Milwaukee County Transit System

(MCTS)

**Milwaukee, Wisconsin**

Assessment

Of

ADA Complementary Paratransit Service

Capacity Constraints

July 10-13, 2001

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**With**

**Multisystems, Inc.**

**Final Report: January 11, 2002**

CONTENTS

[**I.** **Purpose of the Assessment** 1](#__RefHeading___Toc525116132)

[**II.** **Overview of the Assessment** 3](#__RefHeading___Toc525116133)

[**III.** **Background** 7](#__RefHeading___Toc525116134)

[**IV.** **Summary of Findings** 11](#__RefHeading___Toc525116135)

[**V.** **Observations Regarding ADA Complementary Paratransit
Eligibility Determinations** 15](#__RefHeading___Toc525116136)

[**VI.** **Observations Regarding Telephone Access to the Transit Plus
System** 22](#__RefHeading___Toc525116137)

[**VII.** **Observations Regarding the Handling and Scheduling of Trip
Requests** 29](#__RefHeading___Toc525116138)

[**VIII.** **Observations Regarding Service Provision**
38](#__RefHeading___Toc525116139)

[A. On Time Performance 42](#__RefHeading___Toc525116140)

[B. Trip Length 45](#__RefHeading___Toc525116141)

[**IX.** **Resources** 52](#__RefHeading___Toc525116142)

*Attachment A. MCTS Response*

*Attachment B. Assessment On-Site Schedule*

*Attachment C. Transit Plus Rider's Guide*

*Attachment D. Summary of Transit Plus Complaints on File at MCTS,
January-June, 2001*

*Attachment E. Laidlaw Call Distributor Reports for May 2001*

*Attachment F. St. Ann Center Trip Request Faxes*

*Attachment G. Travel Times for Trips to the Eisenhower Center, May 16,
2001*

I. 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 compliance assessments is to assist the transit
agency and the FTA in assessing whether capacity constraints exist in
ADA Complementary Paratransit services. The assessments examine service
standards and policies related to issues of capacity constraints such as
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 significant 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 that will assist the transit service provider in
ensuring that service can be effectively monitored by transit agencies
for capacity constraints.

An on-site assessment of ADA Complementary Paratransit service provided
by the Milwaukee County Transit System (MCTS) in Milwaukee, Wisconsin
was conducted from July 10 through July 13, 2001. Planners
Collaborative, Inc., located in Boston, Massachusetts, and Multisystems,
Inc., located in Cambridge, Massachusetts, conducted the assessment for
the FTA Office of Civil Rights. The assessment focused on compliance of
MCTS's ADA Complementary Paratransit service, known as Transit Plus,
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 MCTS'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 summarized.
Recommendations for addressing some of the findings are also provided.

MCTS was provided a draft copy of the report for review and response. A
copy of the correspondence received from MCTS 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 DOT ADA Complementary
Paratransit capacity constraints requirements of the regulations.
Several possible types of capacity constraints are identified by the
regulations. These include "wait listing" trips, having caps on the
number of trips provided, or recurring patterns or practices that result
in a significant number of trip denials, untimely pick-ups, or
excessively 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 system use was not 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 a critical part of using any ADA
Complementary Paratransit service.

**Pre-Assessment**

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

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

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-   A copy of the current service provider contract;

-   A copy of the operator manual, which details service policies and
    practices to drivers and employees;

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

-   A description of the service standards adopted by MCTS related to
    on-time performance, trip denials, travel times, and telephone
    service, if any.

Additional information was requested to 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 MCTS;

-   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 six customers and
consumer representatives. Additionally, the assessment team reviewed
seven complaints on file with FTA. These complaints were filed in 1998
and 1999.

**On-Site Assessment**

The on-site assessment began with an opening conference, held at 9:00 AM
on Tuesday,

July 10, 2001. MCTS representatives attending the meeting included
Carmela Peot, Director of Paratransit Services; Dan Boehm, Paratransit
Services Contract Manager; and Anita Gulotta-Connelly, Director of
Administration. Amos Owns of the County Audit Department also attended.
Representing the ADA Complementary Paratransit contractors were Cynthia
Long and Morgen McClelland of Laidlaw Transit, and John Doherty of
Transit Express. Russell Thatcher and Patricia Monahan of Multisystems,
Inc. and Terry Regan of Planners Collaborative represented the FTA
assessment team. Cheryl Hershey, the ADA Team Leader of FTA's Office of
Civil Rights, and Rhonda Reed, FTA Region 5 Civil Rights Officer,
participated in the opening conference via telephone.

[]{.mark}

Cheryl Hershey opened the meeting by thanking the MCTS for their
cooperation in the assessment. She reviewed the purpose of the
assessment and emphasized that it was intended to assist the MCTS 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 Friday.

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

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

MCTS staff indicated that they were happy to assist in any way during
the course of the assessment. They also indicated that some of the ADA
Complementary Paratransit provided by MCTS goes beyond the minimum ADA
Complementary Paratransit requirements. Specifically, same day service
is provided throughout Milwaukee County including areas outside of the
required ¾ mile corridors on either side of fixed bus routes. They asked
if the assessment would differentiate between required service and this
extra service. Russell Thatcher indicated that the assessment team would
base findings on ADA required service.

Following the opening conference, the assessment team met with MCTS
staff to review the eligibility determination process, customer
complaint procedures and records and budget information.

On Wednesday, July 11, the assessment team observed operations at
Transit Express, one of the MCTS's two ADA Complementary Paratransit
contractors. The assessment team observed the reservations, scheduling,
and dispatch functions and interviewed staff in those areas. The
assessment team members sat with different call takers and listened to
calls as they were received. Basic information (e.g., date and time
requested, origin and destination addresses, mobility aids used by the
rider, whether the request was served, and the negotiated trip time) was
recorded for each call observed. Information about staffing, phone
system design and capacity, and the available fleet was also collected.
Several drivers were also interviewed. Finally, completed manifests for
a sample day were requested and an estimate of on-time performance was
developed based on actual recorded pick-up and drop-off times for the
sampled trips.

A similar review of operations at Laidlaw Transit, the second
contractor, was conducted on Thursday, July 12.

The assessment team spent Friday morning, July 13, tabulating and
organizing information collected and reviewing the data with the MCTS
Paratransit Manager and Contracts Manager. An exit conference was held
at 1:15 PM.

All persons who participated in the opening conference (noted above)
were also at the exit conference. The following individuals were also in
attendance: Jerome Heer of the Milwaukee County Audit Department; Steve
Nigh and Ron Rutkowski of the Milwaukee County Department of Public
Works.

At the exit conference, the assessment team reviewed initial findings in
each of the following areas:

-   Customer comments and issues;

-   Service eligibility;

-   Telephone access;

-   Handling of trip requests and trip denials;

-   On-time performance;

-   Trip duration; and

-   Vehicle, manpower, and financial resources.

# Background

MCTS provides public transit services in Milwaukee County and in limited
parts of neighboring Waukesha and Ozaukee Counties. This includes fixed
route bus and ADA Complementary Paratransit service throughout the area,
trolley service in downtown Milwaukee, and vanpool service. About
965,000 people live in the MCTS serves area, which covers about 243
square miles.

MCTS is part of county government. The Managing Director of MCTS reports
to the County Executive. Transit services in the county are overseen by
the County Commissioners and a seven-person Transportation Public Works
and Transit Committee appointed by the Commissioners.

Fixed route service is provided with a fleet of about 546 buses and
trolleys. About 71 million rides are provided on the system's 77 routes.
Accessible service is provided on 28 of these routes.

Fixed route service is available seven days a week, 365 days a year.
Fixed route service operates as early as 5:00 AM and as late as 1:45 AM
on weekdays. The non-discounted one-way adult fare is \$1.50. Seniors,
persons with disabilities, and children under 12 years of age pay 75
cents. Children under age 6 accompanied by a fare paying person 12 or
older ride for free. Weekly passes are available for \$11.00, and
tickets are available in quantities of 10 for \$11.00 (\$1.10 each).
Students who have a School Permit (sold at area schools for \$5.00 per
year) pay \$1.00 per ride and can purchase tickets in quantities of 10
for \$9.00 (90 cents each).

In addition to the fixed route bus service, about 20 vans are used to
provide vanpool services to employers not served by the bus system.

**Description of the ADA Complementary Paratransit Service**

MCTS began providing ADA Complementary Paratransit service for the
county beginning on January 1, 2000. Prior to that time, the county's
Department of Public Works had provided the service. The service is
known as "Transit Plus."

Transit Plus service is provided to all of Milwaukee County and to the
parts of Ozaukee and Waukesha Counties where fixed route service is
provided. Outside of Milwaukee County, corridors ¾ miles wide on either
side of fixed routes define the ADA Complementary Paratransit service
area. Service is provided seven days a week, 365 days a year from 4:30
AM to 1:00 PM. Subscription service is not provided on 6 major holidays,
but riders can get these trips on a demand basis if they still need to
travel. Prior to August 1, 2001, the one-way fare was \$2.50 regardless
of distance. On August 1, 2001, the fare was increased to \$3.00. A copy
of the Transit Plus *Rider's Guide* is included as Attachment C.

Transit Plus service is provided by two private companies under contract
to MCTS. The service area is divided into two zones and each contractor
is responsible for all trips that are made by riders who reside in that
zone. Laidlaw Transit serves the north zone (about 45% of the trips) and
Transit Express serves the south zone (about 55% of the trips). In the
north zone, Laidlaw provides some service through a subcontractor --
Guardian Transportation. In the south zone, all service is operated
directly by Transit Express.

Each contractor handles all aspects of operation. They take
reservations, create the schedules, and deliver the service. Both
contractors accept Transit Plus reservations from 8 AM to 5 PM, 365 days
a year. Reservation requests may be made from 1 to 14 days in advance of
the trip. Contractors are paid on a per hour basis. The contractors own
all vehicles. MCTS manages the eligibility determination process, and
administers and monitors the provision of service.

Both contractors use the PASS reservations/scheduling/dispatching
system, which was purchased by the county and leased to the contractors.
The contractors enter actual time and trip disposition information into
the system, and MCTS receives complete trip files from each and prepares
reports and special data queries.

About 15,000 persons are registered with MCTS as ADA-eligible. In
calendar year 2000, a total of 525,663 one-way passenger trips were
provided under the Transit Plus program. It is estimated that 557,200
one-way passenger trips will be provided in calendar year 2001.

**Supplemental Taxi Service**

While this assessment focuses only on Transit Plus services, it should
be noted that MCTS also offers a supplemental taxi service. The taxi
service is available to ADA Complementary Paratransit eligible persons.

One cab company, American United, provides taxi service. Taxi service is
most often used for same day trips. Riders cannot book round-trips; they
must call for a return ride when they are ready. Subscription service is
available for medical, employment, and educational trips only. For trips
with a total meter cost of up to \$14.60, riders pay \$2.50 (\$3.00 as
of 8/1). Riders must pay the \$2.50/\$3.00 plus anything over \$14.60
for longer trips. Tipping the taxi drivers is permitted. In calendar
year 2000, a total of 192,170 one-way taxi trips were subsidized by
MCTS.

Because the taxis are not accessible, only persons who are ambulatory or
who can transfer from their wheelchair to a taxi use the service.

**Contracts with Agencies**

MCTS also has contracts with six Goodwill Industries agencies and one
medical rehabilitation agency. These agencies operate their own
transportation for clients and MCTS reimburses them for persons
transported who are ADA Complementary Paratransit eligible. In calendar
year 2000, these agencies provided 266,348 one-way passenger trips.

This supplemental service is not, however, considered part of the formal
ADA Complementary Paratransit program and was therefore not reviewed in
detail as part of this assessment.

**Voluntary Compliance Agreement with the FTA**

In 1997, Milwaukee County reported to FTA that it was not able to fully
implement all requirements for ADA Complementary Paratransit service by
the statutory deadline of

January 26, 1997. As a result, the County entered into a voluntary
compliance agreement (VCA) with the FTA and agreed to certain actions
and milestones for achieving full compliance. As part of the VCA, the
County reviewed the structure of the Transit Plus program and
implemented a new service design. Prior to the VCA, 16-17 contractors
provided Transit Plus service and contractors were paid on a per trip
basis. This was changed to the current design, which has two prime
contractors operating in two zones and paid on a per hour basis.

**Settlement Agreement with the Wisconsin Coalition for Advocacy**

In 1999, the Wisconsin Coalition for Advocacy (WCA) filed a class action
lawsuit against the county claiming that the service did not comply with
requirements for ADA Complementary Paratransit service contained in the
USDOT ADA regulations. This suit was settled in May of 2000. The terms
of the settlement called for:

-   Changes in the scheduling policies and parameters;

-   An expansion of the Transit Plus service area to include parts of
    Waukesha County where fixed route bus service was operated and
    coordination with Waukesha County in the provision of this service;

-   Continued involvement of consumers and the Transit Plus Advisory
    Council (TPAC) in the development and assessment of the program;

-   More timely processing of applications for ADA Complementary
    Paratransit eligibility;

-   One-time funding of accessibility improvements (such as the
    installation of ramps) to enable persons to access the ADA
    Complementary Paratransit service;

-   The County providing sufficient capacity to meet ADA Complementary
    Paratransit system demand;

-   A maximum trip request denial rate of 3.5% for the Transit Plus
    service;

-   Best efforts to reduce telephone hold times;

-   A re-definition of the on-time window to be 5 minutes before to 30
    minutes after the negotiated pick-up time and an on-time performance
    standard of 90% within this window;

-   A tightening of the on-time window to be zero minutes before and 25
    minutes after the negotiated time beginning July 31, 2001.

-   A re-definition of maximum ride times and free service vouchers for
    riders who reported and were determined to have experienced
    excessive ride times;

-   Monthly reports to be submitted to WCA by MCTS documenting progress
    in meeting the terms of the settlement; and

-   An independent audit of the service.

Please note that while recognizing the settlement agreement is a mutual
agreement between parties to improve service and resolve issues, FTA is
not a party to this agreement. The standards established by this
agreement does not reflect FTA's involvement or endorsement, and the
agreement does not supercede the regulatory requirements contained in
the DOT ADA regulations.

**Consumer Comments**

In order to identify potential areas of concern, prior to the assessment
the team interviewed six consumers and consumer representatives and
reviewed six complaints filed with FTA from 1998 through 2000.

In addition, during the field assessment, the team reviewed Transit Plus
complaint records at MCTS for the period from January through June 2001.
A tabulation of these complaints is provided in Attachment D.

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

# Summary of Findings

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

**Findings Regarding ADA Complementary Paratransit**

**Eligibility Determinations**

1.  The eligibility determination process used by MCTS does not appear
    to limit access to ADA Complementary Paratransit service by eligible
    applicants. MCTS staff appears to have a very good understanding of
    ADA Complementary Paratransit eligibility requirements and appear to
    make determinations that are thorough and accurate.

2.  Determinations of eligibility appear to be made in a timely way.
    Interviews are typically scheduled within a week and at the most
    within two weeks. Most determinations are made on the day of the
    interview. The only delays noted were the result of incomplete
    information and documentation provided by applicants.

3.  The scheduled fixed route weekday service hours are greater than the
    ADA Complementary Paratransit service hours.

**Findings Regarding Telephone Access**

1.  First-hand observations of both carriers did not reveal substantial
    problems getting through on the phones or long hold times once calls
    were answered. Only one call, which was being handled by a new call
    taker at Transit Express, was observed to be on hold for more than
    five minutes.

2.  Automatic call distribution reports generated by the phone system at
    Laidlaw Transit indicate that hold times likely exceed the MCTS
    standard on certain days. Average daily hold times of over two
    minutes were recorded on 15 of the 31 days in May 2001. A maximum
    daily hold time of over seven minutes was recorded on May 5^th^.
    Given that these are daily averages, it is also likely that hold
    times during peak calling periods are significantly higher.

3.  The telephone system at Transit Express does not appear capable of
    generating daily service and performance reports. This lack of
    reporting capability makes it very difficult to ensure that hold
    time standards are being met.

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

1.  MCTS and its contractors do not appear to employ waiting lists or
    trip caps in the operation of the Transit Plus service.

2.  Since January 2001, there have consistently been approximately
    200-400 one-way trip requests per month as denials. This represents
    between 0.2-0.7% of all trips requested and about 0.5-1.6% of all
    non-subscription, "demand" trips requested.

3.  There was evidence that some trips that are not accommodated within
    an hour of the requested time are not being recorded as trip
    denials. This appears to be the exception rather than the rule,
    however, and appears to be an issue of call taker training. The true
    denial rate is therefore probably slightly higher than the reported
    rate.

4.  There appear to be some patterns to the small number of trip denials
    that would make the rate for certain requests higher than the
    system-wide average. The denial rate during certain peak travel
    hours appears to be 1.8-3.5% and during some very limited times as
    high as 6.6% of all "demand" requests. In the north part of the
    service area, the denial rate for trips made less than five days in
    advance is estimated to be 3.4-5.2%. And, individuals who use
    wheelchairs appear to be 50% more likely to be denied a trip than
    persons who are ambulatory.

5.  The settlement agreement between MCTS and the Wisconsin Coalition
    for Advocacy calls for MCTS to deny no more than 3.5% of all trip
    requests; however, MCTS stated that its goal is to accommodate all
    trip requests from eligible riders. The settlement agreement
    conflicts with FTA guidance regarding trip denials on this point.
    MCTS' policy to plan, budget, and strive to provide all requested
    trips is in accordance with FTA guidance.

**Findings Regarding Service Provision**

1.  It appears that 94 to 97% of passenger pick-ups are made on time or
    early.

2.  A detailed analysis of on-time performance showed that 37% of
    pick-ups are made early (6 or more minutes before the negotiated
    pick-up time).

3.  It appears that the existence of three different standards over a
    19-month period has led to confusion among both users and drivers of
    the system as to what constitutes "on-time performance." In
    interviews with drivers, several believed that the standard was
    still 15 minutes early to 15 minutes late.

4.  Some schedules appear to require operators to make early pick-ups in
    order to perform runs on time. While there was no evidence that the
    contractors force riders to leave early, it appears that scheduling
    and performing trips before, as well as after the scheduled time, is
    still a normal method of operation. This practice may lead customers
    to feel like they have to be ready early, despite formal policies
    regarding the pick-up window.

5.  Significant staff effort is dedicated at Transit Express to
    developing workable schedules and to monitoring operators and runs
    on the day of service. Operators appear to be checking-in frequently
    with dispatchers at Transit Express to provide an update on the
    status of runs and to receive direction and instructions for
    continuing runs. The schedulers at Laidlaw, on the other hand,
    appear to rely more on the automated system to develop and
    "clean-up" schedules. The dispatchers at Laidlaw also appear to rely
    more on operators to report current or potential schedule problems.
    These methods of operation at Laidlaw could be contributing to
    on-time performance problems.

6.  About 85% of all Transit Plus trips take 60 minutes or less. Of the
    roughly 15% of trips with travel times of over 60 minutes, less than
    half of one percent take more than 120 minutes.

7.  The percentage of trips with long travel times is consistent between
    the two Transit Plus carriers.

8.  The repetition of destination addresses and customers' names on Ride
    Duration Detail reports appears to indicate that many long travel
    times occur on regularly scheduled group trips, particularly for the
    customers that are picked up first in the morning or dropped off
    last in the afternoon. Residential addresses for customers with long
    trips are often located on the outskirts of the Transit Plus service
    area.

9.  Based on review of the May 2001 sample of trips, the travel time for
    over half of all Transit Plus trips is comparable to, or better
    than, the travel time on a fixed route trip between the same origin
    and destination. For the other half of the trips, however, travel
    time on Transit Plus is significantly longer than on comparable
    fixed route trips.

10. According to estimates of fixed route travel times developed by
    MCTS, all 14 of the excessive ride duration complaints received
    between June 2000 and June 2001 were found to have exceeded the
    standards established in the settlement between Milwaukee and the
    WCA. According to estimates of fixed route travel times developed by
    the assessment team, 63% of a sample of 38 trips taken in May 2001
    were found to be within that standard, and 37% were found to exceed
    it.

**Findings Regarding Resources**

1.  The process used by MCTS to estimate demand and funding needs for
    the Transit Plus service appears to accurately consider current
    level of demand, projected growth in demand and any past unmet
    needs. The availability of funding does not appear to limit the
    service from being operated in full compliance with the ADA
    Complementary Paratransit regulations.

2.  Transit Plus contractors appear to have an adequate number of
    vehicles and other capital equipment to meet the full demand for
    service.

3.  At the time of the review, the contractors appeared to have an
    adequate number of available operators and other staff to provide
    service in full compliance with the regulations. There appeared to
    have been a shortage of operators at Laidlaw Transit in the winter
    of 2000/2001, but this problem had been corrected.

4.  Operators appear to be adequately trained to operate vehicles and
    accessibility equipment safely and to properly assist and treat
    individuals with disabilities in a respectful and courteous way.

5.  Training for other personnel appears, for the most part, also to be
    thorough. Recent efforts have been made to provide remedial
    instruction to call takers, schedulers, and dispatchers in the
    proper use of the automated reservations, scheduling, and dispatch
    system. However, at the time of the review, there was still evidence
    that some call takers may not be recording trip denials
    appropriately, which may be causing trip denials to be
    underreported.

6.  While both contractors appear to have an adequate number of
    available spare drivers to cover pull-out, they tend to operate with
    little or no spare, or "floater" capacity at certain times of the
    service day. This requires dispatchers to use existing runs to cover
    in-service problems, which in some cases can cause scheduled trips
    to be performed late. The lack of spare capacity appears to be
    related to the fact that MCTS does not provide reimbursement for
    spare capacity but only pays for vehicle time used in the provision
    of service.

# 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:

-   An understanding of the handling and review of applications was
    developed through interviews of MCTS staff, a review of application
    materials, and first-hand observation of the in-person interview and
    assessment process.

-   Eligibility determination outcomes were reviewed.

-   Records for recently reviewed applications were examined, and the
    processing time for each was determined.

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

**Consumer Comments**

The eligibility determination process was discussed in telephone
interviews with six riders and local agency staff and advocates. No
issues were raised about the accuracy of the determinations being made
by the MCTS. All persons contacted also felt that the determinations
were being made in a timely way.

MCTS complaint records for the period from January 1 to June 30, 2001,
were also reviewed (see summary in Attachment D). None of the complaints
on file related to the eligibility determination process.

Neither were any of the complaints on file with FTA related to the
eligibility determination process.

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

MCTS determines ADA Complementary Paratransit eligibility based on an
in-person interview and functional assessment. Individuals who call MCTS
inquiring about the program are sent a letter describing the eligibility
determination process, a one-page general information sheet that
describes the Transit Plus program, and a brief two-page application
form. The cover letter asks applicants to call as soon as possible to
schedule an interview at the MCTS offices. Applicants are instructed to
bring the completed application form, and a letter from a licensed
physician providing information about their specific disability to the
interview.

The application form requests the following information:

-   Name, address, phone number, etc.;

-   Types of mobility aids used and when these aids are used;

-   If the applicant has ever used the MCTS fixed route bus service, and
    under what circumstances they are able to use the bus;

-   Whether there are any barriers at the applicant's home or at
    frequent destinations that would make it difficult for a Transit
    Plus driver to assist them to and from the vehicle; and

-   Whether the person requires the assistance of a personal care
    attendant.

When individuals call for an interview appointment, a day and time is
given and their name, date of the call and interview date is entered
into a database. Daily interview schedules are then prepared for the
staff that performs the interviews and assessments.

The eligibility staff arranges transportation to and from the interview,
if needed by applicants. If applicants are current riders and are being
recertified, travel to/from the interview is arranged on Transit Plus.
If new applicants need transportation, this is arranged separately
through contracts with local van and taxi companies. These companies
bill MCTS for the service.

MCTS staff members perform the interviews/assessments. Three staff
members are trained to perform this task. Interviews are conducted at
the MCTS offices every Monday, Tuesday, Thursday, and Friday. On
Wednesdays, staff is available to travel to facilities/agencies in the
community to conduct interviews. Off-site interviews will be arranged if
the host agency has 10 or more applicants that are applying for the
service. Applicants are greeted and the interview/assessment process is
explained. The interviewer also reviews the application form for
completeness and to get an idea of the applicant's disability and
potential travel issues. Applicants are then directed to an interview
room.

Applicants are asked how they got to the interview and how they usually
travel in the community. Information about fixed route bus service in
the area where they live is also noted. To assess cognitive ability, the
applicant is shown a video that simulates a bus trip. The applicant is
asked to identify the bus, basic route information, and the destination
that they are told to watch for. The ability of the applicant to
understand and respond to questions in the interview is also noted.

To assess physical ability, the applicant is observed walking to and
from the interview room. The interviewer assesses the applicant's
walking speed, gait, and use of mobility aids (if applicable). In the
interview room, some standard tests of balance, strength, and gait are
administered (based on the Tinetti Gait and Balance Tests used widely by
physical therapists).

If the applicant is determined to be eligible, based on the information
in the application and on interview/assessment observations, a photo ID
is prepared following the interview. A Rider's Guide is also given to
the new rider. In some cases, the applicant may not have brought
professional verification of disability or there may still be follow-up
questions that the MCTS staff feels need to be asked of the verifying
professional. In these cases, a photo is taken and the person is told
what additional information is required and that they will be contacted
as soon as this information is received. When a final decision is made,
eligibility and customer information is entered into the Trapeze system
to enable the applicant to begin using the Transit Plus service.

MCTS grants permanent eligibility to persons whose functional abilities
to use fixed route service are not expected to change. Others are
typically granted eligibility for periods ranging from one to 10 years.
Temporary, or "short-term" eligibility is granted if the person needs
service for a temporary condition or if functional ability is expected
to change in the near future. Applicants whose eligibility is about to
expire are sent a notice of the need to reapply. Notices are sent out
three months prior to the recorded expiration date.

If MCTS staff determine that applicants are able to use fixed route
service some of the time, they are granted conditional eligibility and
receive a letter which details the conditions under which they are
eligible for Transit Plus service. If applicants are determined to be
able to use the fixed route system under all conditions, they are denied
Transit Plus eligibility and receive a letter detailing the reasons for
the determination. Persons denied eligibility or granted only
conditional eligibility are given the opportunity to appeal. If an
appeal is requested, the Paratransit Services Director first reviews the
determination. If this review does not resolve the issue, an appeal
before a four-person panel is arranged. The current panel is comprised
of MCTS's Director of Labor Relations, the Director of Work Services at
the local Goodwill Industries, the Director of the Center for
Transportation Education at the University of Wisconsin-Milwaukee, and
the Transportation Planning Director at the County Department of Public
Works.

As part of the assessment, sample letters of determination were examined
to ensure that information about the appeal process was included and
that letters limiting eligibility explained the reasons for conditioning
or denying eligibility. This review showed that the letters of
determination sent to persons denied eligibility or determined
conditionally eligible do provide detailed information about the right
to appeal and how to initiate an appeal. The letters also were very
detailed in describing exactly why the applicants' eligibility was
conditioned or why they were denied eligibility.

In some cases, individuals schedule but do not appear for interviews. In
other cases, applications are filed without the required professional
verification of disability. To ensure that requests for eligibility are
not lost in the system, MCTS maintains several computerized lists of
pending applications covering all reasons for applications to still be
in process.

**Determination Outcomes**

At the time of the assessment, MCTS reported that about 15,000 persons
were registered for the Transit Plus service. MCTS reviews about 300-350
new applications per month and conducts recertification reviews for
another 100-150 persons each month.

Table 1 below shows determination outcomes for the month of June 2001.
As shown, about 87% of applicants were granted unconditional eligibility
for some period of time. Another 13% of applicants were granted
conditional eligibility. Only one applicant was denied eligibility.

**Table 1. Transit Plus Eligibility Determination Outcomes for June
2001**

  -------------------------------------------- --------------------------
  **Determination**                            **Number**

  Permanent Unconditional                      272

  Non-Permanent (1-10 Years) Unconditional     102

  Short-Term (\< 1 Year) Unconditional         14

  Permanent Conditional                        11

  Non-Permanent (1-10 Years) Conditional       46

  Short-Term (\< 1 Year) Conditional           1

  Denied                                       1

  TOTAL                                        447
  -------------------------------------------- --------------------------

MCTS staff reported that they have had only one appeal that has gone to
the formal Appeal Panel since May 1999 when a major recertification of
eligibility was started. Any other questions about determinations have
been resolved informally through a review and follow-up contact by the
Director of Paratransit Services.

**Review of Recent Denials of Eligibility**

A review of ten recent denials of eligibility was conducted as part of
the assessment. The full files were reviewed and discussed with the
eligibility staff. Reasons for the determination that the applicant
could always use fixed route were noted. As indicated above, only a
small number of applicants are typically denied eligibility.

The review showed that all ten denials appeared reasonable. Six
applicants noted physical disabilities or health conditions. These
conditions did not appear to significantly affect functional ability,
however, based on statements from the applicant and observations in the
assessment. Conditions included mild arthritis, diabetes, epilepsy, and
obesity. One person had a vision impairment (20/200 vision) but appeared
fully functional and indicated that her major difficulty was managing
heavy packages on the fixed route bus. Two persons reported mild mental
retardation, but indicated they currently used fixed route buses and
could manage throughout the system. Finally, one applicant reported a
mental illness, which did not appear to be severe enough to impair full
use of fixed route service.

**Review of Application Processing Times**

The ADA regulations require that transit agencies provide presumptive
eligibility to applicants if determinations cannot be made within 21
calendar days of the receipt of a completed application. In the MCTS
process, an "application" would not be considered complete until an
interview/assessment had been conducted and both a complete application
and verification of disability from a qualified professional had been
received.

To check the timeliness of eligibility determinations, both the time
required to schedule interviews and the time to make a final
determination after the completion of interviews was considered. MCTS
maintains two separate records that track the processing of requests for
determinations of eligibility. The first is a computer listing that
shows the date when applicants call requesting an interview appointment.
This listing shows the date of the call and the date that the interview
was scheduled. Final dates of determination are then maintained
separately as part of the eligibility determination database.

A random sample of 98 records from May 2001 was examined from the
listing that showed the dates of requests for interviews and the actual
interview date. As shown in Table 2 below, all but one person was
scheduled for an interview within 12 days from the date they called. One
person was scheduled 21 days out, but a review of this record showed
that the person was a current rider, was re-applying and was in no hurry
to schedule the interview since her eligibility would not lapse. In 83
instances (85% of the time), interviews were arranged in seven days or
less. One person was a walk-in to the MCTS office.

**Table 2. Time Required to Schedule an Eligibility Interview,**

**Based on 98 Randomly Selected Records**

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

  Same day                                  1

  1 day                                     13

  2 days                                    5

  3 days                                    17

  4 days                                    12

  5 days                                    13

  6 days                                    16

  7 days                                    6

  8 days                                    6

  10 days                                   6

  12 days                                   2

  21 days                                   1

  TOTAL                                     98
  ----------------------------------------- -----------------------------

The final determination dates for 40 randomly selected applicants from
May of 2001 were then looked up in the eligibility database. Table 3
below presents the information from this review. As shown, 38 of the 40
determinations were made on the same day that the interview was
conducted. In one case, required professional verification had to be
sent following the interview, and the determination was made five days
after the interview. In the final case, professional verification of
disability was not provided by the applicant and the application was
still pending.

**Table 3. Time Required to make Final Eligibility Determinations**

**Following Completion of an Interview,**

**Based on 40 Randomly Selected records from May 2001**

  ----------------------------------------- -----------------------------
  **\# Of Days From Interview to Final      **Number of Applicants**
  Determination**                           

  Same day as interview                     38

  5 days after interview                    1

  Still pending                             1

  TOTAL                                     40
  ----------------------------------------- -----------------------------

**Other Service Access Issues**

In addition to issues of eligibility, the assessment team reviewed a
sample of fixed service bus route schedules to compare fixed route and
ADA Complementary service hours. Fixed route service is available seven
days a week, 365 days a year. The sample of fixed route schedules
indicates that service operates as early as 5:00 AM and as late as 1:45
AM on weekdays. ADA Complementary Paratransit Service is provided seven
days a week, 365 days a year from

4:30 AM to 1:00 AM. The DOT ADA regulations at 49 CFR section 37.131(e)
require the following:

> ADA complementary paratransit service shall be available throughout
> the same hours and days as the entity's fixed route service.

**Findings**

1.  The eligibility determination process used by MCTS does not appear
    to limit access to ADA Complementary Paratransit service by eligible
    applicants. MCTS staff appears to have a very good understanding of
    ADA Complementary Paratransit eligibility requirements and appear to
    make determinations that are thorough and accurate.

2.  Determinations of eligibility appear to be made in a timely way.
    Interviews are typically scheduled within a week and at the most
    within two weeks. Most determinations are made on the day of the
    interview. The only delays noted were the result of incomplete
    information and documentation provided by applicants.

3.  The scheduled fixed route weekday service hours are greater than the
    ADA Complementary Paratransit service hours.

**Recommendations**

1.  MCTS may want to consider adding one more person to its appeal
    panel. It is recommended that this person be a professional that
    could bring a high level of understanding about the disability of
    the applicant. MCTS could maintain a listing of local physicians,
    psychiatrists, Orientation and Mobility Instructors, and other
    professionals who are willing to participate in the process. An
    appropriate professional, based on the particular disability of the
    applicant, could then be involved in the appeal. Adding one
    additional member also will make it a five-person panel, which will
    help avoid split votes on appeals.

2.  MCTS should modify its ADA Complementary Paratransit service hours,
    or its fixed route service hours, in order to make ADA Complementary
    Paratransit service available for the same hours as fixed route
    service.

# Observations Regarding Telephone Access to the Transit Plus System

This part of the assessment addresses telephone access to the service.
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. An inability to get through on the phone to
place trip requests or to check on rides could discourage people from
using the service and could therefore be considered a form of capacity
constraint.

The following information was collected:

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

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

-   The design of the phone systems and the staffing of phones by each
    contractor was reviewed;

-   The handling of calls in both reservations and dispatch as observed
    at each contractor site; and

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

**Consumer Comments**

A total of six riders, advocates and local agency staff were contacted
by phone prior to the assessment. All were asked about issues with the
Transit Plus service. Comments on telephone access to the service were
specifically requested. These interviews indicated that telephone access
was somewhat of an issue. Of the six persons interviewed, three
indicated some problems with phone service. One person noted that
callers could sometimes be on hold for 10-15 minutes. A second person
said that phone hold times had been a problem but seemed to be better in
the last few months. The third person did not indicate problems with
hold times but said that the major phone problem is that callers get
cut-off. The person who expressed concern about hold times said that
there did not seem to be any particular time when the phones were
busiest. She also indicated that this is not a consistent problem, but
can occur sometimes.

Customer comments and complaints on file at MCTS for the period from
January 1 through

June 30, 2001 were reviewed. A tabulation of complaints by type is
provided in Attachment D. As shown, a total of 70 complaints (13.6% of
all complaints) were received regarding issues with the reservations
process. MCTS staff noted that there had been some phone system problems
in January and February, which caused some calls to be cut-off abruptly.
The issue was addressed with the phone company and complaints about
phone service have decreased in recent months.

**MCTS Phone Service Policies and Standards**

Transit Plus customers call the carrier that provides service in the
zone in which they reside to schedule or cancel trips, to check on
rides, or to comment on the service. Customers who live in the north
zone call Laidlaw Transit, and customers in the south zone call Transit
Express. Trip reservations are accepted between 8:00 AM and 5:00 PM, 365
days a year. Dispatch/customer service calls are accepted during all
hours of operation (4:30 AM to 1 AM).

MCTS has established telephone service performance standards for its
contractors. The following standards are included in the current
contracts:

-   All calls must be answered;

-   No calls can be disconnected by carrier staff; and

-   No call can be on hold for longer than two minutes.

**Observations of Contractor Telephone Services and Capacity**

Information about telephone system design and capacity and about
staffing of the reservations and dispatch/customer service functions was
obtained from each contractor. The handling of calls was also observed
for several hours at each contractor site. Calls to each contractor were
also made at various times of day. Finally, telephone service reports
were requested and reviewed. Information and observations for each
contractor are discussed below.

***Transit Express***

Customers call Transit Express at 264-7433 (voice or TTY). When calls
are received, there is an automated greeting that presents callers with
three options. They can press "3" to get Transit Plus; press "4" for
Department on Aging, Employment, Title 19, or Charter service; or dial a
direct extension. Callers can also hold for operator assistance if they
are not sure which option to choose.

Transit Plus handles calls through a central call sequencer that
searches for open lines. There are 14 incoming lines and two outgoing
lines dedicated to the Transit Plus service. Six call stations in the
Transit Plus reservations/dispatch area plus a station for the manager
of the operation, serve these 14 lines. Each station can handle up to
three incoming calls, but call takers typically handle only two calls at
a time. Incoming calls ring on all available stations and are served by
any available staff.

If a caller is placed on hold for more than 30 seconds, that line will
begin to beep. Any available staff can then intervene and assist with
the call.

Four or five call takers are typically available on weekdays. Three
dispatchers are also on duty during peak service hours.

It was also noted that trip requests are accepted by fax. This option is
typically used by agencies to reserve rides for clients who are
traveling to and from programs. Call takers enter information and fax
back confirmations during slow call times.

The reservations area at Transit Express was observed between the hours
of 8:30 and 11:00 AM on Wednesday, July 11, 2001. Assessment team
members sat with three call takers and recorded the handling of calls.
During this period of time, all calls appeared to be handled with little
or no hold time. "Beeping" lines with calls on hold were observed only
once or twice. Only one call was observed to be on hold for several
minutes (about 5-7 minutes) with a new call taker.

Several calls were also made from an outside phone to the Transit
Express phone number during the morning and afternoon of July 11. No
busy signals were encountered and call takers answered all calls by the
third ring.

Telephone service reports were not available. The manager of Transit
Express indicated that he did not believe that the system was set-up to
generate daily call reports.

***Laidlaw Transit***

Customers contact Laidlaw at 967-9600 (967-0290 TTY). The automated
greeting asks callers to choose one of three options. Callers select "1"
to schedule a ride; "2" to cancel a ride; and "3" for dispatch (to ask
about rides scheduled for that day). The greeting also refers callers to
the general Transit Plus number at MCTS (414-343-1700) if they are
calling about subscription service, need information about eligibility,
or need other general information. Callers can also press "0" or stay on
the line for all other needs.

The reservations area is served by 12 phone lines, and is staffed by
five call takers from 8:00 AM until 5:00 PM on weekdays, and by 1-2 call
takers on weekends. Calls are routed through a call distributor to the
call taker that has been available for the longest period of time.

A significant number of trip reservations are also faxed to call takers.
These fax requests are handled between calls and a confirmation is faxed
back to the customer. One of the senior call takers at Laidlaw estimated
that 30-40% of the non-subscription trip requests that she handles are
received by fax.

An additional 10 lines are connected through the call distributor to the
dispatch area. During peak weekday hours, 3-4 dispatchers plus a
dispatch clerk are typically on duty. The dispatch clerk's primary
function is to handle incoming calls, gather information from the
dispatchers, and respond to the caller.

The cancellation line is not part of the call distributor system. Calls
to that line go to a separate phone in dispatch, which is always
answered either by a staff person or an answering machine; when a
message has been left on the machine, a light flashes to alert dispatch
staff to the message.

Observations of the reservations area were conducted on July 12, 2001,
from approximately

8:00 AM until 11:00 AM. Since calls are distributed to call takers from
a central queue, it was not possible to observe how long calls were on
hold before being answered by a call taker. However, call volume
appeared and was confirmed by reservations staff to be light, with
breaks in between calls, so it is likely that hold times were minimal.

Several calls were also made throughout the day to the Laidlaw number
from an outside phone. No busy signals were encountered and calls were
picked-up by call takers with minimum holds.

Call handling in Laidlaw's dispatch office was also observed on July 12,
2001, during the afternoon peak between the hours of 3:00 and 4:30 PM.
Again, call volume was light for that time of day. No observations of
calls being placed on hold for more than a moment or two were made.

Monthly summary reports from the call distributor were reviewed, but
because only daily averages of key statistics were included, the reports
were not helpful in identifying hold times or abandoned call rates by
time of day. Laidlaw staff indicated that they are exploring options for
generating more detailed data from the system in order to measure
telephone system performance, and respond to customer complaints.

Call distributor reports for the month of May 2001 are provided in
Attachment E. The report for "Group 1" presents information on calls to
the reservations area. The "Group 2" report provides information about
calls to dispatch. As shown, the reservations area received a total of
5,132 calls, an average of about 166 calls per day. During this period,
the *average* hold time in the queue for an average day was 2 minutes, 9
seconds. Average hold times per day ranged from 36 seconds to 7 minutes,
32 seconds. The longest average daily hold times were on Saturdays (7:32
on May 5 and 5:11 on May 12). With an average of over two minutes, hold
times at peak periods were likely to be significantly higher, and
therefore in excess of the standard established by MCTS.

In May 2001, customers abandoned about 10% of the calls to the
reservations area before being answered, at an average time in the queue
of 2 minutes, 56 seconds before the customer hung up. Again, daily
averages covered a wide range, from 1 minute 10 seconds to 6 minutes, 59
seconds. These average hold times before hanging up also indicate that
there are days and times during which hold times are likely to exceed
the MCTS standards significantly.

The reports in Attachment E also show that the dispatch office received
a total of 3,985 calls during May 2001, for an average of 128 calls per
day. The average time on hold before a call was answered on an average
day was 23 seconds. The longest average daily hold times were on
weekends (1:50 on Saturday, May 12 and 1:41 on Sunday, May 6). These
daily averages could be misleading, though, given the long hours of the
dispatch function. Low call volume in early morning and late evening
hours could offset much higher hold times during peak hours and skew the
daily average. Customers abandoned 170 calls, or 4.3%, before they spoke
with a dispatcher. Average time spent on hold before disconnecting was 2
minutes and 23 seconds.

Interestingly, customers disconnected 47% of calls that were answered by
a dispatcher and placed on hold. An examination of other monthly reports
showed that, in all but two months in 2000-2001, roughly this same
percentage of calls were disconnected while on hold. This may be
explained by the fact that customers make "Where's My Ride?" calls to
the dispatch line, and may be reluctant to spend more than a minimum
amount of time away from their front doors, in case the vehicle arrives
while they are on the phone. In many cases, the vehicle probably arrives
while the customer is on the phone, and they disconnect the call. In
other cases, customers are likely to feel that it is safer to hang up
and call back, if necessary, than to risk missing the vehicle. The short
average time before calls are answered in dispatch makes it easy for
customers to make repeat calls to check on the status of their ride.

Key daily reservations phone statistics from the week of May 13-19,
2001, are presented in Tables 4 and 5 on the following page. Table 4
provides information for calls to the reservations and Table 5
summarizes key telephone performance statistics for the Laidlaw dispatch
area for that sample week.

Table 4. Key Telephone Performance Information for Laidlaw Reservations
Lines, May 13 - 19, 2001

  ------------------ ------- --------- -------- --------- --------- ------- ---------
                     5/13    5/14      5/15     5/16      5/17      5/18    5/19
                     (Sun)   (Mon)     (Tues)   (Wed)     (Thurs)   (Fri)   (Sat)

  Daily Totals                                                              

  Total Calls        30      220       196      207       188       177     57

  Avg. Hold Time     73      180       117      137       83        220     197
  (sec.)                                                                    

  Number (%) Calls   6 (20%) 27        12       21        17 (9%)   32      9 (15.8%)
  Abandoned                  (12.2%)   (6.1%)   (10.1%)             (18%)   

  Avg. Time before   175     240       178      139       104       164     70
  Abandoned (sec.)                                                          
  ------------------ ------- --------- -------- --------- --------- ------- ---------

Table 5. Key Telephone Performance Information for Laidlaw Dispatch
Lines, May 13 - 19, 2001

  ------------------ --------- --------- --------- --------- --------- --------- ---------
                     5/13      5/14      5/15      5/16      5/17      5/18      5/19
                     (Sun)     (Mon)     (Tues)    (Wed)     (Thurs)   (Fri)     (Sat)

  Daily Totals                                                                   

  Total Calls        76        170       157       130       130       144       62

  Avg. Hold Time     36        12        30        13        10        11        53
  (sec.)                                                                         

  Number (%) Calls   5 (6.6%)  5 (2.9%)  6 (3.8%)  0         1 (.8%)   1 (.7%)   2 (3.8%)
  Abandoned                                                                      

  Avg. Time before   94        89        54        0         70        99        53
  Abandoned (sec.)                                                               

  Number (%) Calls   50        53        82        69        51        70        45
  Disconnected While (65.8%)   (31.2%)   (52.2%)   (53.1%)   (39.2%)   (48.6%)   (72.6%)
  on Hold                                                                        
  ------------------ --------- --------- --------- --------- --------- --------- ---------

**Findings**

1.  First-hand observations of both carriers did not reveal substantial
    problems getting through on the phones or long hold times once calls
    were answered. Only one call, which was being handled by a new call
    taker at Transit Express, was observed to be on hold for more than
    five minutes.

2.  Automatic call distribution reports generated by the phone system at
    Laidlaw Transit indicate that hold times likely exceed the MCTS
    standard on certain days. Average daily hold times of over two
    minutes were recorded on 15 of the 31 days in May 2001. A maximum
    daily hold time of over seven minutes was recorded on May 5^th^.
    Given that these are daily averages, it is also likely that hold
    times during peak calling periods are significantly higher.

3.  The telephone system at Transit Express does not appear capable of
    generating daily service and performance reports. This lack of
    reporting capability makes it very difficult to ensure that hold
    time standards are being met.

**Recommendations**

1.  MCTS should require contractors to prepare more detailed telephone
    service reports and keep them on file. These reports should then be
    periodically checked by MCTS to ensure contract compliance. Daily
    reports should be prepared which show key service and performance
    data for each one-hour period of the day. At a minimum, the
    following information should be tracked by day, and by hour, for
    both the reservations and dispatch phone lines:

    -   Average hold times

    -   Maximum hold times

    -   Number of abandoned calls

    -   Average time on hold before abandoned

2.  It may also be possible to program the report function to record the
    number and percentage of calls on hold longer than 2 minutes so that
    specific information regarding compliance with the hold time
    standard can be measured.

3.  MCTS and its contractors should use this more detailed information
    to ensure that adequate reservations and dispatch staff are
    scheduled to work during all days and hours of service. Staffing
    levels should be adjusted as needed to match call volumes to ensure
    adequate coverage during peak hours and on weekends. MCTS and its
    contractors should also use this more detailed information to
    investigate and respond to customer complaints regarding telephone
    access.

# Observations Regarding the Handling and Scheduling of Trip Requests

This portion of the assessment examined how trip requests from riders
were handled. Particular attention was given to whether contractors
employed any forms 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 MCTS;

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

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

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

**Consumer Comments**

Four of the six riders, advocates and agency representatives contacted
prior to the assessment indicated that trip requests were not always
accommodated. Three characterized this as a significant problem. All
four noted the need to call well in advance to get a trip at the time
desired and indicated that it is difficult to get trips on a "next day"
basis. Two people noted that trips are scheduled more than one hour from
the time requested and one person felt that these trips were not
properly recorded as denials and that denials were therefore
undercounted. Two people also noted that sometimes only one leg of a
trip can be accommodated and one-way trips are offered.

Between January 1 and June 30, 2001, MCTS received 26 complaints about
denied trip requests (5% of all complaints -- see Attachment D).
Nineteen of these (or 73%) reported trip denials by Laidlaw Transit. The
remaining seven (or 27%) cited denials by Transit Express.

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

As noted above, Transit Plus trip requests are accepted from 14 days in
advance up to 5:00 PM on the day before service. It was also observed
that contractors will accept same day trip requests and will serve these
requests on a space available basis. Contractors are allowed to
negotiate trip times with callers to efficiently group trips, but are
instructed to schedule trips within one hour of the time requested.
Trips which cannot be scheduled or which can only be scheduled more than
an hour from the requested time are recorded as denials. Trips that are
offered within an hour of the requested time but not accepted by the
caller are recorded as "refused" trips.

The settlement agreement between MCTS and the Wisconsin Coalition for
Advocacy calls for MCTS to deny no more than 3.5% of all trip requests.
MCTS stated, however, that its goal is to accommodate all trip requests
from eligible riders. As discussed later in Section IX, MCTS develops an
estimate of demand at the beginning of each year. This estimate is used
to project the number of vehicle hours of service that will be needed.
This projected number of vehicle hours is then included in each carrier
contract. Section 2.3 of Exhibit B of the service contracts then gives
contractors the ability to adjust vehicle hours to "meet demand."

MCTS tracks and analyzes trip denials on a monthly basis. The number and
percentage of trip requests that are denied is examined for the system
as a whole and for each provider. Reports are also prepared which
provide a detailed breakdown of trip denials by time of day, day of the
week, and by type of mobility aids used (ambulatory versus riders who
use wheelchairs). The reports also show the percent subscription trips
by day and by time of day. Each month staff reviews these reports to
identify patterns of denials.

Both contractors take and schedule trip requests using the Trapeze
automated reservations, scheduling, and dispatch system. However, the
two contractors use this system in different ways. Following is a
description of the reservation and scheduling process used by each
contractor.

***Transit Express***

At Transit Express, call takers enter trip request information into the
Trapeze system but do not actually place trip requests on scheduled
runs. For trip requests placed more than three days in advance, the date
and time requested by the caller is simply added into the system without
any negotiation. Trips requested during off-peak times, regardless of
the amount of advance notice, are also simply added into the system as
requested. If a trip request is called in three or fewer days in advance
for travel during peak morning or afternoon hours, the call takers are
instructed to get clearance from a scheduler before booking the trip.
Schedulers keep track of the number of trips already in the system
during peak hours and ask call takers to begin negotiating trip times
when the peak-hour schedules get tight. For example, if a trip is
requested one day in advance for 8:30 AM in the morning, the call taker
will put the caller on hold and will contact the scheduler with the trip
details. The scheduler may then tell the call taker to offer a pick-up
time of 8:00 or 9:00 AM if the 8:00 AM time period is already heavily
booked.

If no time can be offered within an hour of the requested time, the call
taker is instructed to record the request as a denial.

***Laidlaw Transit***

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

If the automated system finds no trip options, or if the only options
found are more than an hour from the requested time, the call taker is
instructed to code that trip as a denial.

**Reported Handling of Trip Requests**

Service reports developed by MCTS for the period January 1999 through
June 2001, including the number of trips requested and the number of
requests denied and refused, were reviewed as part of the assessment.
These reports are based on data entered into the Trapeze system by the
contractors. Table 6 presents information on trips requested, denied and
refused for the period that the Transit Plus service has been operated
by MCTS (January 2000 through June 2001).

**Table 6. Reported Transit Plus Trip Denials, January 2000 -- June
2001**

  ----------- ------------- ------------- ----------- ----------- -----------
  **Month,    **Trips       **Trips       **Trips     **% Trip    **Trips
  Year**      Requested**   Scheduled**   Denied**    Requests    Refused**
                                                      Denied**    

  January,    51,299        51,006        **264**     **0.5%**    29
  2000                                                            

  February    52,335        51,836        **474**     **0.9%**    25

  March       58,265        57,446        **788**     **1.4%**    31

  April       51,189        50,605        **568**     **1.1%**    16

  May         56,442        56,192        **208**     **0.4%**    42

  June        54,840        54,680        **159**     **0.3%**    1

  July        52,160        51,972        **138**     **0.3%**    50

  August      57,724        57,559        **107**     **0.2%**    58

  September   53,539        53,347        **128**     **0.2%**    64

  October     56,860        56,612        **159**     **0.3%**    89

  November    54,928        54,743        **124**     **0.2%**    61

  December    53,533        53,308        **166**     **0.3%**    59

  January,    58,634        58,392        **166**     **0.3%**    76
  2001                                                            

  February    53,185        52,772        **355**     **0.7%**    58

  March       58,327        57,946        **306**     **0.5%**    75

  April       55,622        55,219        **249**     **0.4%**    154

  May         59,193        58,854        **199**     **0.3%**    140

  June        55,293        55,062        **113**     **0.2%**    118
  ----------- ------------- ------------- ----------- ----------- -----------

As shown in Table 6, the number and percentage of denied trip requests
that have been reported by the contractors has consistently been low.
For most months, less than 0.5% of all trip requests are denied. March
and April of 2000 had the highest percentage of trip denials, 1.4% and
1.1% respectively. Reported trip denials rose slightly in February and
March of 2001, but fell to only 0.2% of all trip requests in June 2001.

It was also noted that the Laidlaw Transit consistently reports a
slightly higher percentage of trip denials than Transit Express. For the
period from January through June 2001, Laidlaw reported 158,189 total
trip requests and 851 denials (0.5%). For this same period, Transit
Express reported 182,065 total requests and 537 denials (0.3%). And, in
May and June 2001, Laidlaw reported 229 of the 258 total system-wide
denials.

It is important to note that the denial rates shown in Table 6 are based
on all trip requests, including both subscription trips and "demand"
trips. During this period of time, subscription trips accounted for
about 56% of all trips provided. Assuming a similar split between
subscription and demand trips for total trips requested (which assumes
an equal distribution of cancellations and no-shows between these types
of trips), and assuming that all denials are for demand trip requests,
the rate of denial for demand trips would be about 2.3 times higher than
the rate based on all trip requests. This would suggest that the rate of
trip denials for demand trips has been between 0.5% and 1.6% for the
period from January to June 2001.

Prior to January 2000, when the service was operated by the Department
of Public Works, there were periods of time when there were more
significant problems with trip denials. In April and May 1999, the
overall trip denial rates ran 2-3% of all trips, which suggests that the
rate for demand trips was perhaps 5-7%. And, in the North area during
those months, the denial rate was 4.7% to 6.3%, which suggests that
denials of demand requests might have been as high as 11% to 15%.

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

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

This analysis indicated that there are some more significant denial
rates at certain times of the day. Table 7 below shows the periods of
the day that had the greatest rate of trip denials in May 2001. Transit
Express reported a total of 26 trip denials in May 2001, but 10 of these
were requests for trips between 6-7 AM (for a denial rate of 6.6%) for
this time period. Similarly, Laidlaw reported a total of 173 trip
denials for the month, and 112 of these occurred during the morning and
afternoon peak hours of 7-9 AM and 2-4 PM.

**Table 7. Peak Periods of Trip Denials by Contractor for May 2001**

  --------------------- ---------------- ---------------- ----------------
  **Provider, Time of   **Total Demand   **Trips Denied** **Estimated % of
  Day**                 Trips Provided**                  Demand Trips
                                                          Denied**

  Transit Express, 6-7  142              10               6.6%
  AM                                                      

  Laidlaw, 7-8 AM       678              24               3.4%

  Laidlaw, 8-9 AM       1,016            36               3.4%

  Laidlaw, 2-3 PM       1,081            21               1.8%

  Laidlaw, 3-4 PM       855              31               3.5%
  --------------------- ---------------- ---------------- ----------------

***Trip Denials by Type of Mobility Aids Used***

A similar detailed analysis of trip denials for ambulatory riders versus
riders who use wheelchairs was also conducted for the month of May 2001.
During this month, riders who used wheelchairs accounted for about 42%
of all completed trips system-wide. Of the 199 trip denials reported,
however, 126 (63%) were for trips requested by riders who use
wheelchairs. This would suggest that riders who use wheelchairs are 50%
more likely to receive a trip denial than are ambulatory riders.

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

Finally, the assessment team analyzed trip denials in May 2001 to
determine if there was a difference in the rate of denials based on the
amount of advance notice given by riders. Table 8 below provides
information about demand requests and trip denials for each contractor.
The number of requests and denials for trips placed 1-14 days in advance
are shown.

As shown, the rate of trip denials at Transit Express was very low
regardless of the amount of advance notice provided (0.1% to 0.2%).
There was a noticeable increase in the number and rate of denials for
next day requests (0.9%), but the number and percentage were still quite
small. It was also interesting to note that there was a fairly even
distribution of trip requests at Transit Express and that 58% of all
requests were made seven or fewer days in advance. The highest percent
of trip requests were placed one and two days in advance (9.7% and 10%
respectively). This suggests that riders are not overly concerned about
calling as far in advance as possible and feel that it is possible to
get next day service.

At Laidlaw, the rate of trip denial did appear to increase as less
advance notice was provided. If only one-day advance notice was
provided, the denial rate was over 5%. It is also interesting to note
that 27.8% of all trip requests were made the full 14 days in advance,
63.8% were made more than a week in advance, and only 5.6% were made one
day in advance. This suggests that riders do feel the need to call well
in advance in the Laidlaw area and may feel that next day service is not
reliable.

**Table 8. Denial Rates by Days Advance Notice Provided and Provider,
May 2001**

  -------------- -------------- -------------- -------------- --------------
                 **Transit                     **Laidlaw      
                 Express**                     Transit**      

  **Advance      **\# And %     **\# And %     **\# And %     **\# And Rate
  Notice**       Demand Trip    Denials**      Demand Trip    of Denials**
                 Requests**                    Requests**     

  14 days        1,202 (8.6%)   1 (0.1%)       3,132 (27.8%)  5 (0.2%)

  13 days        703 (5.0%)     1 (0.1%)       883 (7.8%)     3 (0.3%)

  12 days        720 (5.1%)     1 (0.1%)       773 (6.8%)     3 (0.4%)

  11 days        625 (4.5%)     1 (0.2%)       608 (5.4%)     4 (0.6%)

  10 days        907 (6.5%)     0 (0.0%)       545 (4.8%)     3 (0.6%)

  9 days         865 (6.2%)     0 (0.0%)       565 (5.0%)     11 (1.9%)

  8 days         847 (6.0%)     1 (0.1%)       694 (6.2%)     7 (1.0%)

  7 days         1,211 (8.6%)   1 (0.1%)       709 (6.3%)     19 (2.7%)

  6 days         1,024 (7.3%)   1 (0.1%)       545 (4.8%)     13 (2.4%)

  5 days         966 (6.9%)     2 (0.2%)       513 (4.5%)     9 (1.8%)

  4 days         1,103 (7.9%)   1 (0.1%)       560 (5.0%)     21 (3.8%)

  3 days         1,069 (7.6%)   1 (0.1%)       618 (5.5%)     25 (4.0%)

  2 days         1,410 (10.0%)  3 (0.2%)       501 (4.4%)     17 (3.4%)

  1 day          1,357 (9.7%)   12 (0.9%)      630 (5.6%)     33 (5.2%)

  TOTALS         14,009 (100%)  26 (0.2%)      11,276 (100%)  173 (1.5%)
  -------------- -------------- -------------- -------------- --------------

***Subscription Service***

System-wide, about 56% of all rides are by subscription users. The
percentage of subscription riders using the system is higher during peak
periods. Currently, there exists a long wait list for regular users to
become subscription riders. At this time, MCTS is not adding riders to
the subscription service because the system is already above the 50%
maximum threshold. The fax process is used to accommodate regular trips
that are not on subscription. Some call takers also noted that they
maintain lists of regular riders who make ongoing trips and enter them
into the system as a courtesy. It is clearly a benefit in both
operations and in customer service to have regular, ongoing trips on the
schedule at the same time each day. Otherwise, regular riders have to
keep track of changing times, and the system is less able to build set,
efficient runs. The regulations limit of 50% (49 CFR Part 37 Section
37.133 (b)) is based on the existence of capacity constraints within the
system. If no capacity constraints exist, systems can have as many
subscription trips as are needed.

**Observations of the Reservations and Scheduling Process**

First-hand observations of the reservation and scheduling process were
conducted on Wednesday and Thursday, July 11-12, 2001. Assessment team
members sat with call takers at each operation center, listened in on
phone calls, and recorded information about trip requests and trip times
offered and scheduled.

The bookings of a total of 72 trip requests were observed at Transit
Express on the morning of July 11. All 72 requests were accommodated and
all trips were booked within one hour of the requested time. In all but
two cases, the pick-up time requested was entered into the scheduling
system. The two requests that had times negotiated were both for 5:00 PM
pick-ups and were made two days in advance. When the call taker checked
with the scheduler about the requested time, the scheduler had the call
taker offer a 5:15 PM pick-up to the customer. Both trips were accepted
at this slightly later time.

The call takers at Transit Express indicated that they are able to book
trips at or near the time requested. They confirmed that trip denials
are rare.

Another 66 trip bookings were observed at Laidlaw Transit on Thursday,
July 12. Three of these trip requests could not be accommodated. Two
trips were offered more than one hour from the time requested and were
accepted by the callers. One trip was offered outside the one-hour
scheduling window and was not accepted. The observations at Laidlaw also
showed that a significant number of trips are negotiated within the
one-hour scheduling window. Two trips, for example were offered a full
hour later than the time requested. Another was offered 50 minutes
earlier than requested. A fourth trip was offered 35 minutes after the
requested time.

The call takers at Laidlaw also indicated that trip requests made with
little advance notice are difficult to book during peak travel hours. An
experienced call taker estimated that she is not able to find rides for
callers wanting to travel at peak hours "about 10-15 times per day."

The handling of faxed trip requests was also checked at Laidlaw. Each
call taker is assigned to work with certain agencies and individuals who
regularly book trips by fax. Each call taker maintains three-ring
notebooks with faxed trip requests. The original faxes received from the
agencies/individuals are kept in chronological order sorted by agency.
Call takers pen-in the times offered next to the times requested on
these faxes. The completed forms with the offered times are faxed back
to the agencies/individuals as confirmation of the trip(s) requested.

Fax requests and confirmations were reviewed for the months of June and
July 2001. While most requests were accommodated within an hour,
significant difficulty scheduling trips for one program, the St. Ann
Center, was noted. The fax requests to and from this agency showed at
least 66 trips negotiated outside the one-hour scheduling window for the
two months checked. Attachment F provides a copy of the faxes with
requested and confirmed times showing the trips that could not be
accommodated within an hour. Staff at Laidlaw indicated that the person
handling the requests from St. Ann at that time was a new call taker. A
review of the trip records indicated that she appeared to be booking the
trips using past standing order times, and was not taking into account
apparent requests for changes in those past times.

The St. Ann Center trips scheduled outside the one-hour scheduling
window were then called up on the computerized trip records to see how
they had been coded. They were listed as scheduled trips and did not
appear to be coded as trip denials. Again, according to Laidlaw staff,
this appeared to be due to the fact that the new call taker was not
coding trips appropriately.

**Findings**

1.  MCTS and its contractors do not appear to employ waiting lists or
    trip caps in the operation of the Transit Plus service.

2.  Since January of 2001, there have consistently been a relatively
    small number of reported trip denials for Transit Plus service.
    Contractors record approximately 200-400 one-way trip requests per
    month as denials. This represents between 0.2-0.7% of all trips
    requested and about 0.5-1.6% of all non-subscription, "demand" trips
    requested.

3.  There was evidence that some trips that are not accommodated within
    an hour of the requested time are not being recorded as trip
    denials. This appears to be the exception rather than the rule,
    however, and appears to be an issue of call taker training. The true
    denial rate is therefore probably slightly higher than the reported
    rate.

4.  There appear to be some patterns to the small number of trip denials
    that would make the rate for certain requests higher than the
    system-wide average. The denial rate during certain peak travel
    hours appears to be 1.8-3.5% and during some very limited times as
    high as 6.6% of all "demand" requests. In the north part of the
    service area, the denial rate for trips made less than five days in
    advance is estimated to be 3.4-5.2%. And, individuals who use
    wheelchairs appear to be 50% more likely to be denied a trip than
    persons who are ambulatory.

5.  The settlement agreement between MCTS and the Wisconsin Coalition
    for Advocacy calls for MCTS to deny no more than 3.5% of all trip
    requests; however, MCTS stated that its goal is to accommodate all
    trip requests from eligible riders. The settlement agreement
    conflicts with FTA guidance regarding trip denials on this point.
    MCTS' policy to plan, budget, and strive to provide all requested
    trips is in accordance with FTA guidance.

**Recommendations**

1.  MCTS should consider developing some "flexible capacity" so that it
    can cost-effectively accommodate the small number of trip denials
    that appear to exist. For example, MCTS could amend its contract
    with Transit Express to authorize that contractor to use vehicles in
    operation for other services to transport Transit Plus riders that
    cannot be accommodated on established, dedicated Transit Plus runs.
    The contractor could then be reimbursed on a per trip basis for the
    provision of these trips. Similarly, Laidlaw could be authorized to
    develop subcontracts with existing local companies for the provision
    of rides on a per trip basis. This would probably be a more
    cost-effective way to meet the small number of daily trip denials
    than creating additional dedicated 4-8 hour runs. Over time,
    additional runs could be created if the number and pattern of trips
    purchased on a per trip basis increases to the point where set runs
    would be efficient.

2.  MCTS should consider tape-recording reservations and dispatch phones
    at the contractor locations. This would allow for periodic reviews
    to ensure that trip requests are being handled and recorded
    accurately.

#  Observations Regarding Service Provision

The DOT 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 MCTS;

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

-   The scheduling and dispatch functions at both contractors was
    observed, and schedulers and dispatchers were interviewed;

-   Drivers for both contractors were interviewed;

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

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

-   Travel times by Transit Plus were compared to fixed route travel
    times for comparable trips.

**Consumer Comments**

Five of the six riders and agency representatives contacted in
preparation for the assessment cited on-time performance as a major
service issue. Most of the concern was about late pick-ups. Three
individuals also mentioned that early pick-ups are a problem. One agency
representative noted that vehicles often arrive before riders are
through with work. Three people noted that pick-up times seem to change.
Riders are given one time by call takers and then may get another time
from dispatchers if they call to check on their ride.

Three of the six persons contacted mentioned long ride times as somewhat
of an issue. One person indicated that ride times were a problem only
for certain programs and clients. A second person indicated that ride
times were a problem "sometimes" but that this was not a frequent issue.
The third person felt that the standard established through the recent
legal settlement allowed rides that were too long.

On-time performance was a major issue in four of the six formal ADA
complaints filed by local riders with the FTA. Late rides were noted in
these complaints. Three of these complaints also reported problems with
the handling and accuracy of trip information. One complainant noted
that drop-offs had been made at the wrong location. Another noted that
the origin and destination addresses were being confused in the trip
reservation process.

Two of the six formal complaints filed with FTA noted long travel times
as a problem. One of these was for a trip that had a pick-up in the
North service region and a drop-off in the South area.

Of the 500 recent complaints on file at Transit Plus that were reviewed
as part of the assessment, 136 (or 27%) relate to on-time performance.
On-time performance was the most frequent type of complaint received. A
total of 108 complaints (21%) reported that trips were not provided on
time. Another 20 people (4%) complained about the time that they
eventually arrived at their destination. Finally, 8 riders complained
about pick-up times even though they knew the times were within the on
time "window" used by MCTS.

Only 10 complaints (1.9% of the total) were about ride duration.

Several complaints cite trip information errors. Twenty-three complaints
(4.6%) were categorized as problems about either "pick-up/drop-off
errors" or "address problems."

**MCTS Service Policies and Standards**

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

MCTS has recently changed the pick-up window used in scheduling trips
and determining on-time performance. Prior to February 2000, pick-ups
were to be made within a 30-minute window, which began 15 minutes before
the negotiated pick-up time and extended until 15 minutes after the
negotiated time (-15/+15). Customers were asked to be waiting for the
vehicle during this time and contractors were to schedule and make
pick-ups within this window. From February 2000 through July 2001, the
pick-up window was defined to begin 5 minutes before the negotiated
pick-up time and extend to 30 minutes after the negotiated pick-up time
(-5/+30). Beginning August 1, 2001, the pick-up window again changed to
be defined as beginning at the negotiated time and extending to 25
minutes past the negotiated time (0/+25).

The changes in the pick-up window were made as part of the settlement
negotiated with the Wisconsin Coalition for Advocacy (WCA) and were
intended to solve issues with early vehicle arrivals. MCTS's policy
regarding vehicle wait time is that after vehicles arrive at a pick-up
location they will wait for 5 minutes for the rider to board. After this
time, if the rider does not board, the dispatchers can authorize drivers
to leave and the rider is recorded as a no-show. Under the old --15/+15
window, it was possible for vehicles to arrive 15 minutes before the
pick-up time that was given to riders and then depart 10 minutes before
the negotiated time. Even though riders were asked to be waiting for
vehicles up to 15 minutes early, many individuals apparently did not
understand the pick-up window and were confused when vehicles arrived
and left before the exact pick-up time that they had been given.

As part of the settlement with WCA, MCTS has agreed to ensure that
pick-ups are on-time at least 90% of the time.

MCTS currently does not consider arrival times and on-time arrivals in
its measurement of on-time performance.

***Travel Time Policies and Standards***

MCTS also has established a ride time service standard for the Transit
Plus system as part of the settlement between Milwaukee County and the
WCA. Excessive ride duration is defined as follows:

-   Transit Plus trips that take more than two hours and are one and
    one-half times as long as a comparable trip made using fixed route
    service

-   Transit Plus trips that take over one hour, but less than two hours,
    and are more than twice as long as a comparable trip made using
    fixed route service

MCTS does not specify a goal for the percent of trips that are to have
travel times that meet these standards, which implies that all rides are
to be scheduled and performed within the standard. Customers contacting
Transit Plus about a trip of excessive duration may receive a voucher
for a free trip. MCTS staff records the ride time, origin and
destination of the trip and then check it against a comparable fixed
route trip. If the Transit Plus travel time is found to be excessive, a
free ride voucher is issued.

**Observations of Scheduling and Dispatching**

***Transit Express***

For "going" trips, the call takers at Transit Express record requested
pick-up times as well as appointment times if callers indicate that they
have an appointment. If callers first indicate an appointment/desired
arrival time and are not sure of an appropriate pick-up time, the call
takers will suggest a pick-up time that should get the rider there on
time.

All trip requests go into the system as "unscheduled" trips. The
schedulers then place trip requests onto runs. For most trips, the time
that is finally scheduled is the same as the requested time.
Occasionally, schedulers may need to schedule the pick-up at a time that
is different from the requested time. If the change is significant, the
rider is called and given the revised time. Once the trip is scheduled,
the system records the time assigned by the scheduler as both the
"scheduled" and "negotiated" time.

Scheduling trips is an ongoing process; schedulers are constantly
reviewing and clearing any trips on the "unscheduled" list. The chief
scheduler indicated that about 600-700 trips are manually scheduled each
day.

Dispatchers at Transit Express maintain control of all runs. Operators
radio-in each pick-up and drop-off and are directed by dispatch on any
changes to the rest of the run. Dispatchers identify potential on-time
performance problems well in advance and switch trips between runs to
address any potential problems.

***Laidlaw Transit***

As indicated in the previous section, the call takers at Laidlaw
schedule trips directly onto runs created in the system. If riders
accept pick-up times offered by the Trapeze system, the offered time
becomes the "negotiated" time in the system. For example, if a caller
asks for a 9:00 AM pick-up, the system may find a run that can serve the
trip with a 9:12 AM pick-up, which then becomes the negotiated time.

Laidlaw books trips based solely on requested pick-up time. If callers
indicate an appointment time, the call taker will suggest an appropriate
pick-up time and this will be entered into the system. Information about
the time of the appointment is typically not entered into the system.

The function of the scheduler at Laidlaw is to review runs created by
the automated system and to prepare runs for the day of service. The
scheduler typically runs a "violations" report, which lists all trips
with times that exceed one of the system parameters (e.g., on-time
window or maximum ride time). Adjustments are then made to minimize
violations before final manifests are printed.

Dispatchers at Laidlaw maintain a general sense of the status of each
run and respond to rider and operators requests for information and
assistance. Operators tend to notify dispatch only when problems arise
or when they need guidance. Dispatchers also are made aware of potential
on-time issues as they respond to "Where's my ride?" calls from riders.

**Dispatch Issues**

MCTS staff noted two dispatch issues that had recently been identified
and resolved. First, it was noted that customers reported that pick-up
times quoted by dispatchers sometimes were different from the times
originally negotiated with call takers. It was discovered that
dispatchers were sometimes reading the "Estimated Time" on the dispatch
screen (the latest time calculated by the automated system based on the
status of the run) rather than the negotiated and scheduled pick-up
time. This problem was apparently resolved in February 2001 through
retraining of the dispatchers.

Also, it was discovered that scheduled pick-up times would sometimes
change if trips were moved from one run to another. This happened if the
dispatchers left the "Search Window" function "On" when looking for
another available run. With the "Search Window" on, a new scheduled
pick-up time would be generated by the automated system. Dispatchers
were made aware of the need to keep the window "Off" in recent
retraining. As part of the assessment, it was verified that the "Search
Window" was indeed set at "Off" at both contractor locations.

**Driver Interviews**

Interviews were conducted with several drivers at each contractor site.
Drivers were asked about the feasibility of the schedules and about
early and late pick-ups. Several drivers indicated that, in order to
make all pick-ups on time, it was often necessary to pick some riders up
more than five minutes before the scheduled time. Some drivers also
appeared to be under the impression that the on-time performance window
was still 15 minutes before to 15 minutes after the scheduled time.

## On Time Performance

**Reported On-Time Performance**

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

MCTS then runs monthly reports that calculate on-time performance from
the trip data entered into the Trapeze system by contractors. These
reports tabulate the number and percentage of completed trips that had
actual pick-ups no more than 5 minutes before and no more than 30
minutes after the negotiated time.

Table 9 below shows on-time performance reported by MCTS by carrier for
the period from January through May 2001. As shown, system-wide on-time
performance was between 94% and 97% for this time period. Both of the
contractors had similar levels of performance.

**Table 9. MCTS Reported On-Time Performance by Contractor, Jan.-May,
2001**

  ----------------- ----------------- ----------------- -----------------
                    **% Of Trips                        
                    Performed                           
                    On-Time**                           

  **Month**         **Transit         **Laidlaw**       **Total**
                    Express**                           

  January, 2001     95.1%             93.6%             94.4%

  February          95.0%             95.6%             95.2%

  March             96.5%             96.8%             96.6%

  April             97.3%             96.3%             96.8%

  May               96.7%             96.8%             96.6%
  ----------------- ----------------- ----------------- -----------------

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

The assessment team reviewed the accuracy of on-time performance
reported by MCTS and its contractors by sampling every manifest for both
Transit Express and Laidlaw for May 16, 2001. Each driver is provided a
computer-generated manifest that lists a scheduled pick-up time for
every rider. On this manifest, the driver manually records the actual
pickup time and odometer reading. For this assessment, only pickup times
were reviewed, since trips are not scheduled based on drop-off times and
appointment times are not typically shown on the manifests. The
assessment team recorded rides as being early, on time or late according
to the MCTS standard in effect on May 16, 2001, on time being 5 minutes
early to 30 minutes late.

For May 16, the assessment team analyzed the scheduled and actual pickup
times for 510 rides, every fifth pick up for each manifest. The results
of the analysis are presented in Tables 10-12 on the following page. Of
those rides analyzed, 96.7% were either early or on time. A total of
3.3% fell into the late category of 31 minutes or more past the
negotiated pickup time. Transit Express had an early or on-time
performance of 97.4% and Laidlaw's early or on-time performance for the
day was 95.9%. Less than 1% of the trips were late by greater than 46
minutes or more.

This analysis of a random sample of trips using actual recorded times is
consistent with the reported on-time performance by Transit Plus of
between 94% to 97% for the period January 2001 through May 2001.

It is interesting to note that thirty-seven percent (37%) of the pickups
analyzed were classified as early, meaning an actual pickup of 6 minutes
or more before negotiated pickup time. It appears as if early pickups
are built into the daily operations to ensure a high on-time performance
rate and to avoid late pickups. In interviews, drivers said that most of
their customers like to be picked up early to ensure that they arrive on
time at their destination.

The on-time performance of pickups exceeds the 90% standard agreed upon
as part of the WCA settlement, but in order to meet this rate, there
appears to be a heavy reliance on early pickups. Although there appear
to be few complaints related to early pick ups, a concern is that there
may be a number of clients who feel pressure to be early because the
vehicle is arriving early on a regular basis.

As part of its daily operations, Transit Express relies on the extensive
reassignment of trips among runs to ensure on-time performance. At
Laidlaw, there is less intervention by dispatch and a greater reliance
on maintaining the computer-generated schedule for each run.

Table 10: Transit Express on-time performance data check for May 16,
2001

  ------------- ---------------- ----------- ---------------- --------- ------------
                **Minutes**      **Total**   **Percentage**             

  **Early**     -61 or more      1           0.4%                       

                -60 to -31       12          4.5%             40.5%     **Early**

                -30 to -6        96          35.7%                      

  **On time**   -5 to +30        153         56.9%            56.9%     **On time**

  **Late**      +31 to +45       7           2.6%                       

                +46 to +60       0           0.0%             2.6%      **Late**

                +61              0           0.0%                       

                                 269         100.0%                     

                                                                        

  **Table 11:                                                           
  Laidlaw                                                               
  on-time                                                               
  performance                                                           
  data check                                                            
  for May 16,                                                           
  2001**                                                                

                **Minutes**      **Total**   **Percentage**             

  **Early**     -61 or more      0           0.0%                       

                -60 to -31       4           1.7%             33.6%     **Early**

                -30 to -6        77          32.0%                      

  **On time**   -5 to +30        150         62.2%            62.2%     **On time**

  **Late**      +31 to +45       6           2.5%                       

                +46 to +60       2           0.8%             4.1%      **Late**

                +61              2           0.8%                       

                                 241         100.0%                     

                                                                        

  **Table 12:                                                           
  Combined                                                              
  on-time                                                               
  performance                                                           
  data check                                                            
  for May 16,                                                           
  2001**                                                                

                **Minutes**      **Total**   **Percentage**             

  **Early**     -61 or more      1           0.2%                       

                -60 to -31       16          3.1%             37.3%     **Early**

                -30 to -6        173         33.9%                      

  **On time**   -5 to +30        303         59.4%            59.4%     **On time**

  **Late**      +31 to +45       13          2.5%                       

                +46 to +60       2           0.4%             3.3%      **Late**

                +61              2           0.4%                       

                                 510         100.0%                     
  ------------- ---------------- ----------- ---------------- --------- ------------

Every fifth trip on every manifest for May 16, 2001 was analyzed.

The differences between scheduled pickup time and actual pickup time
were analyzed.

## Trip Length

**Reported Travel Times**

Information from MCTS' monthly reports on Transit Plus performance, and
monthly reports prepared by MCTS for the WCA, was used to determine the
number of trips with excessive trip duration during the month of May
2001. A detailed breakdown of trips provided by travel time and by
carrier is provided in Table 13. As shown, 84.9% of all trips are
performed in 60 minutes or less. Another 14.7% of trips take between 61
and 120 minutes. Only 209 of the 46,484 trips for the month (about 0.4%)
took more than two hours.

Travel times were very similar in each contractor area. Transit Express
reported ride-times that were only marginally longer than Laidlaw. The
average trip lengths reported by each carrier are also very similar. For
the month of May, for example, Laidlaw reported an average trip length
of 6.99 miles and Transit Express reported an average trip length of
6.43 miles.

**Table 13: Transit Plus Travel Times, May 2001**

  ---------- ------------- ----------- ----------- ----------- ----------- ------------
  **Travel   **Laidlaw**               **Transit               **Total**   
  Time**                               Express**                           

             Number        Percent of  Number      Percent of  Number      Percent of
                           Laidlaw                 Transit                 Total Trips
                           Trips                   Express                 
                                                   Trips                   

  0 - 60     17,950        85.5        21,503      84.3        39,453      84.9

  61 - 120   2,953         14.1        3,869       15.2        6,822       14.7

  \>120      81            .4          128         .5          209         .4

  Total      20,984        100         25,500      100         46,484      100
  ---------- ------------- ----------- ----------- ----------- ----------- ------------

As noted above, MCTS staff investigates complaints of excessive ride
duration by calculating an estimate of the travel time for a comparable
trip on the fixed route system, comparing that travel time to the
Transit Plus travel time, and applying the standards established in the
WCA settlement. The MCTS method of estimating fixed route travel time
considers fixed route ride time as well as an estimate of walking and
wait times. Walking time to and from fixed route stops is based on a
speed of 1.3 minutes per block. Waiting time for the first bus is
estimated to be one-half of the headway (or interval between trips) on
the relevant fixed route. Waiting time for transfers to a second or
third bus route is based on the same measure.

According to MCTS complaint records, 14 complaints of excessive ride
duration were received between June 2000 and June 2001. The comparison
of reported ride times to comparable fixed route travel times found all
14 complaints to be valid and to exceed the established travel time
standard.

###### Comparison of Transit Plus and Fixed Route Travel Times {#comparison-of-transit-plus-and-fixed-route-travel-times .unnumbered}

"Ride Duration Detail" reports were reviewed to identify Transit Plus
trips with long actual ride times. One report was prepared which listed
trips scheduled for May 13 -- 19, 2001, with travel times of greater
than 60 minutes but less than 120 minutes. A second report was prepared
which showed trips scheduled for the month of May 2001 with travel times
in excess of 120 minutes. These reports are typically run by MCTS to
review the number of trips with long ride times.

A sample of 35 Transit Plus trips with long actual ride times was
selected at random from among the long trips in the "Ride Duration
Detail" reports to compare ADA Complementary Paratransit and fixed route
travel times. Of the sample trips, Laidlaw served 16 and Transit Express
served 19. Table 14 shows the date for each trip, the origin and
destination, the time of day that the trip was made, the actual travel
times on the Transit Plus system, and the estimated travel time by fixed
route. The differences between Transit Plus travel times and the fixed
route travel times are then shown.

Fixed route travel times were estimated by working with the MCTS fixed
route customer information staff person, who generated travel
itineraries for each trip. In addition to the time that a fixed route
rider would need for onboard travel and waiting to transfer to the next
scheduled bus on a second (and occasionally, a third) route, estimates
of walking time to and from stops were made. Walking time estimates were
based on the fixed route customer service representative's estimation of
the number of blocks between the bus stop and the origin or destination,
and an allowance of three minutes walking time per block, rather than
the 1.3 minutes per block used by MCTS. The slower, 3 minute per block,
walk speed reflects the negative perception people typically have
towards walking, as reflected in the way people make choices of travel
routes and modes.

MCTS currently provides Transit Plus service beyond the ¾ mile corridor
around its fixed bus routes. Eight of the 35 ADA Complementary
Paratransit trips reviewed began or ended in areas that do not receive
fixed route bus service, or receive only limited commuter service, such
as Oak Creek or Franklin (both in the south zone of the Transit Plus
service area). No fixed route travel times were calculated for those
trips, and they are not considered in the summary figures presented
below.

Table 14 shows that the travel time on Transit Plus would be comparable
to fixed route travel time (within 25 minutes) for seven trips, would be
less for seven trips, and would be significantly longer (more than 25
minutes) for thirteen trips. The trips with significantly longer Transit
Plus travel times are highlighted in bold text. In seven of the thirteen
cases, travel time on the Transit Express trip was longer than the
comparable fixed route travel time by an hour or more.

Table 14. Comparison of Travel Times on Transit Express Versus Fixed
Route for 35 Selected Trips

<table>
<colgroup>
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 22%" />
<col style="width: 21%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td><strong>Trip Date</strong></td>
<td><strong>Sample Trip #</strong></td>
<td><strong>Trip Time</strong></td>
<td><strong>Origin</strong></td>
<td><strong>Destination</strong></td>
<td><strong>Transit Plus</strong></td>
<td><strong>Fixed Route</strong></td>
<td><strong>Walk to Bus</strong></td>
<td>Total Fixed Rte</td>
<td><strong>Difference</strong></td>
</tr>
<tr class="even">
<td><strong>5/01</strong></td>
<td><strong>1</strong></td>
<td><strong>1340-1559</strong></td>
<td><strong>200 W. Pleasant St, Milwaukee</strong></td>
<td><strong>8534 W. Mill Rd, Milwaukee</strong></td>
<td><strong>139</strong></td>
<td><strong>75</strong></td>
<td><strong>3</strong></td>
<td><strong>78</strong></td>
<td><strong>61</strong></td>
</tr>
<tr class="odd">
<td><strong>5/07</strong></td>
<td><strong>2</strong></td>
<td><strong>0719-0940</strong></td>
<td><strong>7481 N. Navajo Rd, Fox Point</strong></td>
<td><strong>1340 N. Broadway St, Milw.</strong></td>
<td><strong>141</strong></td>
<td><strong>88</strong></td>
<td><strong>9</strong></td>
<td><strong>97</strong></td>
<td><strong>44</strong></td>
</tr>
<tr class="even">
<td><strong>5/10</strong></td>
<td><strong>3</strong></td>
<td><strong>1437-1723</strong></td>
<td><strong>1000 N. 92<sup>nd</sup> St, West Allis</strong></td>
<td><strong>3547 N. 14<sup>th</sup> St, Milwaukee</strong></td>
<td><strong>166</strong></td>
<td><strong>48</strong></td>
<td><strong>12</strong></td>
<td><strong>60</strong></td>
<td><strong>106</strong></td>
</tr>
<tr class="odd">
<td>5/14</td>
<td>4</td>
<td>1458-1659</td>
<td>1016 Milwaukee Ave, S. Milw.</td>
<td>5720 N. 34<sup>th</sup> St, Milwaukee</td>
<td>121</td>
<td>99</td>
<td>9</td>
<td>108</td>
<td>13</td>
</tr>
<tr class="even">
<td><strong>5/17</strong></td>
<td><strong>5</strong></td>
<td><strong>1950-2255</strong></td>
<td><strong>7519 W. Oklahoma Ave, Milw.</strong></td>
<td><strong>1600 E. River Park Ct, Shorewd</strong></td>
<td><strong>185</strong></td>
<td><strong>76</strong></td>
<td><strong>9</strong></td>
<td><strong>85</strong></td>
<td><strong>100</strong></td>
</tr>
<tr class="odd">
<td>5/23</td>
<td>6</td>
<td>1600-1835</td>
<td>11951 W. Janesville Rd, Hales Cor</td>
<td>8500 N. Greenvale Rd, Bayside</td>
<td>155</td>
<td>159</td>
<td>47</td>
<td>206</td>
<td>-51</td>
</tr>
<tr class="even">
<td>5/31</td>
<td>7</td>
<td>1455-1700</td>
<td>11951 W. Janesville Rd, Hales Cor</td>
<td>8500 N. Greenvale Rd, Bayside</td>
<td>125</td>
<td>159</td>
<td>47</td>
<td>206</td>
<td>-81</td>
</tr>
<tr class="odd">
<td><strong>5/01</strong></td>
<td><strong>8</strong></td>
<td><strong>0717-0918</strong></td>
<td><strong>5219 Lakeside Dr, Greendale</strong></td>
<td><strong>4021 N. 90<sup>th</sup> St, Milwaukee</strong></td>
<td><strong>121</strong></td>
<td><strong>42</strong></td>
<td><strong>21</strong></td>
<td><strong>63</strong></td>
<td><strong>58</strong></td>
</tr>
<tr class="even">
<td>5/03</td>
<td>9</td>
<td>1356-1609</td>
<td>611 W. National Ave, Milwaukee</td>
<td>8860 S. Shepard Ave, Oak Creek</td>
<td>133</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="odd">
<td>5/06</td>
<td>10</td>
<td>1135-1344</td>
<td>10940 S. Nicholson Rd, Oak Creek</td>
<td>4246 W. Highland Blvd, Milw.</td>
<td>129</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td><strong>5/08</strong></td>
<td><strong>11</strong></td>
<td><strong>0735-0940</strong></td>
<td><strong>5210 S. 44<sup>th</sup> St, Greenfield</strong></td>
<td><strong>3221 S. Lake Dr, St. Francis</strong></td>
<td><strong>125</strong></td>
<td><strong>41</strong></td>
<td><strong>13</strong></td>
<td><strong>54</strong></td>
<td><strong>71</strong></td>
</tr>
<tr class="odd">
<td><strong>5/10</strong></td>
<td><strong>12</strong></td>
<td><strong>1501-1715</strong></td>
<td><strong>336 W. Walnut St, Milwaukee</strong></td>
<td><strong>3438 S. Clement Ave, Milwaukee</strong></td>
<td><strong>134</strong></td>
<td><strong>61</strong></td>
<td><strong>9</strong></td>
<td><strong>70</strong></td>
<td><strong>64</strong></td>
</tr>
<tr class="even">
<td><strong>5/11</strong></td>
<td><strong>13</strong></td>
<td><strong>1500-1709</strong></td>
<td><strong>1339 N. Milwaukee St, Milwaukee</strong></td>
<td><strong>4523 W. Tripoli Ave, Milwaukee</strong></td>
<td><strong>129</strong></td>
<td><strong>57</strong></td>
<td><strong>15</strong></td>
<td><strong>72</strong></td>
<td><strong>57</strong></td>
</tr>
<tr class="odd">
<td>5/16</td>
<td>14</td>
<td>1445-1650</td>
<td>4425 W. Woolworth Ave, Milw.</td>
<td>4915 S. Greenleaf Ct, Greenfield</td>
<td>125</td>
<td>100</td>
<td>69</td>
<td>169</td>
<td>-44</td>
</tr>
<tr class="even">
<td><strong>05/18</strong></td>
<td><strong>15</strong></td>
<td><strong>1753-2020</strong></td>
<td><strong>1000 N. 92<sup>nd</sup> St, Wauwatosa</strong></td>
<td><strong>1342 N. 40<sup>th</sup> St, Milwaukee</strong></td>
<td><strong>147</strong></td>
<td><strong>33</strong></td>
<td><strong>3</strong></td>
<td><strong>36</strong></td>
<td><strong>111</strong></td>
</tr>
<tr class="odd">
<td>5/25</td>
<td>16</td>
<td>0719-0928</td>
<td>7599 Francis Ct, Franklin</td>
<td>2801 E. Morgan Ave, Milwaukee</td>
<td>129</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>5/31</td>
<td>17</td>
<td>0730-0939</td>
<td>7599 Francis Ct, Franklin</td>
<td>2801 E. Morgan Ave, Milwaukee</td>
<td>129</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="odd">
<td>5/13</td>
<td>18</td>
<td>1335-1440</td>
<td>7599 Francis Ct, Franklin</td>
<td>2801 E. Morgan Ave, Milwaukee</td>
<td>65</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>5/14</td>
<td>19</td>
<td>1120-1250</td>
<td>10507 S. Chicago Rd, Oak Creek</td>
<td>5600 S. Rosewood Ave, Cudahy</td>
<td>90</td>
<td>40</td>
<td>3</td>
<td>43</td>
<td>47</td>
</tr>
<tr class="odd">
<td>5/14</td>
<td>20</td>
<td>1510-1705</td>
<td>7519 W. Oklahoma Ave, Milw.</td>
<td>2825 S. Chicago Ave, South Milw.</td>
<td>115</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>5/15</td>
<td>21</td>
<td>0849-1013</td>
<td>4425 W. Woolworth Ave, Milw.</td>
<td>4915 S. Greenleaf Ct, Greenfield</td>
<td>84</td>
<td>57</td>
<td>10</td>
<td>67</td>
<td>17</td>
</tr>
<tr class="odd">
<td>5/15</td>
<td>22</td>
<td>1526-1640</td>
<td><h4 id="s.-45th-st-greenfield" class="unnumbered">5392 S.
45<sup>th</sup> St, Greenfield</h4></td>
<td><h4 id="n.-milwaukee-st-milwaukee" class="unnumbered">1340 N.
Milwaukee St, Milwaukee</h4></td>
<td>74</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>5/16</td>
<td>23</td>
<td>1305-1408</td>
<td><h4 id="w.-wisconsin-ave-milwaukee" class="unnumbered">15 W.
Wisconsin Ave, Milwaukee</h4></td>
<td><h4 id="s.-shepard-ave-oak-creek" class="unnumbered">860 S. Shepard
Ave, Oak Creek</h4></td>
<td>63</td>
<td>74</td>
<td>9</td>
<td>83</td>
<td>-20</td>
</tr>
<tr class="odd">
<td>5/16</td>
<td>24</td>
<td>1509-1619</td>
<td>3333 S. Howell Ave, Milwaukee</td>
<td>3300 S. 89<sup>th</sup> St, Milwaukee</td>
<td>70</td>
<td>29</td>
<td>12</td>
<td>41</td>
<td>29</td>
</tr>
<tr class="even">
<td>5/17</td>
<td>25</td>
<td>0830-0935</td>
<td>1511 Chestnut St, S. Milwaukee</td>
<td>2801 E. Morgan Ave, Milwaukee</td>
<td>65</td>
<td>61</td>
<td>3</td>
<td>64</td>
<td>1</td>
</tr>
<tr class="odd">
<td>5/17</td>
<td>26</td>
<td>1420-1620</td>
<td>1647 S. 101<sup>st</sup> St, West Allis</td>
<td>2650 N. 9<sup>th</sup> St, Milwaukee</td>
<td>119</td>
<td>86</td>
<td>21</td>
<td>107</td>
<td>12</td>
</tr>
<tr class="even">
<td>5/18</td>
<td>30</td>
<td>0737-0838</td>
<td>8781 Travis Court, Milwaukee</td>
<td>3601 S. Chicago Ave, S. Milw.</td>
<td>108</td>
<td>92</td>
<td>30</td>
<td>122</td>
<td>-14</td>
</tr>
<tr class="odd">
<td>5/18</td>
<td>31</td>
<td>1454-1556</td>
<td>1016 Milwaukee Ave, S. Milw.</td>
<td>9055 S. 35<sup>th</sup> St, Franklin</td>
<td>65</td>
<td>47</td>
<td>12</td>
<td>59</td>
<td>6</td>
</tr>
<tr class="even">
<td><strong>5/19</strong></td>
<td><strong>32</strong></td>
<td><strong>1555-1711</strong></td>
<td><strong>710 W. Wells St, Milwaukee</strong></td>
<td><strong>3833 E. Obrien Rd, Oak Creek</strong></td>
<td><strong>68</strong></td>
<td><strong>4</strong></td>
<td><strong>24</strong></td>
<td><strong>28</strong></td>
<td><strong>40</strong></td>
</tr>
<tr class="odd">
<td>5/13</td>
<td>33</td>
<td>1230-1418</td>
<td>4262 N. 85<sup>th</sup> St, Milwaukee</td>
<td>1000 W. Bluemound Rd, Milw.</td>
<td>70</td>
<td>104</td>
<td>6</td>
<td>110</td>
<td>-40</td>
</tr>
<tr class="even">
<td>5/14</td>
<td>34</td>
<td>1420-1525</td>
<td>4425 W. Woolworth Ave, Milw.</td>
<td>3262 N. Palmer St, Milwaukee</td>
<td>72</td>
<td>52</td>
<td>3</td>
<td>55</td>
<td>17</td>
</tr>
<tr class="odd">
<td>5/15</td>
<td>35</td>
<td>0702-0810</td>
<td>4821 N 22<sup>nd</sup> St, Milwaukee</td>
<td>4425 W. Woolworth Ave, Milw.</td>
<td>70</td>
<td>40</td>
<td>3</td>
<td>43</td>
<td>27</td>
</tr>
<tr class="even">
<td>5/15</td>
<td>36</td>
<td>1315-1425</td>
<td>2801 E. Morgan Ave, Milwaukee</td>
<td>7635 N. 78<sup>th</sup> St, Milwaukee</td>
<td>80</td>
<td>77</td>
<td>9</td>
<td>86</td>
<td>-9</td>
</tr>
<tr class="odd">
<td>5/16</td>
<td>37</td>
<td>0715-0827</td>
<td>3161 S. 112<sup>th</sup> St, West Allis</td>
<td>5920 W. Center St, Milwaukee</td>
<td>61</td>
<td>No service</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>5/16</td>
<td>38</td>
<td>1500-1610</td>
<td>1339 N. Milwaukee St, Milwaukee</td>
<td>9325 N. Green Bay Rd, Brwn Deer</td>
<td>85</td>
<td>78</td>
<td>3</td>
<td>81</td>
<td>4</td>
</tr>
</tbody>
</table>

The travel times for these trips were compared against the definition of
excessive ride duration as established in the settlement with the WCA.
Transit Plus trips, which were provided in areas not served by fixed
route service, were excluded from this analysis. Table 15 shows that
comparison.

Table 15: Comparison of Transit Plus Travel Times to Definition of
Excessive Ride Duration for 27 Selected Long Trips

  ----------- ----------- ----------- ------------ ----------- -----------
  Sample Trip Transit     Fixed Route Transit Plus Standard    Within
  Number      Plus Travel Travel Time Time as                  Standard?
              Time        (minutes)   Percentage               
              (minutes)               of Fixed                 
                                      Route Time               

  1           139         78          1.78         1.5         No

  2           141         97          1.45         1.5         Yes

  3           166         60          2.76         1.5         No

  4           121         108         1.12         1.5         Yes

  5           185         85          2.18         1.5         No

  6           155         206         0.75         1.5         Yes

  7           125         206         0.61         1.5         Yes

  8           121         63          1.92         1.5         No

  11          125         54          2.30         1.5         No

  12          134         70          1.91         1.5         No

  13          129         72          1.72         1.5         No

  14          125         169         0.74         1.5         Yes

  15          147         36          4.10         1.5         No

  19          90          43          2.10         2.0         No

  21          84          67          1.25         2.0         Yes

  23          63          83          0.76         2.0         Yes

  24          70          41          1.70         2.0         Yes

  25          65          64          1.01         2.0         Yes

  26          119         107         1.11         2.0         Yes

  30          108         122         0.88         2.0         Yes

  31          65          59          1.10         2.0         Yes

  32          68          28          2.43         2.0         No

  33          70          110         0.64         2.0         Yes

  34          72          55          1.31         2.0         Yes

  35          70          43          1.63         2.0         Yes

  36          80          86          0.93         2.0         Yes

  38          85          81          1.05         2.0         Yes
  ----------- ----------- ----------- ------------ ----------- -----------

Of the 27 trips, 17, or 63%, are within the standard set forth in the
settlement. Ten trips, or 37%, exceed the excessive ride duration
threshold.

Consumers contacted prior to this assessment reported some concern with
lengthy travel times to and from the Eisenhower Center, located at 4425
W. Woolworth Avenue in the north zone of the Transit Plus service area.
Laidlaw and Transit Express driver manifests for May 16, 2001, were
reviewed to identify trips to this particular facility. Attachment G
includes tables, which summarize travel times for trips provided by
Laidlaw and Transit Express to and from the Eisenhower Center on that
date. On the whole, most travel times to and from the Eisenhower Center
do not appear to be excessive. Of the 69 trips to or from the Eisenhower
Center that Laidlaw provided on this particular day, eight trips, or
nearly 12%, had travel times of more than 60 minutes. Five of these
relatively lengthy trips took place in the morning, and three in the
afternoon hours. Customers with the longer travel times live in
Wauwatosa and at other addresses noted in the tables in Attachment G.
Transit Express provided a total of 36 trips to or from the Eisenhower
Center on this date. Of those trips, nine, or 25%, had travel times in
excess of 60 minutes. Trips with lengthy travel times were split fairly
evenly between morning (five trips) and afternoon hours (four trips).
The origins or destinations of these longer trips included Franklin,
Cudahy and South Milwaukee.

**Findings**

1.  It appears that 94 to 97% of passenger pick-ups are made on time or
    early.

2.  A detailed analysis of on-time performance showed that 37% of
    pick-ups are made early (6 or more minutes before the negotiated
    pick-up time).

3.  It appears that the existence of three different standards over a
    19-month period has led to confusion among both users and drivers of
    the system as to what constitutes "on-time performance." In
    interviews with drivers, several believed that the standard was
    still 15 minutes early to 15 minutes late.

4.  Some schedules appear to require operators to make early pick-ups in
    order to perform runs on time. While there was no evidence that the
    contractors force riders to leave early, it appears that scheduling
    and performing trips before, as well as after the scheduled time, is
    still a normal method of operation. This practice may lead customers
    to feel like they have to be ready early, despite formal policies
    regarding the pick-up window.

5.  Significant staff effort is dedicated at Transit Express to
    developing workable schedules and to monitoring operators and runs
    on the day of service. Operators appear to be checking-in frequently
    with dispatchers at Transit Express to provide an update on the
    status of runs and to receive direction and instructions for
    continuing runs. The schedulers at Laidlaw, on the other hand,
    appear to rely more on the automated system to develop and
    "clean-up" schedules. The dispatchers at Laidlaw also appear to rely
    more on operators to report current or potential schedule problems.
    These methods of operation at Laidlaw could be contributing to
    on-time performance problems.

6.  About 85% of all Transit Plus trips take 60 minutes or less. Of the
    roughly 15% of trips with travel times of over 60 minutes, less than
    half of one percent take more than 120 minutes.

7.  The percentage of trips with long travel times is consistent between
    the two Transit Plus carriers.

8.  The repetition of destination addresses and customers' names on Ride
    Duration Detail reports appears to indicate that many long travel
    times occur on regularly scheduled group trips, particularly for the
    customers that are picked up first in the morning or dropped off
    last in the afternoon. Residential addresses for customers with long
    trips are often located on the outskirts of the Transit Plus service
    area.

9.  Based on review of the May 2001 sample of long trips, the travel
    time for over half of long Transit Plus trips is comparable to, or
    better than, the travel time on a fixed route trip between the same
    origin and destination. For the remainder of the long trips,
    however, travel time on Transit Plus is significantly longer than on
    comparable fixed route trips.

10. According to estimates of fixed route travel times developed by
    MCTS, the times for all 14 of the excessive ride duration complaints
    received between June 2000 and June 2001 were found to have exceeded
    the standards established in the settlement between Milwaukee and
    the WCA. According to estimates of fixed route travel times
    developed by the assessment team, 63% of a sample of 38 long trips
    taken in May 2001 were found to be within that standard, and 37%
    were found to exceed it.

**Recommendations**

1.  It is recommended that Laidlaw Transit commit additional staff time
    to manual reviews and "clean-up" of schedules created by the
    automated system.

2.  It is also recommended that Laidlaw Transit implement a more
    proactive dispatch policy, require operators to radio in pick-ups
    and drop-offs, and have dispatchers more actively manage runs to
    avoid late trips.

3.  It is recommended that the MCTS expand its effort to inform all of
    its customers and drivers about the recently enacted on-time
    performance standard through an expanded public outreach effort.

4.  It is recommended that call takers notify customers of the pick up
    window time range when confirming scheduled trips with customers.
    For example, "your pick up time has been scheduled for 8:00 a.m. on
    \_\_\_. This means that a vehicle will pick you up between 8:00 a.m.
    and 8:25 a.m."

5.  It is suggested that MCTS and the Transit Plus carriers examine
    regularly scheduled runs on which long travel times occur and
    estimate fixed route travel times for those trips. In cases where
    Transit Plus travel times are not comparable to fixed route travel
    times, breaking those runs into smaller segments should be
    considered. The Ride Duration Detail reports should be used to
    identify such runs.

6.  The Ride Duration Detail reports should also be used to identify
    customers whose travel times regularly exceed 60 or 120 minutes. If
    those travel times are not comparable to a similar fixed route trip,
    assignment of those trips to other runs should be considered.

7.  It is recommended that MCTS analyze ride duration for all or some
    portion of the trips appearing on Ride Duration Detail Reports, not
    only those trips about which customers file a formal complaint.

8.  MCTS should consider revising the excessive ride duration standard.
    Twice the fixed route travel time, as established in the settlement
    between Milwaukee County and the WC, for a similar trip may not be
    considered comparable service, especially when fixed route travel
    time is estimated to include waiting time for each bus at one-half
    the scheduled headway. It seems likely that most bus riders would
    plan to get to the first bus stop shortly before the bus was
    scheduled to arrive there; on routes with long headways, that
    waiting time is likely to be less than half of the headway.

9.  To address the perception among at least some Transit Plus riders
    (such as those traveling to the Eisenhower Center) that travel times
    are excessive, MCTS should continue its public education efforts, so
    that riders expect a shared ride trip rather than one that takes
    them directly from their origin to their destination.

# Resources

During the review, the assessment team collected information about
resources available to provide Transit Plus service. This included
looking at the operating budget for the service, the fleet being made
available by contractors, and the availability of trained personnel to
operate the service.

**Budget**

The process used to develop Transit Plus budgets was reviewed with MCTS
staff. Worksheets used to prepare the 2002 budget were also reviewed.
MCTS first examines trip requests and total trips provided for the past
two years. This information is then used to develop an estimate of
demand for the coming year. The estimate of total trips that will need
to be provided is then translated into an estimate of the number of
service hours needed by each contractor using information about past and
projected productivity (trips/hour). Finally, an estimate of
expenditures is developed by multiplying the number of estimated service
hours by the per hour rate bid by each contractor.

MCTS staff indicated that when they agreed to assume responsibility for
the Transit Plus service in January 2000 they did so with a clear
understanding that the County would provide adequate resources to meet
the full expressed demand. Adequate funding to operate the service was
not, in their view, a constraint. It was noted that the service ran
slightly under budget in 2000 and was on-target so far in 2001.

Table 16 below shows actual net expenditures for the Transit Plus
service for 1998 through 2000 and estimated/requested operating budgets
for 2001 and 2002. The table also shows total trips provided for 1999
and 2000 and estimated trips for 2001 and 2002. As this table shows,
MCTS has estimated increases in ridership of 5-6% each year. These
estimates are consistent with actual ridership growth over the period.
Net expenditures have been adequate to meet the projected growth in
demand each year with an increase of 15.6% in between 2000 and 2001 and
6.8% between 2001 and 2002.

Table 16. Transit Plus Net Expenditures and Total Trips, 1998-2002

+----------------------+-----------+------------+---------+-----------+
| Year                 | Net       | \%         | Total   | \%        |
|                      |           | E          | Ri      | Ridership |
|                      | Exp       | xpenditure | dership | Increase  |
|                      | enditures | Increase   |         | Over      |
|                      |           | Over Prior |         | Prior     |
|                      |           | Year       |         | Year      |
+----------------------+-----------+------------+---------+-----------+
| 1998 Actual          | \$1       | NA         | NA      | N/A       |
|                      | 3,932,252 |            |         |           |
+----------------------+-----------+------------+---------+-----------+
| 1999 Actual          | \$1       | 6.5%       | 500,089 | NA        |
|                      | 4,834,996 |            | *(1)*   |           |
+----------------------+-----------+------------+---------+-----------+
| 2000 Actual          | \$1       | 5.3%       | 525,663 | 5.1%      |
|                      | 5,628,169 |            |         |           |
+----------------------+-----------+------------+---------+-----------+
| 2001                 | \$1       | 15.6%      | 557,200 | 6.0%      |
| Adopted/Estimated    | 8,061,919 |            |         |           |
+----------------------+-----------+------------+---------+-----------+
| 2002                 | \$1       | 6.8%       | 588,600 | 5.6%      |
| Requested/Estimated  | 9,291,623 |            |         |           |
+----------------------+-----------+------------+---------+-----------+

*(1) Total ridership for 1999 is an estimate based on the number of
client trips reported that year. Client trips totaled 476,275 and are
typically 95% of all trips provided.*

Contractor management was also interviewed about the budget made
available to meet the demand. Both of the managers at Transit Express
and Laidlaw indicated that the number of hours of service estimated each
year is adequate to meet the demand. They noted that hours can be
adjusted each quarter and that they were currently running below the
number of hours identified as a target in their contracts. It was
indicated that the small number of trip denials is a function of
operational limitations and contract incentives rather than any
limitations placed on the number of hours that can be operated. Trips
that are at times and locations that cannot be efficiently accommodated
on existing runs are denied. Contractors are paid per revenue-hour and
also keep the fares they collect. There is an incentive, therefore, to
maintain reasonable productivity on all runs. The higher the
productivity, the greater the fare receipts and the greater the
effective reimbursement per hour. The Laidlaw manager also noted that,
because the operation is unionized, they couldn't just add shifts as
needed. New shifts have to be reviewed and approved by the union.
Therefore, they adjust shifts quarterly.

**Fleet**

Transit Express has 80 vehicles to cover 70 daytime runs. Vehicle
maintenance is performed during two shifts Monday through Saturday.
Typically four vehicles are in maintenance and are unavailable for
service leaving 70 vehicles to cover assigned runs and six spare
vehicles. Accordingly Transit Express appears able to provide sufficient
equipment to cover assigned runs.

Laidlaw has 62 vehicles to cover daily runs. Of these 62 vehicles,
Laidlaw owns 54 and has access to an additional 8 through Guardian, its
sub-contractor. Laidlaw reported that they are able to cover their runs
and maintain a 10-15% spares ratio. This would result in 52 to 56
vehicles available for service with 6 to 10 spares.

**Personnel**

Transit Express has a total of 100 trained operators available, of which
about 62 are full-time and 38 are part-time. Operators are paid \$8.50
per hour to start and \$10 per hour after four months on the job. They
also receive vacation and holiday time and full health and life
insurance benefits. Transit Express also noted that they provide bonuses
for good job performance and paid out \$150,000 in bonuses last year. As
a result, they report relatively low turnover. In the past year about 30
new operators have been hired and trained, which translates into a 30%
turnover ratio. In general, Transit Express management reported that
they have plenty of trained operators to cover scheduled runs and that
driver availability is not an issue.

Transit Express noted that they usually have 2-3 spare drivers available
in the morning to cover call-outs. They are able to cover pull out, but
do not have true unassigned spares and "floater" vehicles available
throughout the day to back-up scheduled runs. It was noted that
floater/spare vehicles and drivers, not in revenue service, are not
reimbursed under the current contract.

Transit Express management noted that turnover in call takers is
slightly higher and is more of an issue. Call takers receive \$7.00 per
hour plus benefits to start and can increase to \$9.00 per hour. On the
day that the operation was visited, the service was short one call taker
and was covering a second position with a trainee.

Operators at Transit Express receive 2-4 days of classroom training
(depending on past experience and qualifications). This includes
training in policies, procedures and paperwork, CPR training, 8 hours of
Passenger Assistance Techniques (PAT) training, 4 hours of defensive
driving training, substance abuse training, and map reading. They then
ride for one day with an experienced driver or trainer and drive being
observed for another 2-6 days. There is also annual retraining which
focuses on the latest techniques for securing wheelchairs.

Laidlaw management indicated that they have 83 full-time and 5 part-time
drivers available. They also have 7 drivers available through their
subcontractor (Guardian). Operators receive \$8.54 to start and can
increase to \$10.40 after two years. Vacation, holiday, health and life
insurance benefits are also provided. Even though compensation is
similar to that at Transit express, Laidlaw reported a much higher
turnover ratio. For the past year, the turnover ratio was 88%. Laidlaw
management indicated that they currently have a full complement of
operators but that they experienced a significant driver shortage in the
winter of 2000/2001.

New operators at Laidlaw receive 40 hours of classroom training and
32-40 hours of on-the-road instruction.

Laidlaw management noted that they typically have 6-10 operators on
vacation or on leave and another 2 that call-out on the day of service.
At the time of the review they were operating with 11 spare drivers and
reported that they currently are experiencing no problems meeting
pullout. A review of run sheets and pullout logs for the weeks of May
2-8, 2001 and June 9-15, 2001 showed that they do in fact meet pullout
but often use all available spares to meet pullout. Spares are often not
available as "floaters" throughout the day and in-service problems are
typically handled by shifting trips between runs.

**Findings**

1.  The process used by MCTS to estimate demand and funding needs for
    the Transit Plus service appears to accurately consider current
    level of demand, projected growth in demand and any past unmet
    needs. The availability of funding does not appear to limit the
    service from being operated in full compliance with the ADA
    Complementary Paratransit regulations.

2.  Transit Plus contractors appear to have an adequate number of
    vehicles and other capital equipment to meet the full demand for
    service.

3.  At the time of the review, the contractors appeared to have an
    adequate number of available operators and other staff to provide
    service in full compliance with the regulations. There appeared to
    have been a shortage of operators at Laidlaw Transit in the winter
    of 2000/2001, but this problem had been corrected.

4.  Operators appear to be adequately trained to operate vehicles and
    accessibility equipment safely and to properly assist and treat
    individuals with disabilities in a respectful and courteous way.

5.  Training for other personnel appears, for the most part, to also be
    thorough. Recent efforts have been made to provide remedial
    instruction to call takers, schedulers, and dispatchers in the
    proper use of the automated reservations, scheduling, and dispatch
    system. However, at the time of the review, there was still evidence
    that some call takers may not be recording trip denials
    appropriately, which may be causing trip denials to be
    underreported.

6.  While both contractors appear to have an adequate number of
    available spare drivers to cover pull-out, they tend to operate with
    little or no spare, or "floater" capacity at certain times of the
    service day. This requires dispatchers to use existing runs to cover
    in-service problems, which in some cases can cause scheduled trips
    to be performed late. The lack of spare capacity appears to be
    related to the fact that MCTS does not provide reimbursement for
    spare capacity but only pays for vehicle time used in the provision
    of service.

**Recommendations**

1.  MCTS should monitor the performance of call takers to ensure that
    trip denials are being properly recorded. Call takers should be
    retrained as needed.

2.  MCTS should consider reimbursing contractors for a reasonable amount
    of back-up capacity throughout the service day so that dispatchers
    have an option to handle same day service problems with "floater"
    vehicles and drivers and without always having to rearrange existing
    runs and schedules.

    **Attachment A**

**Response from MCTS**

**PLEASE NOTE**

**Attachment A** includes a letter from MCTS. The letter refers to an
"Exhibit 1" that includes several MCTS documents, including a revised
*Rider's Guide* (July 2001). A full copy of the Rider's Guide appears in
**Attachment C**. In this attachment, the assessment team has included
from the revised *Rider's Guide* only the cover and pages 29 and 30. All
other pages have remain unchanged from the January 2001 version of the
*Rider's Guide*.

**Attachment B**

**Assessment On-Site Schedule**

**ADA Complementary Paratransit Service Assessment**

**Milwaukee County Transit System**

**Milwaukee, Wisconsin**

**July 10-13,2001**

**SCHEDULE**

+-------+---------------------------+----------------------+---------+
| **T   | **Activity**              | **Who**              | **      |
| ime** |                           |                      | Where** |
+-------+---------------------------+----------------------+---------+
| **Tue |                           |                      |         |
| sday, |                           |                      |         |
| July  |                           |                      |         |
| 10,   |                           |                      |         |
| 2     |                           |                      |         |
| 001** |                           |                      |         |
+-------+---------------------------+----------------------+---------+
| 9:00  | Opening Conference        | All & FTA            | MCTS    |
| am    |                           |                      |         |
+-------+---------------------------+----------------------+---------+
| 9:30  | Review service design.    | All Assessment Team  | MCTS    |
| am    |                           | Members              |         |
|       | Review contract           |                      |         |
|       | management.               | MCTS Director of     |         |
|       |                           | Paratransit          |         |
|       | Review information sent   |                      |         |
|       | in advance.               | MCTS Paratransit     |         |
|       |                           | Contract Mgr         |         |
|       | Review information        |                      |         |
|       | available on-site.        |                      |         |
|       |                           |                      |         |
|       | Review standard reports   |                      |         |
|       | and info.                 |                      |         |
+-------+---------------------------+----------------------+---------+
| 10:30 | Review service planning & | Russell Thatcher     | MCTS    |
| am    | budgeting                 |                      |         |
|       |                           | MCTS Director of     |         |
|       | Transit Plus complaint    | Paratransit          |         |
|       | files                     |                      |         |
|       |                           | MCTS Dir. of         |         |
|       |                           | Administration       |         |
|       |                           |                      |         |
|       |                           | Terry Regan, Patti   |         |
|       |                           | Monahan              |         |
+-------+---------------------------+----------------------+---------+
| 1:00  | Review eligibility        | Russell Thatcher     | MCTS    |
| pm    | determination             |                      |         |
|       |                           | MCTS Eligibility     |         |
|       |                           | Manager              |         |
+-------+---------------------------+----------------------+---------+
| 1:00  | Compare Transit Plus      | Patti Monahan        | MCTS    |
| pm    | travel times to fixed     |                      |         |
|       | route travel times        | MCTS fixed route CIS |         |
|       |                           | staff                |         |
|       | MCTS reviews of travel    |                      |         |
|       | time based on customer    |                      |         |
|       | complaints                |                      |         |
+-------+---------------------------+----------------------+---------+
| **    |                           |                      |         |
| Wedne |                           |                      |         |
| sday, |                           |                      |         |
| July  |                           |                      |         |
| 11,   |                           |                      |         |
| 2     |                           |                      |         |
| 001** |                           |                      |         |
+-------+---------------------------+----------------------+---------+
| 7:30  | Tour of Transit Express   | All Assessment Team  | Transit |
| am    | operation                 | Members              | Express |
|       |                           |                      |         |
|       |                           | Transit Express      |         |
|       |                           | Manager              |         |
+-------+---------------------------+----------------------+---------+
| 8:00  | Observe reservations      | All Assessment Team  | Transit |
| am    | process                   | Members              | Express |
+-------+---------------------------+----------------------+---------+
| 10:00 | Review ACD call reports   | Patti Monahan        | Transit |
| am    |                           |                      | Express |
|       | Review manpower and fleet | Russell Thatcher,    |         |
|       | information               | Terry Regan          |         |
|       |                           |                      |         |
|       | Review operator training  | Transit Express      |         |
|       | curriculum                | Manager              |         |
+-------+---------------------------+----------------------+---------+
| 12-1  | Interview drivers         | All Assessment Team  | Transit |
| pm    |                           | Members              | Express |
+-------+---------------------------+----------------------+---------+
| 1-3   | Review scheduling         | Russell Thatcher     | Transit |
| pm    |                           |                      | Express |
|       | Review On-Time            | Transit Express Lead |         |
|       | Information               | Scheduler            |         |
|       |                           |                      |         |
|       |                           | Patti Monahan, Terry |         |
|       |                           | Regan                |         |
+-------+---------------------------+----------------------+---------+
| 3-5   | Observe dispatch          | All Assessment Team  | Transit |
| pm    |                           | Members              | Express |
+-------+---------------------------+----------------------+---------+

+-------+---------------------------+----------------------+---------+
| *     |                           |                      |         |
| *Thur |                           |                      |         |
| sday, |                           |                      |         |
| July  |                           |                      |         |
| 12,   |                           |                      |         |
| 2     |                           |                      |         |
| 001** |                           |                      |         |
+-------+---------------------------+----------------------+---------+
| 7:30  | Tour of Laidlaw operation | All Assessment Team  | Laidlaw |
| am    |                           | Members              |         |
|       |                           |                      |         |
|       |                           | Laidlaw Manager      |         |
+-------+---------------------------+----------------------+---------+
| 8:00  | Observe reservations      | All Assessment Team  | Laidlaw |
| am    | process                   | Members              |         |
+-------+---------------------------+----------------------+---------+
| 10:00 | Review ACD call reports   | Patti Monahan        | Laidlaw |
| am    |                           |                      |         |
|       | Review manpower and fleet | Russell Thatcher,    |         |
|       | information               | Terry Regan          |         |
|       |                           |                      |         |
|       | Review operator training  | Laidlaw Manager      |         |
|       | curriculum                |                      |         |
+-------+---------------------------+----------------------+---------+
| 12-1  | Interview drivers         | All Assessment Team  | Laidlaw |
| pm    |                           | Members              |         |
+-------+---------------------------+----------------------+---------+
| 1-3   | Review scheduling         | Russell Thatcher     | Laidlaw |
| pm    |                           |                      |         |
|       | Review On-Time            | Laidlaw Lead         |         |
|       | Information               | Scheduler            |         |
|       |                           |                      |         |
|       |                           | Patti Monahan, Terry |         |
|       |                           | Regan                |         |
+-------+---------------------------+----------------------+---------+
| 3-5   | Observe dispatch          | All Assessment Team  | Laidlaw |
| pm    |                           | Members              |         |
+-------+---------------------------+----------------------+---------+
| **Fr  |                           |                      |         |
| iday, |                           |                      |         |
| July  |                           |                      |         |
| 13,   |                           |                      |         |
| 2     |                           |                      |         |
| 001** |                           |                      |         |
+-------+---------------------------+----------------------+---------+
| 8:00  | Tabulate and analyze data | All Assessment Team  | MCTS    |
| am    |                           | Members              |         |
+-------+---------------------------+----------------------+---------+
| 1:15  | Exit Conference           | All & FTA            | MCTS    |
| pm    |                           |                      |         |
+-------+---------------------------+----------------------+---------+

**Attachment C**

**MCTS's Transit Plus**

**RIDER'S GUIDE**

**Attachment D**

**Summary of Transit Plus Complaints on File at MCTS, January-June,
2001**

  ---------------------- ------------- ----------- ----------- -------------- ----------- -----------
  **Transit Plus:                                                                         
  Complaints received                                                                     
  for the period:                                                                         
  January 1 - June 30,                                                                    
  2001**                                                                                  

  ***Ranked by total                                                                      
  number of complaints                                                                    
  by category***                                                                          

                                                                                          

                         **Laidlaw**   **Transit   **Total**   **Percent of   **Laidlaw   **TE
                                       Express**               Complaints**   Percent**   Percent**

  On Time                69            39          108         20.9%          64%         36%

  Reservation            42            28          70          13.6%          60%         40%

  Failed Trip            56            8           64          12.4%          88%         13%

  Safety                 29            23          52          10.1%          56%         44%

  Incident/Injury        22            15          37          7.2%           59%         41%

  Denial                 19            7           26          5.0%           73%         27%

  Discourteousness       9             11          20          3.9%           45%         55%

  Drop off time          13            7           20          3.9%           65%         35%

  Pick up drop off error 11            7           18          3.5%           61%         39%

  Commendation           9             7           16          3.1%           56%         44%

  Other                  5             9           14          2.7%           36%         64%

  Fare Dispute           5             5           10          1.9%           50%         50%

  Ride Duration          5             5           10          1.9%           50%         50%

  Door to Door           6             3           9           1.7%           67%         33%

  Accessibility          5             3           8           1.6%           63%         38%

  Pickup Time complaint  7             1           8           1.6%           88%         13%
  (in window)                                                                             

  Policy/Procedure       5             2           7           1.4%           71%         29%

  Subscription           5             2           7           1.4%           71%         29%

  Address Problem        2             3           5           1.0%           40%         60%

  Equipment Problem      0             2           2           0.4%           0%          100%

  Mobility Aid Damage    0             2           2           0.4%           0%          100%

  Vehicle Cleanliness    0             2           2           0.4%           0%          100%

  Routing                0             1           1           0.2%           0%          100%

                                                               0.0%                       

  Total w/commendations  324           192         516                                    

  Total less             315           185         500         100.0%         63%         37%
  commendations                                                                           

                                                                                          

  *The number and                                                                         
  categorization of                                                                       
  complaints are derived                                                                  
  from Transit Plus                                                                       
  monthly complaint                                                                       
  summary*                                                                                

  *sheets. It does not                                                                    
  necessarily reflect                                                                     
  all complaints                                                                          
  received because some                                                                   
  complaints are handled                                                                  
  directly*                                                                               

  *by the service                                                                         
  providers, and may not                                                                  
  be included within                                                                      
  these summaries.*                                                                       

                                                                                          

  *Total complaints*     500                                                              

  *Total rides provided* 276754                                                           

  *Complaints per ride*  0.001807                                                         

  *Approximately 2                                                                        
  written complaints per                                                                  
  1,000 trips provided.*                                                                  

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

**Attachment E**

**Laidlaw Call Distributor Reports for May 2001**

**Attachment F**

**St. Ann Center Trip Request Faxes**

**Attachment G**

**Summary of Travel Times for Trips to the**

**Eisenhower Center, May 16, 2001**

**Travel Times for Laidlaw Transit Plus Trips to and from Eisenhower
Center,**

**May 16, 2001**

  ------------- ------------- ----------- ---------------------------------
  Run Number    Trip Time     Travel Time Comments
                              (minutes)   

  510           0700-0800     60          

                0730-0810     40          

                0745-0810     25          

                0800-0810     10          

  509           0708-0733     25          

                0708-0733     25          

                0708-0733     25          

  511           0650-0800     70          From Wauwatosa

                0700-0800     60          

                0715-0800     45          

  512           0740-0816     36          

                0752-0816     24          

                0802-0816     14          

  613           1436-1550     74          To 3475 N. Summit Ave.

                1436-1509     33          

                1436-1536     60          

                1436-1555     79          To 3262 N. Palmer St.

  612           1445-1507     22          

                1445-1535     50          

                1445-1507     22          

                1445-1525     40          

  611           1400-1420     20          

                1400-1420     20          

                1445-1525     40          

                1445-1505     20          

  610           1400-1420     20          

                1400-1420     20          

                1445-1500     15          

                1445-1515     30          

                1445-1530     45          

                1445-1545     60          

  609           1442-1514     32          

                1442-1532     50          

  505           0720-0820     60          

                0729-0820     51          

                0745-0820     35          

                0739-0820     41          

                0757-0820     23          

                0807-0820     13          

                0807-0820     13          

  681           1300-1321     21          

                1450-1513     23          

                1450-1520     30          

                1450-1534     44          

                1450-1537     47          

  682           1445-1530     45          

                1445-1523     38          

                1445-1523     38          

                1445-1515     30          

                1445-1540     55          

                1445-1540     55          

  551           1617-1730     73          To 7733 W. Fiebrantz

  581           0700-0832     92          From 8535 W. North Ave, Wauwatosa

                0700-0832     92          From 8535 W. North Ave, Wauwatosa

                0704-0832     88          From 2972 N. 89^th^ St.

                0734-0832     88          From 2972 N. 89^th^ St.

                0730-0832     62          

                0745-0832     47          

  605           1435-1444     9           

                1435-1444     9           

                1435-1453     18          

                1435-1531     56          

                1435-1514     39          

                1435-1506     31          

  582           0725-0820     55          

                0725-0820     55          

                0754-0820     26          

                0758-0820     22          

                0815-0820     5           
  ------------- ------------- ----------- ---------------------------------

**Travel Times for Transit Express Transit Plus Trips to and from
Eisenhower Center,**

**May 16, 2001**

  ----------------- ----------------- ----------------- -----------------
  Run Number        Trip Time         Travel Time       Comments

  107               0725-0804         39                

                    0725-0804         39                

                    0725-0804         39                

                    0704-0804         60                

                    0657-0804         67                

  134               0754-0815         21                

                    0720-0815         55                

                    0712-0815         63                

                    0734-0815         41                

                    0700-0815         75                

  113               0720-0830         70                

                    0700-0800         60                From Franklin

                    1440-1535         55                To Cudahy

                    1440-1531         51                To Cudahy

                    1440-1524         44                

                    1440-1547         67                

                    1440-1515         40                

  119               0805-0851         46                

                    0805-0851         46                

                    0805-0851         46                

  140               1458-1548         50                

                    1458-1543         45                

                    1458-1548         50                

                    1458-1523         25                

  125               0734-0807         33                

                    0707-0807         60                

                    0707-0807         60                

                    0707-0807         60                

                    0707-0807         60                

  114               0748-0821         33                

                    0726-0821         55                

                    0707-0821         74                From S. Milwaukee

                    1508-1610         62                

                    1508-1610         62                

                    1508-1610         62                

                    1508-1604         56                
  ----------------- ----------------- ----------------- -----------------