**Maryland Mass Transit Administration (MTA)**

**Baltimore, Maryland**

**Assessment of Lift Reliability and Maintenance**

**April 30-May 3, 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**

**April 17, 2002**

**CONTENTS**

[**I.** **Purpose of the Assessment** 1](#purpose-of-the-assessment)

[**II.** **Background** 3](#background)

[**III.** **Overview of the Assessment** 4](#overview-of-the-assessment)

[**IV.** **Observations of Lift Reliability & Maintenance**
6](#observations-of-lift-reliability-maintenance)

[A. Rider Experiences and Observations
6](#a.-rider-experiences-and-observations)

[B. Policies and Procedures Regarding Lift Reliability and Maintenance
12](#b.-policies-and-procedures-regarding-lift-reliability-and-maintenance)

[C. Assessment Team Observations 15](#c.-assessment-team-observations)

[D. Findings and Recommendations 24](#d.-findings-and-recommendations)

[1. Findings 24](#findings)

[2. Recommendations 25](#recommendations)

Attachment A Bus and Line Assignment by Division -- March 2001

Attachment B MTA Notification Letter & On-site Assessment Schedule

Attachment C MTA Response

Attachment D Sample Maintenance Forms and Reports

Attachment E Excerpts from MTA's *Transit Operations Student Handbook
and MTA Rule Book* and Related Materials

Attachment F Assessment Review Forms

# Purpose of the Assessment

The U.S. Department of Transportation (USDOT) regulations implementing
the Americans with Disabilities Act of 1990 (ADA) contain two primary
provisions to ensure that vehicles with accessibility features are
reliable and properly maintained. General equipment maintenance
requirements, which pertain to all types of entities and services, are
contained in 49 CFR §37.161:

\(a\) Public and private entities providing transportation services
shall maintain in operative condition those features of facilities and
vehicles that are required to make the vehicles and facilities readily
accessible to and usable by individuals with disabilities. These
features include, but are not limited to, lifts and other means of
access to vehicles, securement devices, elevators, signage and systems
to facilitate communications with persons with impaired vision or
hearing.

*(b) Accessibility features shall be repaired promptly if they are
damaged or out of order. When an accessibility feature is out of order,
the entity shall take reasonable steps to accommodate individuals with
disabilities who would otherwise use the feature.*

> *(c) This section does not prohibit isolated or temporary
> interruptions in service or access due to maintenance or repairs.*

In addition to the general maintenance provisions described above that
apply to all transportation providers, 49 CFR §37.163 requires public
entities to keep vehicle lifts in operative condition as follows:

> *(a) This section applies only to public entities with respect to
> lifts in non-rail vehicles.*
>
> *(b) The entity shall establish a system of regular and frequent
> maintenance checks of lifts sufficient to determine if they are
> operative.*
>
> *(c) The entity shall ensure that vehicle operators report to the
> entity, by the most immediate means available, any failure of a lift
> to operate in service.*

*(d) Except as provided in paragraph (e) of this section, when a lift is
discovered to be inoperative, the entity shall take the vehicle out of
service before the beginning of the vehicle\'s next service day and
ensure that the lift is repaired before the vehicle returns to service.*

> *(e) If there is no spare vehicle available to take the place of a
> vehicle with an inoperable lift, such that taking the vehicle out of
> service will reduce the transportation service the entity is able to
> provide, the public entity may keep the vehicle in service with an
> inoperable lift for no more than five days (if the entity serves an
> area of 50,000 or less population) or three days (if the entity serves
> an area of over 50,000 population) from the day on which the lift is
> discovered to be inoperative.*
>
> *(f) In any case in which a vehicle is operating on a fixed route with
> an inoperative lift, and the headway to the next accessible vehicle on
> the route exceeds 30 minutes, the entity shall promptly provide
> alternative transportation to individuals with disabilities who are
> unable to use the vehicle because its lift does not work.*

The Federal Transit Administration (FTA) is responsible for ensuring
compliance with the ADA and the USDOT regulations (49 CFR Parts 27, 37,
and 38) that implement this civil rights law. As part of its compliance
efforts, FTA, through its Office of Civil Rights, conducts periodic
assessments of fixed route transit services operated by grantees.

This report includes the results of the Assessment of Lift Reliability
and Maintenance at the Maryland Mass Transit Administration (MTA), based
in Baltimore, Maryland, which was conducted from April 30-May 3, 2001.
This report summarizes the observations and findings of the on-site
assessment of MTA's fixed route bus service. A description of key
features of the fixed route bus service is first provided. A description
of the approach and methodology used to carry out the assessment is then
provided. Observations and findings related to the ADA requirements are
summarized then described. The major findings of the assessment are
summarized at the end of this report. Recommendations of the review team
for addressing issues identified also are provided.

# Background

The Maryland Mass Transit Administration (MTA) is an agency of the
Maryland Department of Transportation. MTA provides local bus, commuter
bus, subway, light rail, rail freight, commuter trains, and ADA
Complementary Paratransit services, either by direct operation or
through service contractors. MTA provides bus service to Baltimore City,
Baltimore County, and portions of three contiguous counties. MTA's MARC
commuter rail system operates on two routes to Baltimore, one to
Washington, DC via Camden Yards and one between Washington DC and
Perryville via Penn Station in Baltimore. MTA also operates a fleet of
53 articulated light rail vehicles on two light rail routes, one from
Hunt Valley to Cromwell Station and the other from Penn Station to BWI
Airport. The 30 miles of LRT route share a common line through much of
the City of Baltimore. MTA also serves the city center with a 15.5-mile
Metro rapid rail line, serving 14 stations with 119 rapid rail cars.

MTA operates 56 fixed bus routes and contracts with private providers to
operate 17 commuter bus routes, serving Baltimore and Washington, DC
(see Attachment A). MTA's revenue bus fleet consists of 827 buses, of
which 597, or 72%, are accessible. The fleet includes 60 new 2000
lift-equipped buses that had not been accepted for delivery at the time
of the assessment, but were scheduled for delivery in the spring of
2001. Most of the bus fleet and all rail vehicles are equipped with
public address (PA) systems to assist operators in making stop
announcements. The 80 new buses ordered in FY 2000 are equipped with
automated stop announcement systems. The new equipment, manufactured by
Clever Devices, provides automatic interior stop and exterior route
identification announcements along with text displays of stops inside
the bus. A detailed description of how fixed route bus service is
assigned to MTA's four operating divisions -- Bush, Eastern, Kirk, and
Northwest -- will be presented later in this report.

For this review, the assessment team evaluated fixed route bus lift
maintenance and reliability for service directly operated by MTA. The
review did not include an assessment of fixed route bus lift maintenance
and reliability for the private contractors.

# Overview of the Assessment

In a letter (Attachment B) dated March 21, 2001, the FTA Office of Civil
Rights notified Maryland MTA that this compliance assessment would be
conducted in late April/early May. This assessment focused on compliance
with wheelchair lift reliability and maintenance requirements of the DOT
ADA regulations, as outlined in the first section of this report. The
assessment first involved the collection and review of key service
information from MTA prior to the on-site visit. This information
included:

-   A current fixed route system map;

-   A complete set of schedules for each fixed route;

-   Fixed route bus fleet and division/garage information;

-   The *Transit Operations -- Student Handbook and MTA Rulebook*, which
    includes the "Wheelchair Lift Operator's Handbook";

-   Notices, bulletins, and memoranda detailing lift use policies and
    procedures; and

-   Recent service complaints regarding lift reliability and
    maintenance.

    Prior to the site visit, the assessment team contacted several local
    human service agency representatives and persons with disabilities
    who regularly use MTA's fixed route bus service to discuss their
    experiences with the transit system. The assessment team also
    reviewed two complaints concerning lift reliability and maintenance
    that had been filed with the FTA Office of Civil Rights.

    Planners Collaborative, Inc. of Boston, Massachusetts, and
    Multisystems, Inc. of Cambridge, Massachusetts, conducted the
    assessment. Rosemary Mathias of Multisystems served as the
    assessment team leader. Brian Barber, Terry Regan, and Donald
    Kidston of Planners Collaborative assisted with the review. A
    schedule for the assessment can be found in Attachment B.

On Monday, April 30, four consumers who use wheelchairs agreed to ride
the fixed route system with assessment team members. The Maryland
Disabilities Law Center (MDLC) and the Maryland Center for Independent
Living (CIL) recommended these individuals. MTA was not aware that the
assessment team would be riding the system that day with consumers. The
results of this activity are described in the next section.

On Tuesday and Wednesday, May 1 & 2, the assessment team observed
morning bus pullout and conducted the lift reliability and maintenance
reviews at each of the four MTA divisions: Bush, Eastern, Kirk, and
Northwest. During the reviews, managers, mechanics, and drivers were
asked about operating practices and procedures related to lift
reliability and maintenance. Training materials also were reviewed and
the assessment team met with staff from Central Radio Communications and
reviewed dispatch logs pertaining to boarding of wheelchair passengers
and lift-related failures.

An exit conference was conducted on Thursday, May 3. In addition to Ms.
Mathias, Mr. Barber, and Mr. Regan, the following MTA representatives
attended the meeting:

-   James Fitzgerald, Chief - Eastern Division

-   Mike Hannan, Chief - Northwest Division

-   Shirley Nicholson, Chief - Bush Division

-   Bill Sellers, Assistant Manager of Bus Operations

-   Ruth Silverstone, Director of Interagency Programs/ADA Coordinator

-   Aaron Smith Sr., Manager of Bus Operations

Cheryl Hershey, ADA Group Leader from the FTA Office of Civil Rights
participated via conference call.

A draft copy of this report was provided to MTA on July 27, 2001 for
review and comment. FTA also requested that MTA provide a list of
corrective actions at that time. A copy of MTA's response to the draft
report appears in Attachment C.

# Observations of Lift Reliability & Maintenance 

To determine Maryland MTA's current performance with respect to lift
reliability and maintenance, the assessment team performed the following
activities:

-   Conducted telephone interviews with agencies and individuals who are
    regular riders or who have clients who are regular riders of the MTA
    bus system;

-   Reviewed MTA's policies and procedures for assigning buses and
    cycling lifts;

-   Reviewed the operator training materials and disciplinary practices;

-   Rode the bus system with consumers who use wheelchairs;

-   Observed drivers perform lift cycling during morning pullout;

-   Interviewed bus drivers, mechanics, and managers to gauge their
    understanding of lift use policies and procedures; and

-   Reviewed maintenance records and dispatch logs.

## A. Rider Experiences and Observations {#a.-rider-experiences-and-observations .unnumbered}

**FTA Complaints**

Prior to the site visit, the assessment team reviewed complaints filed
with the FTA Office of Civil Rights. FTA provided the assessment team
with copies of two open complaints that were still under investigation
at the time of this assessment. Both complaints relate to lift
reliability.

The first complaint was filed with the FTA Office of Civil Rights in
1998, and alleges that lifts are not working on two routes; are not
working 50% to 75% of the time overall; and that drivers are being
improperly trained or not trained at all with respect to lift operation.
The customer reported these situations as ongoing problems.

The second complaint related to three incidents that occurred during
April 2000 (and also filed with the MTA's ADA Coordinator and is
reported in Table IV.A.1):

-   The first incident reportedly occurred when the customer attempted
    to board a bus and the driver said the lift did not work, but did
    not attempt to deploy the lift.

-   A second incident reportedly occurred the next day when the customer
    attempted to board a different bus with the same driver and was told
    the bus was too crowded, although the customer said that the back of
    the bus was empty.

-   A third incident reportedly occurred a week later when the customer
    said the driver was making negative comments about her and she had
    trouble boarding the bus. The incident escalated to the point where
    MTA police were called.

The Maryland Disabilities Law Center (MDLC) filed the complaints with
the FTA on behalf of the individual reporting these problems. MTA
responded to the FTA complaint in writing and stated that the driver
described in the first two bullets above had been cautioned and
re-instructed to follow proper procedures. The operator was given a
"final warning" and was told that future complaints of this nature
"would result in strong disciplinary action." The driver identified in
the third incident reported above has retired.

**Customer/Agency Contacts**

The assessment team interviewed seven human service agency
representatives and individuals who regularly use the MTA fixed route
service or whose clients use the service. Several of the consumers have
filed complaints with MTA. The common complaint was that drivers do not
appear to notify dispatchers of lift failures as required by MTA
policies and procedures, nor do they always advise passengers about when
the next accessible bus will be by to pick them up. According to one
regular passenger, about 25% of the time there is a lift-related
problem. Although service has improved slightly in the past six months,
she said it is "not enough to start dancing in the streets." Sometimes
the passenger said the driver seems to have a problem aligning the lift
(mounted at the front door of the buses) with the curb and can damage
the lift if it is not deployed properly. This is a particularly problem
when parked cars block the stop and make it hard for the drivers to stop
next to the curb.

The MDLC conducted a review of MTA maintenance logs to try to determine
whether drivers were calling in malfunctioning lifts, as required by MTA
policies and procedures. The results of MDLC's review are contained in a
report provided by Allison Scharf, Staff Attorney. The report \"Are Bus
Operators Calling in Malfunctioning Lifts as Required by the ADA?\"
prepared by MDLC, 7/13/00, covered the period from February through May
2000. During that period MDLC had received 13 reports of lifts failures
that included sufficient information for the incident to be tracked in
MTA's maintenance records (i.e., date and coach number were provided
with the complaint). Of the 13, only two or three (13%-23% of the
reported lift failures) were identified in the MTA maintenance logs and
only one of those buses appeared to have been repaired within a week.
Further, during the period from January through June 2000, MDLC counted
366 repairs that were made and appeared to be unrelated to road calls.
In part, MDLC concluded:

(E)ither the lifts are failing due to operator error (meaning the lifts
are not in need of repair), operators are claiming lifts are broken when
they are not, and/or that not all of the buses are undergoing pre-trip
inspections, preventing discovery of the defect until the driver has to
deploy the lift on the road some time in the future.

MDLC also concluded:

> *When lifts fail and drivers do not call the malfunction in, no one at
> MTA knows that a passenger is waiting. Consequently, people may end up
> stranded or they may have to wait for long periods of time before
> another lift-equipped bus arrives.*

######## MTA Complaints {#mta-complaints .unnumbered}

Prior to the site visit, MTA provided summaries of lift-related
complaints logged since March 2000. Most complaints are directed to the
MTA ADA Coordinator or the MTA Complaint/Info Coordinator. Table IV.A.1
shows a list of 12 complaints that were received by the Complaint/Info
Coordinator. Table IV.A.2 shows a list of 10 complaints relating to 30
incidents that were received by the ADA Coordinator. There was no
overlap noted between the two sets of complaints, although some of the
individuals have complained through both points of contact, but relating
to different incidents.

**Table IV.A.1 - Complaints Reported by Complaint/Info Coordinator**

  ---------------- ------------------------- ----------------------------------
  **Date**         **Reported Complaint**    **Action Taken**

  3/14/00          Lift not working          Coach was sent to shop for repairs

  3/27/00          Defective lift            Coach was sent to shop for repairs

  4/11/00          Defective lift            Coach sent to shop for repairs

  4/15/00          Broken lift               Operator reported lift; bus sent
                                             for repairs

  8/12/00          Broken lift               Coach was sent to shop for repairs

  9/13/00          Broken lift               Operator reported lift; bus sent
                                             to shop

  1/4/01           Defective lift            Radio Room informed; bus sent to
                                             shop

  1/19/01          Defective lift            Operator reported lift; bus sent
                                             to shop

  2/1/01           Defective lift            Bus sent to shop for lift repair

  2/6/01           Lift inoperable           Defective lift reported to shop

  2/15/01          Lift defective            Patron advised another lift bus
                                             was on the way; defective lift bus
                                             sent to shop

  2/15/01          Defective lift            Radio Room informed; bus sent to
                                             shop

  Source: MTA                                
  Complaint/Info                             
  Coordinator                                
  ---------------- ------------------------- ----------------------------------

Generally, it appears the complaints logged by the MTA Complaint/Info
Coordinator related to real-time incidents that generated telephone
calls. The complaints directed to the ADA Coordinator were written
complaints. In most cases, it appears the complaints resulted in
instruction for drivers or maintenance work. However, some complaints do
not appear to be fully addressed in the MTA response. For example, a
complaint dated 3/4/00 in Table IV.A.2 indicates that the "bus driver
passed customer." The MTA action was stated as "Bus was filled to
capacity." The response does not appear to answer the question of why
the driver passed by the customer who likely could not see the bus was
full and may not have known when to expect the next accessible bus.

**Metro Wheels**

Additionally, MTA recently began a monitoring program called, "Metro
Wheels," developed by Transit Access, a consulting firm that created
this on-line, consumer-based service-monitoring program through a grant
from Easter Seals Project ACTION. Volunteers with disabilities agree to
ride the system and evaluate service provided for each of their trips,
submitted via the Internet. Transit Access tabulates the results and
reports back to MTA. MTA includes four evaluations for its fixed route
service:

-   MTA Bus - Wheelchair Pick-Up Report

-   MTA Bus - Wheelchair Pass-Up Report

-   MTA Bus - Visually Impaired Riders Report

-   MTA Bus - Ambulatory Riders Report

This program started in March 2001 and results were not available at the
time of the review. MTA is hoping to use the early data as a benchmark
against which to measure future performance. MTA also evaluates its ADA
Complementary Paratransit service using two other Metro Wheels modules.

> **Table IV.A.2 - Complaints Reported by ADA Coordinator**

  -----------------------------------------------------------------------
  **Date**   **Reported Complaint**    **Action Taken**
  ---------- ------------------------- ----------------------------------
  10/24/00   Broken lift not called in Operator instructed in correct
                                       lift deployment

  10/25/00   Broken lift not called in Operator instructed in correct
                                       lift deployment

  12/15/00   Driver unable to get near Requested Planning & Scheduling
             curb in order to employ   Department to look at stops
             lift due to parked cars   

  12/19/00   Told by operator to wait  Maintenance Department adjusted
             for next lift bus because slack chain and micro switch
             of overcrowded            
             conditions; next bus had  
             broken lift               

  12/21/00   Broken lift bus           Chain guard was striking sensitive
                                       edge/needed repairs were made

  12/30/00   Due to a broken lift bus  Explained that it takes a while
             another was dispatched    for a bus to be dispatched from a
             but took a long time      division/apologized for the delay

  1/4/01     Due to lift malfunction,  Repair person was dispatched and
             customer stuck on bus     repaired the bus/customer
                                       commended repair person

  1/29/01    Lift not working          No resolution due to
                                       misinformation from customer

  1/30/01    Lift not working          No resolution due to
                                       misinformation from customer

  2/6/01     Why did coach not arrive  It arrived but was extremely late
                                       due to heavy traffic, line will be
                                       monitored

  2/8/01     Coach had broken lift     Records show there were no
                                       reported problems with that coach

  2/11/01    Lift not working          No resolution due to
                                       misinformation from customer

  2/12/01    Were buses that passed    Records do not justify a complaint
             her scheduled as lift?    of a non-lift equipped bus during
                                       that period

  2/16/01    Coach did not have lift   Our records indicated that the
                                       coach did have a lift

  2/23/01    Did the driver call in    The operator did call in and the
             defective lift            coach was replaced

  10/17/00   Lift not                  The division manager took
             operable/operator did not appropriate action for this
             call in                   occurrence

  1/12/01    Bus did not stop to pick  Not resolved due to misinformation
             up customer               from customer
  -----------------------------------------------------------------------

  ------------- ------------------------- ----------------------------------
  4/18/00       Driver told customer lift Driver was interviewed by his
                did not work              division manager and cautioned and
                                          instructed on lift procedures

  4/19/00       Same driver as above told Same as above
                customer bus was too      
                crowded to let her on     

  4/26/00       Driver insensitive to     Driver has retired
                persons with disabilities 

  12/5/00       Lift not                  Operator was cautioned and
                operable/operator did not instructed about the proper
                call in problem in front  procedures when operating a
                of customer               lift-equipped bus

  3/4/00        Bus driver passed         Bus was filled to capacity
                customer                  

  3/24/00       Customer boarded with     Customers need only to let the
                crutches/driver did not   operator know if they need to sit
                ask passengers in         in the priority seating. All or
                priority seating to move  our operators received specialized
                                          sensitivity training that included
                                          training about specialized seating

  4/14/00       Customer used             MTA reissued bulletins reminding
                crutches/driver did not   operators to ask passengers to
                wait until customer was   vacate seats reserved for
                seated when he drove away customers with disabilities
                from the stop             

  4/23/00       Same complaint as 4/14/00 Same as above

  N/A           Difficult for customer to MTA staff continues to work with
                use buses when it snows   local governments and business
                because curb cuts and bus owners to rectify this serious
                stops are covered with    customer service problem
                snow                      

  12/00         Driver did not wait until Operator was instructed on the
                customer was seated when  importance of waiting for
                he pulled away            customers to be seated before
                                          pulling away

  1/01          Driver did not call in    Operators were interviewed and
                wheelchair passenger      noted on personnel files
                pickup                    

  2/7/01        Malfunctioning lift       Operator was interviewed

  2/15/01       Operator did not wait     Operator was interviewed and
                until customer with       instructed
                crutches was safely       
                seated                    

  Source: MTA                             
  ADA                                     
  Coordinator                             
  ------------- ------------------------- ----------------------------------

## B. Policies and Procedures Regarding Lift Reliability and Maintenance {#b.-policies-and-procedures-regarding-lift-reliability-and-maintenance .unnumbered}

**Fleet and Route Assignments**

Each bus is assigned to operate out of one of four districts: Bush,
Eastern, Kirk or Northwest. Table IV.B summarizes the fleet distribution
by garage. Currently, 72% of the fleet is accessible (including the 80
buses on order and in the process of being delivered from the last bus
purchase). It can be seen from the detailed fleet distribution list
included in Attachment C, that the average age of the fleet is 7.92
years. All buses purchased since 1990 are accessible and 46% of the
buses purchased between 1985 and 1989 that are still in service are
accessible. MTA projects that the entire fleet will be accessible by
2005.

> Table IV.B - Summary of Fleet Distribution by Garage

  ------------------------ -------------- ----------------- ----------------
  **Division/Garage**      **Total \#     **\# Buses        **% Buses Lift-
                           Buses\***      Lift-Equipped**   Equipped**

  Bush                     238            170               74%

  Eastern                  169            134               79%

  Kirk                     216            136               63%

  Northwest                204            167               82%

  **TOTAL**                **827**        **597**           **72%**

  \* Figures include 80                                     
  new FY 2000 buses (20                                     
  assigned to each                                          
  facility); however, only                                  
  the 20 assigned to                                        
  Eastern had been                                          
  accepted for delivery in                                  
  early May 2000. MTA                                       
  expected the remaining                                    
  60 to be delivered this                                   
  spring.                                                   
  ------------------------ -------------- ----------------- ----------------

Attachment A also includes a list of route assignments by division. Some
routes operate out of two divisions, others out of one division,
depending on the run/block assignment pattern.

MTA provides two types of accessible fixed route services: (1)
lift-equipped service designated on most bus routes at stated times of
the day and (2) Call-A-Lift service for trips on timetables that are not
designated as being lift equipped. Call-A-Lift service may be requested
by e-mail or phone by 4 p.m. the day before the planned trip. According
to MTA staff, Call-A-Lift is rarely used now as those requests have been
used to help determine accessible route assignments for designated lift
service.

Most of MTA's weekday routes are accessible to some degree. MTA does not
maintain a list of accessible routes for easy customer reference. The
MTA System Map does not indicate which routes are accessible. Patrons
must have printed schedules, or contact MTA, to find out about
accessible service if they do not have a printed schedule. Schedules are
available on-line; however, the index does not indicate which routes are
accessible, and it is time-consuming to check each schedule. The
individual schedules must be viewed to ascertain whether and when
lift-equipped service is available. Printed schedules with an
International Symbol of Accessibility (ISA) on the front include
lift-equipped runs. A "W" in the left column of most schedules indicates
an accessible bus on a particular run. All buses operated on Saturday
and Sunday are accessible.

Drivers are instructed to call Radio Dispatch every time a customer
using the lift, boards the bus. All lift failures also are to be
reported to Radio Dispatch, which will then notify the appropriate
division if a road call is warranted. Dispatch staff indicated that it
can get very busy during peak hours and sometimes drivers cannot get
through to report boarding of people who use wheelchairs and they call
back later. A Radio Dispatch log sheet -- "Unscheduled Wheelchair Pick
Ups" -- is used to record boarding of lift-users. A "Wheelchair Defect
Log" is used to record failures, although there are very few entries on
these logs, suggesting that calls may be going directly to the divisions
without being logged. During the exit conference, it also was noted that
drivers might record wheelchair pick-ups using Mobile Data Terminals
(MDTs); however, this was not mentioned during the interviews with Radio
Dispatch personnel. They only mentioned the Unscheduled Wheelchair Pick
Ups log. Further, MTA uses the log to generate reported boarding of
people who use wheelchairs (without counting any MDT transmissions).
Additionally, when calling in pick-ups, drivers do not differentiate
between regular lift service and Call-A-Lift so the form actually should
be capturing boarding of all lift-users, whether regularly scheduled or
requested through Call-A-Lift.

**Lift Cycling and Pre-trip Inspections**

The Rulebook and supporting bulletins require that lifts be cycled at
pullout and at certain terminus points throughout the day. Each garage
has a designated lift cycling location, typically after the pre-trip
inspection is complete, where drivers are instructed to cycle their
lifts. Periodically, managers or starters report that they observe lift
cycling, sometimes unbeknownst to the drivers. At one garage, there is a
security camera that is used to monitor lift cycling and can be used to
determine whether drivers are truthful about whether a lift was cycling.
At another division, the Chief said he often monitors lift cycling.

Drivers are required to perform pre-trip inspections of buses using the
"Mass Transit Administration Vehicle Report" card, included in
Attachment D. Drivers use the cards to identify any defective items
found during the pre-trip inspection or at any time along the route. The
checklist includes wheelchair lifts, however, the list does not include
wheelchair securements or the public address system. The cards are kept
on the bus and updated by each driver throughout the day. Safety issues
-- including lift failures -- are reported to the starter or maintenance
prior to pullout. Depending on the nature of the defect, the bus may be
sent into service or, if there is a serious safety issue (e.g.,
missing/broken mirrors), it may be pulled off the route and sent to the
shop.

Buses that have non-working lifts that require more than a day to repair
are recorded on "Tripper Sheets," which are used by starters to assign
buses to non-lift routes (e.g., school routes or short routes that are
not designated as being lift-equipped). The maintenance departments
generate the Tripper Sheets to keep track of buses needing repair.
According to MTA maintenance staff and starters who were interviewed, if
a lift fails during the pre-trip inspection and it is not assigned to a
lift-equipped block of runs, then it will likely be used in service. If
the bus is assigned to a block that is designated as being
lift-equipped, it will be replaced if another accessible bus is
available. If there are no spares available, then the bus will be used
in service and brought back into the shop as soon as possible that day
for maintenance. MTA reports that it makes every effort to use a bus
with a functioning lift on a particular run, if it is expected that
there will be passengers who need the lift.

**Routine Maintenance**

Generally, each garage is responsible for maintaining its own fleet.
Several types of maintenance are performed including preventive, routine
repair work, and in-service. A centralized record-keeping system is
used. Repair and maintenance information is captured in real-time in a
centralized computer database. Lifts are supposed to be inspected and
preventive maintenance is to be performed regularly -- every 60 days for
buses that are pre-1990 and every 6,000 miles for newer buses, according
to the Operations Department (there was some variation in this
interpretation among garages). A copy of the "Wheelchair Lift
Inspection" form is included in Attachment D. Routine lift inspections
include 24 items. The maintenance departments also report that lifts are
cycled by mechanics during maintenance repairs.

In-service repairs occur when a bus breaks down while in revenue
service. If, for example, a wheelchair lift malfunctions, the driver
contacts Radio Dispatch and a maintenance truck is sent to assist the
driver, if needed. Some repairs are simple and can be corrected quickly
while the bus is in service (e.g., dirt that is jamming the mechanism).
Others are more complicated and require the bus to be removed from
service (e.g., a lift that is stuck in a partially deployed position).
Road calls are supposed to be logged by Radio dispatch and the
appropriate operating division (garage) is notified of in-service
failures.

**Training**

The assessment team spoke with a transportation supervisor and one
senior bus trainer at the Kirk Garage about their responsibilities,
focusing on training and retraining. According to the senior bus
trainer, ADA material is included throughout the six**-**week training
period. Two to three days of the period are devoted to ADA matters.
There is a wheelchair in the training area to help sensitize drivers to
the needs of passengers who use wheelchairs. They try to teach respect
for the riders with disabilities in addition to the special actions
needed to serve their requirements.

Bus drivers are trained in proper lift and securement operation as part
of their regular driver-training program. Excerpts from MTA's *Transit
Operations Student Handbook and MTA Rule Book* are found in Attachment
E. The "Wheelchair Lift Operator's Handbook" section of the document
includes specific directions on when to cycle lifts (during pullout) and
what to do if the lift fails (contact Radio Dispatch). Drivers also are
instructed to call Radio Dispatch to advise them of every lift boarding.
The handbook includes information about the size of a common wheelchair
that may be accommodated (30 by 48 inches) and a maximum of 600 pounds.
It reminds drivers that standees are permitted on the lift. In the event
of a lift failure, the instructions remind drivers to contact Radio
Dispatch and to inform the passenger of the next available lift-equipped
bus or alternative travel arrangements that have been made. Additional
training is provided on how to operate each type of lift. Drivers also
are instructed in securing wheelchairs and passenger sensitivity issues.

Attachment E also includes other training materials pertaining to
passenger sensitivity and disability awareness. An instructor's
checklist is included, along with a copy of the "Wheelchair Lift
Training" form, which all drivers must sign affirming that they
understand how to use the lift.

Additionally, the attachment includes copies of a series of memos
distributed to drivers at each division indicating the requirements for
cycling and use, as well as other ADA-related requirements (such as stop
announcements and vehicle identification).

**Monitoring and Discipline**

MTA staff report that they do ride checks with \"spotters\" who report
on ADA-related services delivered in the field. They feel that driver
problems result from drivers losing focus on ADA issues that they
receive during training. Drivers with reported problems are given a
caution and first sent to the Information and Service Section to read
and listen to complaints. They are then referred to their training
material on ADA services and procedures. The Transportation Supervisor
also instructs drivers in a 20-30 minute talk about ADA compliance. This
may be followed by compulsory driver attendance at a monthly Community
Advisory Committee meeting (where riders with disabilities discuss their
problems) if the Transportation Supervisor feels this will increase
driver sensitivity. Very serious infractions, or repeated cautions can
result in driver suspension.

## C. Assessment Team Observations {#c.-assessment-team-observations .unnumbered}

The assessment team observed the following areas to assess lift
reliability and maintenance at the MTA:

-   Field observations;

-   Morning pullout at the four MTA garage facilities; and

-   Wheelchair lift defect record keeping and maintenance.

Each subsection below describes the process used to assess each of the
three areas described above.

**Field Observations**

On the first day of the review, the four assessment team members rode
with four volunteer consumers to observe the system from a consumer
perspective. The Maryland Disabilities Law Center and the Maryland
Center for Independent Living identified the volunteers, who agreed to
spend part of the afternoon riding buses with the assessment team. All
of the consumers used wheelchairs, although one of them had an oversized
wheelchair (in excess of 48 inches long) that could not be accommodated
by all the lifts/securement areas. Assessment team members also
requested drivers to deploy lifts to permit them to board and alight the
bus. A copy of the Ride Along form used in this assessment is included
in Attachment F.

Twenty observations were made that afternoon. Table IV.C.1 shows the
breakdown of pass-bys, lifts reportedly not working, buses with no lift
(which should have been lift-equipped), and the refused standee. Of the
20 attempted boardings, 11 (55%) were successful. A later review of the
Radio Dispatch logs revealed three of the eleven pickups were called in;
the two defective lifts were not reported[^1]. The driver who refused
the standee (one of the assessment team members who claimed to have a
problem walking up steps) told him that lifts were only for people who
used wheelchairs, which is contrary to MTA's stated policies. The five
incidents of no lift when the buses should have had them appear to be
accurate, based on a review of the block assignments for those routes.
These results seem to be consistent with the types of complaints
reported by passengers in the previous section. Generally drivers did
not offer to assist individuals who use wheel chairs in securing their
chairs. In an instance in which the individual using the wheelchair was
having difficulty maneuvering on the bus, the driver responded by
treating the passenger very rudely.

**Table IV.C.1 - Summary of Ride-along Results**

**April 30, 2001**

  ----------------------------------- ------------------ -----------------
  **Outcome**                         **\#               **% Of Total
                                      Observations**     Attempted
                                                         Boardings**

  Successful Boardings                11                 55%

  Pass-by                             1                  5%

  Lift Reportedly Not Working         2                  10%

  No Lift (scheduled to be            5                  25%
  lift-equipped)                                         

  Refused Standee                     1                  5%

  Total Observations                  20                 100%
  ----------------------------------- ------------------ -----------------

**Morning Pullout**

Morning pullouts were observed at all four MTA garages. Assessment team
members started the observations between 4:30 a.m. and 5:30 a.m.,
depending on the garage, and concluded at about 7:30 a.m. The assessment
schedule is shown below.

> May 1 Kirk Garage (Barber & Regan)
>
> Northwest Garage (Mathias & Silverstone)
>
> May 2 Bush Garage (Mathias & Silverstone)
>
> Eastern Garage (Barber & Regan)

A series of memos issued by each division outlines the lift cycling
procedures for drivers. Drivers are required to cycle lifts at pullout
and relief drivers are required to cycle lifts at designated places on
their routes. The field observations included morning pullout only. Each
garage has designated a lift testing area, typically on the way to the
exit after completing the rest of the pre-trip inspection. At one
garage, a security camera is positioned to record lift cycling
activities. According to division managers, drivers are routinely
observed to ensure they are cycling lifts as required. Defects are noted
on the Mass Transit Administration Vehicle Report, which is kept with
the bus (see Attachment D). Each driver must update the card if any
defects are found. Drivers are required to call Radio Dispatch if the
lift is not functioning properly.

Table IV.C.2 shows a summary of the results of the observations of
morning pullout at each of the MTA divisions/garages. A copy of the form
used to record observations and interview drivers is included in
Attachment F. The observations indicate that 90% of the 192 lifts were
working. At Kirk 96% of the lifts were functional and at Bush, 95% were
functional. At Northwest, 81% of the lifts were functional and at
Eastern 85% of the lifts were functional.

During the pullout, the assessment team also observed that many
wheelchair securements appeared to be very dirty and some were in
disrepair. Manufacturers of securement devices recommend that the straps
be kept off the floor and cleaned regularly with mild soap and water.
Harsh cleaners, dirt, and grease can easily accumulate on the straps,
making them stiff and dysfunctional. On one wheelchair clamp, the
release knob was missing, which would have made it very difficult to
operate without causing injury to the driver or a customer. In a couple
of cases the flip-up seats appeared to be stuck in the down position.

> Table IV.C.2 - Summary of Observations at Sample Garages

May 1 & 2, 2001

+-------------------+----------------+----------------+----------------+
| ** Division/**    | **Wheelchair   |                |                |
|                   | Lift Cycling** |                |                |
| **Garage**        |                |                |                |
|                   | **(Pullout     |                |                |
|                   | O              |                |                |
|                   | bservations)** |                |                |
+-------------------+----------------+----------------+----------------+
|                   | **\#**         | **\#**         | **%**          |
|                   |                |                |                |
|                   | **Observed**   | **Working**    | **Working**    |
+-------------------+----------------+----------------+----------------+
| **Bush**          | 41             | 39             | 95%            |
+-------------------+----------------+----------------+----------------+
| **Eastern**       | 60             | 51             | 85%            |
+-------------------+----------------+----------------+----------------+
| **Kirk**          | 49             | 47             | 96%            |
+-------------------+----------------+----------------+----------------+
| **Northwest**     | 42             | 34             | 81%            |
+-------------------+----------------+----------------+----------------+
| **Total**         | **192**        | **172**        | **90%**        |
+-------------------+----------------+----------------+----------------+

If a driver encounters a malfunctioning lift during pre-trip inspection,
he or she is supposed to contact Radio Dispatch or their starter for
instructions on how to proceed. According to division staff, if a bus is
assigned to a run that is designated as being non-lift equipped, the bus
will be sent into service. If the run/block is designated as being
accessible, a spare bus with a functioning lift will be used, if
available. At Bush Garage, periodically the lift mechanic is assigned to
observe morning pullout and to troubleshoot lift problems. During that
time he watches for drivers who may not be operating lifts properly
during the cycling process and troubleshoots easy repairs. If a lift is
going to take more than a day to repair, maintenance records the bus
number on a "Tripper Sheet" so that the starters will know to assign the
bus to a route that does not require a lift.

Brief observations for each garage follow.

**Bush Garage**

Bush Garage is located on the southwest side of Baltimore, not far from
Camden Yards. There are 238 buses assigned to Bush. Of those, 170 are
lift equipped. Forty-one observations of the lift cycling were made
between 5:00 a.m. and 7:00 a.m., and two lifts did not work. No buses
were returned for maintenance.

The lift cycling station at Bush recently has been moved from its
original location next to the main building. Because of space
limitations buses got backed up while awaiting inspection. Now the lift
cycling area is in the parking lot. Since the change was recent, drivers
were still stopping at both locations. Those buses that are not
lift-equipped do not stop at the cycling station. All the lifts were
cycled by drivers at the lift cycling station during the assessment
observation on May 2, 2001. The lift cycling is performed separately
from the other pre-trip inspections and is the last thing checked before
each bus pulled out of the garage.

During the assessment, a lift mechanic and the Assistant Division Chief
observed morning pullout. Both advised drivers of corrective actions
when a lift seemed to malfunction. Both were able to "listen" to a lift
and tell if something was wrong with it. The mechanic does this
periodically to help troubleshoot lift problems before the buses are put
into service. One procedure involved making sure the lift was properly
reset prior to deployment.

The lift cycling procedure took only a few minutes for each bus. Up to
three buses at a time could cycle their lifts at the long curbside
station. During the inspection, random checks were made to determine
whether securements were clean and in good working order.

The "Tripper Sheet" for May 2, 2001, contained a total of five buses
with malfunctioning lifts. This list is compiled by maintenance at the
end of each day and distributed to the Transportation Section for use in
matching routes and buses for the following day's runs. Approximately 2%
of all lift-equipped buses assigned to Bush were on the \"Tripper
Sheet\" on May 2.

**Eastern Garage**

Eastern Garage is located near the intersection of Eastern Avenue and
the John F. Kennedy Memorial Highway. There are 169 buses assigned to
Eastern. Of those, 134 are lift equipped. Sixty observations of the lift
cycling were made between 5:30 a.m. and 7:30 a.m., and nine lifts did
not work. No buses were returned for maintenance. All nine were sent
into service.

The lift cycling station at Eastern is located on the eastside of the
main building, directly in line with an exit gate. All buses are brought
into position behind (to the north) of the lift cycling station, and
pass through the lift cycle station area. Buses that do not have lifts
by-pass the cycling station. All the lifts were cycled by drivers at the
lift cycling station during the assessment observation on May 2, 2001.
The lift cycling is the last thing checked before each bus pulled out of
the station, and is performed separately from the other pre-trip
inspections.

During the assessment visit, the Chief - Bus Operations, Eastern
Division, was monitoring the procedures and was able to advise drivers
of corrective actions when a lift seemed to malfunction. One procedure
involved making sure that the front wheels of the bus were straight
before beginning the lift cycle. Another involved correcting the
sequence of switch operations that started each cycle.

The lift cycling procedure took only a few minutes for each bus. Up to
three buses at a time could cycle their lifts at the long curbside
station. During the inspection the assessment team boarded each bus to
observe the condition of wheelchair securement belts and to ask the
driver the number of his/her route block.

The "Tripper Sheet" for May 2, 2001 contained a total of 11
lift-equipped buses on the list of buses with malfunctioning lifts.
Approximately 8% of all lift-equipped buses assigned to Eastern were on
the \"Tripper Sheet\" on that day.

**Comments by Maintenance Personnel -** Maintenance personnel reported
that they do not bring a bus in for repair until all the parts have been
received. There is one repair bay devoted to wheelchair lifts, and it is
usually occupied. One mechanic at Eastern is trained to work on lifts.
At the time of the assessment he was training two other mechanics. Lifts
get repaired on the working shift of the one trained mechanic. Lifts are
routinely inspected every three months. It takes about eight to twelve
hours to repair each lift. Repair usually occurs over a two-day period.

Mechanics feel a high proportion of the service calls result from driver
error and inexperience. Drivers sometimes deploy lifts on a high curb or
storm drain and they become stuck. Then the brakes are locked and the
bus is not able to function. High curbs seem prominent in Baltimore,
especially in new construction.

**Comments by Drivers -** Five drivers were interviewed in the Day Room
of the Eastern Garage. Three of them had been driving for MTA for 18
years, one had seven years of experience and one had three and a half
years. They reported that:

-   Training was good. Sensitivity to needs of ADA riders was well
    covered in training.

-   They usually were sent out on a route even if their lift was not
    working. Sometimes this involved a route change to a school or other
    non-lift route.

-   Often they drove their originally assigned route and just did not
    pick up passengers who use wheelchairs.

-   Drivers reported that lift cycling at the morning pull-out at the
    Garage was usually observed by the Garage Superintendent or a
    mechanic, and that notes were taken when lifts did not work.

-   Drivers wished ADA riders used their identification cards more, so
    they could be assured that they had been given proper orientation to
    rider responsibilities. Drivers also felt that a memo should be sent
    to all ID cardholders to remind them of their responsibilities as
    riders using the lifts.

-   Most drivers said that passengers who use wheelchairs do not want to
    use the securement restraints and do not want help getting into
    position. They prefer to use the brakes on their wheelchairs as
    on-bus restraints.

-   If lifts malfunctioned on the road, drivers called the Garage to
    report it. If the malfunctioning lift made the bus inoperable,
    drivers were expected to stay with the bus until it was serviced,
    while ambulatory passengers went to a replacement bus. On-board
    wheelchair passengers had to wait with the driver for service, which
    could take up to two hours.

-   One driver wished for a manual backup on the lifts that would permit
    the driver to over-ride the system and at least bring the lift back
    into the bus if it was stuck in the down position.

-   Most drivers felt the securement belts were too dirty to use. Only
    the new buses have relatively clean securement belts.

**Kirk Garage**

Kirk Garage is located north of Penn Station. There are 216 buses
assigned to Kirk including 20 NABI 2000 buses, which had not been
delivered at the time of the assessment. The lift cycling station at
Kirk is located directly outside of the open bays of the maintenance
area. All the lifts were cycled by the driver at the lift cycling
station. The lift cycling is performed separately from the other
pre-trip inspections and is the last thing checked before buses leave
the garage.

Forty-nine observations of the lift cycling were made between 5:25 a.m.
and 7:33 a.m., and two lifts did not work. During observation of morning
pullout, the chief mechanic was monitoring the procedures and was able
to offer tips to the drivers when a lift was having operational
difficulties. One procedure involved making sure that the front wheels
of the bus were straight before beginning the lift operation. There
appeared to be a good working relationship between the transportation
personnel and the maintenance personnel.

The "Tripper Sheet" for May 1, 2001, contained a total of 13 buses with
malfunctioning lifts. This is approximately 11% of all lift-equipped
buses assigned to Kirk.

**Comments by Maintenance Personnel -** Mechanics offered many insights
into the reasons for lift failures.

-   Mechanics suggested that many new wheelchairs are too large for the
    lifts.

-   The lifts are rated for 600 pounds and the new wheelchairs with
    passengers often exceed this amount.

-   The old screw-type lifts have many problems and maintenance has a
    hard time keeping them in working order.

-   They try to inspect two lift-equipped buses a day during the morning
    maintenance shift.

-   Maintenance thinks that the driver improperly deploying the lift on
    a high curb or storm drain, causing the lift to become stuck, is
    responsible for 60% to 70% of the service calls. Then the brakes are
    locked and the bus is not able to function.

**Northwest Garage**

Northwest Garage is located near the Reisterstown Plaza Metro station.
There are 204 buses assigned to Northwest. Of those, 157 are lift
equipped. Observations of the lift cycling were made between 4:30 a.m.
and 6:30 a.m., and eight lifts did not work. No buses were returned for
maintenance. All eight buses were sent into service.

The lift cycling station at Northwest is located at the exit adjacent to
the maintenance garage (all buses are stored inside). Buses that are not
lift-equipped by-pass the cycling station. All the lifts were cycled by
drivers at the lift cycling station during the assessment observation on
May 1, 2001. The lift cycling is the last thing checked before each bus
pulled out of the station, and is performed separately from the other
pre-trip inspections.

During the assessment visit, Mike Hannah, Chief - Bus Operations,
Northwest Division, was monitoring the procedures and advised drivers of
corrective actions when a lift seemed to malfunction. He said he often
observes morning pullout from just inside the building where drivers
cannot see him so he can observe whether lifts are properly cycled. He
has developed a "Gate Check" form to capture this lift cycling
information.

The lift cycling procedure took only a few minutes for each bus. Up to
three buses at a time could cycle their lifts at the long curbside
station.

The "Tripper Sheet" for May 1, 2001, included 17 lift-equipped buses
with malfunctioning lifts. Approximately 10% of all lift-equipped buses
assigned to Northwest were on the \"Tripper Sheet\" on that day. A
further review of "Tripper Sheets" between March 1 and May1, 2001,
revealed that on average, 11 buses were listed on the trip sheet,
ranging from two to seventeen. The review also suggested that some of
those buses remain on the sheets for weeks at a time. For example, bus
#3003 was observed to be on the list from March 5-April 10, 2001.
Likewise, bus #7041 was observed to be on the list from at least March
1-May 1, 2001.

The Division Chief cited a lack of mechanics as a major contributor to
the lift reliability problems in his facility. He currently has only 1-2
lift mechanics and could use at least 3 (1 per shift). Each lift
inspection takes at least 3 hours and is supposed to be conducted every
30 to 60 days.

**Maintenance Practices**

During the on-site visit, the assessment team looked at two general
maintenance practices that are important to lift reliability and
maintenance: (1) routine lift inspections and (2) service calls for
lift-related problems. The results of this analysis are described below.

**Routine Lift Inspections**

According to the MTA policy, lifts are supposed to be inspected and
preventive maintenance is to be performed regularly -- every 60 days for
buses that were manufactured before1990 and every 6,000 miles for newer
buses. There was some variation in this interpretation among garages.
Using computer-generated Repair History Reports, the assessment was able
to ascertain the number of lift inspections performed during the
four-month period between January 1 and May 2, 2001. Table IV.C.3 shows
the results of this analysis. The number of lift-equipped buses does not
include the 80 new NABI buses that were in the process of being
delivered during this period.

**Table IV.C.3 Lift Inspections**

**January 1, 2001-May 2, 2001**

  --------------------- ----------------- --------------- ------------- --------------
  **Division/Garage**   **\#              **\# Lift       **Average \#  **Average \#
                        Lift-Equipped     Inspections**   Inspections   Hours per
                        Buses**                           per Bus**     Inspection**

  Bush                  150               321             2.1           3.9 hours

  Eastern               114               217             1.9           4.9 hours

  Kirk                  116               174             1.5           3.8 hours

  Northwest             137               177             1.3           3.4 hours

  Total                 517               889             1.7           4.0 hours
  --------------------- ----------------- --------------- ------------- --------------

Table IV.C.3 indicates that, on average, 1.7 inspections per bus were
performed. Given the four-month period, it would seem that two or more
inspections should have occurred. According to the table, only Bush
appears to have completed the expected number of inspections, with
Eastern close behind at 1.9 inspections. At the same time, the Northwest
Garage only inspected its buses an average of 1.3 times (and had the
worst reliability record based on Tripper Sheets). Interviews with
maintenance and division managers suggest that there may not be enough
mechanics to get the inspections done on time and to keep up with
routine repairs. A more detailed analysis could clarify whether MTA has
enough resources devoted to lift maintenance. The repair histories
include the time spent on each inspection and could provide valuable
insight into basic staffing needs. Again, it appears that Eastern is
spending the most time on its inspections while Northwest is spending
the least amount of time (4.9 versus 3.4 hours respectively).
Considering that lift mechanics work both in the shop and on the road,
this would appear to be a potential problem.

**Service Calls**

During the period from January 1 through May 2, 2001, a total of 292
service calls (road calls) were logged in the maintenance records. In
contrast, looking at the Radio Dispatch log, only 42 service calls were
logged through their records. This discrepancy suggests that drivers may
not be radioing in their lift failures, but may be reporting them on
defect cards or to their own divisions. It also may suggest that Radio
Dispatch only logs calls that they need to follow-up on. In any case, it
is not clear from the records whether drivers are following through and
calling in lift problems. This is the same issue raised by MDLC as cited
earlier in this report.

Table IV.C.4 shows the service calls for lift-related problems found in
the computerized Repair History reports. Again, the 80 NABI buses were
not counted in the totals. Table 7 shows the number of service calls per
lift-equipped bus, which ranges from 0.46 for Eastern to 0.62 for
Northwest. If the percentage of total service calls by division is
compared to the percentage of total lift-equipped fleet assigned by
division, it appears that Eastern with 18% of the service calls and 22%
of the fleet is performing better than the others. Further analysis
could help to clarify whether the garages are keeping up with routine
and preventive maintenance in order to minimize service calls.

**Table IV.C.4 - Service Calls for Lift-Related Problems**

**January 1, 2001-May 1, 2001**

  --------------------- --------------- ---------- --------------- ------------ ------------
  **Division/Garage**   **\#            **\#       **Service Calls **% Of Total **% Of Total
                        Lift-Equipped   Service    per             Lift         Service
                        Buses**         Calls**    Lift-equipped   Equipped     Calls by
                                                   Bus**           Fleet        Division**
                                                                   Assigned**   

  Bush                  150             86         0.57            29%          29%

  Eastern               114             52         0.46            22%          18%

  Kirk                  116             69         0.59            22%          24%

  Northwest             137             85         0.62            26%          29%

  Total                 517             292        0.56            100%         100%
  --------------------- --------------- ---------- --------------- ------------ ------------

## D. Findings and Recommendations {#d.-findings-and-recommendations .unnumbered}

### Findings

1.  Overall, 72% of the MTA's fleet is lift- (or ramp-) equipped. MTA
    estimates the entire fleet will be accessible by 2005.

2.  Overall, 90% of the lifts observed during pullout were functioning.
    Most drivers appeared to be comfortable operating the lift; however,
    none appeared to check securements during the pre-trip inspection.

3.  Eleven of twenty passengers (55%) observed were able to board
    in-service buses using a lift.

4.  There is no readily available list of which routes are lift equipped
    and when. Individual schedules must be consulted. MTA assigns buses
    to blocks of work (which include multiple routes). The system map
    does not indicate which routes are accessible. The ISA is used to
    denote routes with at least some accessible buses, but passengers
    must look for a "W" in the left column or a note at the bottom of
    the schedule to determine when an accessible bus is expected. The
    absence of fully accessible routes and/or clear public information
    on lift-equipped service could be an impediment to transit access
    for individuals with mobility impairments.

5.  MTA has instituted a regular process of pre-trip inspections,
    preventive maintenance checks, and lift inspections as required by
    49 CFR §37.163. However, lift failures, either during pullout or
    in-service are not reported and recorded in a consistent fashion in
    radio dispatch and maintenance logs.

6.  From January through May 2001, 889 inspections were performed. On
    average, 1.7 inspections per bus have been made during a period when
    at least two inspections should have been made per vehicle. On
    average, the inspections take about three to four hours.

7.  From January through May 2001, there were 292 service calls,
    according to repair histories.

8.  The use of maintenance and operations personnel to observe pullout
    appears to be very beneficial for troubleshooting lift problems
    before drivers leave the garage.

9.  Overall, inoperable lifts on buses used in service do not appear to
    be repaired within 5 days as required by the ADA. This shortcoming
    may be due, in part, to an apparent lack of maintenance personnel.

10. MTA has developed a driver-training program that addresses lift
    operations and other ADA-related issues.

11. Between March 2000 and March 2001, MTA logged about 40 passenger
    complaints relating to lift problems.

12. Drivers reportedly pass-by passengers using wheelchairs who are
    waiting for buses on routes/blocks designated as wheelchair
    accessible.

13. Drivers do not always allow standees on lifts.

14. Drivers do not always make passengers who use wheelchairs or
    crutches feel welcome and comfortable on fixed route service.

### Recommendations

1.  The MTA should review the distribution of its accessible vehicles to
    determine whether those assignments are clearly understood by
    persons wishing to use the system. The printed materials also should
    be examined to find better ways to provide public information about
    lift-equipped services.

2.  The MTA should increase its focus on preventive maintenance for
    lifts and initiate more frequent inspections to address lift issues
    before they become in-service vehicle repairs. This effort may
    require additional maintenance personnel as that area may be
    understaffed.

3.  Inoperable lifts should be repaired within three days from the day
    they are identified as inoperable, or they should be removed from
    service in accordance with 49 CFR § 37.163(e).

4.  The procedure for reporting defective lifts through Radio Dispatch
    should be examined. It is not clear whether all calls are logged
    there, or only ones that require follow-up. This lack of record
    keeping makes it difficult to keep statistics on maintenance
    efforts.

5.  Maintenance personnel should be involved with driver retraining to
    ensure that drivers are instructed in troubleshooting lifts and are
    better able to make minor adjustments while in service.

6.  The practice of monitoring pullout with lift-mechanics and division
    personnel should be done regularly.

7.  Drivers should be instructed in passenger sensitivity and radio
    procedures. MTA should consider dropping the requirement for drivers
    to call in each wheelchair boarding. Transit use by persons who use
    wheelchairs can be counted on a sampling basis.

8.  It is recommended that in accordance with 49 CFR §37.163(f), the MTA
    should review its procedures for providing alternative
    transportation to lift users when buses are operating with operative
    lifts.

**Attachment A**

**Bus and Line Assignment by Division -- March 2001**

**Attachment B**

**MTA Notification Letter & On-site Assessment Schedule**

Baltimore Lift Reliability & Maintenance Review

April 30 -- May 3, 2001

+--------+--------------+----------------+---------------+-------------+
| **Revi | **Monday**   | **Tuesday**    | **Wednesday** | *           |
| ewer** |              |                |               | *Thursday** |
+--------+--------------+----------------+---------------+-------------+
| Ma     | AM -- arrive | 4:20 AM --     | 5:00 AM --    | AM --       |
| thias, |              | Northwest      | Bush Garage   | prepare for |
|        | PM -- ride   | Garage         |               | exit        |
| Team   | with         |                | (With Ruth    | conference, |
| Leader | consumers    | (With Ruth     | Silverstone,  | follow up   |
|        |              | Silverstone,   | MTA)          | on details  |
|        |              | MTA)           |               |             |
|        |              |                | Lift          | 1 PM - Exit |
|        |              | Lift           | reliability & |             |
|        |              | reliability &  | maintenance,  |             |
|        |              | maintenance    |               |             |
|        |              |                | Radio         |             |
|        |              |                | dispatch      |             |
+--------+--------------+----------------+---------------+-------------+
| Barber | AM -- arrive | 5:30 AM --     | 5:30 AM --    | AM --       |
|        |              | Kirk Garage    | Eastern       | prepare for |
|        | PM -- ride   |                | Garage        | exit        |
|        | with         | Lift           |               | conference, |
|        | consumers    | reliability &  | Lift          | follow up   |
|        |              | maintenance    | reliability & | on details  |
|        |              |                | maintenance   |             |
|        |              |                |               | 1 PM - Exit |
+--------+--------------+----------------+---------------+-------------+
| Regan  | AM -- arrive | 5:30 AM --     | 5:00 AM --    | AM --       |
|        |              | Kirk Garage    | Eastern       | prepare for |
|        | PM -- ride   |                | Garage        | exit        |
|        | with         | Lift           |               | conference, |
|        | consumers    | reliability &  | Lift          | follow up   |
|        |              | maintenance    | reliability & | on details  |
|        |              |                | maintenance   |             |
|        |              |                |               | 1 PM --     |
|        |              |                |               | Exit        |
+--------+--------------+----------------+---------------+-------------+
| K      | AM -- arrive |                |               |             |
| idston |              |                |               |             |
|        | PM -- ride   |                |               |             |
|        | with         |                |               |             |
|        | consumers    |                |               |             |
+--------+--------------+----------------+---------------+-------------+

#######  {#section .unnumbered}

**Attachment C**

**MTA Response**

**Attachment D**

**Sample Maintenance Forms & Reports**

**Attachment E**

**Excerpts from MTA's *Transit Operations: ***

***Student Handbook and MTA Rule Book***

**and Related Materials**

**Attachment F**

**Assessment Review Forms**

Consumer Assessment Form

Transit System Name: [**MTA Baltimore**]{.underline} Date:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Route #/Line Name:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Bus #\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

  -------------- ------------------------------------------------------------------------------------------------------------------------ --------------- ------------------------------------------
  Boarded at:                                                                                                                             Disembarked at: 

  Location:      \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_                                                                                   Location:       \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

  Time:          \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_                                                                                   Time:           \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

  Riding with:   \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_                   
  -------------- ------------------------------------------------------------------------------------------------------------------------ --------------- ------------------------------------------

Origin Comments

1.  Was the stop accessible?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

2.  Was the path of travel accessible?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

3.  Did the driver stop with easy access for boarding?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Boarding the Bus**

4.  Was the driver professional and courteous?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

5.  Did the lift work properly?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\- If so, was the mobility device secured properly?  yes  no
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

> \- If [not]{.underline}, did driver appear to call dispatch?  yes 
> no \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
>
> \- If [not]{.underline}, did the driver tell the passenger when &

how they would be transported?  yes  no
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

6.  Did the driver pass by the passenger without

stopping?  yes  no \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Equipment**

7.  Did the securements work properly?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

8.  Did the destination sign work properly?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

9.  Did the stop request bell work properly?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

10. Were stop announcements made?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\- If so, did the driver use  voice  PA  auto announcements

\- If so, were they clear & audible?  yes  no
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Destination**

11. Did the lift work properly?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

12. Was the stop accessible?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

13. Was the path of travel accessible?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

14. Did driver stop with easy access for deboarding?  yes  no
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Notes:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Signature and Name:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_(rev.
4/27/01)

**Record of Lift Cycling and Working Condition of Lifts and Access
Features**

Transit Agency: [MTA Baltimore]{.underline}

Garage Location:  Bush  Eastern  Kirk  Northwest

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Time:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Page \_\_\_\_\_ of \_\_\_\_\_\_

Bus #: \_\_\_\_\_\_\_\_ Route/Block #: \_\_\_\_\_\_\_\_ Lift Cycled By 
Driver  Mechanic  Starter

Lift/Ramp Worked?  Yes  No Securements Appear Functional?  Yes  No

PA Worked?  Yes  No Securements Clean?  Yes  No

Kneelers Worked? [N/A]{.underline}

Operator Familiarity with Equipment:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**Comments:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Interview of Drivers/Operators**

1.  What is the agency's policy regarding lift cycling?

2.  What training do they received in operating lifts, securement
    systems, and other access features?

3.  What do they do if a lift malfunctions when being cycled at the
    garage? On the route?

4.  What do they do if a lift malfunctions in service?

Reviewer Name and Signature:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(rev. 4/24/01)

[^1]: It was noted during the Exit Conference that some drivers might
    have been using mobile data terminals to record pick-ups; however,
    that information was not offered during the interview with Radio
    Dispatch personnel.