Birmingham Jefferson County Transit Authority

(BJCTA)

**Birmingham, Alabama**

Assessment

of

ADA Complementary Paratransit Service

Capacity Constraints

April 29 -- May 2, 2002

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**with**

**Multisystems, Inc.**

**Final Report: October 25, 2002**

**CONTENTS**

**I. Purpose of the Assessment** 1

**II. Overview of the Assessment** 3

**III. Background** 7

**IV. Summary of Findings** 11

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

**Determinations** 17

**VI. Observations Regarding Telephone Access** 23

**VII. Observations Regarding the Handling and Scheduling of Trip
Requests** 27

**VIII. Observations Regarding Service Provision** 35

**IX. Resources and Overall Level of Service** 54

**X. Other Compliance Issues** 62

**Attachment A. BJCTA Response**

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

**Attachment C. BJCTA VIP Service Riders Guide**

**Attachment D. BJCTA ADA Complementary Paratransit Eligibility
Application Materials**

**Attachment E. Sample Eligibility Denial Letter and Instructions for
Appealing**

**Attachment F. Sample Completed VIP Manifest Showing Pick-Ups Made Out
of Sequence**

# 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 Birmingham-Jefferson County Transit Authority
(BJCTA) in Birmingham, Alabama was conducted from April 29 through May
2, 2002. 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 BJCTA'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 BJCTA'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.

BJCTA was provided with a draft copy of the report for review and
response. A copy of the correspondence received from BJCTA on September
20, 2002 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 DOT ADA
regulations. Several possible types of capacity constraints are
identified by the regulations. These include "wait listing" trips,
having caps on the number of trips provided, or recurring patterns or
practices that result in a substantial number of trip denials, 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;

```{=html}
<!-- -->
```
-   A copy of the paratransit service "Riders Guide," which details
    service policies to customers; and

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

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 BJCTA;

-   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 five customers and
consumer representatives. The assessment team also reviewed ten
complaints on file with FTA. These complaints were filed between
September 2000 and February 2002.

**On-Site Assessment**

The on-site compliance assessment began with an opening conference, held
at 1:00 PM on Monday, April 29, 2002. BJCTA representatives attending
the meeting included:

Kenneth Gordon, General Manager; Ella Bowman, Director of Planning and
Development; and Debra Anderson-Burse, Director of Administration and
Contracts. Also attending the meeting was Lynn Rivers, General Manager
of First Transit, BJCTA's contractor for fixed route and paratransit
services. Russell Thatcher and Rosemary Mathias of Multisystems, Inc.,
and

David Chia of Planners Collaborative represented the FTA assessment
team. Cheryl Hershey of FTA's Office of Civil Rights in Washington,
D.C., and Frank Billue, FTA's Civil Rights Officer for Region IV also
participated in the opening conference via telephone.

[]{.mark}

Cheryl Hershey opened the meeting by thanking BJCTA for their
cooperation in the assessment. She reviewed the purpose of the
assessment and emphasized that it was intended to assist BJCTA in
providing effective ADA Complementary Paratransit service. Ms. Hershey
explained that:

-   Preliminary findings and an opportunity to respond would be provided
    at a closing meeting on Thursday, May 2, and\\

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

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

Mr. Gordon indicated that BJCTA 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 senior
BJCTA staff to review the service structure and standards and the
information available on-site. Information about the planning and
budgeting process and about budgets and expenditures for paratransit
service in recent years was reviewed. Available paratransit service
reports were also reviewed. In the late afternoon, the assessment team
reviewed BJCTA's service complaints related to the paratransit service,
and began reviewing internal service monitoring procedures.

In the morning on Tuesday, April 30, the team met with the paratransit
contractor staff and toured the paratransit operations center. One
member of the team then sat with the morning reservationist and observed
the trip reservations, scheduling and dispatching process. The
assessment team member observed calls as they were received. Basic
information (e.g., date and time requested, trip origin and destination
addresses, 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. Calls were also placed to the reservations office to gather
information about phone access and hold times. The other team members
reviewed driver availability, pull-out, and vehicle availability
information with the general manager and assistant general manager.

During the mid-day on April 30, drivers were interviewed as they
returned from their morning shifts. They were asked about training and
preparation for the job, the schedules that they were asked to run, and
the extent of dispatch support received.

The afternoon of April 30 was spent reviewing completed driver manifests
for two randomly selected days of service -- Tuesday, October 23, 2001
and Wednesday, March 20, 2002. On-time performance for these two days
was calculated based on actual driver entries. A sample of rides with
long on-board travel times was collected for comparison to fixed route
service and with ride time standards. The team also met with the lead
reservationist/scheduler to review the process used to finalize runs and
prepare manifests for the next day.

On Wednesday, May 1, the assessment team again observed the reservations
process -- both in the early morning and in the late afternoon (the
identified peak calling times). Additional information about the
handling of trip requests was gathered. The team also reviewed completed
trip request forms for several days to determine if trip requests were
scheduled and to compare requested trip times to final scheduled times.

On Wednesday afternoon, the team completed its review of completed
driver manifests and its calculations of on-time performance for
selected days. The dispatching process was also observed during the
afternoon peak travel period. In the late afternoon, the team then
returned to the BJCTA offices and met with staff to review the ADA
Complementary Paratransit eligibility determination process, to
calculate fixed route travel times for sample paratransit trips, and to
finish collecting information about the BJCTA's service monitoring
activities.

On Thursday morning, May 2, the team compiled information collected in
preparation for the exit conference. Some additional follow-up work on
eligibility determinations and service monitoring was also completed.

An exit conference was held at 1:00 PM on Thursday, May 2, 2002.
Attending the exit conference for BJCTA were Kenneth Gordon, Ella
Bowman, and Debra Anderson-Burse. Attending for First Transit were Lynn
Rivers and Assistant General Manager Raymond Taylor. Attending for the
assessment team were Russell Thatcher, Rosemary Mathias, and Brian
Barber. Roberta Wolgast of FTA's Office of Civil Rights in Washington,
D.C., participated via telephone.

Ms. Wolgast opened the exit conference by thanking BJCTA for their
cooperation in the assessment. 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:

-   Eligibility determination,

-   Telephone access,

-   Handling of trip requests and trip denials,

-   On-time performance,

-   Trip duration,

-   Planning and budgeting, and

-   Vehicle, manpower, and financial resources.

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

# Background

BJCTA provides public transit services in the Birmingham metropolitan
area. BJCTA provides fixed route bus and ADA Complementary Paratransit
service. About 650,000 people live in the BJCTA service area, which
covers about 1,074 square miles.

Fixed route bus service is provided with a fleet of 76 buses operating
on three downtown circulator routes, 25 regional routes, and two
"neighborhood shuttle" routes. Most fixed route bus service operates
only on weekdays with the first route starting at 4:40 AM and the last
stop scheduled at 7:22 PM. The downtown circulators operate seven days a
week and run from

9:00 AM to midnight, Monday through Saturday, and 9:00 AM to 9:00 PM on
Sundays. In FY2000, a total of 2,640,505 unlinked trips were provided on
the fixed route bus system.[^1]

The base fixed route fare is \$1.00 per ride on the regional and local
shuttle services. The downtown circulator fare is \$0.50 per ride.

**Description of the ADA Complementary Paratransit Service**

BJCTA contracts with First Transit for the operation of its ADA
paratransit service, known as the MAX VIP service. First Transit is also
the operator of all fixed route services.

VIP service is provided in all areas within ¾ of a mile of fixed routes.
The VIP program Riders Guide indicates that service is provided from
5:00 AM to 8:00 PM, Monday through Friday, and from 8:00 AM to 6:00 PM
on Saturdays. The fare for VIP service is \$1.50 per one-way ride. A
copy of the "BJCTA VIP Service Rider's Guide" is included as Attachment
C.

Requests for VIP service trips are accepted up to 14 days in advance
from 8:00 AM to 4:00 PM, Monday through Saturday, and from 1:00 PM to
5:00 PM on Sundays. First Transit uses the StrataGen automated system to
record, schedule and dispatch VIP trips.

About 3,020 people are registered with BJCTA as ADA Paratransit Eligible
riders. In FY 2001 (July 2000 through June 2001), a total of 112,968
one-way passenger trips were provided on the VIP service. At the time of
the assessment, the VIP service was operated using a fleet of 22

lift-equipped body-on-chassis minibuses, 18 of which were in peak-hour
service.

**Recent VIP Service Changes**

Three significant changes were reportedly made in the VIP service in the
year prior to the assessment. These changes appear to have had an
impact, both positive and negative, on the service and are important to
understanding the information and findings presented in this report.
These changes are described below.

-   In April 2001, additional funding for VIP service was provided by
    the City of Birmingham. This funding allowed for an expansion of
    service hours. For several years prior to this time, 15 vehicles
    were scheduled for peak-hour operation. Since April 2001, the
    contractor for VIP service has been authorized by BJCTA to operate
    17-18 peak-hour vehicles. This issue is discussed in more detail in
    the "Resources and Overall Level of Service" section of this report.

-   BJCTA also took delivery of 18 new VIP vehicles in April 2001. This
    significantly improved the quality and reliability of the
    paratransit fleet. Four additional new vehicles were purchased in
    March 2002. As a result, 22 vehicles in the VIP service are 2001 or
    2002 models.

-   Also in April 2001, BJCTA purchased a new paratransit reservation,
    scheduling, and dispatch system (StrataGen). Staff at BJCTA and
    First Transit reported significant problems in the transition to
    this new system. Significant issues appear to still exist with this
    new software, which is described in several sections of this report.

-   In January 2002, BJCTA negotiated a new contract with the union for
    paratransit operators. A significant increase in pay was provided.
    Prior to this time, it was reported that paratransit driver turnover
    was high, as drivers would move from the paratransit to the fixed
    route system as higher paying fixed route jobs became available.
    This impacted the ability of First Transit to cover scheduled runs
    and provide adequate service back-up. Since January 2002,
    paratransit driver turnover has decreased significantly. This issue
    is discussed in more detail in the "On Time Performance" and
    "Resources and Overall Level of Service" sections of this report.

**Formal ADA Complaints Received by FTA**

FTA received ten formal ADA complaints from riders and advocates in the
BJCTA area between September 2000 and February 2002. These complaints
were reviewed prior to the on-site assessment and used to focus the
issues examined during the assessment.

Nine of the complaints were from individuals. A tenth was received from
a local service agency and covered issues experienced by several riders
(some of whom had also submitted separate, individual complaints). Table
1 below shows the issues cited in each complaint.

As shown, the most significant issue (raised in 8 of the complaints) was
on-time performance. These complaints cited late pick-ups, late arrivals
and missed appointments, as well as very early pick-ups. Six
complainants also cited excessively long paratransit ride times. Rides
up to 2-3 hours were reported. Four complainants indicated problems
caused by incorrect trip information, with schedules to make pick-ups
and drop-offs at incorrect locations. Three complainants indicated that
phone lines are often busy and that calls are placed on hold for long
periods of time. One person indicated capacity problems, noting that
when he called on October 13, 2000 for a ride on October 19, 2000, he
was told that vehicles were booked for that entire week. Finally, one
person noted that his ride never showed up and he was forced to make
other travel arrangements.

**Table 1. Concerns Expressed In 10 ADA Complaints Submitted to FTA**

  --------------------------------------------------- -------------------
  **Issues**                                          **\# of
                                                      Allegations**

  On-Time Performance                                 8

  Excessively Long Ride Times                         6

  Inaccurate/Incorrect Trip Information               4

  Busy Phones/Excessive Hold Times                    3

  Trip Denials                                        1

  Missed trips                                        1
  --------------------------------------------------- -------------------

**Consumer Comments**

Prior to the assessment, in order to identify current areas of concern,
the team interviewed five VIP riders and service agency staff who assist
individuals with use of the service. Two of these individuals had filed
formal ADA complaints with FTA.

Three of the individuals contacted indicated that some aspects of the
service had improved in recent months, but all indicated that there were
still problems of one kind or another. The most significant problem,
cited by all of those contacted, was on-time performance. Issues ranged
from vehicles arriving extremely early to consistently getting to
appointments late. It was also noted that sometimes no specific pick-up
time is given and riders do not know when the vehicle will show-up. One
of the people contacted indicated that he had used the service in the
past, but stopped using it in September 2001 due to problems with
service reliability. Other problems cited were long travel times, delays
in getting applications for eligibility processed, an inability to get
accurate information about the status of a late ride, long wait times
for unscheduled "will-call" pick-ups on return trips, and some problems
getting through on the phones. One person indicated problems with trip
requests being denied.

In addition, during the field assessment, the team reviewed BJCTA
complaint records for the period from August 2001 through February 2002.
Table 2 below provides a summary of issues raised in these complaints.
As shown, five complaints related to on-time performance; two cited
phone problems (no answer and long hold times); two cited dispatcher
professionalism on the radio; and two noted problems with the
reservations and scheduling process and incorrect address problems.

**Table 2 Summary of ADA Paratransit Complaints Received by BJCTA,**

**August 2001 through February 2002.**

  ----------------------- -----------------------------------------------
  **Date**                **Type of Complaint**

  August 1, 2001          Reservations/scheduling issue

  August 30, 2001         Dispatching radio conduct issue

  September 6, 2001       Dispatching radio conduct issue

  September 6, 2001       Missed trip (called early for return trip;
                          never picked up)

  September 12, 2001      Incorrect address

  September 26, 2001      Late trip

  December 5, 2001        Late ride and related telephone issue (no
                          answer at First Transit dispatch) Confirmed by
                          BJCTA

  December 7, 2001        Late pick-up -- requested 8 am pick-up was told
                          only available vehicle was 6:40 am and then the
                          vehicle showed up at 8:50 am

  January 16, 2002        Reckless driver issue

  January 31, 2002        Schedule change (by passenger) resulting in
                          late trip (dispatch tried to work it in)

  February 8, 2002        Put on hold for \> 15 minutes; told she did not
                          have a reservation

  February 11, 2002       Waited 4 hours for will-call return
  ----------------------- -----------------------------------------------

# 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 BJCTA. Recommendations are also included
in the report for BJCTA's consideration in developing corrective
actions.

**A. Findings Regarding ADA Complementary Paratransit**

> **Eligibility Determinations**

1.  A small number of applicants for ADA paratransit eligibility appear
    to be denied because they reside outside the ADA paratransit service
    area. While BJCTA is not required to provide trips that have origins
    or destinations outside the defined service area, determinations of
    eligibility should not be based on place or residence. Individuals
    may live outside the service area and may take trips that are within
    the area.

2.  Some applicants for ADA paratransit eligibility also appear to be
    denied because they have incorrectly completed the application
    materials. Specifically, some individuals appear to not understand
    that the professional verification portion of the application must
    be completed by a third-party. They complete this section
    themselves. In these cases, records indicate that BJCTA staff sends
    a "denial" letter indicating that the reason for the denial is that
    the application has not been properly completed.

3.  As required by the regulations, most determinations of ADA
    paratransit eligibility (96%) appear to be made within 21 days of
    the receipt of a completed application. In some instances, however,
    it was noted that determinations could take 22 days or more.

4.  The database of eligible riders appears to contain incorrect
    information. The automated system that is used to maintain records
    of eligible riders also appears to change eligibility information
    when it is upgraded or when modifications are made. These system
    problems may be removing eligible riders from the database, which
    could impact the ability to schedule riders for these persons.

**B. Findings Regarding Telephone Access**

1.  The reservations office is staffed from 5:00 AM to 8:00 PM on
    weekdays; from 7:30 AM to 6:00 PM on Saturdays; and from 1:00 to
    5:00 PM on Sundays. 49 CFR SS 37.131 (b)(1) requires that, "the
    entity shall make reservation service available during at least all
    normal business hours of the administrative offices, as well as
    during times comparable to normal business hours, on a day when the
    entity's offices are not open before a service day."

2.  The current standard for answering incoming calls is that all calls
    are to be answered by the third ring. No standard for hold time has
    been established.

3.  Telephone performance appears to be adequate and does not appear to
    be a capacity constraint. While there are some times when no open
    phone lines are available and customers receive a busy signal, this
    seems to occur for only a short period of time and customers can get
    through if they call back once or twice. Hold times for reservations
    seem short. Hold times for "Where's my ride?" calls can be longer,
    particularly if taken by the receptionist or administrative staff
    who are not located in the dispatch area. These hold times appear to
    be reasonable, however, for this type of service.

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

1.  Four (4) of 295 trip requests sampled between April 25 and April 30
    were scheduled for pick-up more than one hour from the requested
    time. FTA considers this practice a denial of service.

2.  BJCTA does not appear to use trip caps in the scheduling of ADA
    Complementary Paratransit trips.

3.  BJCTA does not appear to use waiting lists in a way that violate the
    DOT ADA requirements. Some trips are placed on a standby list or
    waiting list when they cannot be scheduled on set runs, but all
    trips on standby or wait lists appear to eventually be scheduled.

4.  Limited capacity does not appear to be a cause of BJCTA denial of
    trip requests. All trip requests that were observed and examined
    appeared to be served. However, in addition to the trip denials
    cited in finding number one, some trips are scheduled at times that
    may not meet rider needs to make appointments. Of the 295 trip
    requests examined, 29 (or 10%) were assigned scheduled drop-off
    times that were either after the stated appointment times or pick-up
    times less than 20 minutes before the appointment times. Scheduling
    pick-ups less than 20 minutes before appointment times could cause
    riders to be late for appointments since vehicles can arrive for
    pick-ups up to 20 minutes after the scheduled time.

5.  The information recorded by reservationists/dispatchers on VIP
    Reservation forms is often incomplete. This could cause trips to be
    scheduled incorrectly.

6.  Reservationists/dispatchers also do not routinely verify trip
    information with callers. This could lead to miscommunication
    between callers and schedulers and inaccurate scheduling of trips.

7.  The StrataGen scheduling system is not being used as originally
    planned. Real-time scheduling is not being done due to problems with
    the system and inadequate staffing of the reservations function,
    which does not allow adequate time to be spent entering trip
    requests directly into the system when riders call.

**D. Findings Regarding Service Provision**

1.  The current on-time performance standard adopted by BJCTA allows
    vehicles to make drop-offs up to 20 minutes after stated appointment
    times. Since late arrival at work for medical appointments or
    classes could negatively affect a person's employment, medical
    services or education, adherence to such a standard could be
    considered a limit on the availability of paratransit service.

2.  A significant number of rides appear to be performed late. A review
    of trip records for two randomly selected days indicated that 11-12%
    of pick-ups were late (more than 20 minutes after the scheduled
    time. More significantly, 22-29% of drop-offs were made after the
    stated appointment times for this same sample of trips. This very
    high percentage of late drop-offs is likely a result of the current
    on-time standard, which permits drop-offs to be made up to 20
    minutes late.

3.  Based on the analysis of sample trips conducted as part of the
    assessment, the on-time performance reported in BJCTA monthly
    service reports does not appear to be accurate. Actual trip
    information does not appear to have been regularly entered into the
    StrataGen system. Reported performance was therefore based on
    general information from staff rather than on actual ride times.

4.  A significant number of VIP rides appear to have excessively long
    ride times. Eighty-five percent of the 20 long paratransit trips
    identified for two service days exceeded the maximum travel time
    standards set by BJCTA. On average, the trip standard was exceeded
    by 61 minutes. Long rides are often the result of scheduling too
    many passengers on trips rather than in-service problems. Nine of
    the 20 long trips examined were scheduled with ride times that
    exceeded the established maximum ride time standard adopted by
    BJCTA.

5.  The problem of too many passengers on trips also is reflected in the
    comparison of direct distance to on board miles. For the 20 long
    trips reviewed, the average direct distance of the trips was 9
    miles. Average on-board mileage was, however, 29 miles (more than
    three times the direct distance).

6.  BJCTA does not appear to regularly monitor VIP ride times. A recent
    "Exceptions" report has been designed to begin monitoring ride
    times, but this report uses on-board miles rather than direct miles
    to compare ride times to the maximum travel time standard adopted.

7.  A lack of ongoing dispatch control appears to be contributing to
    poor on-time performance. Drivers do not radio-in pick-ups and
    drop-offs and dispatchers do not routinely check on the status of
    all runs. The current operating practice relies heavily on riders to
    notify the dispatch center to make staff aware that vehicles are
    running late.

8.  Pick-up and drop-off times included on manifests often appear to be
    inaccurate -- specifically for subscription trips. Changes in ride
    times appear to have been made with riders and agencies, but these
    changes have not consistently been entered into the StrataGen
    system. Inaccurate information will cause the system to not
    recognize available times correctly. Available capacity will not be
    correctly identified. Also, trips will be scheduled at times that
    appear to be available but these times may actually be fully booked.

9.  Drivers appear to often complete runs out of sequence and appear to
    be authorized to do this. This appears to be done because
    information on manifests is often inaccurate. This practice could
    contribute to poor on-time performance and long ride times.

10. Call-backs do not appear to be consistently made to inform riders of
    scheduled pick-up times. An examination of 235 trip records
    indicated that call-backs are made only 24% of the time. Riders
    therefore often appear to be unaware of scheduled pick-up times that
    are significantly different from times requested. This appears to be
    contributing to significant rider dissatisfaction with the
    reliability of the service.

11. The reservations and scheduling functions appear to be understaffed.
    While First Transit may have been able to operate the system with
    current staff prior to the introduction of the StrataGen system,
    full and appropriate use of the new system appears to require
    additional staff. Given current duties and responsibilities,
    reservationists do not have the time to enter trips directly into
    the system. As a result, a hybrid paper/automated system is being
    used to book and schedule rides. The current system does not permit
    ride times to be negotiated in real-time, requires multiple handling
    of trip information (which can cause inaccuracies), and requires
    that call-backs be made to inform riders of scheduled pick-up times.

12. Problems created by the extra steps required to manually record trip
    requests and then schedule them after the fact also appears to be
    impacting the dispatch function. Dispatchers do not appear to have
    the time to keep track of all runs on an ongoing basis to ensure
    that pick-ups and drop-offs are performed in a timely manner and to
    proactively rearrange schedules should in-service problems arise.

13. The large percentage of will-calls, same day trip requests, and same
    day trip changes appears to have an impact on on-time performance
    and travel times. While some riders may be given additional travel
    flexibility, many other riders might be inconvenienced as same day
    changes are being accommodated. Many comments and complaints about
    late trips also appear to be related to will-calls, which indicates
    that the system really does not have the capacity to adequately
    respond to the level of same day trip additions and changes that now
    occur.

14. Problems appear to exist in the functioning of the StrataGen system,
    the use of the system, or both. Subscription trips, which should be
    anchored to specific runs, appear to move around in the system. A
    subscription trip was even observed to move from a scheduled run to
    the standby list. These types of system problems appear to be
    contributing to poor on-time performance and missed trips (if the
    standby and wait lists are not constantly monitored). Without more
    in-depth analysis, it was not clear whether these problems are due
    to system design or incorrect use of the system by staff.

**E. Findings Regarding Resources**

1.  High turnover of paratransit operators and the lack of availability
    of extraboard operators appear to have contributed to VIP service
    delivery problems in past years. Recent changes in VIP operator
    compensation and in the hiring practices used for VIP and fixed
    route operators appear to have addressed these problems. It appears
    that First Transit now has enough operators to adequately cover all
    call-outs and provide service back up.

2.  Understaffing in the reservations, scheduling and dispatch functions
    appears to have impacted VIP service quality. As detailed in other
    sections of this report, understaffing appears to have kept
    real-time scheduling from being fully implemented, accurate
    schedules (particularly subscription schedules) from being
    developed, and adequate dispatch control from being maintained.

3.  The BJCTA budget for ADA paratransit service does not reflect a
    steady increase in recent years needed to accommodate expected
    increases in demand. The budget and corresponding expenses were held
    constant for several years. One increase in April of 2001 was
    approved. Prior to April of 2001, requests for increases in funding
    for ADA paratransit service do not appear to have been approved for
    several years.

4.  The number of VIP trips provided per year is low given the service
    area population. BJCTA provides about 0.17 trips per capita per year
    on the VIP program. Data from other cities indicates a significantly
    higher trip-making rate. It appears that some people who are ADA
    paratransit eligible in the BJCTA area are using the CLASTRAN
    service even though it has a significantly higher fare. These riders
    indicated that they have elected to use the more expensive CLASTRAN
    system because of the poor reliability of the VIP service.

5.  Once BJCTA addresses VIP service issues -- specifically on-time
    performance and long ride times -- an increase in demand should be
    expected.

**F. Findings Regarding Other Compliance Issues**

1.  BJCTA is not meeting the requirements of Section 37.131(e) of 49 CFR
    Part 37, which requires that "...paratransit service shall be
    provided throughout the same days and hours as the entity's fixed
    route service." In the area where DART fixed route service is
    provided, BJCTA must expand VIP service hours to match the hours of
    the three DART routes. This will mean expanding VIP hours, at least
    in some DART areas, until 10:00 PM Mondays through Thursdays, until
    12:00 midnight on Fridays and Saturdays, and from 9:00 AM until 9:00
    PM on Sundays.

2.  Although advertised, adequate VIP service also does not appear to
    exist between the hours of 5:00-6:00 AM and from 6:00-8:00 PM. No
    regularly scheduled runs appear to be in service before 6:00 AM.
    Only one run (plus any available extraboard drivers) is scheduled
    after 6:05 PM. Given the size of the service area, it is doubtful
    that VIP could meet potential demand with one vehicle and extraboard
    operators between 6:00 and 8:00 PM. It is likely that the lack of
    scheduled runs has contributed to low demand during these times.

# 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 BJCTA staff and a review of
    application materials.

-   Eligibility determination outcomes for 37 recently filed
    applications were reviewed.

-   Four recent denials of eligibility were reviewed with staff.

-   Records for applications submitted between January 1, 2002 and April
    16, 2002 were examined, and the processing time for each was
    determined.

**Consumer Comments**

None of the formal complaints on file with the FTA cited issues with the
eligibility determination process. However, three of the five
individuals contacted prior to the field assessment indicated that there
were problems. One person indicated that they did not feel that staff
understood cognitive disabilities and that inappropriate decisions were
being made for applicants with cognitive impairments. The other two
persons, both of whom worked with a local agency and assisted clients
with applications, felt that decisions were fair and accurate but
indicated that there can be delays in the processing of requests for
certification. Both indicated that it can take several weeks to receive
an eligibility decision. One person noted that after a decision is made,
riders must still appear in person to have a photo taken and an ID card
made and that there sometimes are problems and delays in getting
eligible riders entered into the computer system once they are
determined eligible.

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

BJCTA staff makes determinations of ADA paratransit eligibility.
Determinations are made based on information provided in a paper
application as well as information obtained through follow-up calls to
applicants and/or professionals familiar with applicants.

Individuals interested in applying for the service are directed to call
BJCTA. If the contractor staff receives inquiries on the reservations
phone line, callers are referred to BJCTA. When individuals call and
inquire about registering for the service, BJCTA staff explains the VIP
program to be sure that the person understands the nature of the service
and the criteria used to determine eligibility. If callers indicate that
they have a disability that prevents use of the fixed route system, they
are mailed the following items:

-   A general application form;

-   An insert titled "Certification of Paratransit Need for Persons with
    Vision Loss/Blindness" that includes additional questions to be
    answered only by applicants with vision disabilities;

-   A "Certification of Need for a Personal Care Attendant" form. This
    form is separate from the application to allow riders to request and
    be certified to travel with a PCA without filing a completely new
    application;

-   A form that is to be completed by a professional familiar with the
    applicant that requests verification of the disability and
    information about functional abilities; and

-   An information sheet titled "Categories of Eligibility" that
    indicates possible determination outcomes on one side, and lists
    types of professionals that can provide information about functional
    abilities or medical information on the reverse side.

Copies of these forms are provided in Attachment D.

When application materials are returned to BJCTA, the Director of
Administration and Contracts does an initial review of the material. She
adds her thoughts on the determination to the file and notes any
additional information that would be helpful in making a decision.
Another staff person who works with the Director then follows-up by
phone with the applicant or the professional providing information about
the applicant. It was reported that telephone follow-up is done about
80% of the time. Once all follow-up information has been collected, the
Director and her assistant discuss the application and make a joint
decision on eligibility.

If applicants are determined to be eligible, they are sent a letter that
indicates that they have been approved for the VIP service and are
instructed to have a photo taken and an ID made at the paratransit
office. Eligibility is typically granted for a period of three years,
unless a temporary disability is indicated, or the person's functional
ability is expected to change in a shorter period of time. If applicants
are determined not eligible for VIP service, they are sent a letter
indicating the reason for the denial and information about the appeals
process.

A copy of a sample denial letter and the instructions for submitting an
appeal request are provided in Attachment E. This two-page form titled
"Request for Case Review -- MAX VIP ADA Eligibility Determination"
indicates that appellants must submit additional written material to
support their appeals. The form then indicates that the Review Committee
will consider the information and will make a decision within 30 days of
its receipt. The appeal instructions do not indicate that a hearing at
which the appellant can provide information in person is part of the
process. BJCTA staff indicated that a very small number of applicants
are denied eligibility and that they have never had a request for an
appeal. They were not able to indicate the membership of the Review
Committee since it had never been convened.

**Determination Outcomes**

At the time of the assessment, there were about 3020 persons registered
to use the VIP service. Records indicated that BJCTA receives about 25
applications per month.

Determination outcome records were reviewed for selected applications
received from

January 2002 through March 2002. During this period, 71 persons were
determined to be eligible for VIP service. Sixty-three applicants (or
89%) were granted unconditional eligibility, 8 (or 11%) were granted
conditional eligibility. No applicants were given temporary eligibility
during this sample period. Six applicants were determined to be
ineligible. Finally, five applications were still pending, and another
five were being held as incomplete.

**Review of Recent Determination Decisions**

Thirty-seven applications, received between November 2001 and March
2002, were selected and the outcomes and decisions were reviewed with
staff. This sample included four of the six persons denied eligibility
during the past three months, three applications still pending
determinations, and 30 applicants granted unconditional or conditional
eligibility.

The determinations for the 30 applicants granted conditional or
unconditional eligibility appeared appropriate. Several issues were
noted, however, with the applications that were not yet processed and
with the denials of eligibility. These issues are described below.

-   Two applicants were sent letters indicating that they had been
    denied eligibility because they did not have a professional complete
    the "professional verification" portion of the application material.
    Both individuals appeared to have misunderstood that this portion of
    the application was to be completed by a professional and had
    answered the questions themselves. It seemed clear that one
    applicant did not understand that a professional should complete
    that part of the application material because in response to the
    question "Capacity in which you know applicant:" he wrote, "I am who
    I am." Rather than holding these applications as incomplete and
    notifying the applicants that information from a professional was
    needed, both were sent letters of denial.

-   One applicant was denied because he lived outside of the VIP service
    area.

-   Two applications received from individuals who live outside the
    service area and who had indicated that they planned to move into
    the service area were considered to be "pending." Both had been
    received in January of 2002 and no decision had been made as of the
    time of the review.

-   One application, received on November 28, 2001, was still "pending."
    Staff could not explain why a decision had not been made; there was
    no documentation in the file indicating why the application was not
    processed; and the person was not in the computer file of eligible
    riders.

**Review of Application Processing Times**

Since January 2002, BJCTA staff has maintained a log tracking actions on
all ADA paratransit applications received. The log includes the date the
application was received, the date when a decision was reached, and the
date that a letter of determination was sent. The entries in this log,
for applications received from January 7, 2002 through April 16, 2002,
were reviewed as part of the assessment. Table 3 below shows the
processing times for each of these determinations. As shown, 96% of all
determinations were made in 21 days or less. Sixty-four percent (64%) of
all determinations were made in 14 days or less. Of the three
applications that took longer than 21 days to process, one took 22 days,
a second took 29 days, and the third took 31 days. In one case, the file
indicated that there were problems getting appropriate professional
verification of disability.

**Table 3. Processing Time for ADA Paratransit Eligibility
Determinations,**

**January 7, 2002 Through March 31, 2002**

  --------------------------------- ------------------- ------------------
  **Days Elapsed Between Receipt of **Number of         **Percent**
  Applications and Date Letter of   Applicants**        
  Determination Sent**                                  

  7 days or less                    17                  23%

  8-14 days                         31                  41%

  15-21 days                        24                  32%

  More than 21 days                 3                   4%

  TOTAL                             75                  100%
  --------------------------------- ------------------- ------------------

**Computer Files of Eligible Riders**

While observing the VIP reservations process at First Transit, it was
noted that several "VIP Reservation" forms (onto which trip request
information is manually recorded before being entered into the system)
indicated that riders were "Not in the system." When the reservationists
were asked about this, they indicated that individuals sometimes call
and request a ride, but are not in the database of eligible riders. It
was noted that callers often indicate that they have received letters
from BJCTA indicating they are eligible. When this happens, the
reservationists make a note to call the BJCTA eligibility staff to check
on eligibility.

Information about two such situations was recorded and researched. In
one instance, it was found that a rider was sent a letter of eligibility
on April 16, 2002, had called on April 23 for a ride and was not yet in
the database of eligible riders. In the second case, the rider's
application file indicated that a letter of determination was sent on
December 20, 2001. This rider called for a rider on April 22, 2002 and
was not found in the system.

BJCTA staff indicated that they have often had to reenter information
about eligible riders. They insisted that all individuals are entered
into the system before letters of determination are sent, but that they
have observed that some riders "disappear" from the database. They
speculated that information in the database might be changing when the
system is worked on (upgrades are installed, or programming changes are
made). In one of the specific cases researched as part of the
assessment, staff remembered having to re-enter the person at least
twice since

December 2001.

A further review of the computer eligibility records indicated extensive
problems with the accuracy of eligibility information. In many cases,
the "start dates," "end dates," and "expiration dates" in the system did
not agree with information in the paper files. A pattern was noted that
supports BJCTA staff suspicions that the inaccuracies are due to system
upgrades/modifications. BJCTA staff noted that the most recent upgrade
was performed in early April 2002. It was noted that many files showed
start dates of 4/4/02 and expiration dates of 4/4/05, but that paper
eligibility files indicated different eligibility start and expiration
dates. In one instance, for example, the paper file showed that the
riders eligibility was due to expire on 12/18/02, but the computer
record had extended this person's eligibility to 4/4/05 (three years
from the date of the apparent system upgrade).

It was also noted that the system appears to insert the date when the
file was last opened into certain fields. While BJCTA staff opened rider
records to check on the accuracy of information, it was noted that
5/1/02 (the date this was being done) was being inserted in some fields.

**Findings**

1.  A small number of applicants for ADA Complementary Paratransit
    eligibility appear to be denied because they reside outside the VIP
    service area. While BJCTA is not required to provide trips that have
    origins or destinations outside the defined service area,
    determinations of eligibility should not be based on place of
    residence. Individuals may live outside the service area and may
    take trips that are within the area.

2.  Some applicants for ADA paratransit eligibility also appear to be
    denied because they have incorrectly completed the application
    materials. Specifically, some individuals appear to not understand
    that the professional verification portion of the application must
    be completed by a third-party. They complete this section
    themselves. In these cases, records indicate that BJCTA staff sends
    a "denial" letter indicating that the reason for the denial is that
    the application has not been properly completed.

3.  As required by the regulations, most determinations of ADA
    paratransit eligibility (96%) appear to be made within 21 days of
    the receipt of a completed application. In some instances, however,
    it was noted that determinations could take 22 days or more.

4.  The database of eligible riders appears to contain incorrect
    information. The automated system that is used to maintain records
    of eligible riders also appears to change eligibility information
    when it is upgraded or when modifications are made. These system
    problems may be removing eligible riders from the database, which
    could impact the ability to schedule riders for these persons.

**Recommendations**

1.  BJCTA should discontinue the practice of denying ADA Complementary
    Paratransit eligibility to otherwise eligible applicants because
    they reside outside the service area and should review decisions in
    the past that have been made on this basis.

2.  To minimize applicant misunderstanding, it is recommended that BJCTA
    consolidate the various application forms and develop a cover letter
    to go with a consolidated application that clearly explains what
    portion of the application is to be completed by the applicant and
    what portion is to be completed by a third-party professional. When
    applicants incorrectly complete the application materials, BJCTA
    should treat the application as incomplete. Rather than denying the
    applicant service eligibility, applicants should be notified that a
    complete corrected application must be submitted before a
    determination of eligibility can be made.

3.  BJCTA should develop a procedure to ensure that applicants whose
    determinations take longer than 21 days are authorized to use the
    service until a determination of eligibility is made.

4.  BJCTA should work with the contractor from whom the automated system
    was purchased to eliminate unintended changes to customer records
    when system upgrades or modifications are made. While BJCTA is
    working to revise and correct the computer system, it is recommended
    that a procedure be established with the VIP contractor to ensure
    that a prompt review of records is conducted when it is discovered
    that callers are not in the eligible rider database. First Transit
    reservationists should immediately notify BJCTA staff, who should
    then review not only the central database, but also the paper
    eligibility files. This review should be done promptly so that trips
    can be scheduled in a timely way for eligible riders.

# 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,

-   BJCTA'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

-   Several calls were made to the reservations office during the
    morning and afternoon hours that were identified as peak calling
    times.

**Consumer Comments**

None of the five riders or advocates contacted indicated major
difficulty with telephone access on weekdays. Two noted that the phones
are sometimes busy, but that it was possible even during busy times to
get through after a few calls. One person noted that busy signals and
hold times had been more of a problem in past years, but that access had
improved in the past six months. Two persons indicated problems with
weekend reservations capacity. One rider indicated that he had called
late on Friday afternoon, after the reservations lines had been closed,
for a trip on Monday morning. He was instructed to call back Monday
morning rather than Saturday or Sunday. One rider noted that when the
lines are busy, the phone system activates a recorded message indicating
that all operators are busy. It does not allow callers to remain on
hold.

None of the formal ADA complaints received by FTA were about telephone
access problems. Only one of the twelve service complaints on file at
BJCTA for the period from August 2001 through February 2002 related to
phone problems.

**VIP Phone Service Standards and Performance Monitoring**

BJCTA staff indicated that it is their goal to have all VIP phone calls
answered by the third ring. This standard is not, however, formally
included in the "Operations Management Services Agreement" between the
BJCTA and First Transit, its contractor for VIP services.

As described below, the VIP phone system does not utilize a central call
manager that would permit hold times, servicing times, and other phone
performance information to be captured and reported. Consequently, there
were no phone service records available for review as part of the
compliance assessment. Given the current system design, monitoring of
telephone access and performance is possible only through limited
first-hand observations of the reservations/dispatch office and through
random calls to the office.

**VIP Phone Service Design**

A single phone number (205-521-0810) is available to VIP riders for
placing trip requests, changing or canceling rides, and checking on late
pick-ups. This number connects to two phone lines in the
reservations/dispatch office, which is located in the general dispatch
and driver break area on the first floor of the operations center. The
VIP reservationists/dispatchers in this area can therefore serve up to
two callers at any given time. When two people are on duty, each can
handle one line. If one person is on duty, he or she can serve a second
caller while another caller is placed on hold.

The two phone lines in the reservations/dispatch area are also used for
outgoing calls. If call backs to riders are being made, or if
dispatchers are calling drivers or BJCTA for rider eligibility
information, only one line is available for incoming VIP calls.

If the two primary lines are in use, calls on the main 521-0810 number
rollover to a third line within the operations center. This line is
covered by a general receptionist located in a different area on the
first floor of the operations center. If this person is not on duty, or
if this line is in use, the call will roll over to a fourth phone line
covered by administrative staff on the second floor of the operations
center.

If the two primary lines and the two roll over lines are in use, calls
appear to go to a general voice mail system. As part of the assessment,
several calls were made to the 521-0810 number during peak call times
(the early morning and the late afternoon). On one occasion, after
several rings, a recorded message indicated that, "There are no
operators available. Press star (\*) to go back to the main menu." When
the star (\*) button was pressed, a voice mail directory was activated
which provided instructions for leaving a voice mail for various First
Transit staff. There did not appear to be any way to get back to the VIP
reservations/dispatch line.

**Reservations and Dispatch Staffing**

The reservations and dispatch office is staffed from 5:00 AM to 8:00 PM
on weekdays; from 7:30 AM to 6:00 PM on Saturdays; and from 1:00 to 5:00
PM on Sundays. Prior to April 2002, three staff covered these hours. A
morning reservationist/dispatcher worked weekdays from 5:00 AM until
1-2:00 PM. An afternoon reservationist/dispatcher worked weekdays from

12:00 noon until 8:00 PM. A third person worked just Saturdays from 7:30
AM until 6:00 PM. Sunday afternoon hours were covered by one of these
three persons on a rotating basis. Therefore, prior to April 2002, only
one staff person was available to handle calls and to manage the
reservations, scheduling, and dispatching processes (along with other
duties) with the exception of the one or two hours on weekdays from noon
until 1:00-2:00 PM.

On April 1, 2002, a fourth reservationist/dispatcher was hired to
provided back up during peak service hours. This person now works a
weekday split shift from 6:00 AM to 10:00 AM and from 2:00 PM until 6:00
PM. At the time of the review, this person was still in training. He was
also responsible for the reconciliation of trip data (entering actual
pick-up/drop-off times and pick-up/drop-off mileage into the system from
completed driver manifests). He was, however, able to provide some back
up to the primary reservationists when the service was busy.

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

Assessment team members observed the reservations/dispatch process for
several hours in the morning on Tuesday, April 30. Observations were
also made for several hours during the morning and afternoon peak hours
on Wednesday, May 1.

It was observed that the personnel in the reservations/dispatch office
were able to directly handle most calls without excessive hold times.
There were times, however, when both lines in this office were in use
for several minutes and calls were directed to the rollover lines. It
was observed that during the morning and afternoon peak hours, the
receptionist who handled the first rollover line walked into the
dispatch office about 1-2 times per hour with completed trip request
forms or with questions about late trips. The administrative staff
person who covers the fourth (rollover) line was not observed coming
down to the dispatch area to relay information during the hours that
were observed.

The back up, using the rollover lines in other areas of the building,
appear to work for trip reservations. In these cases, the receptionist
and the administrative staff person simply record the request on a "VIP
Reservation" form and walk it down when convenient to the dispatch
office for batch scheduling at a later time. This set-up is less
efficient and appropriate, however, for calls checking on the status of
rides and late vehicles. In these cases, the receptionist or
administrative staff person must immediately walk to the dispatch
office, wait until the dispatcher is available to contact the driver on
the radio, and then walk back to their desk to relay the information to
the caller. Although it was not directly observed, it seems that this
process could lead to delays and longer hold times for these "Where's my
ride?" calls.

Six calls were also made to the reservations office at various times
during peak calling hours on these days. On five occasions, the calls
were answered promptly. On one occasion, the phone rang several times
and a recorded message eventually came on indicating that, "No operators
are available. Press star (\*) to go back to the main menu." At this
time, it appeared that all four primary and rollover lines were in use.
A second call was placed immediately after this message was received.
This second, follow-up call was answered promptly.

## Findings {#findings .unnumbered}

1.  The reservations office is staffed from 5:00 AM to 8:00 PM on
    weekdays, from 7:30 AM to 6:00 PM on Saturdays, and from 1:00 to
    5:00 PM on Sundays. 49 CFR section 37.131(b)(1) requires that, "the
    entity shall make reservation service available during at least all
    normal business hours of the administrative offices, as well as
    during times comparable to normal business hours, on a day when the
    entity's offices are not open before a service day."

2.  The current standard for answering incoming calls is that all calls
    are to be answered by the third ring. No standard for hold time has
    been established.

3.  Telephone performance appears to be adequate and does not appear to
    be a capacity constraint. While there are some times when no open
    phone lines are available and customers receive a busy signal, this
    seems to occur for only a short period of time and customers can get
    through if they call back once or twice. Hold times for reservations
    seem short. Hold times for "Where's my ride?" calls can be longer,
    particularly if taken by the receptionist or administrative staff
    who are not located in the dispatch area. These hold times appear to
    be reasonable, however, for this type of service.

## Recommendations {#recommendations .unnumbered}

1.  BJCTA should make reservations services available on Sunday mornings
    to make reservation service available during times comparable to
    normal business hours. BJCTA might want to consider use of voice
    mail to receive reservations during low call volume periods when
    personnel are not otherwise scheduled to work.

2.  BJCTA should consider a more complete standard for phone
    performance. A standard that defines a maximum average hold time for
    any hourly period of the day should be considered. The use of
    standards and performance measurement will help to assure that
    availability of reservations service does not limit availability of
    paratransit service.

3.  BJCTA should consider using a more sophisticated phone system that
    would not only do a better job of managing calls, but would allow
    performance reports to be generated daily. A call management system
    that would hold calls in a central queue and then direct them to the
    first available line in the dispatch office should be considered.
    This system would let the reservationists/dispatchers focus on one
    customer at a time. It would also make the use of rollover lines in
    other parts of the operations center unnecessary. Such a system
    would also be capable of tracking hold time for each call and for
    reporting of hold time information.

# Observations Regarding the Handling and Scheduling of Trip Requests

In this portion of the compliance assessment, the team examined how trip
requests from riders were handled. Particular attention was given to
whether BJCTA 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 BJCTA;

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

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

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

**Consumer Comments**

There were no indications from persons contacted in advance of the
on-site assessment or from a review of complaints on file at FTA or
BJCTA that trip caps were being used or that waiting lists were being
used for non-subscription trips. Agency representatives noted that
clients are not always able to get subscription service and might be
placed on a waiting list, but waiting lists for subscription service are
permitted by the DOT ADA regulations.

Riders and advocates contacted in advance of the on-site assessment
indicated varying experiences regarding trip denials. Four of the six
riders and agency representatives contacted indicated that trip denials
were not a major issue. Three of these individuals indicated that trips
are scheduled within an hour of the requested time. One person noted
that he could recall being denied trips only twice since 1998. Two
persons contacted, however, indicated that trips are denied. One person
indicated that it was difficult to get trips scheduled if calls were
made three or fewer days in advance. She estimated that half of her
requests for next day service are not scheduled. The second person had
not experienced trip denials, but indicated that she had heard from
agency clients that trips are sometimes denied, particularly next day
trip requests.

Only one of the formal complaints filed with the FTA indicated problems
with trip denials and none claimed that trip caps or waiting lists were
being inappropriately used. The person who reported a problem with trip
denials noted that he was unable to book a ride the week of

October 16-20, 2000 and had been told that the schedules for the entire
week were full.

None of the 12 service complaints on file at BJCTA for the period from
August 2001 through February 2002 were related to trip caps, waiting
lists or trip denials.

**Reservations and Scheduling Policies and Procedures**

As noted in the "Background" section of this report, VIP trip
reservations are accepted from

8:00 AM until 4:00 PM, Monday through Saturday, and from 1:00 PM until
5:00 PM on Sunday. The formal policy as indicated in the Rider's Guide
is that trip requests are accepted up to 14 days in advance. Operations
staff indicated, though, that requests up to 30 days in advance are
sometimes accepted.

Reservations and scheduling is performed using the StrataGen Systems
ADEPT[^2] Version 3 scheduling software. The system is owned by BJCTA
and made available to First Transit for use in operating the service.
This system was installed in April 2001. BJCTA and First Transit staff
indicated that there were problems with the transition to this new
system and that several modifications and upgrades have been made since
the system was first installed.

The StrataGen system is designed to permit "real time" reservations and
scheduling that allows for negotiation of ride times when riders call to
request trips. It is designed to permit trip requests to be entered
directly as calls are received. BJCTA staff indicated that they had
hoped to operate the service in this way when the new system was
installed. However, for a number of reasons (described below), a paper
reservations process is used, and "real time" scheduling has not yet
been implemented. Instead, a "batch scheduling" process is used.

When riders call, trip requests are recorded on paper "VIP Reservation"
forms. Callers provide their name, origin, destination, and the date and
time that they wish to travel. Most callers provide an appointment or
desired arrival time when scheduling the "going" portion of their trip.
A requested pick-up time is typically stated for the "return" portion of
the trip. Because the request is not being entered into the system and
scheduled at the time of the call, a scheduled pick-up time is not
provided when appointment times are given. If callers ask when they will
be picked-up, reservationists/schedulers indicated that they typically
tell the callers to be ready an hour before their appointment. This
practice varies from the reservations process detailed in the Rider's
Guide, which indicates that a scheduled time will be provided and that
riders should be ready and waiting for vehicles 20 minutes before their
scheduled pick-up time.

Completed VIP Reservation forms are filed by trip date. The
reservationists/schedulers then enter and schedule trip requests into
the StrataGen system when they have time. Some trip requests are entered
and scheduled during off-peak hours on the day the request was placed,
but most are entered and scheduled one day before service is to be
provided. For example, on

April 30, the reservationist/scheduler entered most of the
non-subscription trip requests for

May 1, which were taken from the vertical file box.

As each trip request is entered, StrataGen suggests routing and vehicle
assignments and the scheduler selects what she believes to be the best
option, based on her knowledge of the service area and system.
Periodically, as trip requests are being scheduled, the scheduler
"re-batches" the trips, which means that she asks the system to generate
updated schedules based on what trips are in the system. When the system
re-batches all trips, those trips that are not "anchored" can be moved
to different runs, and scheduled pick-up and drop-off times can be
adjusted within established parameters. Trips that were previously
scheduled on runs can also be taken off of those runs by the system and
placed in one of two "holding" files. One file is called the "standby
list," and the other is called the "wait list." First Transit staff
explained that the standby list is supposed to be used when the trip
cannot be scheduled at the time of the call and no promise of a ride is
given to the caller (i.e., denied trips). The wait list is supposed to
be used for trip requests that cannot be scheduled at the time of the
call, but for which service is promised and only specific pick-up times
are needed. Trips that end up on the standby or wait lists have to be
manually fit onto runs or placed on extraboard/back-up runs. According
to First Transit's General Manager, about 30 trips a day end up on the
wait or standby lists which then have to be rescheduled on the system or
manually scheduled.

The scheduler places as many trips as possible on scheduled runs. A few
trips each day cannot be placed on scheduled runs. These trips are put
in the standby list and are then either placed on extraboard/back-up
runs or are same day dispatched as cancellations and no-shows open times
on runs. Once the scheduler has entered and scheduled all trips requests
from the "VIP Reservations" vertical file, she scans each route on the
computer to see if it appears to be reasonable.

The morning reservationist/dispatcher is primarily responsible for
developing schedules each day. She indicated that she usually completes
the scheduling process for the next day by 1:00 or 2:00 PM, which is
when she ends her day. Any trip requests for the next day received after
this time must be scheduled into the system by the afternoon
reservationists/dispatchers. The same process basic process is used,
with trip requests first being recorded on the paper forms and then
being entered and scheduled as time permits. The standby and wait lists
are checked first thing each morning to see if any trips have been added
the prior afternoon. If trips are on the lists, they are added to
extraboard/back-up runs or are same day dispatched.

As trips are entered and scheduled, the scheduler records the scheduled
pick-up times on the paper VIP Reservations form. The afternoon
reservationist/dispatcher is then supposed to call back all
non-subscription riders scheduled for the next day to advise them of
their scheduled pick-up times. Call-backs are supposed to be made after
the reservations close at 4:00 PM.

Ongoing subscription trips are maintained in the system and are loaded
on runs as new days of service are created. Subscription trips are
permitted for any purpose as long as they recur at least once a week.
About 70-80% of all trips appear to be subscription trips, most for
agency programs. Staff noted that new subscription trips often cannot be
accommodated and that riders desiring this service are placed on a
waiting list. These riders must call-in regularly to book their rides.
The lead scheduler indicated that the list of subscription trips is
reviewed every three to six months, but that most agency trips have
remained the same for years.

A significant percentage of return trips are handled on a "will-call"
basis. That is, the return time is not entered into the system and the
rider calls back on the day of service when he or she is ready to be
picked up. Will-calls are permitted for any purpose. Staff indicated
that about 10-15 will-call return trips are handled each day. Given that
about 80-90 one-way, non-subscription trips are provided each day, this
suggests that about 28% of all non-subscription return trips are handled
as "will-calls." Most will-calls occur during the afternoon, when people
are finished with their appointments. Although StrataGen has the
capability of storing trips in a will-call list, currently, First
Transit does not record the will-call request until the rider calls and
asks to be picked up. As a result, dispatchers never know for any given
day how many or when will-calls might be expected to occur.

VIP riders are also allowed to call for an early pick-up if they are
done ahead of schedule. Dispatchers will try to accommodate the
requested change in most cases.

According to the reservationists/dispatchers, a batch scheduling system
is still being used and trip requests are still being recorded on paper
for several reasons. First, riders are not used to providing detailed
address information when they call and place trip requests. Without
detailed address information, the process of scheduling trips can be
time-consuming. Specific address information must first be obtained. The
origin and destination must then be geo-coded. It was indicated that
this often took several minutes. Second, it was noted that the
reservationists also serve as dispatchers. They also have other duties,
including selling fare media and checking drivers in and out at the
beginning and end of their shifts. It is therefore not possible for them
to focus on a more detailed, automated real-time reservations and
scheduling process. Finally, it was noted that there have been problems
with the StrataGen system. Information is recorded on paper as a backup
just in case trips are mishandled in the system.

**Reported Trip Denials**

Monthly VIP service reports for the period from September 2001 through
February 2002 were reviewed as part of the assessment. These reports
indicated that all trip requests for this

six-month period had been scheduled. No trip denials were reported.

Prior to the on-site assessment, BJCTA also provided summary service
reports for October 1998 through February 2002. Again, these reports
showed no trip denials.

BJCTA and First Transit staff also indicated that all trip requests are
recorded and accommodated.

**Observations of the Trip Reservations Process**

The assessment team sat with reservationists throughout the day on
Tuesday, April 30, 2002. Direct observations of the handling of trip
requests were made from about 8:30 until 11:00 AM and again in the early
afternoon from about 1:30 until 3:00 PM. Additional observations were
made on Wednesday morning and afternoon, May 1, 2002

During the observations, the assessment team could not listen to the
conversations between the reservationists and callers because
"splitters" were not available. Assessment team members therefore
observed how the reservationists handled calls and asked them to
summarize the conversation and actions taken for each call.

Even though the reservations process was observed for six hours during
peak calling times, only 38 trip requests were placed during this time.
All 38 were recorded on VIP Reservation forms and filed for scheduling.
No callers were told that the trip could not be accommodated.

Table 4 below shows the distribution of trip requests by the number of
days advance notice given. As shown, the vast majority of trips were
requested less than seven days in advance. Also, eight trip requests
were "same day" requests with callers asking for trips in some cases
only hours away. These same day requests were all added to vehicle
schedules for the day and radioed to drivers on the road or added to
extraboard schedules.

**Table 4. Distribution of Trip Requests by the Amount of Advance Notice
Provided,**

**38 Observed Trip Requests 4/30/02-5/1/02**

  ---------------------------- --------------------- --------------------
  **\# Of Days In Advance**    **\# Of Trips**       **Percent**

  Same Day                     8                     21%

  1 Day                        5                     13%

  2 Days                       6                     16%

  3 Days                       5                     13%

  4 Days                       2                     5%

  5 Days                       2                     5%

  6 Days                       4                     11%

  7 Days                       0                     0%

  8 Days                       2                     5%

  9 Days                       2                     5%

  10 Days                      0                     0%

  11 Days                      0                     0%

  12 Days                      1                     3%

  13 Days                      0                     0%

  14 Days                      1                     3%

  TOTALS                       38                    100%
  ---------------------------- --------------------- --------------------

This distribution of trip requests suggests that riders are not overly
concerned about placing trip requests several days in advance to be sure
that the requests are accommodated. The large number of same day
requests indicates that riders have come to expect that capacity will be
available even on the day of service.

The assessment team also examined completed VIP Reservation forms to see
how

non-subscription trips requests were scheduled. Forms for six days in
April 2002 (April 22, 23, 24, 25, 29, and 30) were reviewed. The
"scheduled times" which were added to the forms during the scheduling
process were compared to the stated appointment times or the requested
pick-up times listed.

Table 5 provides summary information from this analysis. For each day,
it shows the total number of completed VIP Trip Reservation forms
examined, the number scheduled appropriately (within one hour of the
requested time or responsive to the appointment time), the number not
scheduled and left on standby, the number that had scheduled times
greater than one hour from the requested pick-up time and the number
that were scheduled less than twenty minutes before the requested
appointment time.

**Table 5. Scheduling of Non-Subscription Trips for Six Days in April
2002**

  ---------- ------------ ---------------- ----------- -------------- ---------------
  **Date**   **Total Trip **Trips          **Trips     **Trips        **Trips
             Requests     Scheduled        Left on     Scheduled More Scheduled Less
             Examined**   Responsively**   Standby**   than 1 Hour    Than 20 Minutes
                                                       from Requested Before
                                                       Time**         Appointment**

  4/22/02    63           48               5           1              9

  4/23/02    55           41               11          0              3

  4/24/02    52           38               9           0              5

  4/25/02    57           44               7           1              5

  4/29/02    36           27               5           1              3

  4/30/02    32           17               10          1              4

  TOTALS     295          **215**          **47**      **4**          **29**

  \%                      **73%**          **16%**     **1.4%**       **10%**
  ---------- ------------ ---------------- ----------- -------------- ---------------

As shown, about 7-8 trips per day could not be scheduled onto set runs
and were placed on the standby list. These trip requests were then
served by back-up drivers or same day dispatched.

Four (4) of the sampled trips were scheduled for pick-up more than one
hour from the requested time. 49 CFR ss 37.131(b)(2) states that,
..."the entity shall not require an ADA paratransit eligible individual
to schedule a trip more than one hour before or after the individual's
desired departure time." FTA considers this practice a denial of
service.

Twenty-nine (29) of the 295 trip requests examined also were determined
to have scheduled times that were not responsive to requests for
appointments or drop-off times. All of these trips had scheduled
drop-off times that were either after the stated appointment time, or
scheduled pick-up times less than 20 minutes before the appointment
time. If the vehicle were to arrive late in the twenty-minute pick-up
window, it is likely that riders would arrive late to appointments. None
of the return trip requests were scheduled more than an hour from the
requested pick-up times.

The review of the VIP Reservation forms also indicated that in many
cases very minimal information is recorded as riders place trip
requests. Abbreviations were often used for destinations. Partial
address information was often recorded for origins and destinations.
Reservationists appear to know most riders and therefore do not find it
necessary to write down detailed trip information. However, this
practice makes it more difficult to enter and schedule trip requests
because the automated system requires detailed address information in
order to geocode origins and destinations.

It was also observed that reservationists typically do not read back and
verify trip information with callers. Again, the process is very
congenial and many trips and riders are well known. However, for new
riders or trips that are not common, this could result in
miscommunications of trip information and errors in scheduling of trips.

**Findings**

1.  Four (4) of 295 trip requests sampled between April 25 and April 30
    were scheduled for pick-up more than one hour from the requested
    time. FTA considers this practice a denial of service.

2.  BJCTA does not appear to use trip caps in the scheduling of ADA
    Complementary Paratransit trips.

3.  BJCTA does not appear to use waiting lists in a way that violate the
    DOT ADA requirements. Some trips are placed on a standby list or
    waiting list when they cannot be scheduled on set runs, but all
    trips on standby or wait lists appear to eventually be scheduled.

4.  Limited capacity does not appear to be a cause of BJCTA denial of
    trip requests. All trip requests that were observed and examined
    appeared to be served. However, in addition to the trip denials
    cited in finding number one, some trips are scheduled at times that
    may not meet rider needs to make appointments. Of the 295 trip
    requests examined, 29 (or 10%) were assigned scheduled drop-off
    times that were either after the stated appointment times or pick-up
    times less than 20 minutes before the appointment times. Scheduling
    pick-ups less than 20 minutes before appointment times could cause
    riders to be late for appointments since vehicles can arrive for
    pick-ups up to 20 minutes after the scheduled time.

5.  The information recorded by reservationists/dispatchers on VIP
    Reservation forms is often incomplete. This could cause trips to be
    scheduled incorrectly.

6.  Reservationists/dispatchers also do not routinely verify trip
    information with callers. This could lead to miscommunication
    between callers and schedulers and inaccurate scheduling of trips.

7.  The StrataGen scheduling system is not being used as originally
    planned. Real-time scheduling is not being done due to problems with
    the system and inadequate staffing of the reservations function,
    which does not allow adequate time to be spent entering trip
    requests directly into the system when riders call.

**Recommendations**

1.  Riders should be instructed to provide more detailed trip
    information when placing trip requests. This would remove one
    obstacle that is now making it difficult to properly use the
    automated scheduling system for real-time scheduling.

2.  BJCTA should consider separating the functions of
    reservations/scheduling and dispatch. This would allow
    reservationists to focus on properly entering trip requests directly
    into the StrataGen system.

3.  If trip requests were entered directly into the system and real-time
    scheduling was fully implemented, reservationists would have an
    opportunity to negotiate trip times with riders. This may then
    enable trip requests during peak travel times to be adjusted
    slightly and to be accommodated with more responsive schedule times.
    It would also eliminate the need for many call-backs.

4.  If the implementation of real-time scheduling and the negotiation of
    trip times do not allow all trips to be scheduled responsively,
    BJCTA should consider expanding VIP service capacity during peak
    travel hours so that all trips can be responsively accommodated.

5.  Reservationists should repeat all trip information back to callers
    at the end of the booking process to ensure that the request has
    been properly recorded/entered and to ensure that callers have a
    clear understanding of pick-up and estimated arrival times.

6.  It is recommended that additional staff training in the StrataGen
    computer program be provided and that staff begin fully utilizing
    the software available to them. It also is recommended that BJCTA
    and First Transit communicate with StrataGen to clearly indicate the
    problems that appear to still exist after the April 2002 system
    upgrade.

7.  It is recommended that, with additional training, the scheduling
    process be refined so that trips are not repeatedly batched
    throughout the scheduling process, which can result in a lot of
    movement of trips. It also is recommended that the scheduling
    parameters be carefully reviewed so that staff is aware of computer
    assumptions about travel speeds, pick-up and drop-off windows, etc.

# Observations Regarding Service Provision

The DOT ADA 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 BJCTA;

-   BJCTA'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;

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

-   Actual pick-up and drop-off times reported on completed manifests
    for two randomly selected days were used to tabulate on-time
    performance to compare to reported performance; and

-   Travel times for a sample of relatively long rides on the VIP
    service were analyzed.

**Consumer Comments**

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

on-time performance as a major service issue. Concerns were expressed
about pick-ups being very early sometimes and very late other times.
Late pick-ups for return trips were cited as a particular problem.
Consumers contacted also indicated that scheduled pick-up times are
often not communicated to callers. Individuals contacted also said that
very late pick-ups often resulted in arrivals well past appointment
times.

Long ride times were also reported to be a significant problem. Four of
the six people contacted indicated that ride times seem to be
excessively long. Two local agency staff indicated that ride times of
two hours or more are common for certain clients. The other two people
contacted indicated that ride times have gotten better in the past 4-6
months but that long rides still occur.

On-time performance and long ride times were also the predominant issues
raised in formal complaints on file with FTA. Eight of the ten
complaints reviewed cited long ride times as a major issue. On-time
performance was also indicated in eight of the ten complaints on file.
Ride times of up to three hours were cited in these complaints.

Of the twelve service complaints received by BJCTA between August 2001
and February 2002, half were about poor on-time performance. None of the
12 internal BJCTA complaints were related to on-board travel time.

**BJCTA Service Standards and Policies**

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

BJCTA has established a 40-minute pick-up window for the VIP service.
Riders are asked to be ready 20 minutes before their scheduled pick-up
time. Riders are also told that the vehicle can arrive up to 20 minutes
after the scheduled pick-up time.

The contract between BJCTA and First Transit indicates that pick-ups are
considered to be late if made more than 20 minutes after the scheduled
time. There is no requirement regarding early arrivals. The stated goal
in the contract is for at least 95% of all pick-ups to be made no more
than 20 minutes after the scheduled time. If performance falls below 95%
for any month, BJCTA reserves the right to assess a \$500 performance
penalty.

The contract between BJCTA and First Transit also establishes a
performance standard for on-time arrivals. Drop-offs are considered late
if they are made more than 20 minutes after the stated appointment time.
BJCTA has established a 95% on-time arrival goal and reserves the right
to assess a \$500 penalty if performance falls below 95% in any given
month.

***Travel Time Policies and Standards***

BJCTA's contract with First Transit establishes maximum ride times based
on trip distance. These maximum ride times are as follows:

-   Trips less than 10 miles in length should have a ride time of no
    more than 60 minutes;

-   Trips of 10 miles to 20 miles should have a ride time of no more
    than 90 minutes; and

-   Trips longer than 20 miles should have ride times of no more than
    120 minutes.

It is BJCTA's goal that 95% of all trips should meet these ride time
standards. A penalty of \$500 can be imposed if this goal is not met in
any given month.

**Observations of Scheduling and Dispatching**

First-hand observations of the scheduling and dispatching processes
identified several issues that could contribute to service delivery
problems. These include:

-   The reservations/scheduling/dispatch function appears to be
    understaffed. "Dispatchers" have multiple responsibilities. In
    addition to handling the two-way radio and monitoring runs and
    drivers, they record trip requests, sign drivers and vehicles in and
    out, provide general information about the service, and answer
    "Where's my ride?" calls. They also are responsible for selling
    tickets and passes to the public who appear in person, although most
    tickets and passes are sold through the mail or at Central Station.
    Additionally, the morning dispatcher is responsible for developing
    the schedules, and the afternoon dispatcher must handle and schedule
    same day "will-call" requests. On weekdays, there is one morning
    dispatcher, who works from 5:00 AM until 1:00 or 2:00 PM, and an
    afternoon dispatcher who arrives about noon, at which time the
    morning dispatcher finishes scheduling trips for the following day.
    A new dispatcher has been hired (a former driver) to work a split
    shift from 6:00 AM to 10:00 AM and from 2:00 PM until 6:00 PM. He
    began training in early April and, at the time of the assessment,
    was mainly helping to provide back up on the phones. The new
    dispatcher also is responsible for entering actual trip information
    from completed manifests into the system. This appears to
    significantly limit his ability to assist with the reservations,
    scheduling, and dispatch process. On Saturdays and Sundays, one
    person covers all reservations, scheduling, and dispatch functions.

-   The lead scheduler does not appear to run an "exceptions" report as
    part of the schedule clean-up process. This is typically done in
    many paratransit operations to identify trips that are scheduled to
    be too long or which may otherwise not meet established service
    parameters. Staff was not familiar with such a report in the
    StrataGen system. This could be because the system has not been
    set-up to generate this type of report. It also could be that staff
    is not aware of all of the system capabilities.

-   Because dispatchers have multiple functions, they do not appear to
    proactively monitor drivers' adherence to schedules. Drivers did not
    radio in pick-ups and drop-offs, and dispatchers were not observed
    to regularly check with drivers on the status of runs. Dispatchers
    mainly appeared to be responding to driver requests for assistance
    and to be checking with drivers when riders called to report that
    vehicles were running late. In fact, the control of runs appears to
    rely heavily on rider calls. The Rider's Guide instructs riders to
    call if their vehicle is more than 20 minutes late and then suggests
    that riders call every 20 minutes thereafter until the vehicle
    arrives. The Rider's Guide specifically states, "We rely on you to
    let us know your vehicle is late. The longer you wait (to report
    your vehicle is late), the longer it takes for us to come."

-   It was observed that several radio calls from drivers went
    unanswered when dispatchers were busy handling calls or other
    duties.

-   As detailed in the previous section of this report, the lead
    scheduler indicated that subscription trip information is reviewed
    and updated every 3-6 months and that many subscription trips have
    not been updated for a year. A detailed review of completed
    manifests indicated that pick-up and drop-off times in the system
    for many subscription trips appeared to be inaccurate. Drivers were
    routinely making group pick-ups and drop-offs an hour or more before
    the times indicated on the manifests. When asked about these
    situations, dispatchers indicated that changes had been made with
    the agencies and/or riders but that the latest information was not
    yet in the system. In many cases, these trips were scheduled for
    peak travel times but were not actually being performed at those
    times (e.g., scheduled for an 8:30 or 9:00 AM drop-off, but actually
    dropped-off at 7:30 AM). If these trips have in fact been
    rescheduled with the riders and agencies, this would open up peak
    hour capacity. However, the scheduling system still treats these
    trips as scheduled for 8:30-9:00 AM and is unable to offer other
    trips at this time.

-   A review of completed manifests also indicated that drivers
    regularly run schedules out of order. In some cases, the actual
    service provided is very different from the runs created by the
    schedulers. One such manifest is provided in Attachment F. This
    manifest shows that the first pick-up made by the driver was
    actually the 17^th^ entry on his manifest. The run was completed in
    an order completely different from what was originally scheduled.
    This did not appear to be an aberration but was observed on many
    manifests that were examined. Drivers could be performing schedules
    out of order due to inaccurate and outdated trip information. They
    could also be operating in this way due to the lack of ongoing
    dispatcher control of the service. Arrangements between drivers and
    riders/agencies may be made without the dispatchers/schedulers
    knowledge.

-   As noted in the previous section of this report, a significant
    number of return trips are handled on a "will-call" basis. VIP
    riders are not required to book return trips and simply call on the
    day of service when they are ready to be picked-up to return home.
    Almost 30% of all non-subscription return trips are not scheduled
    and are handled as will-calls. While this provides riders with a
    high quality of service, it can be difficult to serve will-call
    trips during peak hours of operation.

-   As noted in the previous section of this report, a significant
    number of same day trip requests are also accepted and accommodated.
    Over 20% of the trip requests observed during the\
    on-site assessment were same day trip requests. Riders appear to
    also be regularly permitted to call and change scheduled trip times
    on the day of service. Again, this provides riders with a very high
    level of service, but can make it very difficult to manage
    operationally.

-   Problems with the use and/or functioning of the StrataGen system
    were noted. For example, as new trip requests were added into the
    system, the scheduler would frequently "re-batch" all trips. When
    trips were re-batched, it was observed that subscription trips would
    "fall out" and be placed on the standby or wait list. Typically,
    subscription trips are "anchored" on specific runs so that pick-up
    and drop-off times for these trips are not changed in the scheduling
    process. Subscription trips could be moving in the StrataGen system
    either because the system is not properly set up or because staff is
    not yet proficient on the use of all of the system features.

-   In the current method of reservations and scheduling, trips that
    have been scheduled often "fall off" the schedule and end up in the
    standby or wait list files. Staff did not appear to check these
    files frequently enough to catch all of the trips that had been
    removed from the schedules. While on-site, a subscription rider
    reported being picked up two hours late. When this situation was
    investigated with staff, it was discovered that the trip had been
    automatically removed from the schedules and placed in the standby
    file. The scheduler had not reviewed the file before manifests were
    finalized and the trip was therefore never placed on a scheduled
    run. Staff discovered that the pick-up had not been made only when
    the rider called reporting the vehicle was late.

**Driver Interviews**

[]{.mark}

While on-site, the assessment team interviewed seven VIP drivers. All
drivers were employees of First Transit. These interviews sought to
gather the following information:

-   Whether the drivers felt they received adequate training,

-   Drivers' concerns about their vehicles and schedules, and

-   Whether the drivers understood VIP operating policies

Of these seven drivers, the longest tenure with First Transit was seven
months (the majority of VIP drivers had been with First Transit for less
than one year).

The following is a summary of driver comments.

**Training.** Overall, the drivers were satisfied with the training they
received from First Transit. Drivers with previous experience received
three weeks of training, including both classroom and on-the-road
training. Drivers with no experience reported receiving up to eight
weeks of training. Drivers were all complimentary of the training. They
believed that they received sufficient training in the area of passenger
sensitivity. Because they had been VIP drivers for only a short period,
some of the drivers had not yet received any refresher training. Other
drivers cited recent additional training in sensitivity, ergonomics, and
emergency situations.

**Vehicles.** Drivers were generally satisfied with their vehicles. Only
one driver said that he drove the same vehicle most days. Several of
them cited a few problems with wheelchair lifts "getting stuck" on
occasion, but they all said that when they reported vehicle problems,
the vehicles were promptly repaired.

**Schedules.** Drivers had a variety of opinions on their daily vehicle
manifests. They said that the schedules were generally tight, but mostly
manageable. Some routing was "illogical." All of the drivers rearranged
their schedules, as they felt necessary. Only one driver said that she
calls the dispatcher to tell her that she is switching the order of
pickups and drop-offs listed on the manifests. All of the other drivers
said that they were allowed to switch the order without asking the
dispatcher beforehand, and they did not need to inform the dispatcher of
changes after the fact.

Four of the drivers interviewed said that they ran late (more than 30
minutes behind schedule) more than once per week. One driver said that
Mondays and Fridays were usually the worst days. When the drivers are
running late, they know to call the dispatcher, who might remove a
passenger from their manifest. Four of the drivers cited passenger trips
of longer than one hour; however, three of the drivers said this was a
rare occurrence.

Drivers said that they received adequate support from the dispatchers.
They also cited help from fellow drivers in locating unfamiliar
addresses.

One driver said that he wanted the grid coordinates put back on the
manifest to help him locate some unfamiliar addresses.

**Procedures.** All drivers knew the steps to follow if they arrived at
a pickup ahead of schedule. They understood that they are to wait at
least five minutes after the start of the pickup window. During this
waiting time, they call the dispatch to see if the passenger is
available to leave early.

If a passenger is not ready for an on-time pickup, the drivers follow
the VIP policy of waiting at least five minutes. Then they call the
dispatcher, who gives them permission to record the passenger as a
no-show and to proceed to the next stop. One driver said that if she
knows the passenger, she may walk up to the door and ring.

**Review of the Call-Back Process**

As noted in the "Observations Regarding the Handling and Scheduling of
Trip Requests" section of this report, the current trip reservations and
scheduling process requires schedulers/dispatchers to call riders back.
Riders are not given scheduled pick-up times at the time that they call
to place trip requests. Instead, the practice is to call riders back
after 4:00 PM on the day before service to let them know the scheduled
times of their trips. Information about call-backs (that the call back
was successful, or that there was no answer) is recorded on the VIP
Reservation forms.

As part of the on-site assessment, call-back information recorded on VIP
Reservation forms was reviewed for six sample days in April 2002 (April
22, 23, 24, 25, 29, and 30). Table 6 below summarizes this analysis. It
shows the total number of VIP Reservation forms examined, the number
that showed that call-backs had been successfully completed, the number
of unsuccessful attempted calls, and the number that did not indicate
any call-back.

**Table 6. Call-Backs for Non-Subscription Trip Requests**

**Six Sample Days in April 2002.**

  ------------ --------------- --------------- --------------- ---------------
  **Date**     **Number of     **Number of     **Number of     **Number of
               Trip Forms      Call-Backs      Call-Backs      Call-Backs Not
               Examined**      Successfully    Attempted But   Made**
                               Completed**     Unsuccessful    
                                               (e.g., no       
                                               answer)**       

  4/22/02      42              1               3               38

  4/23/02      41              10              4               27

  4/24/02      33              1               0               32

  4/25/02      37              6               0               31

  4/29/02      40              18              3               19

  4/30/02      42              21              0               21

  **TOTALS**   **235**         **57**          **10**          **168**
  ------------ --------------- --------------- --------------- ---------------

As shown, only 57 of the 235 trip forms examined (24%) indicated that
call-backs were successfully made. In 168 instances, there was no
indication on the form that any attempt had been made to make a
call-back. It was also noted that many times, the scheduled times
recorded on the VIP Reservation forms were significantly different from
the requested times and no

call-back was made. In these instances, riders would not ever know the
real scheduled time and would probably consider the vehicle to be early
or late when it arrived.

When this information was presented to First Transit staff, they
confirmed that call-backs are often not made due to understaffing in the
reservations, scheduling, dispatch area. Staff indicated that they rely
on riders to call-in the morning of their trips to request specific
schedule times. Based on conversations with customers, it appears that
some regular, long-term riders are used to doing this. Other riders,
however, are not aware that they need to call and do not know when to
expect the vehicle. These riders expressed concerns about the lack of
reliability of the system.

**Reported On-Time Performance**

"Paratransit Summary" reports prepared by BJCTA for the period from
September 2001 through February 2002 were obtained and reviewed as part
of the assessment. On-time pick-up information was provided in these
reports. On-time arrival information is not included in monthly
reporting. Average monthly on-time pick-up performance for this period
is shown in the table below.

**Table 7. BJCTA Reported On-Time Performance for the VIP Service,**

**Based on On-Time Pick-Ups Only, September 2001 -- February 2002.**

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

  September, 2001                97%

  October                        96%

  November                       95%

  December                       97%

  January, 2002                  97%

  February                       97%
  ------------------------------ ----------------------------------------

The First Transit staff person responsible for preparing monthly reports
indicated that calculations of on-time performance are based on
information provided by reservationists/dispatchers. She indicated that
she inquires about the number of trips performed late each day and is
given a number by the reservationists/dispatchers. First Transit has
only recently begun capturing actual pick-up times from completed driver
manifests. At the time of the assessment, actual pick-up and drop-off
times were being entered into the system for the month of April 2002.
Once this month was completed, First Transit staff indicated that
information for prior months would be entered.

**Calculated On-Time Performance for Sample Days**

The assessment team reviewed the accuracy of on-time performance
reported by BJCTA by calculating on-time performance from the original
run manifests for two randomly selected days -- Tuesday, October 23,
2001 and Wednesday, March 20, 2002. On-time pick-ups as well as

on-time arrivals were noted. Actual pick-up times recorded were compared
to scheduled times to determine if pick-ups were made on time. Actual
drop-offs were compared to any listed appointment times to determine if
riders arrived on time.

Table 8 below shows on-time pick-up performance for these two sample
days. As shown, between 63% and 68% of pick-ups were made from 20
minutes before to 20 minutes after the scheduled pick-up time (the
defined on-time window). Another 20-25% of pick-ups were made early
(more than 20 minutes before the scheduled pick-up time). About 6-8% of
all pick-ups were made 1-20 minutes late (21 to 40 minutes after the
scheduled pick-up time), and about

4-5% of all pick-ups were made more than 20 minutes late (41 or more
minutes after the scheduled time).

**Table 8. Calculated On-Time Performance Based on Pick-Ups,**

**Tuesday, October 23, 2001 and Wednesday, March 20, 2002**

  ---------------------------------- ----------- --------- --------- ---------
                                     **October             **March   
                                     23, 2001**            20,       
                                                           2002**    

                                     \# of Trips \%        \# of     \%
                                                           Trips     

  61 or more minutes before the      18          5.3%      7         1.9%
  scheduled pick-up time.                                            

  41-60 minutes before the scheduled 9           2.6%      6         1.7%
  pick-up time.                                                      

  21-40 minutes before the scheduled 58          17.0%     59        16.3%
  pick-up time.                                                      

  20 minutes before to 20 minutes    216         63.5%     247       68.4%
  after the scheduled pick-up time.                                  

  21-40 minutes after the scheduled  22          6.5%      28        7.8%
  pick-up time.                                                      

  41-60 minutes after the scheduled  14          4.1%      7         1.9%
  pick-up time.                                                      

  61 or more minutes after the       3           0.9%      7         1.9%
  scheduled pick-up time.                                            

  TOTALS                             340         99.9%     361       99.9%
  ---------------------------------- ----------- --------- --------- ---------

As shown in Table 9, sample results are different from the on-time
performance typically reported by BJCTA. BJCTA monthly reports show
on-time pick-up performance at between 95% and 97%. These reported
percentages are based only on trips picked up late (early pick-ups are
not considered). The sample days examined showed late pick-ups running
at between 11% and 12%, which would suggest on-time performance based
just on late pick-ups at 88-89%.

Table 9. Comparison of On-time Performance from Sampled Trips to BJCTA
Reports

  -------------------- -------------- -----------------------------------
  Data Source          Date           On-time pick-ups (20 minutes or
                                      less after the scheduled pick-up
                                      time)

  Assessment Team      October 23,    88.5 %
  Sample               2001           

  Assessment Team      March 20, 2002 88.4 %
  Sample                              

  BJCTA Monthly        N/A            95-97 %
  Reports                             
  -------------------- -------------- -----------------------------------

As noted, a large percentage of pick-ups (20-25%) are made early. In
some cases, early pick-ups may be the result of riders wanting to return
before their scheduled pick-up times and calling for earlier pick-ups on
the day of service. First Transit staff also indicated that, in some
cases, revised pick-up times have been negotiated (sometimes between
drivers and riders or agencies) and these new times have not yet been
put into the system. Even allowing for these issues, though, the number
and percentage of early pick-ups is large and indicates that drivers may
be arriving early to be able to make all of the pick-ups that are
scheduled.

Table 9 below shows estimated on-time performance based on appointment
and arrival times for the two sample days examined. As shown, arrivals
were made on or before appointment times only 78% of the time on October
23, 2001 and about 70% of the time on March 20, 2002. A fairly large
percentage of drop-offs (22-30%) were made late. Also, between 49% and
57% of drop-offs were made more than 20 minutes early and between 27-28%
of drop-offs were made more than 40 minutes before the listed
appointment time.

As noted above, the contract between BJCTA and First Transit allows
drop-offs to be made up to 20 minutes after the appointment time without
penalty. Table 10 shows that, between 10% and 17% of drop-offs are made
from 1-20 minutes late. Another 12% of drop-offs were made more than 20
minutes after the appointment times shown on the manifests.

**Table 10. Calculated On-Time Performance Based on Arrivals**

**Tuesday, October 23, 2001 and Wednesday, March 20, 2002**

  ---------------------------------- ----------- --------- --------- ---------
                                     **October             **March   
                                     23, 2001**            20,       
                                                           2002**    

                                     \# Of Trips \%        \# Of     \%
                                                           Trips     

  61 or more minutes before the      22          12.4%     29        16.2%
  appointment time.                                                  

  41-60 minutes before the           26          14.7%     21        11.7%
  appointment time.                                                  

  21-40 minutes before the           52          29.4%     37        20.7%
  appointment time.                                                  

  20 minutes before to 0 minutes     39          22.0%     41        22.9%
  after the appointment time.                                        

  *Total early or on-time*           *139*       *78.5%*   *128*     *71.5%*

  1-20 minutes after the appointment 17          9.6%      30        16.8%
  time.                                                              

  21-40 minutes after the            14          7.9%      14        7.8%
  appointment time.                                                  

  41 to 60 minutes after the         3           1.7%      5         2.8%
  appointment time                                                   

  61 or more minutes after the       4           2.3%      2         1.1%
  appointment time.                                                  

  *Total Late*                       *38*        *21.5%*   *51*      *28.5%*

  TOTALS                             177         100%      179       100%
  ---------------------------------- ----------- --------- --------- ---------

Again, based on information from reservationists/dispatchers, some of
this apparent untimely performance is likely due to changes in
appointment times that have been made verbally with riders and agencies
that have not yet been reflected on the manifests. Even with this
allowance, however, the number and percentage of very early and late
drop-offs is high.

**Reported ADA Complementary Paratransit Travel Times**

As noted above, First Transit is currently in the process of entering
actual pick-up and drop-off times and actual pick-up and drop-off
odometer reading into the StrataGen system. At the time of the
assessment, actual information was in the system for parts of April
2002, and for selected sample days in prior months. Consequently, BJCTA
did not yet have regularly generated reports showing actual VIP travel
times.

BJCTA was able, however, to prepare travel time reports for days for
which actual trip data had been entered. An estimate of typical travel
times was prepared as part of the assessment using actual data entered
for November 30, 2001. This sample report showed the following:

-   312 trips (71.0%) had travel times of 60 minutes or less.

-   53 trips (12.0%) had travel times of 61-90 minutes.

-   46 trips (10.4%) had travel times of 91-120 minutes.

-   20 trips (4.5%) had travel times of 121-150 minutes.

-   6 trips (1.4%) had travel times of 151-180 minutes.

-   3 trips (0.7%) had travel times of 181 or more minutes.

It was not possible, however, to determine how many of the trips on this
day were within the travel time standards set by BJCTA. The "VIP
Exceptions Report," which had been developed by StrataGen to compare
actual ride times to trip miles, was found to be set-up incorrectly. It
showed on-board trip miles rather than shortest-path or direct miles for
trips. So, for example, a relatively short trip (say 5 miles) might be
grouped with several other trips. The rider might be on board for 15
miles and the trip might take 85 minutes. The existing StrataGen report
would show this as a 15-mile trip and the travel time of 85 minutes
would be acceptable given the current standard. The trip should have
been shown, however, as a 5-mile trip with a travel time 25 minutes
greater than the 60-minute maximum established by BJCTA.

**Review of ADA Complementary Paratransit Travel Times for a Sample of
Long Trips**

The assessment team drew a sample of 20 VIP paratransit trips selected
from completed driver manifests for October 23, 2001 and March 20, 2002.
The manifests were scanned for trips with actual travel times that were
long (typically more than 60 minutes) with 11 of those sampled being
longer than 120 minutes. The scheduled and actual paratransit trip
information was recorded, including pick-up and drop-off times and
actual odometer readings (used to calculate trip length for each
passenger). For comparative purposes, the estimated direct driving
distance was calculated for each trip using MapQuest, rather than the
shortest path method. It was felt that by using MapQuest, the driving
distances would be more accurate.

Fixed route trip itineraries for each trip were then developed with the
assistance of BJCTA's fixed route customer service supervisor. The start
and end times for comparable fixed route trips, including transfer
times, were calculated for each trip. The itineraries were based on
scheduled paratransit drop-off times for going trips and scheduled
paratransit pick-up times for return trips. All trips required
transferring at Central Station. An allowance for travel time to and
from bus stops was added at the rate of 5 minutes for less than 2
blocks, 10 minutes for 2 to 6 blocks, and 15 minutes for more than 6
blocks.

Table 11 shows the results of the travel time analysis performed by the
assessment team. The table includes the following information:

-   Origin and destination addresses for selected paratransit trips

-   Direct driving ("Map") mileage for the paratransit trip calculated
    using MapQuest

-   Actual odometer mileage for the paratransit trip (taken from driver
    manifests)

-   Actual paratransit pick-up time

-   Actual paratransit drop-off time

-   Actual paratransit travel time (shaded areas indicate actual travel
    times that met the maximum travel time standards set by BJCTA)

-   Scheduled paratransit pick-up time

-   Scheduled paratransit drop-off time

-   Scheduled paratransit travel time (shaded areas indicate scheduled
    travel times that met the maximum travel time standards set by
    BJCTA)

-   Fixed route start time (for comparable trips at the same time of day
    based on the scheduled pick-up time for return trips)

-   Fixed route end time (for comparable trips at the same time of day
    based on the scheduled paratransit drop-off time for going trips)

-   Fixed route onboard time

-   Travel time allowance to/from stops (as described above)

-   Total fixed route travel time for the trip

-   Difference between actual paratransit travel time and fixed route
    travel time (shaded areas indicate that the actual paratransit
    travel time was less than the comparable fixed route travel time)

```{=html}
<!-- -->
```
-   Maximum travel time allowed by BJCTA, based on trip length (using
    estimated map mileage from MapQuest, not odometer readings)

-   Difference between maximum allowed travel time and actual
    paratransit travel time (shaded areas indicate that the actual
    paratransit travel time was equal to or shorter than the standard
    paratransit travel time)

-   Difference between the maximum allowed travel time and scheduled
    paratransit travel time (shaded areas indicate that the actual
    paratransit travel time was equal to or shorter than the maximum
    allowed travel time)

**Actual Paratransit Travel Time**

The average actual paratransit travel time for the 20 sample trips was 2
hours and 8 minutes (128 minutes). The shortest trip was 55 minutes; the
longest trip was 3 hours and 40 minutes (220 minutes). The table shows
that only three trips were within the maximum travel time standard
established by BJCTA: #1 at 55 minutes, #10 at 60 minutes, and #17 at 85
minutes. The average actual paratransit travel time for trips #1 through
#14 was 1 hour and 53 minutes (113 minutes), compared to a maximum
travel time standard of 60 minutes for those trips with direct driving
distances less than 10 miles. The average actual paratransit travel time
for trips #15 through #20 was 2 hours and 43 minutes (163 minutes),
compared to a maximum travel time standard of 90 minutes for trips with
direct driving distances from 10 to 20 miles. No trips longer than 20
direct driving miles were sampled.

The direct trip mileage (based on the results of MapQuest inquiries)
averaged 9 miles, ranging from 4 to 18 miles. The actual odometer
readings for those trips averaged 29 miles, more than 3 times as long as
the direct mileage trip, and ranged from 7 to 52 miles. Only three trips
had relatively comparable direct driving mileage and actual odometer
distances (#5, #6, #10).

  ------------- ------------------------ ------------- ---------- ------------- ---------- ------------ ------------- ---------- ------------ ----------- ---------- ------------- ------------ ------------ ------------ -------------- -------------- --------------
  **Table 11.                                                                                                                                                                                                                                           
  Travel Time                                                                                                                                                                                                                                           
  Information                                                                                                                                                                                                                                           
  for Selected                                                                                                                                                                                                                                          
  VIP Trips                                                                                                                                                                                                                                             
  Provided on                                                                                                                                                                                                                                           
  October 23,                                                                                                                                                                                                                                           
  2001 and                                                                                                                                                                                                                                              
  March 20,                                                                                                                                                                                                                                             
  2002**                                                                                                                                                                                                                                                

                                                                                                                                                                                                                                                        

  ** **         ** **                    ** **         ** **      **Actual                              **Scheduled                           **Fixed                                                        **Diff**     **Comparison                  
                                                                  Paratransit                           Paratransit                           Route                                                                       to Standard**                 
                                                                  (Pa)**                                (Ps)**                                Travel                                                                                                    
                                                                                                                                              Time**                                                                                                    

  ** **         ** **                    **Mileage**              **PU**        **DO**     **Trav       **PU**        **DO**     **Trav       **Start**   **End**    **Onboard**   **Trav       **Total      **Pa-FR**    **Standard**   **Pa-Stand**   **Ps-Stand**
                                                                                           Time**                                Time**                                            Allow**      Time**                                                  

  **Ref \#**    **Origin/Destination**   **Map**       **Odom**   **Time**      **Time**   **(mins)**   **Time**      **Time**   **(mins)**   **Time**    **Time**   **(mins)**    **(mins)**   **(mins)**   **(mins)**   **(mins)**     **(mins)**     **(mins)**

  1             1221 1st Ct W, Fairview  4             17         9:00          9:55       55           8:06          8:27       21           7:08        8:48       100           20           120          -65          60             -5             -39

                206 16th St S, Birm                                                                                                           #5 to #14                                                                                  Late DO         
                                                                                                                                              with 49 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  2             3119 Lancaster Ct Birm   4             53         7:26          10:29      183          NR            NR         NR           6:53        8:00       67            15           82           101          60             123            NR

                4244 3rd Ave S, Birm                                                                                                          #42 to #17                                                                                                 
                                                                                                                                              with 21                                                                                                   
                                                                                                                                              min.                                                                                                      
                                                                                                                                              transfer                                                                                                  

  3             220 34th St S, Birm      5             23         17:30         18:40      70           16:30         16:50      20           16:59       18:00      61            10           71           -1           60             10             -40

                745 9th Ct W, Birm                                                                                                            #17 to #6                                                                                  Late PU         
                                                                                                                                              with 24 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  4             1105 24th St N, Birm     5             24         14:20         16:43      143          14:30         16:30      120          15:05       16:04      59            10           69           74           60             83             60

                1221 1st Ct W, Fairview                                                                                                       #23 to #5                                                                                                  
                                                                                                                                              with 26 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  5             228 1st Ave N, Birm      6             7          14:15         15:25      70           14:30         15:20      50           14:48       16:35      107           10           117          -47          60             10             -10

                838 Beacon Pkway E, Birm                                                                                                      #3 to #14                                                                                                  
                                                                                                                                              with 49 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  6             3800 8th Ave S, Birm     6             8          13:55         15:15      80           13:50         15:00      70           14:29       15:30      61            10           71           9            60             20             10

                1037 Graymont Ave W,                                                                                                          #17 to #38                                                                                                 
                Birm                                                                                                                          with 27 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  7             2430 11th Ave N, Birm    6             17         14:45         16:15      90           14:30         17:05      155          14:25       15:40      75            10           85           5            60             30             95

                2318 D Ave, Ensley                                                                                                            #22 to #5                                                                                                  
                                                                                                                                              with 24 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  8             728 4th Ct W, Birm       7             27         6:00          7:50       110          6:00          8:30       150          7:43        8:25       42            15           57           53           60             50             90

                4244 3^rd^ Ave S, Birm                                                                                                        #6 to #17                                                                                                  
                                                                                                                                              with 5 min                                                                                                
                                                                                                                                              transfer                                                                                                  

  9             2430 11th Ave N, Birm    7             30         14:35         16:30      115          14:20         14:50      30           14:44       16:30      106           10           116          -1           60             55             -30

                1908 Alabama Ave SW,                                                                                                          \$22 to #41                                                                                                
                Birm                                                                                                                          with 4 min                                                                                                
                                                                                                                                              transfer                                                                                                  

  10            4725 9th Ave S, Birm     8             12         8:15          9:15       60           8:34          8:51       17           7:14        8:39       85            15           100          -40          60             0              -43

                520 Lakeshore Dr, Hmwd                                                                                                        #17 to #42                                                                                 Late DO         
                                                                                                                                              with 28 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  11            4244 3rd Ave S, Birm     8             32         15:25         17:37      132          16:00         16:05      5            16:14       17:30      76            15           91           41           60             72             -55

                865 29th St SW, Birm                                                                                             (as          #17 to #3                                                                                  Early PU        
                                                                                                                                 reported)    with 25 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  12            800 Lakeshore Dr, Birm   8             56         14:50         18:30      220          15:00         15:50      50           15:27       16:48      81            10           91           129          60             160            -10

                3020 Elmyra Dr, Birm                                                                                                          #42 to #3                                                                                                  
                                                                                                                                              with 10 min                                                                                               
                                                                                                                                              transfer                                                                                                  

  13            4244 3rd Ave S, Birm     9             43         15:37         17:52      135          16:00         16:50      50           16:14       17:38      84            20           104          31           60             75             -10

                245 Bayberry Rd, Birm                                                                                                         #17 to #6                                                                                  Early PU        
                                                                                                                                              with 33 min                                                                                               
                                                                                                                                              transfer                                                                                                  
  ------------- ------------------------ ------------- ---------- ------------- ---------- ------------ ------------- ---------- ------------ ----------- ---------- ------------- ------------ ------------ ------------ -------------- -------------- --------------

  ------- ------------------------ ------------- ---------- ------------- ---------- ------------ ------------- ---------- ------------ ----------- ---------- ------------- ------------ ------------ ------------ -------------- -------------- --------------
                                                            **Actual                              **Scheduled                           **Fixed                                                        **Diff**     **Travel Time                 
                                                            Paratransit                           Paratransit                           Route                                                                       Standard**                    
                                                            (Pa)**                                (Ps)**                                Travel                                                                                                    
                                                                                                                                        Time**                                                                                                    

  ** **   ** **                    **Mileage**              **PU**        **DO**     **Trav       **PU**        **DO**     **Trav       **Start**   **End**    **Onboard**   **Trav       **Total      **Pa-FR**    **Standard**   **Pa-Stand**   **Ps-Stand**
                                                                                     Time**                                Time**                                            Allow**      Time**                                                  

  **Ref   **Origin/Destination**   **Map**       **Odom**   **Time**      **Time**   **(mins)**   **Time**      **Time**   **(mins)**   **Time**    **Time**   **(mins)**    **(mins)**   **(mins)**   **(mins)**   **(mins)**     **(mins)**     **(mins)**
  \#**                                                                                                                                                                                                                                            

  14      4244 3rd Ave S, Birm     10            32         15:25         17:30      125          16:00         16:30      30           16:14       17:48      94            15           109          16           60             65             -30

          4732 S Ave, Birm                                                                                                              #17 to #3                                                                                  Early PU        
                                                                                                                                        with 25 min                                                                                               
                                                                                                                                        transfer                                                                                                  

  15      228 1st Ave N, Birm      13            34         13:20         17:00      220          14:30         17:10      160          14:48       16:30      102           20           122          98           90             130            70

          300 Joan Ave, Birm                                                                                                            #3 to #25                                                                                  Early PU        
                                                                                                                                        with 45 min                                                                                               
                                                                                                                                        transfer                                                                                                  

  16      215 21st Ave S, Birm     15            41         14:09         16:30      141          14:00         15:00      60           14:37       16:33      117           20           137          4            90             51             -30

          825 Park Dr, Birm                                                                                                             #14 to #25                                                                                                 
                                                                                                                                        with 45 min                                                                                               
                                                                                                                                        transfer                                                                                                  

  17      776 15th Ct NW, Center   17            25         6:50          8:15       85           6:58          9:00       122          7:01        8:48       107           25           132          -47          90             -5             32
          Point                                                                                                                                                                                                                                   

          215 21st Ave S, Birm                                                                                                          #25 to #14                                                                                                 
                                                                                                                                        with 29 min                                                                                               
                                                                                                                                        transfer                                                                                                  

  18      213 Lakeshore Pkway,     17            31         14:45         18:00      195          14:45         17:55      190          15:27       17:26      121           10           131          64           90             105            100
          Hmwd.                                                                                                                                                                                                                                   

          928 Martinwood Rd, Birm                                                                                                       #42 to #25                                                                                                 
                                                                                                                                        with 38 min                                                                                               
                                                                                                                                        transfer                                                                                                  

  19      4244 3rd Ave S, Birm     18            39         15:25         17:55      150          16:00         17:40      100          16:14       17:42      88            20           108          42           90             60             10

          5304 5th St S, Bessemer                                                                                                       #17 to #1                                                                                  Early PU        
                                                                                                                                        with 25 min                                                                                               
                                                                                                                                        transfer                                                                                                  

  20      3600 8th Ave S, Birm     18            52         13:55         17:00      185          13:55         14:50      55           15:17       16:30      73            15           88           97           90             95             -35

          5917 Sedum St, Brighton                                                                                                       #12 to #45                                                                                                 
                                                                                                                                        with 10 min                                                                                               
                                                                                                                                        transfer                                                                                                  

          Average                  9             29                                  128                                   77                                  85            14           99           29                          61             12
  ------- ------------------------ ------------- ---------- ------------- ---------- ------------ ------------- ---------- ------------ ----------- ---------- ------------- ------------ ------------ ------------ -------------- -------------- --------------

PU = Pick-Up

DO = Drop-Off

"Standard" = BJCTA adopted maximum paratransit travel time standard

Pa = Actual paratransit ride time

Ps = Scheduled paratransit ride time

A review of driver manifests for the two sample days indicated that many
of the trips involved groups of people traveling to/from various social
service programs. In some cases, a group of passengers was picked up
together, and the elapsed on board travel time was greater than the
standard for those passengers dropped-off later in the route. In other
cases, it was observed that one group boarded together, some of them
were dropped-off and then a second group picked-up. Some passengers from
the first group were still onboard after the second group had all been
dropped off, resulting in a trip in excess of 3 hours for at least one
passenger.

In some cases, there may be a mutual desire for passengers to travel
together. However, these appear to be exceptionally long travel times
that would exceed the comfort level of most passengers and often
exceeded the travel times established by the transit agency.

In discussing scheduling with staff, it was learned that drivers are
free to reorganize their routes and that sometimes they work with the
human service agencies to establish schedules, with or without the
involvement of First Transit schedulers.

**Actual Ride Times Compared to Maximum Allowed Travel Times**

As mentioned above, only three trips (#1, #10, #17) met the travel time
standards established for VIP service. Two trips (#3 and #5) were only
10 minutes longer than the 60-minute standard. On average, the trip
standard was exceeded by 61 minutes.

**ADA Complementary Paratransit Travel Times Compared to Fixed Route
Travel Times**

For the sample trips, the equivalent fixed route travel times averaged 1
hour and 39 minutes (99 minutes), including an allowance for traveling
to/from the bus stop and transfer times, as described above. Fixed route
travel times ranged from 57 to 137 minutes. All trips analyzed required
a transfer at Central Station, with transfer times ranging from 4 to 49
minutes. From the table it appears that for six trips (#1, #3, #5, #9,
#10, #17), the actual paratransit travel time would have been less than
the estimated fixed route travel time. In three other cases (#6, #7,
#16), the paratransit travel times would have been less than 10 minutes
longer than the comparable fixed route trip. For the other 11 trips, the
paratransit travel time was longer than the fixed route time -- and in
many cases it was significantly longer.

**Scheduled ADA Complementary Paratransit Travel Time**

As part of the analysis, the assessment team looked at the scheduled
paratransit travel times compared to the established travel time
standard. The table shows that 9 of the 20 trips (45%) were scheduled to
have travel times that were longer than the established maximum allowed
times. Scheduled ride times were typically shorter than actual ride
times, with an average scheduled travel time of 1 hour and 17 minutes
(77 minutes). These trips should not have been scheduled in such a way
that the ride time standard would be exceeded.

**Findings:**

1.  The current on-time performance standard adopted by BJCTA allows
    vehicles to make\
    drop-offs up to 20 minutes after stated appointment times. Since
    late arrival at work for medical appointments or classes could
    negatively affect a person's employment, medical services or
    education, adherence to such a standard could be considered a limit
    on the availability of paratransit service.

2.  A significant number of rides appear to be performed late. A review
    of trip records for two randomly selected days indicated that 11-12%
    of pick-ups were late, e.g., more than 20 minutes after the
    scheduled pick-up time. More significantly, 22-29% of drop-offs were
    made after the stated appointment times for this same sample of
    trips. This very high percentage of late drop-offs is probably a
    result of the current on-time standard, which permits drop-offs to
    be made up to 20 minutes late.

3.  Based on the analysis of sample trips conducted as part of the
    assessment, the on-time performance reported in BJCTA monthly
    service reports does not appear to be accurate. Actual trip
    information does not appear to have been regularly entered into the
    StrataGen system. Reported performance was therefore based on
    general information from staff rather than on actual ride times.

4.  A significant number of VIP rides appear to have excessively long
    ride times. Eighty-five percent of the 20 long paratransit trips
    identified for two service days exceeded the maximum travel time
    standards set by BJCTA. On average, the trip standard was exceeded
    by 61 minutes. Long rides are often the result of scheduling too
    many passengers on trips rather than in-service problems. Nine of
    the 20 long trips examined were *scheduled* with ride times that
    exceeded the established maximum ride time standard adopted by
    BJCTA.

5.  The problem of too many passengers on trips also is reflected in the
    comparison of direct distance to on-board miles. For the 20 long
    trips reviewed, the average direct distance of the trips was 9
    miles. Average on-board mileage was 29 miles, more than three times
    the direct distance.

6.  BJCTA does not appear to regularly monitor VIP ride times. A recent
    "Exceptions" report was designed to begin monitoring ride times, but
    this report uses on-board miles rather than direct miles to compare
    ride times to the maximum travel time standard adopted.

7.  A lack of ongoing dispatch control appears to be contributing to
    poor on-time performance. Drivers do not radio-in pick-ups and
    drop-offs, and dispatchers do not routinely check on the status of
    all runs. The current operating practice relies heavily on riders to
    notify the dispatch center to make staff aware that vehicles are
    running late.

8.  Pick-up and drop-off times included on manifests often appear to be
    inaccurate -- specifically for subscription trips. Changes in ride
    times appear to have been made with riders and agencies, but these
    changes have not consistently been entered into the StrataGen
    system. Inaccurate information will cause the system to not
    recognize available times correctly. Available capacity will not be
    correctly identified. Also, trips will be scheduled at times that
    appear to be available but these times may actually be fully booked.

9.  Drivers often appear to complete runs out of sequence. It appears
    that they are authorized to do so, because information on manifests
    is often inaccurate. This practice could contribute to poor on-time
    performance and long ride times.

10. Call-backs are not consistently made to inform riders of scheduled
    pick-up times. An examination of 235 trip records indicated that
    call-backs are made only 24% of the time. Riders therefore often
    appear to be unaware of scheduled pick-up times that are
    significantly different from the times they requested. This appears
    to be contributing to significant rider dissatisfaction with the
    reliability of the service.

11. The reservations and scheduling functions appear to be understaffed.
    Given current duties and responsibilities, reservationists do not
    have the time to enter trips directly into the StrataGen system. As
    a result, a hybrid paper/automated system is being used to book and
    schedule rides. The current system does not permit ride times to be
    negotiated in real-time, requires multiple handling of trip
    information (which can cause inaccuracies), and requires that
    call-backs be made to inform riders of scheduled pick-up times.

12. Problems created by the extra steps required to manually record trip
    requests and then schedule them after the fact also appears to be
    impacting the dispatch function. Dispatchers do not appear to have
    the time to keep track of all runs on an ongoing basis to ensure
    that pick-ups and drop-offs are performed in a timely manner and to
    proactively rearrange schedules should in-service problems arise.

13. The large percentage of will-calls, same day trip requests, and same
    day trip changes appears to have an impact on on-time performance
    and travel times. While some riders are given additional travel
    flexibility, many other riders are inconvenienced as same day
    changes are being accommodated. Many comments and complaints about
    late trips also appear to be related to will-calls, which indicates
    that the system really does not have the capacity to adequately
    respond to the level of same day trip additions and changes that now
    occur.

14. Problems appear to exist in the functioning of the StrataGen system,
    the use of the system, or both. Subscription trips, which should be
    anchored to specific runs, appear to move around in the system. One
    subscription trip was even observed to move from a scheduled run to
    the standby list. These types of system problems appear to be
    contributing to poor on-time performance and missed trips (if the
    standby and wait lists are not constantly monitored). It was not
    clear whether these problems are due to system design or incorrect
    use of the system by staff.

**Recommendations**

1.  It is recommended that BJCTA change its on-time performance standard
    to consider any drop-offs made after the stated appointment time to
    be late.

2.  It is recommended that BJCTA begin generating on-time performance
    reports based on actual trip information as recorded on manifests.
    This will require actual trip information to be entered into the
    system. Given all of the issues that need to be addressed, BJCTA
    should consider entering actual trip information from here forward,
    but may want to delay catching up on prior months until service and
    staffing issues are addressed.

3.  BJCTA should review existing group runs and split the runs if ride
    times are found to be excessive.

4.  BJCTA should change the current long ride "Exceptions" report to use
    direct trip miles. BJCTA should generate this report each month to
    better monitor ride times and to ensure that ride times do not
    exceed established ride time standards.

5.  BJCTA should make an effort to keep subscription trip times current
    and accurate.

6.  It is recommended that BJCTA separate the reservations/scheduling
    and dispatch functions to allow trips to be booked and scheduled in
    a more efficient manner and to allow adequate dispatch control of
    runs to be maintained. BJCTA should require its contractor to have
    at least one full-time, dedicated reservationist and one full-time,
    dedicated dispatcher on duty at all times that trip reservations are
    accepted. The contractor also should allow the
    reservationist/scheduler to devote full attention to booking and
    scheduling trips and the dispatcher to focus entirely on managing
    and controlling runs. Currently, two staff are in the operations
    center during most hours, but one person (the new dispatcher) is
    working mainly on entering trip information from completed manifests
    into the system.

7.  With more adequate staffing of the reservations, scheduling, and
    dispatch areas, BJCTA should consider requiring that First Transit:

    -   Maintain adequate dispatch control. Drivers should be required
        to radio-in each pick-up and drop-off so that dispatchers have a
        current understanding of the status of each run. Dispatchers
        should also be required to be proactive in recognizing problems
        in advance and moving trips to back-up vehicles or other runs to
        keep the service running on time.

    -   Keep current with subscription trip information and keep
        accurate subscription trip information in the system. A better
        working relationship with agencies and subscription riders
        should be developed and riders/agencies should be required to
        inform the office (not the drivers) of any changes to the
        existing schedule.

    -   Create more accurate schedules and then require drivers to run
        the schedules as designed. If drivers continue to decide how to
        complete runs, dispatch control will not be possible.

    -   Make all call-backs. (Note that only minimal call-backs will be
        needed if adequate staffing permits a real-time scheduling
        process to be implemented.)

8.  BJCTA should consider either limiting will-calls and same day
    additions and changes or should expand capacity to be able to handle
    will-call trips as well as scheduled trips in a timely way. If
    will-calls are limited, BJCTA may want to allow these only for trips
    where predicting the return time is difficult (e.g., certain medical
    trips).

9.  BJCTA should work with the StrataGen manufacturer to identify and
    correct system problems and obtain more training in the use of the
    system for staff.

# 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.

**Fleet**

BJCTA 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.

At the time of the assessment, the fleet consisted of 22 active
vehicles. The entire fleet was replaced in the last year with 18 new
vehicles purchased in April 2001, and 4 new vehicles purchased in March
2002.

On a typical weekday, about 28 runs are scheduled. Eighteen of the 22
active paratransit vehicles are used in peak hour operation.

Drivers interviewed as part of the assessment indicated general
satisfaction with the vehicles. Some minor problems with wheelchair
lifts getting "stuck" on occasion were indicated, but drivers noted that
reported problems are repaired quickly.

Riders and advocates contacted in advance of the on-site assessment did
not express any concerns about the design or condition of vehicles. None
of the 12 complaints on file at BJCTA was about vehicle condition. None
of the formal ADA complaints filed with FTA raised vehicle concerns.

**Personnel**

As indicated in previous sections of this report, staffing of the
reservations, scheduling, and dispatch functions appears to be an issue.
Until April 2002, only one morning and one afternoon "dispatcher" was
used to cover all three functions. These individuals were also asked to
perform other functions as well, such as selling fare media and checking
drivers in and out. A new dispatcher was hired on April 1, 2002, and was
in training at the time of the assessment. This person works a split
shift in order to provide additional help during both the morning and
afternoon peak calling times. At the time of the review, he provided
some help with the phones and with recording of trip requests, but was
also being used to enter actual trip data into the StrataGen system. As
previously noted, understaffing of the reservations, scheduling, and
dispatch functions appears to be causing problems entering data directly
into the StrataGen system, keeping current with subscription trip times,
and maintaining effective dispatch control of the VIP service.

A total of 26 trained operators were available for VIP service at the
time of the assessment. A review of seniority records showed that 19 of
these 26 operators had less than one year of experience and 15 had six
months or less time on the job. First Transit staff indicated that
driver turnover had been a significant issue until just recently when
changes in hiring practices and compensation for paratransit operators
were negotiated with the union.

Prior to January 2002, hiring for all operators, both fixed route and
paratransit, was combined. Paratransit operators were paid between
\$6.00 and \$8.00 per hour and fixed route operators were paid between
\$8.82 and \$14.70 per hour. New fixed route operator positions were
offered first to existing personnel and virtually all new fixed route
operators transferred from paratransit. Essentially, all new hires were
assigned to paratransit service and many operators then quickly
transferred to fixed route service as openings became available. This
resulted in very high paratransit operator turnover. The fixed route
seniority records between July 1 and

December 31, 2001 indicated that a total of 23 operators had moved from
VIP service to the fixed route service during this six-month period.
This suggests a paratransit operator turnover rate of about 88% per
year.

A new paratransit operator contract was negotiated with the union
effective January 2002. Under the new contract, operators are hired
separately for the paratransit and fixed route programs. Paratransit
operator pay was also increased to range from \$9.00 to \$12.00 per
hour. Records from January through March 2002 indicate that these
changes appear to be lowering paratransit operator turnover. During this
three-month period, only five new paratransit operators were hired and
trained, which suggests a turnover rate of 58% per year.

High paratransit operator turnover prior to January 2002 also appears to
have affected run coverage and the availability of extraboard/back
service. A review of pullout records for several days in 2001 and 2002
showed that prior to January 2002, a lack of available extraboard
operators sometimes left runs uncovered or left no back-up capacity for
the day.

Table 12 below provides a summary of the pullout records examined in
2001. For each day examined, it provides information about the number of
"call-outs," the number of extraboard drivers used to cover call-outs,
and the number of extraboard or "report" operators available as back-ups
during the service day.

As shown, the availability of same day back-up was very inconsistent. On
three of the days examined, there were not enough available extraboard
drivers to cover all call-outs. As a result, existing scheduled runs had
to be divided and trips on these runs reassigned to other runs which may
already have been full. This also left no back-up capacity on these
days. On three other days, there were just enough extraboard drivers to
cover call-outs, but again there was no back-up capacity for in-service
problems. On only three of the ten days examined were there enough
extraboard divers to both cover call-outs and provided in service
back-up.

**Table 12. Run Coverage for Selected Days in 2001 and 2002**

  -------------- ------------------ ------------------ ------------------
  **Date**       **\# Of            **\# Of Extraboard **\# Of Extraboard
                 Call-Outs**        Drivers Used to    Drivers Available
                                    Cover Runs**       as Back-Up**

  1/15/01        3                  3                  1

  1/16/01        4                  6                  2

  1/17/01        7                  5                  -2

  1/18/01        6                  6                  0

  1/19/01        4                  4                  1

  2/19/01        4                  3                  -1

  2/20/01        5                  8                  3

  2/21/01        6                  6                  0

  2/22/01        6                  4                  -2

  2/23/01        6                  6                  0
  -------------- ------------------ ------------------ ------------------

An examination of similar records for several days in February 2002
showed that there are now enough extraboard drivers to provide adequate
coverage and back up. A total of seven extraboard drivers are typically
available (there are actually nine extraboard drivers, but two were on
long-term leave at the time of the assessment). This is typically enough
to cover all

call-outs and to provide same day back up as well.

**Operator Training**

As part of the assessment, the First Transit employee trainer was
interviewed and the operator- training curriculum was reviewed. This
review indicated that VIP operators typically receive 140-160 hours of
training before driving on their own. This includes 80 hours of
classroom training. The classroom training includes several sessions on
disability awareness, general passenger relations, and hands-on
instruction in the use of lifts, securement systems, and other
accessibility features of the vehicles. Classroom training is then
followed by 60-80 hours of

on-the-road instruction with an experienced operator. The amount of
on-the-road instruction depends on experience and the instructor's
approval of the trainee. Essentially, driver/instructors do not approve
new operators until they are comfortable with the level of skill
displayed in the on-the-road portion of the training.

The First Transit trainer indicated that periodic disability awareness
and "sensitivity" training are also sponsored. He noted a four-hour
refresher course in 1999 organized with the assistance of the local
center for independent living. He also noted that drivers are brought
together one Saturday each month for additional training or instruction.
Community representatives and disability advocates are often asked to
provide instruction at these sessions.

VIP operators interviewed as part of the assessment expressed general
satisfaction with the type and amount of training provided. All felt
that they were adequately trained for the job. All felt that they had
adequate training in disability awareness and in the use of lifts,
securement systems, and accessibility features.

Riders and advocates contacted prior to the on-site assessment generally
were satisfied with driver performance. One person noted that she did
not think that enough formal disability awareness refresher training was
being offered. She cited the 1999 training with the Center for
Independent Living as the last refresher program that she was aware of.
Only one of the 12 complaints on file at BJCTA related to driver
performance. It expressed concern about reckless driving. None of the
formal ADA complaints filed with FTA raised issues of poor driver
training or performance.

**Budget**

The process used to develop the ADA Complementary Paratransit budget was
reviewed with BJCTA staff. Budget and paratransit expense information
for recent years was also reviewed.

BJCTA staff indicated that the VIP budget is developed each year by
estimating growth in demand. Typically, a 5% increase in demand is
estimated. This increase in demand is then translated into additional
vehicle hours needed to provide all trips requested. The estimate of
vehicle-hours is then used to estimate annual operating costs based on
the per hour rate negotiated with First Transit. This ADA Complementary
Paratransit budget request is then submitted to the BJCTA board. Staff
noted that while additional funding may be requested, member communities
must approve any budget increases. They noted that prior to April 2001,
additional funding for the VIP service was typically not approved.

Table 13 below shows the annual operating budget for the VIP service for
fiscal years 1999-2001 (July 1998 through June 2001). As shown, the
annual operating budget was decreased slightly over this time, from
\$1,106,807 in FY99 to \$1,085,196 in FY01. As a result, the number of
vehicle hours authorized each year and each month was held constant.

**Table 13. Annual VIP Operating Budget, FY1999 through FY 2001**

  ----------------------------------- -----------------------------------
  **Fiscal Year**                     **Approved Budget**

  FY1999                              \$1,106,807

  FY2000                              \$1,028,733

  FY2001                              \$1,085,196
  ----------------------------------- -----------------------------------

Table 14 on the following page shows actual VIP vehicle-hours, and
active and peak-hour vehicles for the period from October 1998 through
February 2002. As can be seen, the number of total active vehicles and
the number of vehicles in peak-hour service remained unchanged from
October 1998 through March 2001. A total fleet of 18 vehicles was
operated, of which 15 were in peak-hour operation. The number of actual
vehicle-hours stayed relatively constant, varying only based on the
number of weekdays and total service days in the month. During this
period, the VIP contractor was authorized by BJCTA to provide about 162
vehicle-hours of VIP service per weekday.

**Table 14. VIP Monthly Vehicle-Hours and Total and Peak Vehicles,
10/98- 2/02**

  ----------- -------------- -------------- ----------- -------------- --------------
  **Month**   **Veh-Hrs.**   **Total/Peak   **Month**   **Veh-Hrs.**   **Total/Peak
                             Vehicles**                                Vehicles**

  10/98       3503.11        18/15          7/00        3458.58        18/15

  11/98       3168.22        18/15          8/00        3576.83        18/15

  12/98       3591.65        18/15          9/00        3413.82        18/15

  1/99        3318.57        18/15          10/00       3699.15        18/15

  2/99        3161.14        18/15          11/00       3666.34        18/15

  3/99        3478.07        18/15          12/00       3438.36        18/15

  4/99        3375.50        18/15          1/01        4157.77        18/15

  5/99        3148.50        18/15          2/01        3981.78        18/15

  6/99        3487.15        18/15          3/01        4887.85        18/15

  7/99        3157.59        18/15          4/01        4432.09        22/18

  8/99        3417.52        18/15          5/01        4057.03        22/18

  9/99        NA             18/15          6/01        4423.38        22/17

  10/99       3558.35        18/15          7/01        4119.20        22/17

  11/99       3404.64        18/15          8/01        4050.00        22/17

  12/99       3611.92        18/15          9/01        3918.96        22/17

  1/00        3400.50        18/15          10/01       5239.88        22/17

  2/00        3223.44        18/15          11/01       4573.21        22/17

  3/00        3514.31        18/15          12/01       4269.60        22/17

  4/00        3084.67        18/15          1/02        4570.99        22/17

  5/00        3571.25        18/15          2/02        4196.65        22/17

  6/00        3540.07        18/15                                     
  ----------- -------------- -------------- ----------- -------------- --------------

In April 2001, BJCTA member communities approved a budget increase for
the VIP service. An additional \$260,000 per year in operating funding
was approved for the service. This budget increase allowed staff to
authorize First Transit to increase the VIP fleet to 22 vehicles total
and to authorize the use of 18 vehicles in peak-hour service. Eighteen
peak hour vehicles were operated for two months after this budget
increase. The number of authorized vehicle-hours was also increased to
about 197 hours per weekday This number was reduced to 17 peak-hour
vehicles after two months, since peak-hour demand for an additional
three vehicles was not found to be needed. At the time of the
assessment, the peak-hour fleet had increased back to 18 vehicles.

BJCTA staff indicated that they have requested an increase in the budget
for VIP service for FY2003. This increase reflects a 5% increase in
demand and seeks to increase the number of weekday service hours from
197 to 203. At the time of the compliance assessment, this request had
not yet been approved.

**Overall Level of Service**

As noted in the eligibility section, about 3020 persons were registered
for the VIP service at the time of the assessment. These riders were
making only about 430-450 one-way trips per weekday. About 70-80% of all
trips provided appear to be subscription trips, most for clients of a
few local agencies. Only 80-90 one-way non-subscription trips appear to
be provided on a typical weekday.

Compared to other cities of similar size, the VIP trip-making rate seems
low. Table 15 below provides population and ridership information for
selected urbanized areas similar in size to Birmingham. The number of
trips per capita per year is also calculated. The information for other
cities is based on data recently collected by Easter Seals Project
ACTION as part of a nationwide study of ADA Complementary Paratransit
service.

As shown, the annual trips provided per capita in other cities range
from 0.21 to 0.54. It should also be noted that the relatively low rates
for the two systems in Florida are likely due to the fact that many
people with disabilities travel under the Florida "Transportation
Disadvantaged" (TD) program rather than under the ADA program in that
state. In Birmingham, only about 0.17 trips per capita per year are
provided.

Riders and agency representatives contacted prior to the on-site
assessment indicated that some people, discouraged with the reliability
of the VIP service have elected to use the countywide paratransit
service (CLASTRAN) instead of the VIP service. They noted that the fare
for CLASTRAN service is \$4.00 each way and that riders would therefore
prefer to use the VIP service. They indicated, though, that poor on-time
performance has led some people to use the CLASTRAN service for some or
all of their trips.

**Table 15. Population, Annual ADA Paratransit Trips, and ADA
Paratransit Trips per Year per Capita for Selected Cities**

  ----------------- ----------------- ----------------- -----------------
  **Cities**        **Service Area    **Annual ADA      **ADA Paratransit
                    Population**      Paratransit       Trips Per Year
                                      Trips**           Per Capita**

  Birmingham        650,000           112,968           0.17

  Jacksonville, FL  834,337           179,763           0.21

  Volusia County,   420,224           103,224           0.25
  FL                                                    

  Rochester, NY     716,072           225,910           0.31

  San Mateo, CA     707,161           293,850           0.42

  Sacramento, CA    930,000           498,067           0.54
  ----------------- ----------------- ----------------- -----------------

**Findings**

1.  High turnover of ADA Complementary Paratransit operators and the
    lack of availability of extraboard operators appear to have
    contributed to VIP service delivery problems in past years. Recent
    changes in VIP operator compensation and in the hiring practices
    used for VIP and fixed route operators appear to have addressed
    these problems. It appears that First Transit now has enough
    operators to adequately cover all call-outs and provide service\
    back-up.

2.  Understaffing in the reservations, scheduling and dispatch functions
    appears to have impacted VIP service quality. As detailed in other
    sections of this report, understaffing appears to have kept
    real-time scheduling from being fully implemented, accurate
    schedules (particularly subscription schedules) from being
    developed, and adequate dispatch control from being maintained.

3.  The BJCTA budget for ADA Complementary Paratransit service does not
    reflect a steady increase in recent years needed to accommodate
    expected increases in demand. The budget and corresponding expenses
    were held constant for several years. One increase in April of 2001
    was approved. Prior to April 2001, requests for increases in funding
    for ADA Complementary Paratransit service do not appear to have been
    approved for several years.

4.  The number of VIP trips provided per year is low given the service
    area population. BJCTA provides about 0.17 trips per capita per year
    on the VIP program. Data from other cities indicates a significantly
    higher trip-making rate. It appears that some people who are ADA
    paratransit eligible in the BJCTA area are using the CLASTRAN
    service even though it has a significantly higher fare. These riders
    indicated that they have elected to use the more expensive CLASTRAN
    system because of the poor reliability of the VIP service.

5.  Once BJCTA addresses VIP service issues -- specifically on-time
    performance and long ride times -- an increase in demand should be
    expected.

**Recommendations**

1.  BJCTA should monitor availability of drivers to ensure that there
    continues to be an adequate number of VIP operators to cover all
    scheduled runs and to provide same day service\
    back-up.

2.  BJCTA should require that its VIP contractor provide adequate staff
    to handle the trip reservations, scheduling, and dispatch functions.
    As noted in other sections of this report, it is recommended that
    BJCTA split the reservations/scheduling function from the dispatch
    function and that BJCTA provide one full-time person dedicated to
    each area on weekdays. If the new dispatcher, hired in April 2002
    continues to spend significant time entering data into the system,
    this would mean adding one additional person to the
    reservations/scheduling/dispatch operation.

3.  BJCTA should adopt a budgeting and service expansion policy that
    allows for a growth of authorized vehicle-hours throughout the year.
    If a 5% growth in demand is anticipated by the end of the next year,
    service hours, as adjusted for seasonal variations, should be
    increased throughout the year to accommodate new trips so that
    adequate hours to meet a 5% increase are in place by the end of the
    year.

4.  As BJCTA addresses service delivery issues noted elsewhere in this
    report, it is recommended that demand for service be closely tracked
    the ensure that adequate service capacity is available to meet
    expected increases in demand.

# Other Compliance Issues

A review of BJCTA's fixed route schedules and VIP operator shifts
indicated that VIP service is not provided during all of the hours that
fixed route is in operation. As noted in the "Background" section of
this report, the VIP service is advertised to operate Monday through
Friday from 5:00 AM until 8:00 PM and Saturdays from 8:00 AM until 6:00
PM. A review of VIP operator shifts and scheduled VIP runs indicated,
however, that no VIP runs are scheduled to begin before 6:00 AM. First
shift VIP drivers report at 5:30 AM, perform required vehicle checks
until 6:00 AM and then begin their runs. First pick-ups are therefore
not scheduled until some time after 6:00 AM.

A review of VIP schedules for the week of April 22, 2002 also showed
that no run is scheduled to be in service past 6:30 PM. Several runs are
scheduled to end at 6:05 PM (Runs 129P, 122P, 148P, 112, 146, 141, 144,
206, 142, 149, and 147P). One run (125P) was scheduled to end at 6:30
PM. Staff indicated that an extraboard driver is used for trips after
this time.

A review of the fixed route schedules also showed that fixed route
service is operated well past 8:00 PM and on Sundays in the DART area.
The Blue and Green DART routes are advertised to be operated until 10:00
PM Mondays through Thursdays, and until 12:00 midnight on Fridays and
Saturdays. DART service is also available from 9:00 AM (Red route) until
9:00 PM (Blue and Green routes) on Sundays.

**Findings**

1.  BJCTA is not meeting the requirements of 49 CFR section 37.131(e)
    which requires that "...paratransit service shall be provided
    throughout the same days and hours as the entity's fixed route
    service." In the area where DART fixed route service is provided,
    BJCTA must expand VIP service hours to match the hours of the three
    DART routes. This will mean expanding VIP hours, at least in some
    DART areas, until 10:00 PM Mondays through Thursdays, until 12:00
    midnight on Fridays and Saturdays, and from 9:00 AM until 9:00 PM on
    Sundays.

2.  Although advertised, adequate VIP service also does not appear to
    exist between the hours of 5:00-6:00 AM and from 6:00-8:00 PM. No
    regularly scheduled runs appear to be in service before 6:00 AM.
    Only one run (plus any available extraboard drivers) is scheduled
    after\
    6:05 PM. Given the size of the service area, it is doubtful that VIP
    could meet potential demand with one vehicle and extraboard
    operators between 6:00 and 8:00 PM. It is likely that the lack of
    scheduled runs has contributed to low demand during these times.

**Recommendations**

1.  To meet regulatory requirements, BJCTA should consider establishing
    a "late night" and a "Sundays only" VIP service area which covers
    the areas served by DART routes.

    **Attachment A**

**Response from BJCTA**

**Attachment B**

**On-Site Assessment Schedule**

**Attachment C**

**Paratransit Customer's Guide**

**Attachment D**

**BJCTA ADA Complementary Paratransit Eligibility Application
Materials**

**Attachment E**

**Sample Eligibility Denial Letter**

**and Instructions for Appealing**

**Attachment F**

**Sample Completed VIP Manifest Showing Pick-Ups Made Out of Sequence**

[^1]: Based on information in the 2000 National Transit Database.

[^2]: ADEPT stands for "Adaptive Decision Engine for Passenger
    Transportation." A system upgrade was performed in early April.