**Capital Area Transportation Authority (CATA)**

**Assessment of Stop Announcement**

**and Route Identification Efforts**

**April 3-6, 2000**

***Summary of Observations***

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, D.C.**

**Prepared by**

**Planners Collaborative, Inc.**

**with**

**Multisystems, Inc.**

**November 21, 2000**

**CONTENTS**

**Purpose of the Assessment . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**

**Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**

**Overview of the Assessment . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4**

**Observations of On-Board Stop Announcements . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . 5**

**Observations of Route Identification System . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . 12**

**Attachment A. CATA Work Rules Excerpt and Policy Memorandum**

**Attachment B. CATA "Route Announcement" Lists and Transmittal
Memorandum**

**Attachment C. March 30, 2000 Memorandum Regarding Use of "Checkers"**

**Attachment D. Completed "On-Board Fixed Route Stop Announcement**

> **Assessment Forms"**

**Attachment E. Completed "Vehicle/Passenger Identification Assessment
Forms"**

**Attachment F. CATA Response to the Draft ADA Assessment of Stop
Announcements and Route Identification Efforts, July 25, 2000**

**Purpose of the Assessment**

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

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

Section 37.167 (c) requires that:

> *"Where vehicles or other conveyances for more than one route serve
> the same stop, the entity shall provide a means by which an individual
> with a visual impairment or other disability can identify the proper
> vehicle to enter or be identified to the vehicle operator as a person
> seeking a ride on a particular route."*

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

An on-site assessment of the fixed route service provided by the Capital
Area Transportation Authority (CATA) of Lansing, Michigan was conducted
April 3-6, 2000. Planners Collaborative, Inc. of Boston, Massachusetts
and Multisystems, Inc. of Cambridge, Massachusetts, conducted the
assessment for the FTA Office of Civil Rights. Russell Thatcher of
Multisystems served as the assessment team leader. Donald Kidston and
Brian Barber of Planners Collaborative assisted with the review. The
assessment focused on CATA's efforts and successes in implementing the
stop announcement and route identification requirements noted above.

This report summarizes the observations and findings of the on-site
assessment of CATA's fixed route service. A description of key features
of the service and a history of stop announcement efforts is first
provided. A description of the approach and methodology used to conduct
the assessment is then provided. Observations and findings related to
each of the two requirements are summarized. Additional observations
regarding employee training and service monitoring efforts are then
provided. Finally, the major findings of the assessment are summarized
in the last section of this report. Recommendations of the review team
for addressing issues identified are also provided.

**Background**

The Capital Area Transportation Authority (CATA) provides public transit
services in the greater Lansing area. This includes both fixed route and
ADA Complementary Paratransit service. In addition to serving the
community of Lansing, CATA has operated transportation services under
contract to Michigan State University (MSU) since August of 1999.

CATA has a fleet of 81 fixed route vehicles, 65 of which are used to
meet peak pullout. The fixed route system includes 29 routes, eight of
which serve MSU. Two routes provide express service to the neighboring
communities of Williamstown, Weberville, and Mason. A new Transportation
Center in downtown Lansing serves as the main terminal and staging area
for community buses. There is also a bus staging area on the MSU campus.

Prior to 1996, bus operators made voice announcements. To ensure that
stops were announced as required, CATA employed "checkers" to ride the
buses and record the announcements being made.

In 1996, CATA purchased and installed DataGuide, an advanced technology
system that employs mobile data terminals (MDTs), an on-board computer,
and a global positioning system (GPS) to provide automated stop
announcements as well as other vehicle information and control
functions. Prior to large-scale installation in the fleet, CATA tested
the DataGuide system on one vehicle for 12 months. The test was very
successful and the system was installed on a total of 75 fixed route
vehicles.

As currently designed, the DataGuide system provides on-board stop
announcements. Changes are being made and an upgraded version of the
system will also provide external announcements at stops served by more
than one route. Installation of the upgraded system was scheduled to
begin in March of 2000. An important feature of the system is that it is
designed to automatically start when the vehicle is started, so that
drivers would not have to remember to activate it. It is also important
to note that the DataGuide system uses the public address (PA) system
speakers on the bus. A separate, manually operated PA system is not
available on the CATA buses. The bus operators cannot manually access
the PA speakers.

Between 1996 and mid-1998, CATA staff reported that the system performed
quite well. Automated stop announcements were accurately and
consistently made by the DataGuide system. In mid-1998, however,
problems began being experienced with the system. CATA staff noted that
problems with the system began to appear as additional functions were
added. In particular, the addition of additional hardware to provide a
video camera passenger monitoring system may have caused system
problems. Potential issues with the vehicle power source were also
noted.

From mid-1998, CATA has worked closely with the DataGuide designers to
identify and correct system problems. Operators and maintenance staff
identified buses and routes on which announcements were not being made
(or were being made inaccurately) and reported problems to the
manufacturer. The manufacturer's technicians would then come on-site to
correct problems noted. Throughout the period from mid-1998 to then end
of 1999, CATA staff noted that the manufacturer was optimistic that a
complete solution was imminent.

At the time of the site visit, CATA staff noted that the manufacturer
had just completed revisions to the system software. It was CATA's
expectation that these revisions would address the problems being
experienced. Installation of the new software program was scheduled to
begin in a few weeks.

**Formal Complaint Concerning Stop Announcements**

Between 1993 and 1996, the FTA Office of Civil Rights received several
complaints from an individual indicating that stop announcements were
not always being made on CATA buses. All complaints were made prior to
the installation of the DataGuide automated stop announcement system.
The complainant also alleged that, as a result of his efforts to track
stop announcement performance and file complaints, drivers treated him
rudely and on one occasion failed to stop to pick him up.

In response to this complaint, FTA requested information from CATA about
stop announcement policies, operator training, and service monitoring.
FTA also requested that CATA conduct an internal investigation of
possible retaliation against the complainant.

FTA's investigation of the complaints found CATA's policies to largely
be in compliance. FTA did find that CATA needed to amend a policy that
required that voice announcements be loud enough to be heard in the
first five rows of seats on the bus. Announcements that could be heard
throughout the bus were required. CATA's internal investigation of
possible retaliation found that a driver had mistakenly driven by the
complainant while he was waiting at a bus stop that was apparently under
construction.

To better track operator performance, CATA employed a detailed service
monitoring process that employed persons with disabilities as "checkers"
to ride buses and record stop announcement information. The DataGuide
system was also purchased to enable announcements to be made more
systematically.

**Overview of the Assessment**

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

-   The most recent fixed route system map;

-   A complete set of schedules for each fixed route;

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

-   The Operator Manual which outlines operating policies and
    procedures;

-   Notices, bulletins, and memoranda detailing stop announcement and
    vehicle/route identification policies;

-   CATA service monitoring information related to stop announcements
    and vehicle/route identification; and

-   Recent service complaints regarding stop announcements or
    vehicle/route identification.

    Prior to the on-site visit, the assessment team also reviewed formal
    complaints on file with FTA concerning stop announcements by CATA.
    Telephone interviews were also conducted with several local human
    service agency representatives and persons with vision disabilities
    who regularly use the CATA fixed route service.

    In order to get more accurate observations of current performance,
    CATA was notified in November of 1999 that an assessment would be
    conducted in the near future. The exact dates of the on-site visit
    were not provided. The notification letter indicated that after
    spending a few days on-site, the assessment team would contact CATA
    to arrange for meetings with staff and to schedule an exit
    conference.

    The on-site assessment was conducted the week of April 3-6, 2000. On
    Monday and Tuesday, April 3-4, the review team rode the fixed route
    system and made observations of stop announcements and vehicle/route
    identification. The assessment team contacted CATA staff on Tuesday
    afternoon and arrangements were made to meet with various CATA
    staff. On Wednesday morning, April 5, the assessment team
    interviewed CATA's Operations Manager and Training Manager. Several
    bus Operators and a shift Supervisor were also interviewed.
    Additional observations of external bus/route identification were
    also made on the afternoon of April 5^th^.

    On Thursday morning, April 6, an exit conference was conducted.
    Attending the exit conference for CATA were Ms. Sandy Draggoo,
    Executive Director, Mr. Dave Smith, Operations Manager. Review team
    members at the exit were Russell Thatcher and Donald Kidston.

    Ms. Cheryl Hershey, FTA's ADA Team Leader, also participated in the
    exit conference by phone.

    On June 14, FTA forwarded a draft report prepared by the assessment
    team to CATA for review. CATA provided comments on the draft report
    and identified corrective actions in a July 25 letter from Chandler,
    Bujold and Chandler. The CATA response appears in Attachment F.

    **Observations of On-Board Stop Announcements**

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

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

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

-   On Wednesday, April 5, several drivers and a shift supervisor were
    interviewed to verify their understanding of stop announcement
    policies;

-   Three individuals who are regular riders of the CATA bus system were
    interviewed by phone;

-   On Monday and Tuesday, April 3-4, the review team rode on 50 bus
    routes and recorded stop announcements.

**CATA Policies and Procedures Regarding On-Board Stop Announcements**

CATA's policy and procedures regarding on-board stop announcements are
detailed in Section 11, "Work Rules," of its employee "Training Manual."
Subsection 23A, titled "Announcement Stops," states:

> *"Operators must announce:*
>
> *major intersections,*
>
> *transfer points,*
>
> *specific locations upon passenger requests.*
>
> *These announcements must be made on the bus speaker system or in a
> loud clear voice when the speaker system is not available or not
> working."*

This section of the work rules also specifies progressive disciplinary
action for failure to make stop announcements as required. A written
warning is to be given for the first offense. Three days off without pay
are specified for a second violation. Five days off without pay are
indicated for a third violation. A fourth violation can be cause for
termination of employment. A copy of subsection 23 of the work rules is
provided in Attachment A.

The "Training Manual" also contains memoranda that are periodically
distributed that clarify or amend work rules and operating policies. One
memorandum that addresses stop announcements was noted. It is dated
October 20, 1994 and instructs operators to make stop announcements in a
way that permits riders to hear the announcements throughout the bus.
Prior to this memorandum, the policy had been to make announcements loud
enough for riders seated in the first five seats to hear the
announcement. A copy of this memorandum is also provided in Attachment
A.

CATA also has developed a detailed set of "Route Announcement"
instructions to be used by operators. The stops that are to be announced
are listed for each route, in both the inbound and outbound directions.
These route announcement lists were first developed in 1991 with the
input of CATA's Local Advisory Committee (LAC).

A revised set of announcements, taking recent route changes into account
was distributed to operators on March 18, 2000. A copy of this most
recent set of route announcements is provided in Attachment B. Also
included is a memorandum, dated March 18, 2000, which was sent to
operators with the updated route announcements. The memo notes that
drivers are to use the revised lists to make voice announcements
"\...when your DataGuide does not work."

As noted in the March 18 memorandum, CATA also has prepared multiple
laminated sets of the "Route Announcements" and makes these available to
operators. The laminated lists are kept in the Dayroom and can be
picked-up by operators at the beginning of their shifts. As part of the
assessment, the review team confirmed that these lists are readily
available to operators.

Finally, on March 30, 2000, CATA distributed a memorandum to all
operators that indicated that CATA was going to re-institute the process
of hiring "checkers" to ride vehicles and note if policies for serving
riders with disabilities (including stop announcements) are being
followed. The memorandum referred operators to subsection 23 of the Work
Rules and also reiterated the policy for making stop announcements (as
well as other policies for serving riders with disabilities). A copy of
this memorandum is provided in Attachment C.

Mr. Dave Smith, CATA's Operations Manager, noted that the policy of
manually announcing stops, implemented in 1991 when the ADA regulations
were first promulgated, has remained in effect since that time. When the
DataGuide system was purchased, and when it was functioning well from
1996 to 1998, voice announcements were rarely made. When problems with
the DataGuide system began to be experienced, there was no major push to
emphasize voice announcements again, since it was hoped that the
automated system could be made fully operational in a short period of
time. As evidenced by the recent memos, voice announcements are being
emphasized again as issues with the DataGuide system have continued.

Mr. Smith also noted that the current practice is for drivers to make
voice announcements without amplification since the PA systems were
incorporated into the DataGuide system.

**CATA Training**

While on site, reviewers met with Mr. James Froehlich, CATA's
Superintendent of Safety, Security and Training. The contents of the
"Training manual," noted above, were reviewed.

Mr. Froehlich noted that all new employees receive training in ADA
requirements when they are hired. He also indicated that periodic
re-training is also done. He noted that a retraining on all ADA
requirements was recently completed. All operators were retrained
between mid-February and the first week of March. On-board stop
announcements as well as external route announcements were discussed in
the retraining.

**Operator and Supervisor Interviews**

To verify the effectiveness of CATA's training concerning stop
announcements, and to get input from operators on stop announcements,
the assessment team interviewed nine bus operators and one shift
supervisor on Wednesday, April 5^th^. Employees were asked to describe
their understanding of the policy regarding on-board stop announcements.

All ten employees understood the CATA policy for on-board stop
announcements. They indicated that the policy was covered in the recent
training and were familiar with the route announcement lists.

Four of the operators mentioned that it would be helpful to have a PA
system so that the announcements could be heard throughout the bus. Two
other operators did not mention a PA system specifically, but did note
that it is difficult to make audible announcements because of the noise
on the buses when there are a lot of passengers.

One operator indicated that it would be helpful to have something that
could hold the route announcement list in a visible position for the
driver. Another operator said he felt it could be hazardous, especially
in rush hour traffic, to be reading from the list to make announcements.
Another operator indicated that passengers would poke fun at drivers who
make announcements when it doesn't seem necessary (few people on-board).

Three operators indicated that the DataGuide system worked well when it
was first installed. They noted that it now doesn't work on most of the
buses. Two employees indicated that some operators would "unplug" the
automated system when it started to operate erratically. Four employees
noted that they felt there were problems with the quality of the voice
generated by the automated system and that the announcements were not
clear, especially to new riders.

**Rider Experiences and Observations**

Prior to the on-site visit, three individuals were interviewed by phone
about their experiences with stop announcements on the CATA fixed route
system. One person serves as the Director of Client Services for an
organization that serves individuals with vision disabilities. The other
two are persons with vision disabilities who regularly ride the fixed
route system. Riders were identified with the assistance of the Michigan
Commission for the Blind.

The agency representative noted that his experience was that CATA was
pretty good about making stop announcements. He said that from time to
time there have been issues, but that overall the effort has been good.

One of the riders noted that the automated stop announcement system
seemed to be working "about 50% of the time" and that there didn't seem
to be any pattern in terms of when and where the system was working. He
noted that drivers will sometimes step in and make voice announcements
if the automated system is not working. He also noted that drivers are
very good about making stop announcements that he specifically requests.

The second rider noted that the automated system "was great when it was
working" but noted that there have been recent problems. She said that
in her experience, drivers usually did not step in to make voice
announcements when the system was not working.

**Assessment Team Observations**

As noted above, the three assessment team members rode on 50 routes
while on-site. Twenty-one (21) of the 29 routes in the system were
ridden (many several times) and announcements at a total of 465 stops
were observed. Thirty-seven (37) different buses (out of 65 peak hour
vehicles typically in operation) were ridden.

An "On-Board Fixed Route Stop Announcement Assessment Form" was used to
collect information. Prior to boarding buses to observe stop
announcements on a particular route, assessment team members recorded on
these forms the stops that were supposed to be announced. CATA "Street
Announcement" lists were used to identify stops to be announced.

Reviewers recorded whether or not announcements were made at each
identified stop. If an announcement was made, reviewers noted whether it
was made by the automated Data Guide system or by the driver (by voice).
Reviewers also noted whether the announcements were clear and audible.
Observations were made about half way back in each bus (typically near
the mid-vehicle door). Copies of the completed "On-Board Fixed Route
Stop Announcement Assessment Forms" are provided in Attachment D.

Table 1 on the following page provides a summary of assessment team
observations. For each route ridden, it shows the route number, bus
number, and date and time of the observations. It then shows the number
of stops that were supposed to be announced between the stop where the
reviewer entered the vehicle and the stop where the reviewer exited (in
some cases, the entire route was not ridden). The number of stops made
by the Data Guide system, the number made by voice, and the total number
of stops announced are then listed. The last column then indicates if
the announcements were clear and audible.

As shown, of the 465 stops that should have been announced, a total of
103 (22%) were actually announced. The automated (Data Guide) system
made twenty-nine announcements and drivers made 74 voice announcements.

On the 10 routes where operators made voice announcements, these
announcements were audible and clear on seven routes and were sometimes
audible and clear on three routes. Because drivers did not have access
to a PA system, all voice announcements were made without any form of
amplification. Reviewers noted that while some drivers would call stops
loudly, other drivers would call stops in a conversational tone and
volume. Because reviewers were focusing on the driver and expecting an
announcement, it was noted that something was called. The announcements
made in this way were often not really audible and clear, though.

On the five routes where the announcements were made by the automated
system, they where audible and clear on two routes, were sometimes
audible and clear on two, and were not audible on one route. It was also
noted that on the downtown loop route (Route 29), the announcements that
were being made by the automated system did not seem to match the list
of stops that should have been announced. This was somewhat difficult to
confirm, though, because the announcements were not always clear.
Reviewers noted that the automated system uses a computer-generated,
synthesized voice and that the annunciation was not always clear. Even
though the reviewers had a written copy of what they were expecting to
hear, it was often not possible to verify that the correct announcement
was made.

**Table 1. Summary of Observations of On-Board Stop Announcements**

  ------------ --------- ---------- ---------- ------------- ----------- ----------- ------------- ----------------
  **Bus \#**   **Route   **Date**   **Time**   **\# of Stops **\# Stops  **\# Stops  **Total Stops **Were
               \#**                            to be         Announced   Announced   Announced**   Announce-ments
                                               Announced**   Auto        by Voice**                Clear and
                                                             System**                              Audible?**

  408          2 (out)   4/3        4:05pm     9             6           0           6             Yes

  411          2 (in)    4/3        5:23pm     5             0           0           0             NA

  406          5 (out)   4/3        2:30pm     16            0           16          16            Sometimes

  409          5 (in)    4/3        3:40pm     9             0           1           1             Yes

  460          7 (out)   4/4        12:10pm    9             0           0           0             NA

  460          7 (in)    4/4        12:40pm    9             0           0           0             NA

  404          8 (out)   4/3        5:43pm     10            0           0           0             NA

  407          8 (in)    4/3        6:35pm     17            0           0           0             NA

  402          9 (out)   4/4        9:40am     15            0           0           0             NA

  411          9 (in)    4/4        10:45am    10            0           0           0             NA

  451          11 (out)  4/4        8:40am     12            0           0           0             NA

  451          11 (in)   4/4        1:30pm     18            0           0           0             NA

  403          9 (in)    4/5        6:15pm     10            3           0           3             Yes

  306          1 (out)   4/3        2:20pm     7             0           0           0             NA

  417          17 (out)  4/3        2:55pm     11            0           0           0             NA

  300          17 (in)   4/3        3:40pm     5             0           0           0             NA

  400          19 (out)  4/3        4:20pm     11            0           0           0             NA

  416          19 (in)   4/3        5:00pm     8             0           8           8             Yes

  470          21 (out)  4/3        5:55pm     8             0           0           0             NA

  470          21 (in)   4/3        6:45pm     8             0           0           0             NA

  500          1 (out)   4/4        6:15am     12            0           0           0             NA

  504          1 (in)    4/3        7:30pm     10            0           7           7             Sometimes

  340          1X (in)   4/4        7:30am     9             0           0           0             NA

  306          1 (out)   4/4        9:04am     11            6           0           6             Sometimes

  335          37 (S)    4/4        10:18am    10            0           0           0             NA

  339          37 (N)    4/4        11:13am    9             0           0           0             NA

  405          1 (in)    4/4        9:50am     5             0           1           1             Yes

  459          23 (out)  4/4        12:50pm    6             0           0           0             NA

  459          23 (in)   4/4        2:25pm     6             0           0           0             NA

  318          1 (out)   4/4        12:24pm    5             0           0           0             NA

  503          1 (in)    4/4        2:50pm     15            0           12          12            Yes

  506          1 (out)   4/4        4:00pm     12            0           7           7             Sometimes

  509          1 (in)    4/4        4:50pm     18            13          0           13            Sometimes

  406          1 (out)   4/6        7:00am     6             0           0           0             NA

  500          1 (in)    4/6        8:11am     6             0           0           0             NA

  335          4 (in)    4/3        4:45pm     7             0           0           0             NA

  335          4 (out)   4/3        4:00pm     7             0           0           0             NA

  327          13 (out)  4/3        5:40pm     9             1           0           1             No

  456          14 (out)  4/3        2:25pm     8             0           0           0             NA

  473          14 (in)   4/3        3:35pm     7             0           0           0             NA

  451          15 (in)   4/3        6:39pm     4             0           0           0             NA

  412          3 (out)   4/4        10:10am    10            0           0           0             NA

  412          3 (in)    4/4        11:06am    11            0           0           0             NA

  461          10 (out)  4/4        12:10pm    11            0           0           0             NA

  473          10 (in)   4/4        1:15pm     8             0           2           2             Yes

  452          12 (out)  4/4        8:28am     9             0           0           0             NA

  452          12 (in)   4/4        9:30am     10            0           0           0             NA

  453          13 (in)   4/4        2:35pm     13            0           11          11            Yes

  451          15 (out)  4/4        2:10pm     7             0           9           9             Yes

  508          29        4/4        4:20pm     7             \*\*        0           \*\*          Sometimes

  **TOTALS**                                   **465**       **29**      **74**      **103**       
  ------------ --------- ---------- ---------- ------------- ----------- ----------- ------------- ----------------

\*\* Announcements made on this downtown loop route didn't appear to
match the list of stops that should have been made.

***Findings and Recommendations***

***Findings***

1.  The on-board stop announcement policy, detailed in CATA's Work Rules
    and associated Training Manual memoranda, appears to be consistent
    with regulatory requirements.

2.  The "Route Announcement" lists prepared by CATA with consumer input
    appear to include major stops and sufficient stops for riders to
    remain oriented as to their location.

3.  Drivers, supervisors, and other employees appear to be familiar with
    the policy, which requires stops to be announced.

4.  The automated system did not appear to be fully functioning when
    on-site observations were made. The automated system announced only
    29 of the 465 stops designated for announcement.

5.  Drivers were observed to not consistently make voice announcements
    when the automated system was not functioning. Voice announcements
    were observed for only 74 of the 436 stops that were not announced
    automatically.

6.  Voice announcements made without amplification by drivers were
    sometimes not audible or clear. On three of the ten routes where
    voice announcements were observed, the announcements were not clear
    and audible.

7.  Automated announcements, using synthesized, computer-generated
    speech, were not always clear. On two of the five routes where
    automated announcements were observed, the announcements could not
    be clearly understood by the reviewers and on one route the
    announcements could be understood only some of the time.

***Recommendations:***

1.  CATA should continue to work with the DataGuide manufacturer to
    address problems that have apparently developed with the system. As
    part of this repair, it is recommended that CATA explore, with the
    input of the Local Advisory Committee, alternatives for improving
    the clarity of the announcements.

2.  CATA should re-emphasize the need for operators to provide manual
    back up should the automated system fail to completely and
    accurately announce stops. Specific guidance for operators detailing
    the circumstances under which voice announcements should be made
    should be developed. This guidance should be incorporated into the
    Work Rules and into training materials.

3.  Options for being able to activate and use a PA system to amplify
    voice announcements should be explored. This should be explored for
    existing buses as well as for future purchases. CATA staff noted
    that 10 newer buses might be able to be easily modified to allow the
    PA system to be used separate from the DataGuide system.

4.  A renewed effort to monitor operator compliance with stop
    announcement policies should be undertaken.

**Observations of Route Identification System**

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

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

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

-   On Wednesday, April 5, several drivers and a shift supervisor were
    interviewed to verify their understanding of bus/passenger
    identification policies and operational practices;

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

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

    **CATA Policies and Procedures Regarding a Route Identification
    System**

    While the "Work Rules" section of the CATA "Training Manual" details
    the on-board stop announcement policy, it does not appear to explain
    requirements for identifying vehicles or passengers at stops served
    by multiple routes.

    The Operations Manager and Superintendent of Training indicated that
    policy in this area has been communicated to operators as part of
    the training. They noted that the policy is for operators to make an
    external voice announcement when there are passengers waiting at a
    stop that is served by more than one route.

    The policy for external stop announcements is referred to in the
    March 30, 2000 memorandum to all operators (see Attachment C). This
    memorandum notes that "checkers" hired to monitor compliance with
    ADA requirements will "\...check for announcements at duplicate
    stops informing passengers of the route your bus is driving."

    Staff also noted that at the downtown Transportation Center, the
    system for identifying vehicles by route is built into the design of
    the center. Buses pull into bays that are designated for each route.
    There is tactile edging at each bus berth. On pillars located near
    each berth there is Braille signage indicating the route number and
    name. These signs are at the same height and at the same location on
    each pillar.

    **CATA Training**

    The Superintendent for Training noted that the policy for making
    external announcements at stops served by two or more routes was
    covered in both initial and refresher training. He noted that it is
    verbally described, but there is no written description of the
    policy.

    **Operator and Supervisor Interviews**

    Six of the nine employees interviewed appeared to have a clear
    understanding of the external stop announcement policy. One employee
    initially was not aware of any policy, but when prompted remembered
    that external announcements were discussed in the recent retraining
    program. Two operators interpreted the policy to mean that if they
    saw someone with a vision impairment at a stop they were to ask what
    bus the individuals were waiting to board.

    **Rider Experiences and Observations**

    All three of the riders who were interviewed indicated that they had
    not heard any external announcements and were not aware of a policy
    on bus identification.

    One rider did note, however, that the downtown Transportation Center
    was well designed and easy for him to use. He noted the various
    design features that had been incorporated for travelers with vision
    disabilities.

    **Assessment Team Observations**

    At various times from Monday, April 3 through Thursday, April 6,
    assessment team members waited at major transfer points to observe
    buses pulling in. Observations were made at the following locations:

-   The Meridian Mall;

-   Meijers (North)

-   The Shaw and Farm Boarding Center at MSU;

-   Grand & Shiawassee at Community College; and

-   Meijers (Southwest at Pennsylvania and Jolly).

A total of 44 buses were observed pulling into these locations. As buses
pulled in, reviewers would note the route number, the bus number, and
the time. They would then listen and observe to see if the bus operator
made any external announcement or identified the bus and route in any
other way. Copies of the completed "Vehicle/Passenger Identification
Assessment Forms" completed by the reviewers are provided in Attachment
E.

As the forms in Attachment E show, reviewers did not observe external
announcements or other identification at any of the sites by any of the
buses observed. In two instances, after the bus was there for a few
minutes and the reviewer had not boarded, the driver offered assistance
or asked which bus the reviewer was waiting to board.

***Findings and Recommendations***

***Findings***

1.  The design features of the new downtown Transportation Center appear
    to provide a good system for assisting riders with vision
    disabilities to identify the bus they need to board.

2.  CATA's Work Rules do not appear to specifically detail a policy for
    external stop announcements. The CATA policy appears to have been
    verbally communicated in operator training and only briefly
    mentioned in a recent memorandum. As a result, three of the ten
    employees interviewed did not have a clear understanding of the
    external stop announcement policy.

3.  Operators did not appear to be making external stop announcements at
    the time of the on-site assessment. In 44 situations where an
    external announcement should have been made, none were observed.

***Recommendations***

1.  An external announcement/bus identification policy should be added
    to CATA's Work Rules and training materials.

2.  A renewed effort to inform operators of this policy and then to
    monitor operator performance should be undertaken by CATA.

**Attachment A**

**CATA Work Rules Excerpt and Policy Memorandum**

**Attachment B**

**CATA "Route Announcement" Lists**

**and Transmittal Memorandum**

**Attachment C**

**March 30, 2000 Memorandum Regarding Use of "Checkers"**

**Attachment D**

**Completed "On-Board Fixed Route Stop Announcement Assessment Forms"**

**Attachment E**

**Completed "Vehicle/Passenger Identification**

**Assessment Forms"**

# Attachment F

CATA Response

to

Draft ADA Assessment of Stop Announcement

and

Route Identification Efforts

July 25, 2000