120 minutes. From August 1-13, 2001, however, there were 60 trips that
took more than two hours and 10 that were longer than two and a half
hours. The longest ride recorded for this period was 165 minutes.

**Comparison of ADA Complementary Paratransit and Fixed Route Travel
Times**

A sample of 24 trips was drawn from the 276 trips included in the Long
Rides report generated by MARTA for the period August 1-13, 2001. The
sample trips were distributed as follows: 10 trips from 0 to 15 miles
(short), 10 trips from 16 to 30 miles (medium), and 4 trips more than 30
miles (long). An attempt was made to select trips from various
geographic areas. Trip distances were based on map longitude/latitude
points (straight line distance) multiplied by a factor of 1.22 to
account for driving distance (calculated by MARTA staff).

Using actual ADA Complementary Paratransit trip origin and destination
data, the estimated fixed route travel times were calculated based on
trip itineraries generated by MARTA's Customer Service Center staff. The
fixed route itineraries include the elapsed time required to travel on
required buses and/or trains (including transfer time) that would be
used to complete the same trip on fixed route during the same time of
day and day of week. Twenty minutes were added to that time to account
for walking to/from the fixed route stops and wait times. The actual ADA
Complementary Paratransit travel times were calculated from information
recorded by the drivers on the manifest (time departing from pick-up to
arrival time at the drop-off). The scheduled ADA Complementary
Paratransit times included in parentheses, indicate the estimated travel
time calculated by the computer for each ADA Complementary Paratransit
trip.

Table 10 on the following pages shows the results of this analysis.
Rides with significantly longer ADA Complementary Paratransit travel
times are shaded in the table. Of the 10 short trips analyzed, 4 ADA
Complementary Paratransit trips were actually shorter than the estimated
travel time for comparable fixed route trips, 2 were slightly longer,
and 4 trips were more than 30 minutes longer on ADA Complementary
Paratransit when compared to fixed route. For the medium-length trips,
the table shows that of the 10 trips analyzed, 2 were shorter, 1 was
less than 30 minutes longer, and 7 were more than 30 minutes longer on
ADA Complementary Paratransit when compared to fixed route, ranging from
38 to 83 minutes longer. Finally, for the 4 long trips analyzed, the
table shows 2 of those trips were shorter and 2 were less than 30
minutes longer.

A more detailed analysis of long ride times suggests that 5 of the trips
with long travel times (#3, #9, #11, #16, #17) were originally scheduled
to be much shorter, but appear to have been reassigned to other
vehicles, which resulted in longer travel times. Two of the trips (#19,
#24) were actually shorter than originally scheduled (143 minutes and
128 minutes respectively). Additionally, with one exception (#3), ride
times for the shorter trips were reasonably comparable to fixed route.
The same is true for trips in the long category, all of which were
within 30 minutes of a comparable fixed route trip. However, long ride
times appears to be a problem in the medium-length trips, with 7 out of
10 being more than 30 minutes longer and as much as 83 minutes longer
than the comparable fixed route trips. All but one of those trips were
in excess of 2 hours (120 minutes).

Table 10. Comparison of ADA Complementary Paratransit and Fixed Route
Travel Times for 24 Selected Trips

+-----+------+---------------+-----+------------+-----+--------------+
| **T | **Da | **Origin /    | **D | **Actual** | **  | **Difference |
| rip | te** | Destination** | ist |            | Est | ADA          |
| \#  |      |               | anc | **(vs.     | ima | C            |
| /   | **/  |               | e** | Sc         | ted | omplementary |
| Ro  | Ti   |               |     | heduled)** | FR  | P            |
| ute | me** |               | **  |            | Tra | aratransit** |
| \   |      |               | (mi | **ADA      | vel |              |
| #** |      |               | les | Com        | Tim | **- Fixed    |
|     |      |               | )** | plementary | e** | Route Travel |
|     |      |               |     | P          |     | Time         |
|     |      |               |     | aratransit | *   | (minutes)**  |
|     |      |               |     | Travel     | *(m |              |
|     |      |               |     | Time       | inu |              |
|     |      |               |     | (          | tes |              |
|     |      |               |     | minutes)** | )** |              |
+=====+======+===============+=====+============+=====+==============+
| #1  | 8/0  | 2500 Hospital | 3   | 17         | 49  | -32          |
| pu  | 3/01 | Blvd          |     |            |     |              |
|     |      |               |     | \(26\)     |     |              |
| Ro  | 4    | 200 High      |     |            |     |              |
| ute | :01p | Creek Dr      |     |            |     |              |
| 549 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #2  | 8/1  | 4400 Ashford  | 6   | 105        | 71  | 34           |
| pu  | 1/01 | Dunwoody Dr   |     |            |     |              |
|     |      |               |     | \(103\)    |     |              |
| Ro  | 6    | 2400 E Club   |     |            |     |              |
| ute | :45p | Dr NE         |     |            |     |              |
| 611 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #3  | 8/   | 000 Butler St | 7   | 120        | 60  | 60           |
| pu  | 2/01 |               |     |            |     |              |
|     |      | 700 Atlanta   |     | \(60\)     |     |              |
| Ro  | 12   | Ave           |     |            |     |              |
| ute | :45p |               |     |            |     |              |
| 426 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #4  | 8/1  | 1800 S Ponce  | 8   | 100        | 64  | 36           |
| pu  | 0/01 | de Leon Ave   |     |            |     |              |
|     |      | SE            |     | \(95\)     |     |              |
| Ro  | 3    |               |     |            |     |              |
| ute | :15p | 600 Reed St   |     |            |     |              |
| 541 |      | SE            |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #5  | 8/1  | 1800 Montreal | 8   | 108        | 85  | 23           |
| pu  | 3/01 | Rd            |     |            |     |              |
|     |      |               |     | \(109\)    |     |              |
| Ro  | 5    | 1700 S        |     |            |     |              |
| ute | :39p | Columbia Pl   |     |            |     |              |
| 159 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #6  | 8/   | 000 Peachtree | 9   | 32         | 41  | -9           |
| pu  | 3/01 | Park Dr NE    |     |            |     |              |
|     |      |               |     | \(32\)     |     |              |
| Ro  | 3    | 200 Booker St |     |            |     |              |
| ute | :36p | SW            |     |            |     |              |
| 561 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #7  | 8/   | 500 Amal Dr   | 9   | 90         | 86  | 4            |
| pu  | 6/01 | SW            |     |            |     |              |
|     |      |               |     | \(98\)     |     |              |
| Ro  | 12   | 2800          |     |            |     |              |
| ute | :00p | Greenbriar    |     |            |     |              |
| 143 |      | Pky SW        |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #8  | 8/   | 700 Atlanta   | 11  | 52         | 53  | -1           |
| a   | 5/01 | Ave           |     |            |     |              |
| ppt |      |               |     | \(51\)     |     |              |
|     | 9    | 1000          |     |            |     |              |
| Ro  | :30a | Washington St |     |            |     |              |
| ute |      | SW            |     |            |     |              |
| 706 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #9  | 8/   | 3100          | 11  | 103        | 69  | 34           |
| pu  | 1/01 | Clairmont Rd  |     |            |     |              |
|     |      | NE            |     | \(25\)     |     |              |
| Ro  | 2    |               |     |            |     |              |
| ute | :41p | 700 N Indian  |     |            |     |              |
| 376 |      | Creek Rd      |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #10 | 8/1  | 2300 Godby Rd | 12  | 20         | 55  | -35          |
| a   | 2/01 |               |     |            |     |              |
| ppt |      | 800 Cascade   |     | \(40\)     |     |              |
|     | 9    | Ave SW        |     |            |     |              |
| Ro  | :30a |               |     |            |     |              |
| ute |      |               |     |            |     |              |
| 772 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #11 | 8/   | 000 Collier   | 16  | 85         | 60  | 25           |
| pu  | 3/01 | Rd NW         |     |            |     |              |
|     |      |               |     | \(41\)     |     |              |
| Ro  | 3    | 1900 Dodson   |     |            |     |              |
| ute | :15p | Dr SW         |     |            |     |              |
| 561 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #12 | 8/1  | 3500 Piedmont | 17  | 146        | 62  | 84           |
| pu  | 0/01 | Rd NE         |     |            |     |              |
|     |      |               |     | \(147\)    |     |              |
| Ro  | 3    | 300 Maple St  |     |            |     |              |
| ute | :15p |               |     |            |     |              |
| 571 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #13 | 8/   | 5700 Hampton  | 20  | 110        | 51  | 59           |
| a   | 7/01 | Ct            |     |            |     |              |
| ppt |      |               |     | \(102\)    |     |              |
|     | 8    | 000 Forsyth   |     |            |     |              |
| Ro  | :15a | SW            |     |            |     |              |
| ute |      |               |     |            |     |              |
| 225 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #14 | 8/   | 1800 Southern | 20  | 132        | 65  | 67           |
| pu  | 2/01 | Ln            |     |            |     |              |
|     |      |               |     | \(119\)    |     |              |
| Ro  | 3    | 1800 Wellborn |     |            |     |              |
| ute | :20p | Rd            |     |            |     |              |
| 439 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #15 | 8/   | 2200          | 21  | 60         | 86  | -26          |
| pu  | 2/01 | Campbelltown  |     |            |     |              |
|     |      | Rd SW         |     | \(62\)     |     |              |
| Ro  | 12   |               |     |            |     |              |
| ute | :00p | 2500          |     |            |     |              |
| 426 |      | Snapfinger Dr |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #16 | 8/   | 1000 Brady    | 21  | 125        | 87  | 38           |
| pu  | 9/01 | Ave NW        |     |            |     |              |
|     |      |               |     | \(30\)     |     |              |
| Ro  | 5    | 5300 Ridge    |     |            |     |              |
| ute | :00p | Forest Dr     |     |            |     |              |
| 440 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #17 | 8/   | 1600 Weymouth | 21  | 155        | 105 | 50           |
| a   | 3/01 | St            |     |            |     |              |
| ppt |      |               |     | \(90\)     |     |              |
|     | 9    | 2100 Marietta |     |            |     |              |
| Ro  | :00a | Blvd NW       |     |            |     |              |
| ute |      |               |     |            |     |              |
| 501 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #18 | 8/   | 3300 Piedmont | 25  | 139        | 67  | 72           |
| pu  | 8/01 | Rd NE         |     |            |     |              |
|     |      |               |     | \(139\)    |     |              |
| Ro  | 3    | 2500 Barge Rd |     |            |     |              |
| ute | :15p | SW            |     |            |     |              |
| 381 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #19 | 8/   | 3000 Howell   | 25  | 86         | 104 | -18          |
| pu  | 3/01 | Mill Rd NW    |     |            |     |              |
|     |      |               |     | \(143\)    |     |              |
| Ro  | 3    | 1100 Allgood  |     |            |     |              |
| ute | :10p | Rd            |     |            |     |              |
| 569 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #20 | 8/   | 800 Park      | 27  | 143        | 80  | 63           |
| pu  | 9/01 | North Blvd    |     |            |     |              |
|     |      |               |     | \(147\)    |     |              |
| Ro  | 2    | 400 Fairburn  |     |            |     |              |
| ute | :30p | Rd SW         |     |            |     |              |
| 469 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #21 | 8/   | 3600 MLK Dr   | 32  | 106        | 96  | 10           |
| pu  | 2/01 |               |     |            |     |              |
|     |      | 5500 Lucille  |     | \(110\)    |     |              |
| Ro  | 4    | Ave           |     |            |     |              |
| ute | :45p |               |     |            |     |              |
| 443 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #22 | 8/   | 1800 James    | 35  | 130        | 100 | 30           |
| pu  | 6/01 | Jackson Pky   |     |            |     |              |
|     |      | NW            |     | \(134\)    |     |              |
| Ro  | 3    |               |     |            |     |              |
| ute | :30p | 5200 Panola   |     |            |     |              |
| 138 |      | Mill Rd       |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #23 | 8/1  | 1000          | 37  | 134        | 140 | -6           |
| pu  | 3/01 | Northfield Ct |     |            |     |              |
|     |      |               |     | \(134\)    |     |              |
| Ro  | 3    | 4700          |     |            |     |              |
| ute | :30p | Briarbend     |     |            |     |              |
| 173 |      | Trace         |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+
| #24 | 8/   | 3000 Flat     | 45  | 84         | 113 | -29          |
| a   | 2/01 | Shoals Rd     |     |            |     |              |
| ppt |      |               |     | \(128\)    |     |              |
|     | 9    | 4400 Sarr Pky |     |            |     |              |
| Ro  | :00a |               |     |            |     |              |
| ute |      |               |     |            |     |              |
| 419 |      |               |     |            |     |              |
+-----+------+---------------+-----+------------+-----+--------------+

**appt** = appointment time for going trips; pu = pick-up time for
return trips; Origin/Destination addresses rounded to nearest 100 block;
Distance calculated by multiplying the air distance by 1.22 (calculated
by MARTA staff); Actual ADA Complementary Paratransit Travel Time
calculated from driver manifests based on time leaving pick-up to time
arriving drop-off as recorded by the driver; Scheduled ADA Complementary
Paratransit Travel Time calculated from Long Rides report (prepared by
MARTA staff); Estimated FR Travel Time based on trip itineraries for
comparable trips at comparable days and times (generated by Customer
Service Center staff) + 20 minutes travel time to/from stop.

**Findings**

1.  MARTA appears to be using drafted and extra board drivers to cover
    regular runs created to accommodate trip requests. This causes a
    shortage of extra board drivers to cover call-outs on the day of
    service.

2.  Without adequate driver back-up capability, runs are regularly
    "split-up" on the day of service and trips are reassigned to covered
    runs. These add-ons on the day of service appear to negatively
    affect on-time performance and ride times.

3.  Scheduler time appears to be diverted away from a thorough review of
    all runs and creation of the best possible schedules by the constant
    need to handle "unscheduled trips" and "capacity denials."

4.  Schedulers do not maintain a log of callbacks to riders when
    negotiated pick-up times are changed. It is therefore not possible
    to confirm that riders are notified of time changes.

5.  Dispatchers appear to spend a significant amount of time reassigning
    trips from uncovered runs, which may be distracting them from
    proactively managing drivers. With little or no back-up service
    capacity, though, there are often no other options for proactively
    handling same day problems and issues.

6.  Drivers are not given scheduled breaks. As a result, it appears that
    some drivers may perform some trips early and the next trip late in
    order to create break times in their runs.

7.  Poor on-time performance appears to be a capacity constraint in the
    MARTA ADA Complementary Paratransit service. In July and August
    2001, on-time performance was below 85% for the month. On-time
    performance was below 80% for 12 days during this two-month period.
    Poor on-time performance appears to be related to efforts to
    minimize trip denials without adding additional driver and service
    capacity.

8.  Some ADA Complementary Paratransit trips appear to be excessively
    long. Of the 24 long trips analyzed in detail, 13 appeared to have
    significantly longer travel times by ADA Complementary Paratransit
    than by fixed route. The most frequent ADA Complementary Paratransit
    ride time issues appear to be related to medium length trips (16-30
    miles long) rather than the longest trips in the system.

**Recommendations**

1.  MARTA should develop adequate driver and service capacity to meet
    trip demand without using extra board drivers to cover regularly
    scheduled runs. An adequate number of extra board drivers should be
    available on the day of service to cover driver absences as well as
    issues that develop throughout the day.

2.  MARTA also needs to program enough runs in the system to avoid
    having so many "unscheduled trips." This would allow schedulers to
    focus on reviewing runs on an ongoing basis and creating more
    workable schedules.

3.  With additional runs in the system, MARTA should then work to
    minimize excessively long ADA Complementary Paratransit trips.
    Schedulers should then have the ability to re-route any rides that
    appear to be excessively long.

4.  With an adequate extra board, dispatchers should then be able to
    focus on proactively tracking all runs on an ongoing basis. We
    recommend that MARTA work toward a dispatch system that would have
    all drivers calling in all pick-ups and drop-offs so that
    dispatchers are aware of the status of all runs at all times.

5.  With better dispatch control, we would recommend that MARTA include
    pick-up window information (or negotiated pick-up times) as well as
    computer generated estimated times on driver manifests. This
    additional information will allow drivers and riders to be "on the
    same page" in terms of expected vehicle arrival times.

6.  MARTA should begin keeping a log of callbacks to riders when
    negotiated pick-up times are changed.

7.  MARTA should consider revising its travel time standard to more
    accurately reflect comparability between fixed route and ADA
    Complementary Paratransit trips. A standard that calls for ADA
    Complementary Paratransit trips to not be significantly longer than
    comparable fixed route trips, considering both fixed route on-board
    times and an allowance for getting to and from stops/stations, is
    suggested. MARTA should compare long ADA Complementary Paratransit
    ride times to fixed route travel times using a methodology similar
    to that used in this assessment. For example MARTA might consider a
    travel time standard of scheduled fixed route travel time between
    stops nearest the ADA Complementary Paratransit trip origin and
    destination, plus 20 or 30 minutes to allow for travel to and from
    the stop. The analysis should focus on ADA Complementary Paratransit
    trips with long scheduled ride times.

# Resources and Overall Level of Service

Information about resources available to provide the ADA Complementary
Paratransit service was collected and reviewed as part of the
assessment. This included information about the number and type of
vehicles available, the number of personnel in each part of the
operation, and the operating budget for the service. It also included a
review of the training program for operators. Findings in each of these
areas are presented below.

The number of individuals served by the ADA Complementary Paratransit
program, and the number of trips provided were also compared to systems
in other major urbanized areas.

**Fleet**

MARTA has a fully accessible fleet of vehicles consistent with the needs
of ADA Complementary Paratransit service. All vehicles are
body-on-chassis minibuses that are able to accommodate three passengers
using wheelchairs as well as several ambulatory riders. All vehicles are
lift-equipped.

At the time of the assessment, the fleet consisted of 94 active
vehicles. This included fifty 1998 model year vehicles and forty-four
2001 model year vehicles. All vehicles had moderate or low mileage.

On a typical weekday, about 81-83 runs are scheduled. A maximum of about
60 vehicles are needed to cover these runs.

**Personnel**

Availability of operators appears to be a major constraint to the
service. There are a total of 85 full-time operator positions and 34
part-time positions currently authorized. This number has remained the
same since FY97 when MARTA brought the service in-house. Of the 119
operator positions authorized, only 90-100 operators were actually
available for duty the week of the assessment. Several operators were on
long-term leave and 9 positions were vacant.

With vacations, same day call outs and other absences, there are
typically not enough operators to cover scheduled runs. Table 11 below
shows the "Daily Operator Compliment" records for Monday, August 20,
through Thursday, August 23. As shown, there were 73-83 runs scheduled
on these days and only 69-75 "straight time" operators available. As a
result, MARTA uses extra board operators, drafted operators, and even
road supervisors to cover scheduled runs. Several of the drafted
operators are typically double-shifting and working 13-14 hour days. As
a result, there are often not enough extra board operators to cover same
day call-outs or same day service issues.

**Table 11. Daily Operator Compliment, August 20-23, 2001**

+----------------------------+---------+---------+---------+---------+
|                            | **M     | **Tu    | **Wedn  | **Thu   |
|                            | onday** | esday** | esday** | rsday** |
|                            |         |         |         |         |
|                            | **Aug.  | **Aug.  | **Aug.  | **Aug   |
|                            | 20**    | 21**    | 22**    | 23**    |
+----------------------------+---------+---------+---------+---------+
| Scheduled to Work          | 96      | 95      | 99      | 91      |
+----------------------------+---------+---------+---------+---------+
| Out for Various Reasons    | \(21\)  | \(26\)  | \(25\)  | \(20\)  |
+----------------------------+---------+---------+---------+---------+
| Available "Straight Time"  | 75      | 69      | 74      | 71      |
| Operators                  |         |         |         |         |
+----------------------------+---------+---------+---------+---------+
| Runs Scheduled             | 81      | 73      | 83      | 81      |
+----------------------------+---------+---------+---------+---------+

It was noted that there are typically vacant ADA Complementary
Paratransit operator positions even though MARTA is constantly hiring
and training new operators. This is because the service sees moderate
turnover (about 46% a year) and because many operators do not complete
the training program. For example, if there are 10 vacancies, a maximum
of 10 new operators can be hired to begin the training program. If only
5-7 of these operators complete the month-long training program, 3-5
original positions remain vacant, and another 4-5 vacancies may develop
during the month of training due to regular turnover. ADA Complementary
Paratransit operators moving into fixed route positions that become
available causes some of the turnover. ADA Complementary Paratransit
operators receive \$8.40 to \$12.30 per hour and fixed route operators
receive \$13.43 to \$17.00 per hour.

As noted earlier in this report, there are five authorized ADA
Complementary Paratransit call taker positions and one reservations
supervisor. This level of staffing was adequate to handle all trip
request calls when the reservations office was open 8 AM to 5 PM on
weekdays, but is not adequate to cover the new weekday hours of 8 AM to
10 PM implemented in March 2000. To cover the extended hours, two
reservationists were rescheduled to afternoon/evening shifts. Only three
reservationists are now available during the peak morning call times.

There are three schedulers (a lead scheduler and two other schedulers).
This level of staffing would normally be adequate to handle the 73-83
weekday runs that are operated. However, much of the schedulers' time is
spent reassigning trips from runs that are not covered due to a shortage
of available operators. Under the current circumstances, not enough time
can be spent cleaning up runs on an ongoing basis to ensure that runs
are as efficient as possible.

There are six full-time dispatchers and two part-time
driver/dispatchers. At peak operating hours there are three dispatchers
on duty. At slower weekday times there are two dispatchers. On weekends
and during early morning hours on weekdays there is one dispatcher on
duty. This level of staffing appears adequate for the number of runs
operated. Again, however, dispatchers spend a lot of time reassigning
trips from uncovered runs caused by same day operator call-outs and the
lack of an extra board. As a result, they are not always able to be as
proactive in the management of runs as is ideal.

**Operator Training**

MARTA ADA Complementary Paratransit operators go through an intensive
31-day training program. The major elements of the training are listed
below:

**Days 1-3:** "Orientation Express," which includes a general
introduction to MARTA. Classes on customer service, safety, security,
and sexual harassment are also included.

**Day 4:** Training on the Americans with Disabilities Act, which covers
the regulatory requirements, disability awareness and sensitivity, and
an introduction to accessibility features of vehicles and wheelchair
securement. This segment is taught in part by a person with a disability
who is employed by the MARTA ADA Complementary Paratransit program.

**Day 5:** Review of ADA Complementary Paratransit and MARTA policies
and procedures, and rules and regulations. The employee handbook is
reviewed and the map book is provided and reviewed.

**Days 8-18:** Each day has four hours of classroom training focused on
defensive driving, map reading and familiarization with the city,
handling and reporting incidents and accidents, manifest reading and
trip planning, radio procedures, and additional training in wheelchair
securement. Another four hours is spent each day on the road in
non-revenue operation with a trainer.

**Days 19-24:** Behind the wheel training in revenue service

**Day 25:** Review day

**Days 26-30:** Continued behind the wheel training in revenue service

**Day 31:** Final exam

In total, operators receive 10 ½ days of classroom instruction, 4 ½ days
of on-road non-revenue vehicle operation, and 11 days of behind the
wheel training in revenue service. The training includes disability
awareness with instruction by a person who has a disability, several
hours of instruction in the use of accessibility equipment, and several
days of actual experience (while being observed) of use of accessibility
equipment.

**Budget**

The process used to develop the ADA Complementary Paratransit budget was
reviewed with MARTA staff. Worksheets used to prepare the 2002 budget
were also reviewed.

As indicated by staff, the labor portions of budgets are developed based
on the number of approved positions in each functional area. The number
of positions in each category is multiplied by the wage rates. Fringe
benefits and other labor-related costs are then added.

For ADA Complementary Paratransit, the budget has been based on the same
119 approved operator positions and other office positions, which have
been fixed since FY97. There have been increases in overtime allowances
in recent years, as the ADA Complementary Paratransit program has had to
double-shift operators and draft operators to work on their scheduled
days off.

The non-labor portion of the budget is developed based on actual costs
from prior years. Projected miles of operation and fleet age are
considered in developing fuel and maintenance cost estimates. Allowances
are also made for projected inflationary increases.

Table 12 below shows budgeted and actual costs for the ADA Complementary
Paratransit program for FY99-01. It also shows the ADA Complementary
Paratransit budget for FY02. For comparison, total MARTA operating costs
for FY99-01 and budgeted costs for all operations for FY02 are also
included. Finally, key service information such as the number of
approved operator positions, overtime costs, total vehicle
revenue-hours, total one-way trips, and trips denied are provided.

As shown, total ADA Complementary Paratransit expenses increased about
9% a year between FY99 and FY01. The total MARTA operating budget
increased a similar amount (about 10% between FY99 and FY00 and another
7% between FY00 and FY01. The ADA Complementary Paratransit budget for
FY02 is about 8% above FY01 actual expenses. MARTA increased its FY02
total operating budget by only about 0.6% over FY01 actual expenses.

**Table 12. Budget, Actual Cost, and Service Information, FY99-FY02**

+-----------------------+-----------+-----------+-----------+-----------+
|                       | **FY99**  | **FY00**  | **FY01**  | **FY02**  |
+-----------------------+-----------+-----------+-----------+-----------+
| Total MARTA Operating | \$29      | \$32      | \$34      | \$34      |
| Expenses              | 6,071,482 | 4,766,262 | 7,769,859 | 9,845,306 |
|                       |           |           |           |           |
|                       |           |           |           | budgeted  |
+-----------------------+-----------+-----------+-----------+-----------+
| Total ADA             | \$        | \$        | \$        | \$        |
| Complementary         | 6,518,387 | 7,118,788 | 7,738,125 | 8,366,548 |
| Paratransit Operating |           |           |           |           |
| Expenses              |           |           |           | budgeted  |
+-----------------------+-----------+-----------+-----------+-----------+
| Approved ADA          | 119       | 119       | 119       | 119       |
| Complementary         |           |           |           |           |
| Paratransit Operators |           |           |           |           |
+-----------------------+-----------+-----------+-----------+-----------+
| ADA Complementary     | \$345,187 | \$505,360 | \$551,185 | NA        |
| Paratransit Overtime  |           |           |           |           |
| Expenses              |           |           |           |           |
+-----------------------+-----------+-----------+-----------+-----------+
| ADA Complementary     | 120,671   | 121,173   | 138,247   | NA        |
| Paratransit           |           |           |           |           |
| Revenue-Hours         |           |           |           |           |
+-----------------------+-----------+-----------+-----------+-----------+
| One-Way ADA           | 149,260   | 151,571   | 166,858   | NA        |
| Complementary         |           |           |           |           |
| Paratransit Client    |           |           |           |           |
| Trips Provided        |           |           |           |           |
+-----------------------+-----------+-----------+-----------+-----------+
| ADA Complementary     | 1,034     | 3,360     | 3,132     | NA        |
| Paratransit Trips     |           |           |           |           |
| Denied                |           |           |           |           |
+-----------------------+-----------+-----------+-----------+-----------+
| Expressed Demand for  | 150,094   | 154,931   | 169,990   | NA        |
| ADA Complementary     |           |           |           |           |
| Paratransit Trips     |           |           |           |           |
+-----------------------+-----------+-----------+-----------+-----------+

MARTA budget staff noted that the increases in ADA Complementary
Paratransit expenses have been largely due to inflationary cost
increases and increases in fringe benefit costs. As noted earlier, the
number of approved ADA Complementary Paratransit operator positions has
remained constant at 119 throughout this period. Overtime expenses have
increased from \$345,187 in FY99 to \$551,185 in FY01. The number of
revenue-hours of ADA Complementary Paratransit service remained almost
constant from FY99 to FY00. Revenue-hours increased by 14% between FY00
and FY01 even though the number of operator positions was unchanged.
Staff reported that this was accomplished through the use of overtime
operators and the use of extra board operators and road supervisors on
scheduled runs.

Demand for the service appears to have exceeded the supply throughout
this period. Between FY99 and FY00, MARTA accommodated only a 1.5%
increase in ADA Complementary Paratransit ridership. The number of trip
denials, however, tripled, from 1,034 in FY99 to 3,360 in FY00. Between
FY00 and FY01, ridership increased by 10%, but 3,132 trip requests were
still denied.

MARTA budget staff indicated that trip denials, latent demand, and
potential increases in demand are not considered in the development of
the ADA Complementary Paratransit budget. As noted above, the budget is
largely based on personnel costs given the number of approved positions
in each area.

The current General Superintendent of ADA Complementary Paratransit
indicated that he has recently requested additional operator positions.
He estimated that about 15 additional operator positions could be
supported by the current overtime budget. Because these operators would
be paid straight time, additional revenue-hours could be operated for
the same amount of money.

**Overall Level of Service**

As noted in the eligibility section, only 2,811 persons were registered
for the MARTA ADA Complementary Paratransit service at the time of the
assessment. These riders were making only 600-700 one-way trips per
weekday.

Compared to other major urbanized areas, these registration and
trip-making rates are very low. Table 13 below provides rider and
ridership information for selected urbanized areas similar in size to
Atlanta. The total population of these areas is shown and the percent of
residents registered for the service is calculated. The number of trips
per capita per year is also calculated. As shown, the percentage of the
population registered for ADA Complementary Paratransit service ranged
from 0.6-1.6% for the other selected systems. In Atlanta, only 0.2% of
the population has registered for the ADA Complementary Paratransit
service. The number of trips provided per year per capita ranged from
.294 to .625 for the other cities shown. In Atlanta, only .134 trips per
year per capita are provided.

While the high ADA Complementary Paratransit fare in Atlanta (twice the
typical ADA Complementary Paratransit fare) may account for some of this
difference, it would not be expected to cause this much of a variation.
And, while eligible riders may make fewer trips due to a high fare, one
would expect persons with disabilities to still register for the
service.

**Table 13. Comparison of Per Capita Eligible Riders and Trips for
Selected Cities**

+----------+---------+---------+---------+---------+---------+---------+
|          | **At    | **D     | **Las   | **Oa    | **Por   | **Se    |
|          | lanta** | allas** | Vegas** | kland** | tland** | attle** |
+----------+---------+---------+---------+---------+---------+---------+
| *        | 1,      | 1,      | 1,      | 1,      | 1,      | 1,      |
| *Service | 241,000 | 904,330 | 110,642 | 500,000 | 175,990 | 700,000 |
| Area     |         |         |         |         |         |         |
| Popu     |         |         |         |         |         |         |
| lation** |         |         |         |         |         |         |
+----------+---------+---------+---------+---------+---------+---------+
| **ADA    | 2,811   | 13,348  | 9,172   | 10,000  | 11,200  | 26,498  |
| Eligible |         |         |         |         |         |         |
| Riders** |         |         |         |         |         |         |
+----------+---------+---------+---------+---------+---------+---------+
| **%      | 0.2%    | 0.7%    | 0.8%    | 0.7%    | 1.0%    | 1.6%    |
| Persons  |         |         |         |         |         |         |
| Regi     |         |         |         |         |         |         |
| stered** |         |         |         |         |         |         |
+----------+---------+---------+---------+---------+---------+---------+
| **ADA    | 166,858 | 559,088 | 604,740 | 937,680 | 689,421 | 809,848 |
| Trips    |         |         |         |         |         |         |
| Provid   |         |         |         |         |         |         |
| ed/Yr.** |         |         |         |         |         |         |
+----------+---------+---------+---------+---------+---------+---------+
| **Trips  | .134    | .294    | .544    | .625    | .586    | .476    |
| /Year/** |         |         |         |         |         |         |
|          |         |         |         |         |         |         |
| **       |         |         |         |         |         |         |
| Capita** |         |         |         |         |         |         |
+----------+---------+---------+---------+---------+---------+---------+

**Findings**

1.  MARTA appears to have an adequate number of vehicles to meet the
    current expressed demand for ADA Complementary Paratransit service.
    However, the fleet may be insufficient to serve increased passenger
    volumes resulting from improved service.

2.  The ADA Complementary Paratransit training program for operators
    seems quite extensive and adequate.

3.  The number of approved ADA Complementary Paratransit operator
    positions and the level of staffing in ADA Complementary Paratransit
    reservations do not, however, appear adequate to meet the demand for
    service. By holding the number of approved operator positions
    constant over the past five years, MARTA appears to have constrained
    ADA Complementary Paratransit service capacity. Failure to increase
    reservations staffing when reservations hours were expanded, had a
    significant adverse impact on telephone service.

4.  The lack of an adequate number of approved operator positions also
    appears to significantly affect MARTA's ability to cover scheduled
    runs, to respond to same day operator call-outs, and to respond to
    same day service issues. This lack of run coverage appears to have
    significantly affected MARTA's ability to provide an acceptable
    level of ADA Complementary Paratransit service. On-time performance
    and ride times, in particular, have been negatively impacted.

5.  During the first eight months of 2001 MARTA had a monthly average of
    2.4% denials of demand trips. The process used by MARTA to develop
    ADA Complementary Paratransit operating budgets does not appear to
    include any consideration of prior trip denials, latent demand, or
    the projected growth in demand for service. The budget process
    starts by looking at the expenses related to the number of approved
    positions for the operation. Since operator positions have been
    constant since FY97, the ADA Complementary Paratransit budget has
    essentially allowed for only inflationary increases and some
    additional overtime. FTA's interpretation of the capacity
    constraints provision regarding denials is that transit service
    providers must plan and budget for zero denials. It does not appear
    that MARTA develops its budget to meet the demand for ADA
    Complementary trips without denials.

6.  The existence of capacity constraints, including trip denials,
    untimely service, and long ride times appears to have depressed
    demand for ADA Complementary Paratransit service in the MARTA area.
    MARTA has far fewer ADA Complementary Paratransit riders per capita
    and far fewer trips per capita than other systems of its size. While
    some of this lower demand may be due to the high fare charged, the
    difference is greater than would be expected due to differences in
    fares.

**Recommendations**

1.  MARTA should increase the number of approved ADA Complementary
    Paratransit operator positions as soon as is possible. This could be
    accomplished by using monies currently budgeted for overtime.

2.  In the future, MARTA should begin the ADA Complementary Paratransit
    budgeting process by first considering the current and projected
    demand for the service. Trends in prior year ridership should be
    considered. Trip denials and their impact on expressed demand should
    be considered. Increases in ridership that will likely result from
    improvements in on-time performance, travel times, and phone hold
    times should also be considered. Once an estimate of ridership has
    been developed, an estimate of revenue-hours needed to provide these
    trips, given current service productivity, should be developed. The
    number of operators needed to cover the estimated number of hours
    and runs should then be developed. Other staffing needs associated
    with a growth in ridership should also be considered. The budget
    should then include this level of staffing to estimate expenses for
    the next year.

    **Attachment A**

**Response from MARTA**

**Attachment B**

**On-Site Assessment Schedule**

**Attachment C**

**Paratransit Customer's Guide**

**Attachment D**

**Summary of ADA Complementary Paratransit Complaints on File at MARTA
September 2000 through August 2001**

MARTA Customer Service Center Complaints, September 2000 through August
2001

  ----------- -------- ----------- ----------- --------- ---------- -------- ----------- -------------- -----------------
  **Month**   **Late   **Driver    **Carrier   **Early   **Change / **Long   **Other**   **Total        **Total
              PU**     Conduct /   No-show**   PU**      Cancel     Ride**               Complaints**   Commendations**
                       Driving**                         Trip w/o                                       
                                                         Notice**                                       

  9/00        17       10          9           2                    1        13          52             2

  10/00       12       7           6           1                    1        5           32             4

  11/00       8        9           2           0                    0        10          29             2

  12/00       6        6           4           0                    0        3           19             2

  1/01        4        6           8           1                    0        2           21             4

  2/01        10       5           5           2                    0        5           27             6

  3/01        9        12          7           2                    0        7           37             6

  4/01        4        5           5           0                    0        15          29             6

  5/01        18       11          3           5                    0        15          52             8

  6/01        23       8           5           4                    0        21          61             3

  7/01        18       9           12          1                    0        20          60             2

  8/01        20       10          16          1         6          1        11          65             11

  Total       149      98          82          19        6          3        127         484            56

  Percent     31%      20%         17%         4%        1%         \<1%     26%         100%           N/A
  ----------- -------- ----------- ----------- --------- ---------- -------- ----------- -------------- -----------------

**Attachment E**

**MARTA ADA Complementary Paratransit Eligibility Application Form and
Materials**

**Attachment F**

**MARTA Daily Service Summary Reports**

**June-August 2001**

**Attachment G**

**Long Ride Report for August 1-13, 2001**