**Gary Public Transportation Corp. (GPTC)**

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**Gary, Indiana**

**Compliance Review**

**of**

ADA Complementary Paratransit Service

**April 22-25, 2003**

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[]{.mark}

***Summary of Observations***

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**with**

**Multisystems, Inc.**

**Final Report: November 21, 2005**

**CONTENTS**

[]{.mark}

[I. Purpose of the Review 1](#purpose-of-the-review)

[II. Overview of the Review 3](#overview-of-the-review)

[III. Background 7](#background)

[IV. Summary of Findings 14](#summary-of-findings)

[V. Compliance with Regulatory Service Criteria
18](#compliance-with-regulatory-service-criteria)

[VI. Observations Regarding ADA Complementary Paratransit Eligibility
Determinations
20](#observations-regarding-ada-complementary-paratransit-eligibility-determinations)

[VII. Observations Regarding Telephone Access, Trip Reservations,
Scheduling, and Dispatching
26](#observations-regarding-telephone-access-trip-reservations-scheduling-and-dispatching)

[VIII. Observations Regarding Service Operation
32](#observations-regarding-service-operation)

[IX. Resources 41](#resources)

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  ------------- ----------------------------------------------------------
  *Attachment   *Response from GPTC*
  A.*           

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

  *Attachment   *Meeting the Transit Challenge -- ADA Paratransit Rider
  C.*           Guide, July 2002*

  *Attachment   *Sample Forms*
  D.*           

  *Attachment   *Certification Application for ADA Paratransit
  E.*           Eligibility*
  ------------- ----------------------------------------------------------

[]{.mark}

# Purpose of the Review

Public entities that operate fixed route transportation services for the
general public are required by the U.S. Department of Transportation
(DOT) 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 US DOT regulations. As part of its
compliance efforts, FTA, through its Office of Civil Rights, conducts
periodic reviews of fixed route transit and ADA Complementary
Paratransit services operated by grantees.

The purpose of the review is to assist the transit agency and FTA in
assessing whether capacity constraints exist in ADA Complementary
Paratransit services. The compliance review examines service policies
and standards related to issues of capacity constraints such as
telephone hold times, trip denials, on-time performance, on-board travel
time, and any other trip-limiting factors. The review considers whether
there are operational patterns or practices that significantly limit the
availability of service, including: trip denials; early or late pickups
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.

From April 22 through 25, 2003, FTA conducted an on-site review of ADA
Complementary Paratransit service provided by the Gary Public
Transportation Corp. (GPTC) in Gary, Indiana. Planners Collaborative,
Inc., located in Boston, Massachusetts, and Multisystems, Inc., based in
Cambridge, Massachusetts, conducted the compliance review for the FTA
Office of Civil Rights. The review focused on compliance of GPTC's ADA
Complementary Paratransit service, specifically with respect to the
"capacity constraints" criterion included in Section 37.131(f) of the
DOT ADA regulations, which requires that ADA Complementary Paratransit
services be operated without capacity constraints.

This report summarizes the observations and findings of the on-site
review of GPTC's ADA Complementary Paratransit service. First, the
report describes key features of the ADA Complementary Paratransit
service. The report then provides a description of the approach and
methodology used to conduct the review. There is a summary of
observations and findings related to each element of the capacity
constraint criteria. The major findings of the review are summarized in
Section IV of this report. Recommendations for addressing some of the
findings also are provided.

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

# Overview of the Review

This review focused on compliance with the ADA Complementary Paratransit
capacity constraints requirements of the DOT ADA regulations. These
regulations identify several possible types of capacity constraints.
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 pickups, 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
review focused on observations and findings regarding:

-   Trip denials and "wait-listing" of trips

-   On-time performance

-   Travel times

The review team also made observations and findings related to three
other sets of policies and practices that could affect access to ADA
Complementary Paratransit service:

-   ADA Complementary Paratransit service eligibility process

-   Telephone capacity

-   Service area and service times

ADA Complementary Paratransit eligibility determinations were assessed
to ensure that the 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 critical to using any ADA Complementary
Paratransit service.

Pre-review

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

-   A description of the administrative structure of GPTC's ADA
    Complementary Paratransit service

-   *GPTC Passenger Assistance Driver Training Manual and Workbook* by
    PennTRAIN, June 1996

-   *Meeting the Transit Challenge, July 2002* (ADA Paratransit Rider's
    Guide)

-   Sample driver logs & trip tickets

-   Daily activity reports for CY 2001 and CY 2002

-   Recent budget information

-   Certification Application for ADA Paratransit Eligibility

-   Results of FTA Triennial Review related to ADA service deficiencies

-   Fixed route service schedules

-   Peer review of ridership and costs

The review team also requested that additional information be available
during the site visit. This information included:

-   Completed applications for ADA Complementary Paratransit service

-   Copies of completed driver manifests for recent months

-   Vehicle fleet and driver information

-   Sample forms used in daily operation

-   Service data from selected sample days and months, including the
    number of trips requested, scheduled, canceled, no-shows, missed
    trips, trips provided, and trip durations

-   Written customer complaints

In addition to the review of data and direct observations, the review
team conducted telephone interviews with several individuals who either
use the GPTC's ADA Complementary Paratransit service or who work with
those users. The review team also reviewed two complaints relating to
ADA Complementary Paratransit service on file with FTA, as well as a
lawsuit filed against GPTC and others by Everybody Counts, Inc. (Center
for Independent Living) et al.

On-site Review

The on-site review began with an opening conference at 9 a.m. on
Tuesday, April 22, 2003. The opening conference, held at the GPTC
administrative offices located at 100 W. Fourth Avenue in Gary. The
following GPTC staff attended the opening conference:

  ----------------- ---------------------------- -------------------------
  Name              **Title**                    **E-mail**

  Arlene Colvin     Interim General Manager      <acolvin@ci.gary.in.us>

  Earnest Anderson  Director of Transportation   none

  Minietta Nelson   Grant Administration Manager <Gptcgptc@aol.com>
  ----------------- ---------------------------- -------------------------

Rosemary Mathias and Patricia Monahan of Multisystems along with Don
Kidston of Planners Collaborative comprised the review team. Roberta
Wolgast, FTA Equal Opportunity Specialist, and Dwight Sinks, FTA Region
V Civil Rights Officer, participated in the opening conference via
teleconference call.

Ms. Wolgast opened the meeting by emphasizing that the purpose of the
ADA compliance reviews is to help transit properties provide effective
ADA Complementary Paratransit service. She also thanked everyone for his
or her cooperation in the conduct of the review. Ms. Wolgast 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 GPTC for review and
    comment before being finalized as a public document. The final
    report would be available via the Freedom of Information Act (FOIA).

Ms. Mathias described the schedule for the on-site review and the
subsequent report. A copy of the review schedule appears in Attachment
B. GPTC staff indicated that they were willing to provide any
information and assistance to the review team. Team members also asked
some questions concerning the information that GPTC had sent before the
site visit.

After the opening conference, the review team met with senior staff to
review the budget and ridership trends for the transit agency. During
the afternoon, the team toured the operations facility at 2101 W. 35^th^
Avenue in Gary and conducted interviews with key staff including
maintenance, reservations/scheduling, and dispatching. Initial data
collection began for the on-time performance, ride duration, and trip
denials.

On Wednesday, April 23, two of the review team members rode for several
hours with two different paratransit drivers (one in the morning and one
in the afternoon). Several drivers were interviewed. The data analysis
continued including a review of the complaint process and complaints
received for the past year. One team member also met with the Director
of Transportation to compile information on comparable fixed route
service for the trip duration analysis and another team member met with
the ADA Coordinator to discuss the ADA eligibility determination
process.

On Thursday, April 24, team members continued to analyze the information
that they had collected from GPTC and the contract carrier. Additional
consumer and agency calls were made. The team also met with the grants
manager to discuss the budget and resources data in more detail. The
afternoon was spent completing the data analysis and preparing for the
exit conference. A preliminary debriefing was provided to operations
staff.

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On Friday, April 25, the review team presented preliminary findings, and
discussed these findings and recommendations with GPTC. GPTC staff who
attended the exit meeting included:

  ----------------- ---------------------------- -------------------------
  Name              **Title**                    **E-mail**

  Arlene Colvin     Interim General Manager      <acolvin@ci.gary.in.us>

  Earnest Anderson  Director of Transportation   none

  Minietta Nelson   Grant Administration Manager <Gptcgptc@aol.com>
  ----------------- ---------------------------- -------------------------

Mr. Sinks from FTA participated in the exit conference via telephone.

The review team reviewed initial findings in the following areas:

-   Customer comments/complaints

-   Fixed route service comparability

-   ADA Complementary Paratransit eligibility

-   Telephone access

-   Trip reservations, scheduling, and dispatch (including denials)

-   Operations - on-time performance, trip duration

-   Resources & funding

At the conclusion of the exit conference, Mr. Sinks emphasized that FTA
was available to provide additional technical assistance to GPTC.

# Background

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In 1974, the Gary Public Transportation Corporation (GPTC) was
established by state statute and the Gary Common Council to sustain
public mass transportation bus service in the City of Gary. As a public
transportation corporation, GPTC functions as a separate municipal
corporation and levies local property taxes to subsidize operating and
capital costs. GPTC has a seven-member board of directors. The Mayor of
the City of Gary appoints three members and the Gary Common Council
appoints four members. GPTC provides fixed route bus and ADA
Complementary Paratransit services throughout the city within a
38-square-mile area with a service area population of 102,746.

GPTC also manages the Adam Benjamin Inter-modal Metro Center in downtown
Gary for the City of Gary, and owns and operates a maintenance and
operations garage at. 2101 W. 35^th^ Avenue in Gary. The fixed route bus
and ADA Complementary Paratransit is based at the 35^th^ Avenue
facility. The Metro Center is the hub for commuter passenger rail
service to South Bend, Indiana and Chicago, Illinois; Greyhound and
Trailways intercity bus services; GPTC local bus services; taxicabs; and
a park-and-ride facility.

GPTC has a collaborative relationship with the Mayor's Organization on
Disabilities to ensure that accessible bus service and other services
are provided for the residents of Gary. GPTC also operates one tri-city
express fixed route, which connects with bus operations in the cities of
East Chicago and Hammond; one suburban express fixed route, which
transports residents to the town of Merrillville and the government
complex at the county seat located in the city of Crown Point; and one
suburban job access circular fixed route, which provides access to major
shopping centers and strip malls. GPTC also operates a point deviation
route (#21), which operates from 10:30 a.m. -- 1:30 p.m. in place of
routes #4, #10, and #14. Route #21 also provides point deviation service
from 6:30 -- 10:30 p.m. in place of routes #4 and #10 (there is no
evening service on route #14). All service is wheelchair accessible.

GPTC is a designated recipient of Federal funds in the urbanized area
covering northeastern Illinois and northwestern Indiana, and
participates in the transportation planning process with the
metropolitan planning organization known as the Northwestern Indiana
Regional Planning Commission (NIRPC). NIRPC's planning area includes
three participating counties -- Lake, Porter, and LaPorte -- located at
the northwestern corner of Indiana and the southern tip of Lake
Michigan. The area includes 711,595 people and covers 1,520 square
miles. There are 41 cities and towns and 44 townships within the NIRPC
planning area.

Description of ADA Complementary Paratransit Service

GPTC began operating ADA Complementary Paratransit services in-house in
2000. Prior to that time, service was provided by a non-profit
organization (Tradewinds) under contract to GPTC. There is a concern
that Tradewinds and other local non-profit providers will discontinue
providing paratransit services to their existing clients and that many
of these clients will turn to GPTC's ADA Complementary Paratransit
service to provide their trips.

GPTC operates ADA Complementary Paratransit throughout the city limits
of Gary and Hammond, as well as in ¾-mile corridors around bus routes
serving adjacent communities. Figure III-1 is a recent GPTC system map.
Gary is in the midst of a route assessment project and a new map will be
developed once that project is complete. Service is provided
curb-to-curb and drivers will assist passengers in and out of vehicles.

Service operates Monday through Saturday from 4:50 a.m. to 11:00 p.m.
There is no Sunday or holiday service, except for the Martin Luther King
Holiday. Fares are \$2.50 within the city limits and \$4.00 to areas
outside the City of Gary (also called "express trips"). Personal care
attendants (PCAs) or family members may accompany passengers for free.
Passengers who are determined eligible for the ADA Complementary
Paratransit service are required to get a free photo I.D. card. The I.D.
also may be used to get discounted (60 cents) fare on fixed route
service. Transfers on fixed route services cost 10 cents.

Customers can call GPTC daily from 8:00 a.m. - 4:30 p.m. (some materials
indicate\
8:30 a.m. - 4:00 p.m.) to request trips. Trips may be scheduled from one
to seven days in advance. The ADA Coordinator takes trip requests on
weekdays and the dispatchers take trip requests on Saturdays. On
Sundays, trip requests may be left on voice mail, which is checked by
the ADA Coordinator. After-hours trip requests also may be left on voice
mail and are confirmed the next morning.

Attachment C includes a Word version of the July 2002 *Meeting the
Transit Challenge* rider's guide. The19-page booklet provides general
information about GPTC's ADA Complementary Paratransit services,
including telephone numbers and a series of frequently asked questions.
It is in the process of being updated. The review team provided
suggestions for updating and correcting the booklet. GPTC does not
maintain a web site.

Policies and Service Standards Related to Capacity Issues

GPTC provided the following information on service standards for ADA
Complementary Paratransit service in response to a request from FTA
prior to the review team's site visit.

-   ***Telephone Call-Handling Standards:*** "None."

-   ***Trip Denials:*** "Currently, no standard has been set regarding
    acceptable percentage of trip denials."

-   ***On-Time Performance:*** "On-time performance is defined as: when
    the service is provided within a ten-minute window, either before or
    after the scheduled time of pickup. The goal is whenever possible to
    provide 100% of all trips scheduled on time. The standard is 95%
    on-time performance."

```{=html}
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```
-   ***Travel Time:** "*The goal for travel time for ADA Paratransit is:
    all trips will be completed within thirty minutes (for local trips),
    or one hour (for express trips). This is the scheduled travel time
    on Local and Express Routes within the GPTC Fixed Route System."

![](media/image1.jpeg){width="9.0in" height="5.622222222222222in"}

Figure III-1. GPTC system map

FTA Triennial Review

In a recent Triennial Review, GPTC was cited for several ADA-related
deficiencies including (1) improper tracking of trip denials, (2) ADA
service provision deficiencies, (3) inadequate training, insufficient
maintenance for ADA equipment, (4) violations of procedures to ensure
lift availability, and (6) improperly implemented appeals process.

FTA required GPTC to submit quarterly progress reports for the quarters
ending in June 2002, September 2002, December 2002, and March 2003. FTA
required GPTC to (1) submit denial and on-time performance reports, (2)
make public transit information available in accessible formats, (3)
submit evidence that the transit agency had incorporated ADA service
provisions into training materials, including the employee rule book,
(4) submit maintenance reports, (5) provide lift availability reports,
and (6) establish an appeals process for ADA eligibility.

The review team's observations of those deficiencies specifically
relating to ADA Complementary Paratransit service are described
throughout this report

Consumer Comments

The review team gathered information about the concerns of riders who
use the ADA Complementary Paratransit service through four sources: (1)
formal complaints submitted to FTA, (2) documentation from a class
action suit filed against GPTC and others, (3) telephone interviews with
riders or professionals who work with riders, and (4) rider comments on
file with GPTC.

Formal Complaints Submitted to FTA

Two complaints against GPTC have been filed with the FTA. Both deal
primarily with fixed route issues; however, the second complaint also
addresses ADA Complementary Paratransit eligibility.

In 1999, a complaint was filed citing several issues including: (1)
problems with fixed route lift reliability ("no buses in Gary have
working lifts"), (2) the need to repair or replace paratransit vans
(non-profit contractor), and (3) the patron is often late for work. This
complaint has been closed.

In 2001, FTA received another complaint relating to problems with fixed
route lift reliability and related issues of providing back-up
paratransit service in the event of a fixed route bus lift failure.
Further, the complaint described problems with inconsistent fares being
charged for that service (i.e., an ADA Complementary Paratransit fare
being charged for back-up fixed route coverage). Also, the complainant
states that she was not able to apply for ADA Complementary Paratransit
eligibility for her 4-year-old daughter because her daughter was not a
fare-paying customer (i.e., she was too young). This complaint is still
open.

Class Action Suit Against GPTC and Others

In July 1998, Everybody Counts (the local Center for Independent Living)
et al. filed a class action suit against Northwestern Indiana Regional
Planning Commission (NIRPC); GPTC; Hammond Transit System; East Chicago
Public Transit; Lake County Economic Opportunities Council, a.k.a. LCEOC
Transportation, Inc.; Tradewinds Rehabilitation Center, Inc.; and
Indiana Department of Transportation. The suit alleged that the
defendants failed to provide "basic and necessary public transportation
services to plaintiffs and other qualified individuals with disabilities
in Lake County, Sate of Indiana." In 2002, Robert Reuter of Access
Systems (a consulting firm), submitted an expert report on behalf of the
plaintiffs.

Specific to GPTC, Mr. Reuter stated that GPTC showed a "consistent
pattern of failure to provide compliant fixed route services and
compliant complementary paratransit services including, but are not
limited to, the following:

a.  "Scheduled rides more than an hour before or an hour after the
    requested pickup time;

b.  "Picked riders up significantly later than their scheduled pick-up
    time;

c.  "Repeatedly failed to pick up riders for scheduled trips;

d.  "Shut down the reservations system prior to the close of normal
    business hours;

e.  "Refused to allow riders to schedule a paratransit ride during its
    regular hours of operation despite the ride being requested at least
    a day in advance;

f.  "Failed to properly train its personnel in the proper operations of
    its vehicles and equipment, including use of the wheelchair lifts,
    tie-downs and other safety-related equipment on its transportation
    vehicles;

g.  "Failed to properly train its personnel in providing requested
    assistance to any passenger with disabilities; and

h.  "Failed to train its personnel to treat passengers with disabilities
    in a respectful and courteous manner."

He also stated that: "GPTC has consistently failed to exercise
sufficient oversight of the subcontractors that provide complimentary
\[sic\] paratransit services on its behalf." [^1]

The lawsuit is still pending.

Telephone Interviews with Customers & Agency Personnel

As part of the review, the team leader contacted individuals who are
users or agency representatives to discuss their impression of the ADA
Complementary Paratransit service provided by GPTC.

An agency representative from Everybody Counts, and representing
[Americans with Disabilities for Attendant Programs
Today](http://g.msn.com/9SE/1?http://www.adapt.org/&&DI=293&IG=f63e61a2-9559-4a35-bf2e-37da8cd2f444&POS=1&CM=WU&CE=1)
(ADAPT), said that many people rely on paratransit services provided by
GPTC and others. He said one problem is that there appears to be no real
mechanism for addressing complaints and that the transit agency needs to
make the process better known so people who do have problems with
service know how to voice their concerns. He also stated that in the
past, service was very restricted and the private non-profit contractor
appeared to serve its own clients first, to the exclusion of ADA
Complementary Paratransit passengers.

He also said that the eligibility process is cumbersome, that people
have to come in to fill out an application and that GPTC does not
provide transportation to the appointment. He said that denials are
still happening and that there are some late pick-ups and some long
rides. He indicated that there is sense that lifts are not reliable (but
he wasn't sure if that was a comment abut fixed route or paratransit
service).

Another individual from the Mayor's Organization on Disabilities said
that transportation has gotten better recently and it is not a regular
topic of discussion at her group's monthly meetings. She indicated that
the Mayor's group has not been officially designated as the grievance
panel for ADA-related issues. She also commented that public education
and information about GPTC's ADA-related service is needed because most
people don't know about it.

A regular rider had good things to say about the service, commenting
that the drivers and vehicles are very nice. She said that while she
does arrive on time for her appointments, she often finds that service
is very late for the pick-ups. She attributes this to times when
substitute drivers are working. She said her regular drivers set up
their rides in a particular order, but the substitute driver might order
the trips differently. She said that sometimes drivers have several
pick-ups scheduled at the same time and it's up to them to figure out
how to get everyone to their destinations on time. She also noted that
she is usually unable to get a very early appointment because of the
number of early morning dialysis trips.

Complaints on File with GPTC

In order to further identify issues of concern to ADA customers, the
review team examined GPTC's ADA Complementary Paratransit service
complaint files. GPTC recently separated complaints about paratransit
and fixed route service (see Consumer Complaint form included in
Attachment D). At the time of the review, the ADA Complementary
Paratransit complaint file contained only one complaint, which concerned
a late pick-up.

Prior to the separation of fixed route and paratransit complaints, GPTC
filed complaint records in the personnel files of employees.
Additionally, older complaint records were stored in GPTC's ADA customer
files, which contain documentation of eligibility determinations and
other records. For a more complete picture of customer complaints
regarding the ADA Complementary Paratransit service, the review team
examined all employee and customer files.

Only one complaint pertaining to the ADA Complementary Paratransit
service was identified in the employee files. The complaint concerned a
customer's difficulty with placing a request on a Saturday, when the
GPTC dispatcher handles trip reservations, for a trip the following
Monday. Two complaints filed by the same customer and dating back to the
beginning of the direct provision of ADA Complementary Paratransit
service by GPTC, were located in the customer files. One of these
complaints concerned a dispute as to whether a trip was a customer
no-show or a missed trip. The other was more of an incident report than
a complaint, and concerned the customer's desire to pay paratransit
fares by the week rather than by the trip.

# Summary of Findings

The following summarizes the findings made as a result of the review.
Please note that findings do not necessarily denote deficiencies, but
are statements of observations made at the time of the compliance
review. The bases for these findings are addressed in other sections of
this report. The findings should be used as the basis for any corrective
actions proposed by GPTC. Recommendations are also included in the
report for GPTC's consideration in developing corrective actions.

On the whole GPTC managers appear to do a good job providing service
given its current resources. However, the level of service provided is
relatively low compared to its peers (only about 25-27 trips per day,
about 15% of those of its peers). Several non-profit social service
agencies currently provide paratransit services for their clients;
however, there is concern that one or more of these programs will cease
operating and many of their clients would become GPTC service users. If
demand increases as expected then the capacity of the ADA Complementary
Paratransit service will have to expand significantly. Service appears
to have improved since GPTC took operations in-house in 2000. Throughout
the on-site work and in this report, the review team evaluated the
current service, while also discussing with GPTC staff some options for
future service expansion should demand increase.

A. Findings Regarding Regulatory Service Criteria

1.  GPTC does not appear to have any capacity constraints with respect
    to service area, fare, trip purpose or days and hours of service.

B. Findings Regarding ADA Complementary Paratransit Eligibility

[]{.mark}

1.  Since February 2002, all 64 applicants for ADA Complementary
    Paratransit service have been determined eligible. As of April 2003
    there were 329 people eligible for service.

2.  GPTC does not include interviews or functional assessments as part
    of its eligibility process. As a result, some individuals who are
    able to independently use accessible fixed route service may be
    incorrectly determined eligible for ADA Complementary Paratransit
    service.

3.  GPTC does not have a policy concerning the youngest age at which a
    child may ride independently on fixed route and ADA Complementary
    Paratransit service. Absence of a clear policy could result in
    denying ADA Complementary Paratransit service to eligible children
    who are old enough to independently use fixed route service.

4.  On average GPTC makes eligibility determinations within 17 days of
    receipt of the application; however, the range is from 1 to 48 days.
    Although the ADA eligibility determination process is a relatively
    simple one, it took more than 21 days to review almost one-third of
    the applications. GPTC staff indicated that presumptive eligibility
    is granted to all applicants who have not received a determination
    within 21 days of submitting a completed application until an
    eligibility determination of is made.

5.  GPTC requires ADA-eligible passengers to acquire a photo I.D. card.
    Although the card is free, passengers are required to book and pay
    for their own ride to the Fourth Street terminal. The discussion on
    49 CFR 37.125 indicates that the entity may not impose unreasonable
    administrative burdens on applicants and that the process may not
    involve \"user fees\" or \"application fees\" to the applicant. The
    fare charged for the trip to obtain the ID card required by GPTC
    could be considered an application user fee.

6.  The grievance policy developed in response to the Triennial Review
    has not been fully implemented. As a result, GPTC did not have an
    administrative appeal process as required by 49 CFR 37.125(g) at the
    time of the review.

7.  GPTC has a suspension policy for riders in which eight no-shows in a
    12-month period could result in a 30-day suspension. GPTC has not
    suspended any riders for excessive no-shows recently. Nevertheless,
    this policy's threshold for potential suspension may be an overly
    restrictive interpretation of the DOT ADA regulations. Appendix D of
    49 CFR Part 37 indicates that suspensions of eligibility for
    no-shows are intended to prevent a "pattern or practice of
    'no-shows.'" It is further noted, "a pattern or practice involves
    intentional, repeated or regular actions, not isolated, accidental
    or singular incidents."

8.  The ADA Complementary Paratransit application form includes a
    section related to functional assessments and interviews, which are
    not currently part of the eligibility process. It also includes a
    statement asking the person whether he/she wishes to appear, will
    send someone else or waives the right to appear. These portions of
    the application could cause confusion and unnecessary effort in
    completion of the application and be an impediment to applying for
    service.

9.  GPTC's approval letter is confusing in that it also includes
    information that would pertain to persons who were either found to
    be ineligible or conditionally eligible. This confusion could delay
    eligible riders in using the service.

10. Also, the approval letter has a section under eligibility
    determination called, "Personal Care Attendant (PCA) is required."
    Although 49 CFR 37.125(i), permits the transit agency to require the
    applicant to indicate whether or not he or she travels with a PCA,
    the transit agency may not require a person to travel with a PCA.

C. Findings Regarding Telephone Access, Trip Reservations, Scheduling,
and Dispatching

1.  GPTC does not have a telephone management system. Currently, GPTC
    does not appear to have capacity constraints related to telephone
    access; however that observation could not be quantified and
    confirmed.

2.  The ADA Coordinator sometimes schedules trips at the same time on
    the same vehicle in two different locations. As a result, it may be
    difficult for the driver to pick up both customers within the
    20-minute on-time pick-up window.

3.  GPTC does not record requested trip times and trip offers to
    customers other than for scheduled trips. GPTC does not record trip
    requests as either for appointments or pick-ups.

4.  GPTC appears to have a small number of denials each month.

5.  GPTC does not appear to count denials in a manner consistent with
    the regulations and does not have a clear procedure for counting the
    trip denials.

-   GPTC records a trip denial as a customer declining a time offered
    other than the requested time. This definition includes times
    offered within one hour of the requested time, which could be
    considered customer refusals rather than denials.

-   GPTC does not record trip offers made more than one hour from the
    customer's requested time as denials if the customer accepts the
    request.

D. Findings Regarding Service Operation

a\. On-Time Performance

1.  GPTC does not appear to have a substantial number of significantly
    late pick-ups. Based on a sample of 155 trips, 97% of pick-ups were
    made early or no more than 15 minutes after the end of the pick-up
    window and 86% of the trips were early or on time. Only 1% of
    passengers were picked up more than 31 minutes after the pick-up
    window and none were picked up more than an hour after the pick-up
    window.

2.  GPTC does not track on-time performance for meeting appointment
    times.

3.  GPTC does not appear to have a substantial number of missed trips.
    GPTC reported 7 missed trips during the nine-month period from April
    2002 through December 2002, and no missed trips for the period
    January through March 2003. No missed trips were identified in the
    review team sample of 195 scheduled trips from driver's Logs for 7
    days in March of 2003.

4.  When trips are rescheduled during the service day because a customer
    is unable to travel at the scheduled time due to a medical
    condition, GPTC does not create a new trip record. As a result, the
    actual time of performance of the trip is inaccurate and the trip
    duration may be overstated.

5.  GPTC's policy for no-shows is to wait five minutes after the
    scheduled time before declaring the customer a no-show. Staff
    described the practice as waiting until five minutes after the
    pick-up window (15 minutes after the scheduled pick-up time). Both
    the policy and practice could delay drivers and customers in serving
    other trips.

b\. Analysis of Trip Length

1.  The travel time analysis indicates that there are no capacity
    constraints related to ADA Complementary Paratransit trip length.

2.  Analysis of a sample of 155 trips provided in March 2003 indicated
    an average trip length of 24 minutes. Most trips (74%) were
    completed in 30 minutes or less; 99% were completed in 60 minutes or
    less. Of the 2 trips with travel times of more than 60 minutes, the
    first was completed in 65 minutes, the second in 70 minutes.

3.  When the actual travel times of 18 ADA Complementary Paratransit
    trips provided during March 2003 were compared to the estimated
    travel times for comparable fixed route trips, ADA Complementary
    Paratransit travel times were shorter in all cases. The average
    travel time for the sample of ADA Complementary Paratransit trips
    was 27 minutes, while the average fixed route travel time was 65
    minutes. Fixed route trips involved an average of 1 transfer and 8
    minutes of walking time to and from bus stops. ADA Complementary
    Paratransit travel times ranged from 20% to 90% of the fixed route
    travel time for comparable trips, or 40% on average.

4.  GPTC's travel time standard establishes a maximum ride time of 30
    minutes for a local trip and 60 minutes for an express trip (a trip
    to a destination within the ADA service area but outside of the City
    of Gary). This standard is based on scheduled fixed route travel
    times for each type of trip. Only 1 of the 18 trips in the sample,
    or 6%, exceeded the GPTC standard.

E. Findings Regarding Resources

1.  Within the limits of the overall transportation budget, financial
    support does not currently appear to be an impediment to the
    delivery of ADA Complementary Paratransit services. However, that
    could change if the demand for ADA Complementary Paratransit
    increases, as is expected.

2.  Current service appears to serve a small portion of the potential
    market for ADA Complementary Paratransit service. Service demand
    could rise sharply if other service providers reduce their level of
    service and the market becomes more aware of GPTC services.

3.  Driver assignments appear to be adequate to serve current demand for
    passenger service.

4.  The fleet assigned for use for ADA Complementary Paratransit
    Services appears to limit access for people who are ambulatory but
    have a mobility impairment. The design of the vehicle entrance makes
    entry and egress quite difficult and it is virtually impossible to
    secure two wheelchairs in the back of the van.

# Compliance with Regulatory Service Criteria

The Background section of this report described the fixed route and ADA
Complementary Paratransit services provided by GPTC. This section of the
report compares the fixed route and ADA Complementary Paratransit
service criteria to the regulatory criteria for ADA Complementary
Paratransit services contained in 49 CFR section 37.131(a), and (c)
through (e). These service criteria address: service area, fares, trip
purpose, and days and hours of operation. The remaining service criteria
-- response time and capacity constraints -- are addressed in other
sections of this report.

Service Area

Section 37.131(a) of the DOT's regulations implementing the ADA requires
that complementary paratransit service be provided, at a minimum, in all
areas that are within ¾ of a mile of

non-commuter public fixed route services. As described in the background
section, Gary provides ADA Complementary Paratransit throughout the City
of Gary and along ¾-mile corridors for those routes extending beyond the
City. In fact, during the discussion it was discovered that GPTC was
serving an area well beyond its defined service area.

Fares

Section 37.131(c) of the DOT ADA regulations requires that complementary
paratransit service fares be no more than twice the base, non-discounted
fixed route fare for a comparable trip. Regular fixed route fares are
\$1.25 for adults and 60 cents for seniors and people with disabilities.
Transfers are \$0.15 for adults and \$0.10 for seniors and people with
disabilities. Express routes are \$2.00. ADA Complementary Paratransit
fares are \$2.50 for local service and \$4.00 for express service.
Accordingly the ADA Complementary Paratransit fares equal twice the base
fixed route fares as allowed by the regulations.

Trip Purpose

Section 37.131(d) of the DOT ADA regulations requires that there be no
restrictions or priorities based on trip purpose in the provision of ADA
Complementary Paratransit service. None of the public information
describing GPTC's service indicates that trip restrictions or priorities
are employed. Riders and agency staff contacted also did not indicate
any issues with trip purpose restrictions or priorities. Observations of
the reservations and scheduling processes, described later in this
report, also indicated that trip requests are handled without any
restrictions or priorities.

Days and Hours of Operation

Section 37.131(e) of the DOT's regulations implementing the ADA requires
that complementary paratransit service be available during the same days
and hours as the fixed route service. GPTC's fixed route bus service is
available from 5:15 a.m. (Route #17 South Broadway Express) until 11:04
p.m. (Route #16 Colonial Gardens,), although most routes conclude after
the evening rush hour. Service is provided Monday through Saturday;
there is no service on Sundays and holidays, except for the Martin
Luther King Holiday. GPTC's ADA complementary paratransit service begins
at 4:50 a.m. and the last pick-up is at 11:00 p.m., Monday through
Saturday and on the Martin Luther King holiday. It appears that GPTC ADA
Complementary paratransit service is available during the same hours and
days as fixed route service.

Findings

1.  GPTC does not appear to have any capacity constraints with respect
    to service area, fare, trip purpose or days and hours of service.

Recommendations

1.  None.

# Observations Regarding ADA Complementary Paratransit Eligibility Determinations 

The review team assessed GPTC's ADA Complementary Paratransit
eligibility determination process in order to establish whether or not
determinations are being made in a way that accurately reflects the
functional abilities of applicants. The time required to process
requests for eligibility also was reviewed. The assessment was conducted
as follows:

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

-   Eligibility issues cited in formal ADA complaints on file at FTA
    were reviewed.

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

-   Eligibility determination outcomes for all applications filed during
    the past year were reviewed.

-   The processing times for all applications filed during the last year
    were noted.

Consumer Comments

One customer commented that she was told that her 4-year-old daughter
was not eligible to apply for ADA Complementary Paratransit because of
her age. Another said he thought people had to come into the office for
an in-person interview in order to complete the eligibility
determination process. He felt this was too burdensome.

Overview of the Eligibility Determination Process

Most customers who are interested in becoming eligible for ADA
Complementary Paratransit service begin the process with a call to the
ADA Coordinator (sometimes referred to as the ADA Scheduling Clerk).
During the initial call, she provides background information about the
ADA service and informs the caller about how to use the service. She
also tries to get a sense of whether or not they can use fixed route
service. She then sends an application to anyone who wishes to apply for
eligibility. A copy of the five-page application is included in
Attachment E. Also included is a sample approval letter.

Applications are returned to the 100 W. Fourth Avenue address. The ADA
Coordinator records the date it was received and reviews all
applications for completeness. If something minor is missing, she will
call to collect the information. If there are more substantial
omissions, she will return the form requesting the missing information.
If approved, the approval date is added and an ID number is assigned.
The Director of Transportation signs the approval letters. The approval
letter is then sent and the applicant is advised of the need to obtain a
photo ID card from the main terminal on W. Fourth Avenue. The photo ID
is free; however, the passenger is required to pay for the trip to get
the ID card.

All applicants since February 2002 have been approved for full
eligibility. There are currently 329 people eligible to use the ADA
service. Since February 2002, 64 people have been determined eligible.
Of those 35 have an ID card and 29 have not received an ID card.

There has been no formal re-certification process. However, during the
past year, the ADA Coordinator has been calling all registrants to
verify their contact information and to determine whether they wished to
remain on the certification list. As of March 2003, she had completed
most of the calls.

Application Form

Basic information about the passenger and the person's functional
abilities is requested on the application form. There is no formal
interview or functional assessment at this time; however, in the middle
of page 4, the applicant is asked to sign a statement verifying that the
information provided is accurate. The statement is then repeated almost
verbatim and then additional information is provided stating:

*"I consent to the Applicant's interview and the functional assessment
of his/her travel abilities and limitation to determine ADA Paratransit
Service eligibility. I acknowledge that I may be present during the
interview and any functional assessment."*

The form then asks the applicant to check whether he/she will be
present, if they designate someone else to go to the
interview/assessment or waive the right to an assessment.

This portion of the application was discussed with staff during the site
visit. Having this type of statement in the application would lead the
person to believe that they will be required to be interviewed or go
through a functional assessment. Unless these procedures become part of
the assessment process, it appears unnecessary to include them in the
application. Additionally, the purpose of an interview or functional
assessment is to assess the individual's ability to use fixed route
service and whether or not they meet the criteria for ADA Complementary
Paratransit service. It is unclear how attendance at an interview by
someone other than the applicant would serve the purpose of the
interview. It is also unclear why someone would be asked to waive his or
her right to an interview or assessment. These items were removed from
the application while the review team was on site.

The name of, and contact information for, a professional who is
qualified to attest to the person's functional abilities is requested on
page 5 of the application form. Verification by the professional of the
applicant's functional abilities is not requested on the form. The
form's purpose appears to be to be limited to identification of a
professional familiar with the applicant's functional abilities.

Approval Letter

The approval letter appears to be unclear. The approval letter includes
a checklist of eligibility determination. However, the list also
includes "capable of using GPTC Fixed Route Service" and "Incomplete
application." Presumably these two outcomes would result in a person
being deemed not eligible for ADA Complementary Paratransit, but could
be the basis for either denying eligibility or granting conditional
eligibility. The next paragraph also begins, "If you are determined to
be eligible..." Addressing people who are not eligible for service in a
letter designed to notify people that they are eligible could be
confusing to the recipient. Separate letters for approved applications
(conditional, full, temporary) and denied applications or requests for
more information could help to eliminate this potential confusion.

Also, the approval letter has a section under eligibility determination
called, "Personal Care Attendant (PCA) is required." Although 49 CFR
37.125(i), permits the transit agency to require the applicant to
indicate whether or not he or she travels with a PCA, the transit agency
may not require a person to travel with a PCA. The approval letter could
be revised to indicate that the client is authorized to travel with a
PCA rather than indicating that one is required in order to avoid
potential confusion.

Determination Statistics and Outcomes

Section 37.125(c) of the DOT ADA regulations provides that presumptive
eligibility must be granted to applicants if a determination cannot be
made within 21 days of the receipt of a "completed application." As
mentioned above, all applicants who completed applications were
determined eligible to use ADA Complementary Paratransit service. The
team reviewed all applications received since February 2002 to analyze
how long it took to complete the eligibility determination process.

All 64 applications, received since February 2002, were analyzed to
determine how long it took to complete the eligibility determination
process. The review revealed that on average, applications were
processed in 17 days. However, the review period ranged from 1 to 48
days and almost one-third of the applications (21 out of 64) took more
than 21 days. The ADA Coordinator indicated that presumptive eligibility
was afforded to persons whose applications were not processed in 21
days.

Transporting Children

There was one complaint that included a comment that GPTC had told her
that her 4-year-old daughter was too young to be eligible for ADA
Complementary Paratransit (because she was too young to ride without an
adult).

Section 37.123(e) of the regulations states: "The following individuals
are ADA paratransit eligible: (1) Any individual with a disability who
is unable, as the result of a physical or mental impairment (including a
vision impairment), and without the assistance of another individual
(except the operator of a wheelchair lift or other boarding assistance
device), to board, ride, or disembark from any vehicle on the system
which is readily accessible to and usable individuals with disabilities.
Presumably infants and toddlers, because of their age-related
development and not as a result of their disability, would be unable to
independently use accessible fixed route vehicles, and accordingly,
would not be eligible for ADA Complementary Paratransit service.

However, with older children, it is less clear. Some parents may feel
comfortable allowing their children to ride independently on some trips
at an early age. It is not uncommon to see 6 or 7-year old children
independently using fixed route service. Section 37.121 of the
regulations states that: (a) Except as provided in paragraph (c) of this
section, each public entity operating a fixed route system shall provide
paratransit or other special service to individuals with disabilities
that is comparable to the level of service provided to individuals
without disabilities who use the fixed route system." If a child is old
enough to travel independently and is eligible for ADA Complementary
Paratransit service, the above citation indicates that the transit
operator is required to provide him or her with comparable service. That
is travel restrictions by age for such an individual should be
comparable to those for people without disabilities who use the fixed
route service.

In discussions with GPTC's managers, it appears that GPTC does not have
an age policy for fixed route service but that it is GPTC's practice to
permit 6-year-olds to ride independently on fixed routes. GPTC has no
formal policy covering the age at which children with disabilities may
be determined eligible to ride ADA Complementary Paratransit service.

No-Show Suspension Policy

According to the ride guide, a no-show is defined as a trip in which the
passenger is not present at the confirmed pickup time and location when
a Paratransit vehicle arrives to provide service. When a passenger
cancels a trip with less than one-hour notice, it is also classified as
a no-show. If a passenger appears to be a no-show, the driver calls the
dispatcher, who will attempt to reach the passenger by telephone. If
there is no answer, the driver will be instructed to wait 5 minutes
before departing. Part of the procedure is for the dispatcher to log
no-shows on a no-show form (see Attachment D).

According to the rider guide, passengers who accumulate eight no-shows
during a 12-month period will be ineligible to use Paratransit service
for 14 days, beginning two days after the date of the last no-show. Any
additional no-shows after the 14-day suspension will result in a 30-day
suspension of service. After the fourth no-show within a 12-month period
is assessed, the passenger will be notified in writing by GPTC that
his/her ridership privileges are in jeopardy. (See further analysis of
no-shows in Section VII.)

Appeals Process and Materials

According to page 15 of the rider's guide (*Meeting the Transit
Challenge*), grievances should be submitted in writing or on cassette
tape. If the problem cannot be resolved, the grievance may be appealed
to the "Accessible Transportation Advisory Committee." However, this
group does not appear to be active. During the site visit, GPTC staff
indicated that the Mayor's Organization on Disabilities was now
designated to be the grievance board if someone disagreed with the
outcome of their eligibility determination process (or other operational
issues such as a service suspension). However, the president of the
Mayor's Organization indicated that there was no formal agreement for
the Mayor's Organization to act as GPTC's ADA grievance board. This was
also cited as an issue in the recent Triennial Review.

Findings

1.  Since February 2002, all 64 applicants for ADA Complementary
    Paratransit service have been determined eligible. As of April 2003
    there were 329 people eligible for service.

2.  GPTC does not include interviews or functional assessments as part
    of its eligibility process. As a result, some individuals who are
    able to independently use accessible fixed route service may be
    incorrectly determined eligible for ADA Complementary Paratransit
    service.

3.  GPTC does not have a policy concerning the youngest age at which a
    child may ride independently on fixed route and ADA Complementary
    Paratransit service. Absence of a clear policy could result in
    denying ADA Complementary Paratransit service to eligible children
    who are old enough to independently use fixed route service.

4.  On average GPTC makes eligibility determinations within 17 days of
    receipt of the application; however, the range is from 1 to 48 days.
    Although the ADA eligibility determination process is a relatively
    simple one, it took more than 21 days to review almost one-third of
    the applications. GPTC staff indicated that presumptive eligibility
    is granted to all applicants who have not received a determination
    within 21 days of submitting a completed application until an
    eligibility determination of is made.

5.  GPTC requires ADA-eligible passengers to acquire a photo I.D. card.
    Although the card is free, passengers are required to book and pay
    for their own ride to the Fourth Street terminal. The discussion on
    49 CFR 37.125 indicates that the entity may not impose unreasonable
    administrative burdens on applicants and that the process may not
    involve \"user fees\" or \"application fees\" to the applicant. The
    fare charged for the trip to obtain the ID card required by GPTC
    could be considered an application user fee.

6.  The grievance policy developed in response to the Triennial Review
    has not been fully implemented. As a result, GPTC did not have an
    administrative appeal process as required by 49 CFR 37.125(g) at the
    time of the review.

7.  GPTC has a suspension policy for riders in which eight no-shows in a
    12-month period could result in a 30-day suspension. GPTC has not
    suspended any riders for excessive no-shows recently. Nevertheless,
    this policy's threshold for potential suspension may be an overly
    restrictive interpretation of the DOT ADA regulations. Appendix D of
    49 CFR Part 37 indicates that suspensions of eligibility for
    no-shows are intended to prevent a "pattern or practice of
    'no-shows.'" It is further noted, "a pattern or practice involves
    intentional, repeated or regular actions, not isolated, accidental
    or singular incidents."

8.  The ADA Complementary Paratransit application form includes a
    section related to functional assessments and interviews, which are
    not currently part of the eligibility process. It also includes a
    statement asking the person whether he/she wishes to appear, will
    send someone else or waives the right to appear. These portions of
    the application could cause confusion and unnecessary effort in
    completion of the application and be an impediment to applying for
    service.

9.  GPTC's approval letter is confusing in that it also includes
    information that would pertain to persons who were either found to
    be ineligible or conditionally eligible. This confusion could delay
    eligible riders in using the service.

10. Also, the approval letter has a section under eligibility
    determination called, "Personal Care Attendant (PCA) is required."
    Although 49 CFR 37.125(i), permits the transit agency to require the
    applicant to indicate whether or not he or she travels with a PCA,
    the transit agency may not require a person to travel with a PCA.

Recommendations

1.  GPTC should consider including interviews and/or in-person
    functional assessments as part of its eligibility determination
    process to be sure that applicants are being screened appropriately.

2.  GPTC should consider establishing a policy for how young a passenger
    may be to ride fixed route and paratransit services independently,
    and by extension, the youngest age at which a child may be eligible
    to use ADA Complementary Paratransit.

3.  GPTC should modify its eligibility determination process so that
    determinations are made within 21 days.

4.  GPTC should provide a free ride to get the required photo I.D. card.

5.  If GPTC institutes interviews and/ or in person assessments as part
    of its eligibility process it should consider taking the photos for
    the photo ID at that time to avoid scheduling an additional trip for
    eligible riders. IDs could be mailed with positive eligibility
    determinations.

6.  GPTC must establish an administrative appeal process to address
    eligibility denials passenger service suspensions or other customer
    sanctions.

7.  GPTC should consider revising its suspension policy for no-shows so
    that, when enforced, the policy does not unduly penalize riders.

8.  GPTC should revise its eligibility determination form to reflect the
    process used to determine eligibility. The form could either request
    a health care professional to comment on the person's ability to use
    fixed route transit as part of the application process, or request
    the name of the health care professional for follow-up by GPTC.

9.  GPTC should consider developing separate letters to cover persons
    who are fully eligible, conditionally eligible or not eligible to
    avoid including potentially confusing information that does not
    pertain to that applicant.

10. The approval letter should be revised to indicate that the client is
    authorized to travel with a PCA rather than indicating that one is
    required.

# Observations Regarding Telephone Access, Trip Reservations, Scheduling, and Dispatching

[]{.mark}

The purpose of the review team's assessment of the telephone system and
trip reservation and scheduling process was to determine whether riders
who use GPTC's ADA Complementary Paratransit service can effectively
reach reservations staff to make their trip request. Information
reviewed and observations made on telephone system capacity, trip
reservations, and scheduling included:

-   Consumer interviews, review of complaints filed with FTA, and review
    of complaints filed with GPTC

-   A review of GPTC's policies and procedures for taking trip
    reservations and scheduling trips for ADA Complementary Paratransit
    service

-   Direct observations of call-taking practices at the GPTC office

Consumer Comments

One customer commented that sometimes trip requests are denied, but that
has improved in the past two years since GPTC took control of the
operation. There also were stated concerns about how the schedules were
developed and the amount of latitude afforded to drivers who may not
arrive on-time for a pick-up because of multiple trips being scheduled
for the same vehicle at the same time. Some customers were concerned
that they were being picked up late (past the pick-up window), although
usually the drop-off was on time. The problem, they said, was not
knowing how late the driver would be and whether they would actually be
on time for an appointment.

Driver Interviews

During the ride-alongs and at the base facility, the review team
interviewed drivers about reservations, scheduling, dispatching,
training, and other operational aspects of service. The drivers
generally felt that the schedules were all right, although sometimes two
trips are scheduled for the same pick-up time in two different
locations. Drivers also felt free to adjust the schedule to make it work
for them.

Policies and Procedures

The ADA Coordinator has two telephone lines, voice mail, and a TDD
machine. There is no call management system or tracking of call
disposition. After-hours calls automatically roll to voice mail.

Trip Requests

Trip requests are made by calling the ADA Coordinator between 8:00 a.m.
and 4:30 p.m. Monday through Friday, and by calling dispatch on
Saturdays. On Sundays, holidays, and after-hours, trip requests may be
left on voice mail. Reservations are accepted from one to seven days in
advance. Most GPTC trips are regularly recurring trips, commonly
referred to as subscription or standing order trips. These trips are
recorded in a text table and carried forward for each service day from
the same weekday for the previous week. When accepting trip reservations
GPTC does not record requested pick-up or drop-off times. If the
requested pick-up time can be served the trip is scheduled. The trip
request is recorded on a reservation form and added to the drivers log
for the service day (see Attachment D). If a drop-off is requested a
pick-up time one hour before the drop-off time will be scheduled. There
is no provision on the reservation form or driver's log to identify that
the trip has been scheduled to meet an appointment time.

Denials

If three people are already scheduled for the requested pick-up time,
and as a result the trip is not available, alternative times are offered
to the customer up to two hours before and two hours after the requested
pick-up time. If the customer accepts the requested time it is recorded
as a scheduled trip. If the customer declines the requested time it is
recorded as a denial. GPTC does not record the time offered to the
customer when the trip is declined.

Cancellations

It is GPTC's practice to classify a customer request for a trip
cancellation made one hour or more before the scheduled pick-up time as
a cancellation. GPTC has forms to record requested trip cancellations.
The review team observed that not all cancellations are recorded on the
cancellation forms. Dispatchers sometimes do not complete the forms but
instead will record the cancellation on the dispatcher's copy of the
driver's log. If the cancellation request is received before the driver
begins route service the dispatcher will record the cancellation on the
driver's copy of the driver's log as well as their own.

In one instance the form, apparently completed by a dispatcher,
cancelled only one leg of a round trip on the cancellation form but
cancelled both on the dispatcher's Driver's Log, presumably at the
customers request. Although, unclear recording of this cancellation did
not appear to impact customer service, inconsistent use of the
cancellation forms can lead to errors and make it difficult to track
service performance.

No-Shows

GPTC described a "No Show" as occurring when the customer is not
available for pick-up within the pick-up window and, as a result, the
trip is not served or when the customer cancels the trip less than one
hour before the scheduled pick-up time.

GPTC's practice for classifying a customer as a no-show for a given trip
is initiated by the driver. The driver waits until the end of the
pick-up window (10 minutes after the scheduled pick-up time). If the
customer has not appeared by that time the driver contacts the
dispatcher. The dispatcher tries to reach the customer by telephone. If
the customer cannot be reached he/she is classified as a no show and the
driver is released to proceed to the next stop on the route. This
practice can delay the driver by as much as 25 minutes. Should the
driver arrive before or at the beginning of the pick-up window (10
minutes before the scheduled pick-up time), they would have to wait 20
minutes until the end of the pick-up window and then an additional
period of time to attempt to communicate with the customer through the
dispatcher (say 5 minutes). An alternative approach might be for the
driver to contact the dispatcher after the pick-up window begins (no
earlier than 10 minutes before the scheduled pick-up time) as soon as it
appears that the customer may be a no show (after waiting for several
minutes). Then GPTC would continue with its procedure for declaring a
customer a no show for the particular trip. This approach could reduce
the potential delay to the driver to less than 10 minutes.
Implementation of this approach would require clear communication with
customers in advance reminding them that they are to be ready for
pick-up throughout the 20 minute pick-up window and advising them of the
revised no-show procedures.

Dispatchers use two-way radios at a base station to handle both fixed
route and ADA Complementary Paratransit service. Paratransit drivers are
required to contact dispatch upon arriving to pick-up and drop-off
passengers. The time the passenger boarded is recorded, along with the
fare. If the customer is a no-show, the driver completes the no-show
form (see Attachment D). If a person cancels, the dispatcher is supposed
to complete a Cancellation Form (see Attachment D), although sometimes
the cancellation is simply noted on the duplicate driver's log.

Missed Trips

A missed trip is recorded when through no fault of the passenger, GPTC
fails to provide service for a scheduled trip.

Observations of GPTC's Telephone System, Reservations, Scheduling, and
Dispatching Practices

Trip Requests

Because most trips are standing order trips, call volume appears to be
very low. While on-site, the review team did not observe any new
reservation requests. The ADA Coordinator (with assistance from another
support staff member) was able to address all calls without difficulty.
On Sundays and holidays, reservations may be left on voice mail. The ADA
Coordinator checks the voice mail and advises dispatch of any
last-minute schedule changes.

Denials

Denials as measured by GPTC may include trip refusals by the customer.
49 CFR 37.131(b)(2) states, "The entity (GPTC) may negotiate pickup
times with the individual, but the entity shall not require an ADA
paratransit eligible individual to schedule a trip to begin more than
one hour before or after the individual's desired departure time." If
the service provider offers the customer a trip that will meet the
customer's needs within one hour of the requested pick-up time this is
commonly categorized as a trip refusal by the customer rather than a
denial of service by the operator. A trip offer, even within one hour of
the requested pick-up time, which would cause a customer to be late for
an appointment or require a customer to leave before the end of an
activity, such as work, school or a medical appointment, would not be
considered an offer that meets the customer's needs.

Also denials as reported by GPTC may omit trips commonly counted as
denials. Pick-up times offered more than one hour from the requested
pick-up time are typically recorded as denials, even if the trip is also
accepted by the customer and also counted as a scheduled trip. Such a
trip offer is considered a capacity constraint in accordance with 49 CFR
37.123 (f) and the above cited reference on scheduling trip requests.

Based upon review team observations and discussions with GPTC staff it
appears that occurrences of both under-counting and over-counting of
denials is small and will be off setting to some degree. Accordingly,
although GPTC does not report trip denials as they should, the number of
denials reported appears to be representative of the number of denials
if reported as discussed above.

Cancellations

GPTC has forms to record requested trip cancellations. However, not all
cancellations are recorded on the cancellation forms. Dispatchers
sometimes do not complete the forms but will record the cancellation on
the driver's log. If the cancellation request is received before the
driver begins route service the dispatcher will record the cancellation
on the driver's copy of the driver's log.

Changes in trip requests are not consistently documented. Changes are
sometimes documented on cancellation and reservations forms and
sometimes on the dispatcher's Drivers Log. In one case the form,
apparently completed by a dispatcher cancelled only one leg of a round
trip on the cancellation form but cancelled both on the dispatcher's
Driver's Log, presumably at the customer's request. Inconsistent use of
the cancellation forms can lead to errors and make it difficult to track
service performance.

GPTC reports cancellations in its Daily Activity report summary. Data
from these reports for the year 2002 appears in Table VII-1.

According to GPTC's report, 724, or 8.9% of 8,174 scheduled trips were
cancelled during 2002. Reported monthly cancellation rates ranged from
0% in August to 22.4% in December. Based upon the review teams analysis
of a sample of driver's logs for all scheduled trips for 7 days in early
March of 2003, 41 trips, or 21%, of a total of 193 trips requested, were
cancelled by customers. The apparent reason for this wide variation in
cancellations was the change in definition of trip disposition by GPTC.
According to GPTC managers, customer no-shows caused by medical
emergencies or similar problems had not been classified. These trips
appear as no penalty no shows in Table VII-1. Late in 2002 GPTC changed
the classification of these trips to Cancellations accounting for the
large monthly variation in cancellations.

Table VII-1. GPTC ADA Daily Activity Report Summary for 2002

  ---------------- ------------- ------------------- ------------- ------------ -------------
  **Month**        **Trips       **Cancellations**   **No Shows**  **No Penalty **Trips
                   Scheduled**                                     No Shows**   Completed**

  January          764           30                  10            70           654

  February         728           29                  17            108          574

  March            801           95                  15            77           614

  April            706           71                  14            0            621

  May              669           36                  18            3            612

  June             540           28                  9             0            503

  July             594           2                   14            2            576

  August           623           0                   9             1            613

  September        644           93                  10            0            541

  October          688           68                  6             88           526

  November         703           112                 5             0            586

  December         714           160                 11            0            543

  **Total**        **8,174**     **724**             **138**       **349**      **6,963**

  **Percentage**   ** **         **8.9%**            **1.7%**      **4.3%**     **85.2%**
  ---------------- ------------- ------------------- ------------- ------------ -------------

No-Shows

As indicated in Table VII-1, GPTC reported 138 no shows or 1.7% of
scheduled trips during 2002. No shows ranged from 5 or 0.7% for November
2002, to 18 or 2.7% for May 2002. No customer no shows were noted in the
review team sample of 195 scheduled trips from driver's logs for the
sample days in March 2003.

Missed Trips

GPTC reported 7 missed trips in its quarterly reports to FTA for the
period April through December 2002. In GPTC's ADA Late Record Reports,
it cited no missed trips for the period January through March 2003. No
missed trips were noted in the review team sample of 195 scheduled trips
from driver's Logs for sample days in March 2003.

Findings

1.  GPTC does not have a telephone management system. Currently, GPTC
    does not appear to have capacity constraints related to telephone
    access; however that observation could not be quantified and
    confirmed.

2.  The ADA Coordinator sometimes schedules trips at the same time on
    the same vehicle in two different locations. As a result, it may be
    difficult for the driver to pick up both customers within the
    20-minute on-time pick-up window

3.  GPTC does not record requested trip times and trip offers to
    customers other than for scheduled trips. GPTC does not record trip
    requests as either for appointments or pick-ups.

4.  GPTC appears to have a small number of denials each month.

5.  GPTC does not appear to count denials in a manner consistent with
    the regulations and does not have a clear procedure for counting the
    trip denials.

6.  GPTC records a trip denial as a customer declining a time offered
    other than the requested time. This definition includes times
    offered within one hour of the requested time, which could be
    considered customer refusals rather than denials.

7.  GPTC does not record trip offers made more than one hour from the
    customer's requested time as denials if the customer accepts the
    request.

Recommendations

1.  As the system, and associated call volume grows, GPTC should
    consider installing a call management system to track calls.

2.  The ADA Coordinator should work with drivers and dispatchers to
    develop schedules that reflect the time-order pick-up of passengers,
    rather than relying on drivers to determine how to run a schedule.
    This will help to even out variations in service level when
    different drivers operate a particular route.

3.  GPTC should record all requested trip times, including appointment
    times, and trip offers to customers even if the trip is denied or
    refused. This will permit the measurement and documentation of
    denials and refusals.

4.  GPTC should eliminate denials by offering customers trips within one
    hour of the requested time and adding flexible service capacity as
    needed to serve those trips. Flexible capacity could be provided by
    using supplementary taxi or van service, using road supervisors, or
    providing and using "protect" drivers.

5.  GPTC should establish a written procedure for counting denials in
    accordance with 49 CFR 37.131(b)(2). When the requested trip time is
    not available, GPTC might consider offering customers trip times
    both before and after the requested time to assure the customer is
    offered a time which will permit him/her to reach a destination on
    time for an appointment or return from an appointment. When
    customers refuse to accept a responsive trip offer within one hour
    of the requested pick-up time it should be recorded as a customer
    refusal or some category other than a denial.

6.  GPTC should record trip offers made more than one hour from the
    customer's requested time as denials even if the customer accepts
    the request. The request can also be recorded as a scheduled trip.

7.  GPCT should carefully monitor any trip capacity denials to identify
    patterns of denials based on trip location, time of day or day of
    week.

# Observations Regarding Service Operation

The review team observed GPTC's operations to determine whether
requested trips are being served in a timely fashion and are not
excessively long. Information reviewed and observations on operations
and service delivery included:

-   Consumer interviews, review of complaints filed with FTA, and review
    of complaints filed with GPTC

-   Review of GPTC's Complementary Paratransit service policies and
    procedures

-   Observations of calls to the ADA Trip Scheduler

-   Interviews with drivers

-   Review of trip manifests and analysis of on-time performance

-   Analysis of ADA Complementary Paratransit service trip lengths

Consumer Comments

Two people said that there were problems with capacity, particularly in
the early morning when many dialysis trips are scheduled. One customer
also commented that pick-ups were often late (due in part to drivers
designing their own schedules) but that she usually arrived on time to
her destination. There also was a comment about some rides being long.

Driver Interviews

Drivers were asked about operational issues such as training, customer
interaction, on-time performance and travel time. Driver training was
not a concern to the drivers; however, it was noted that it is provided
when hired and then only at quarterly work schedule picks when training
updates are given, as needed. There are no regular safety meetings.
Drivers will assist passengers with fastening their seatbelts, as well
as securing wheelchairs. They also will assist passengers in and out of
vehicles. Although the service is curb-to-cub, they will assist
passengers to the door from time-to-time. As mentioned in the previous
section there were concerns expressed about multiple trips being booked
at the same time. Drivers felt that most passengers arrived at their
destinations within 30 minutes.

Service Policies and Procedures

GPTC provided the following information on service standards for ADA
Complementary Paratransit service in response to a request from FTA
prior to the review team's site visit.

-   ***On-Time Performance:*** "On-time performance is defined as: when
    the service is provided within a ten-minute window, either before or
    after the scheduled time of pickup. The goal is whenever possible to
    provide 100% of all trips scheduled on time. The standard is 95%
    on-time performance."

-   ***Travel Time:** "*The goal for travel time for ADA Paratransit is:
    all trips will be completed within thirty minutes (for local trips),
    or one hour (for express trips). This is the scheduled travel time
    on Local and Express Routes within the GPTC Fixed Route System."

Analysis of On-Time Performance

For purpose of measuring and reporting late pick-ups, GPTC considers the
requested drop off time for customers who have appointments or the
requested pick-up time for customers who do not have an appointment. If
a customer is dropped off before an appointment time, GPTC counts that
trip as on time, whether or not the pick-up was on time in accordance
with GPTC policy for on-time pick-ups. If the trip request is for a
pick-up, GPTC considers the trip on time if the customer is picked up
earlier than 10 minutes after the scheduled pick-up time or before the
end of the pick-up window. GPTC uses data collected on completed
driver's logs to monitor on-time performance. The driver's logs have
pre-recorded scheduled pick-up times. Whether the trip request is for an
appointment or pick-up is not recorded, and the requested pick-up time
is not recorded. If the pick-up time varies by 5 or more minutes from
the scheduled pick-up time, the driver will enter the actual pick-up
time on the driver's log. Drivers also record the odometer reading at
both the pick-up and drop-off locations, as well as the time when the
passenger is dropped off. Using this approach, GPTC reports on time
performance of 99.8% for the 12-month period from March 2002 through
February 2003 (see Table VIII-1).

[]{.mark}

Table VIII-1. On-Time Performance as Reported by GPTC

+----------------+-----------------+-----------------+----------------+
| **Month**      | **Completed     | **Late Trips**  | **Percentage** |
|                | Trips**         |                 |                |
|                |                 |                 | **On Time**    |
+----------------+-----------------+-----------------+----------------+
| March 2002     | 624             | 0               | 100%           |
+----------------+-----------------+-----------------+----------------+
| April 2002     | 617             | 3               | 99.5%          |
+----------------+-----------------+-----------------+----------------+
| May 2002       | 616             | 2               | 99.7%          |
+----------------+-----------------+-----------------+----------------+
| June 2002      | 503             | 0               | 100%           |
+----------------+-----------------+-----------------+----------------+
| July 2002      | 577             | 4               | 99.3%          |
+----------------+-----------------+-----------------+----------------+
| August 2002    | 613             | 5               | 99.2%          |
+----------------+-----------------+-----------------+----------------+
| September 2002 | 644             | 1               | 99.8%          |
+----------------+-----------------+-----------------+----------------+
| October 2002   | 578             | 0               | 100%           |
+----------------+-----------------+-----------------+----------------+
| November 2002  | 703             | 1               | 99.9%          |
+----------------+-----------------+-----------------+----------------+
| December 2002  | 714             | 2               | 99.8%          |
+----------------+-----------------+-----------------+----------------+
| January 2003   | 578             | 0               | 100%           |
+----------------+-----------------+-----------------+----------------+
| February 2003  | 578             | 0               | 100%           |
+----------------+-----------------+-----------------+----------------+
| Total          | 7,345           | 18              | 99.8%          |
+----------------+-----------------+-----------------+----------------+

Many of GPTC's passengers are dialysis patients who may not be medically
ready to travel at their scheduled pick-up times after receiving
dialysis treatment. It is GPTC's practice to provide service for all
such pick-ups. Depending upon the particular situation, a driver may be
asked to wait for the customer, the driver may complete another trip and
return later to pick-up the dialysis patient, or a the driver may be
dispatched at a later time in response to the customer's delayed pick-up
request. In such cases GPTC records this as a single trip. The pick-up
time for the trip is recorded as the time the of the vehicle's original
arrival. The drop-off time is recorded as either, the actual drop-off
time, or the recorded pick-up time plus the travel time from pick-up to
drop-off. This practice produces in inaccurate trip record and can
result in trips of short duration appearing to be excessively long.

To further assess on-time performance the review team analyzed a sample
of completed driver's logs. The sample included all completed trips on
the dates of March 1, 3-7, and 19, 2003 (see Table VIII-2). Late
pick-ups were measured based upon the scheduled and actual pick-up times
recorded on the driver's log. When the actual pick-up time was less than
10 minutes after the scheduled pick-up time, the trip is considered on
time. Included in on-time pick-ups are all trips in which the customer
was picked up within the 20-minute pick-up window (10 minutes before to
10 minutes after the scheduled pick-up time). Also included in the on
time trips are trips in which the customer was picked up more than 10
minutes before the scheduled pick-up time.

When the vehicle reportedly arrived at the pick-up location 11 to 25
minutes after the scheduled time or 1-15 minutes after the end of the
10-minute pickup window, it is considered to be 1-15 minutes late.
According to this approach, 86% of pick-ups were on time with 97% of
pick-ups less than 15 minutes late. There were no pick-ups more than 60
minutes late. Although this approach results in more late trips than
reported by GPTC, there does not appear to be a substantial number of
significantly late pick-ups.

Since scheduled appointment times are not recorded by GPTC, the review
team was unable to independently verify GPTC's reported on time
performance for drop-offs. Apparently GPTC is able to compute on-time
performance for drop-offs by using first hand knowledge of the small
number of daily trip makers who have appointments. A large percentage of
these passengers make recurring trips.

Table VIII-2. On-Time Performance for Sample Days in March 2003

  ----------------- ----------------- ----------------- -----------------
  Trip Disposition  \# Trips          Percentage        Cumulative
                                                        Percentage

  On Time           134               86%               86%

  1-15 Minutes Late 16                10%               97%

  16-30 Minutes     3                 2%                99%
  Late                                                  

  31-60 Minutes     2                 1%                100%
  Late                                                  

  Total Late        21                14%               

  Total Trips       155               100%              
  ----------------- ----------------- ----------------- -----------------

Findings

1.  GPTC does not appear to have a substantial number of significantly
    late pick-ups. Based on a sample of 155 trips, 97% of pick-ups were
    made early or no more than 15 minutes after the end of the pick-up
    window and 86% of the trips were early or on time. Only 1% of
    passengers were picked up more than 31 minutes after the pick-up
    window and none were picked up more than an hour after the pick-up
    window.

2.  GPTC does not track on-time performance for meeting appointment
    times.

3.  GPTC does not appear to have a substantial number of missed trips.
    GPTC reported seven missed trips during the nine-month period from
    April 2002 through December 2002, and no missed trips for the period
    January through March 2003. No missed trips were identified in the
    review team sample of 195 scheduled trips from driver's Logs for
    seven days in March of 2003.

4.  When trips are rescheduled during the service day because a customer
    is unable to travel at the scheduled time due to a medical
    condition, GPTC does not create a new trip record. As a result, the
    actual time of performance of the trip is inaccurate and the trip
    duration may be overstated.

5.  GPTC's policy for no-shows is to wait five minutes after the
    scheduled time before declaring the customer a no-show. Staff
    described the practice as waiting until five minutes after the
    pick-up window (15 minutes after the scheduled pick-up time). Both
    the policy and practice could delay drivers and customers in serving
    other trips.

Recommendations

1.  GPTC should measure and report on time performance for both pick-ups
    and drop offs. Trip request forms and driver's logs should include
    appointment times, when appointment times are requested, in addition
    to pick up times for all trip requests.

2.  When trips are rescheduled during the service day because a customer
    is unable to travel at the scheduled time due to a medical
    condition, GPTC should categorize the customer as an excused no show
    or some other category it deems appropriate and schedule a new "same
    day" trip to accommodate the customer at a later time. This will
    permit a more accurate accounting of service provided. Since same
    day service is not required by the US DOT regulations, GPTC does not
    have to comply with the same service standards it uses for next day
    trip requests.

3.  Gary should consider revising its no-show procedures. Most systems
    allow a vehicle to arrive at any time within the stated pick-up
    window and then to wait only 5 minutes for the passenger to appear
    before declaring a no-show. By waiting until the end of the pick-up
    window, drivers are wasting time and may be late picking up another
    customer.

Analysis of Trip Length

For this portion of the study, the review team reviewed GPTC's ADA
Complementary Paratransit service trip length (travel time) performance
policies and procedures, analyzed a sample of driver manifests to assess
average trip length, and performed a comparison of travel times between
ADA Complementary Paratransit trips and comparable fixed route trips.

GPTC has established a service standard of no more than 30 minutes for
local ADA Complementary Paratransit trips, and no more than 60 minutes
for "express" Paratransit trips. Trips to destinations within the ADA
service area but outside of the City of Gary are considered "express."
These travel time standards are based on scheduled GPTC fixed route
travel times for local and express trips.

For this analysis, a sample of 155 GPTC ADA Complementary Paratransit
trips was drawn from trips provided on March 1, March 3 to March 8, and
March 19, 2003. Table VII-3 shows the average trip length for trips
within the sample. The table shows that the average travel time for all
trips was 24 minutes (individual travel times ranged from 10 to 70
minutes). The majority of trips (74%) were completed in 30 minutes or
less; nearly all trips (99%) were completed in 60 minutes or less. Only
2 trips took more than an hour, and not significantly so. Travel time on
the one trip was 65 minutes, and on the other, 70 minutes.

Table VIII-3. Average Sample Trip Length

Sample Days in March 2003

+------------------------------+---------------------------------------+
|                              | **Sample Days March 2003**            |
+------------------------------+---------------------------------------+
| \# Trips                     | 155                                   |
+------------------------------+---------------------------------------+
| Average Trip Length          | 24 minutes                            |
+------------------------------+---------------------------------------+
| 30 minutes or less           | 115                                   |
|                              |                                       |
|                              | 74%                                   |
+------------------------------+---------------------------------------+
| 31-60 minutes                | 38                                    |
|                              |                                       |
|                              | 25%                                   |
+------------------------------+---------------------------------------+
| 61 minutes or more           | 2                                     |
|                              |                                       |
|                              | 1%                                    |
+------------------------------+---------------------------------------+

As noted above, GPTC's standard for ADA Complementary Paratransit travel
time is no more than 30 minutes for local trips and no more than 60
minutes for express trips. Although Table VII-3 does not present trip
length data by type of trip, the fact that 74% of all trips in the
sample were completed in 30 minutes or less and 99% of all trips were
completed in 60 minutes or less indicates that most travel times are
likely to fall within GPTC's standard.

A sample of 18 ADA Complementary Paratransit was selected from among
trips provided between March 10 and 22, 2003 for further analysis[^2].
First, the travel times for those trips were compared to GPTC's service
standards for paratransit ride duration. Of the 18 trips, only 1 (which
accounted for 6% of the sample) exceeded the GPTC standard. That trip
was a local trip that lasted 40 minutes, 10 minutes over the 30-minute
standard.

Next, travel times for the sample trips were compared to travel times
for comparable trips using fixed route, as a means of assessing whether
these paratransit trip lengths are significantly long relative to fixed
route service. The review team worked with GPTC's Superintendent of
Transportation to develop trip itineraries and estimate the fixed route
travel times. Based on the origin and destination addresses and time of
day, the review team determined the bus route(s) that one would use to
make the same trip on GPTC's fixed route buses. Each fixed route travel
time is the sum of the following components:

-   Travel time on each bus

-   Transfers (waiting) time for multi-bus trips (included in fixed
    route travel time)

-   Walking time at each end of the trip

    -   5 minutes allowance for less than 1 block

    -   10 minutes allowance for 1 to 3 blocks

    -   15 minutes allowance for 4 to 6 blocks

    -   20 minutes allowance for more than 6 blocks

Table VIII-3 shows the time of day that the trips were made, the origin
and destination for each trip, the actual travel times on ADA
Complementary Paratransit service, and the estimated travel times by
fixed route. The table also indicates the number of transfers required
to complete the trip on fixed route, as well as travel time allowance to
and from the bus stops. The second and third columns from the right-hand
side of the table compare the ADA Complementary Paratransit service with
GPTC's fixed route travel times. In the "Travel Time Difference" column,
the figures represent the difference in travel times between the two. A
minus sign (-) means that the ADA Complementary Paratransit travel time
was actually less than the estimated fixed route travel time. In the
"Travel Time Ratio" column, a value less than 1.0 also means a shorter
travel time for ADA Complementary Paratransit service, value of 1.0
means that the trips were the same length, and a value greater than 1.0
means that the ADA Complementary Paratransit trip was longer than the
comparable fixed route trip. The last column in the table indicates
whether or not the paratransit trip met GPTC's internal paratransit
travel time standard.

As shown in the table, the average travel time for the comparable fixed
route trips, with an average of 1 transfer, was 65 minutes, which is
more than twice as long, on average, as the same trip made on the ADA
Complementary Paratransit service. The table shows that all of the trips
in the sample had *shorter* travel times on ADA Complementary
Paratransit than would have been the case for comparable trips on fixed
route bus service, sometimes by a significant amount.

The average time spent making an ADA Complementary Paratransit trip was
40% of the average time for a comparable fixed route trip. For
individual paratransit trips, actual travel times range from 20% to 90%
of the estimated fixed route travel time. In most cases, the longer
fixed route travel times include a transfer from one bus route to
another, usually in downtown Gary. Walking time to a bus stop on both
ends of the trip accounted for an average of 8 minutes per trip.

Table VIII-3. Comparison of Travel Times on Paratransit vs. Fixed Route
for Selected Trips: March 2003

<table>
<colgroup>
<col style="width: 19%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="4"><strong>Paratransit (Para)</strong></td>
<td colspan="4"><strong>Fixed Route (FR)</strong></td>
<td colspan="3"><strong>Comparison</strong></td>
</tr>
<tr class="even">
<td><strong>Origin / Destination</strong></td>
<td><strong>PU/DO Time</strong></td>
<td><strong>Actual Mileage</strong></td>
<td><strong>Total Travel Time (mins)</strong></td>
<td><strong># Transfers</strong></td>
<td><strong>Travel Time (mins)</strong></td>
<td><strong>Walk Time to/from Stops (mins)</strong></td>
<td><strong>Total Travel Time (mins)</strong></td>
<td><strong>Diff. Para - FR (mins)</strong></td>
<td><strong>Ratio Para:FR</strong></td>
<td><strong>Within GPTC Standard</strong></td>
</tr>
<tr class="odd">
<td>4800 Broadway to<br />
1300 E. 6th Ave.</td>
<td>05:00 pu</td>
<td>6</td>
<td>20</td>
<td>1</td>
<td>31</td>
<td>10</td>
<td>41</td>
<td>-21</td>
<td>0.5</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>1200 Ellsworth St. to<br />
4800 Broadway*</td>
<td>05:15 pu</td>
<td>10</td>
<td>40</td>
<td>1</td>
<td>45</td>
<td>0</td>
<td>45</td>
<td>-5</td>
<td>0.9</td>
<td>No</td>
</tr>
<tr class="odd">
<td>1900 Missouri St. to<br />
00 W. 81st St.</td>
<td>07:30 pu</td>
<td>12</td>
<td>25</td>
<td>1</td>
<td>80</td>
<td>15</td>
<td>95</td>
<td>-70</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>500 E. 21st Ave. to<br />
Meijers US 30</td>
<td>07:00 pu</td>
<td>12</td>
<td>25</td>
<td>2</td>
<td>95</td>
<td>0</td>
<td>95</td>
<td>-70</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td>Ultra Foods, 61st Ave., to<br />
4300 Johnson St.</td>
<td>14:00 pu</td>
<td>3</td>
<td>15</td>
<td>1</td>
<td>39</td>
<td>10</td>
<td>49</td>
<td>-34</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>1100 Delaware St. to<br />
4000 MLK Drive</td>
<td>16:00 pu</td>
<td>6</td>
<td>30</td>
<td>1</td>
<td>59</td>
<td>25</td>
<td>84</td>
<td>-54</td>
<td>0.4</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td>2100 Wright St. to<br />
5800 Broadway</td>
<td>13:00 pu</td>
<td>9</td>
<td>35</td>
<td>1</td>
<td>61</td>
<td>0</td>
<td>61</td>
<td>-26</td>
<td>0.6</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>Trump Casino to<br />
3200 Pierce St.**</td>
<td>21:00 pu</td>
<td>11</td>
<td>25</td>
<td>1</td>
<td>62</td>
<td>0</td>
<td>62</td>
<td>-37</td>
<td>0.4</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td>2400 Central Ave. to<br />
WalMart US 30</td>
<td>13:00 pu</td>
<td>11</td>
<td>20</td>
<td>2</td>
<td>65</td>
<td>0</td>
<td>65</td>
<td>-45</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>3800 Madison St. to<br />
700 Harris Blvd.***</td>
<td>07:00 pu</td>
<td>14</td>
<td>25</td>
<td>1</td>
<td>65</td>
<td>10</td>
<td>75</td>
<td>-50</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td>7600 Harold Ave. to<br />
2400 McKinley St.</td>
<td>17:00 pu</td>
<td>11</td>
<td>15</td>
<td>1</td>
<td>48</td>
<td>5</td>
<td>53</td>
<td>-38</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>2600 Waverly Drive to<br />
1300 E. 79th St.</td>
<td>07:00 pu</td>
<td>14</td>
<td>25</td>
<td>1</td>
<td>90</td>
<td>15</td>
<td>105</td>
<td>-80</td>
<td>0.2</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td><p>2200 Kentucky St. to<br />
St. Catherine's Hospital,</p>
<p>E. Chicago</p></td>
<td>10:30 pu</td>
<td>11</td>
<td>36</td>
<td>1</td>
<td>50</td>
<td>0</td>
<td>50</td>
<td>-14</td>
<td>0.7</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>3200 Pierce St. to<br />
4th and Lake</td>
<td>13:00 pu</td>
<td>7</td>
<td>25</td>
<td>1</td>
<td>60</td>
<td>0</td>
<td>60</td>
<td>-35</td>
<td>0.4</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td>2200 Jennings St. to<br />
500 Tyler St.</td>
<td>05:30 pu</td>
<td>4</td>
<td>25</td>
<td>1</td>
<td>50</td>
<td>25</td>
<td>75</td>
<td>-50</td>
<td>0.3</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>1000 E. Ridge Rd. to<br />
2300 Harrison St.</td>
<td>14:00 pu</td>
<td>7</td>
<td>15</td>
<td>0</td>
<td>15</td>
<td>5</td>
<td>20</td>
<td>-5</td>
<td>0.8</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td>2200 Williams St. to<br />
3200 Broadway</td>
<td>11:30 pu</td>
<td>4</td>
<td>20</td>
<td>1</td>
<td>35</td>
<td>10</td>
<td>45</td>
<td>-25</td>
<td>0.4</td>
<td>Yes</td>
</tr>
<tr class="even">
<td>00 W 81st St. to<br />
1900 Missouri</td>
<td>12:00 pu</td>
<td>18</td>
<td>60</td>
<td>1</td>
<td>80</td>
<td>15</td>
<td>95</td>
<td>-35</td>
<td>0.6</td>
<td>Yes</td>
</tr>
<tr class="odd">
<td><strong>AVERAGE</strong></td>
<td><strong> </strong></td>
<td><strong>9</strong></td>
<td><strong>27</strong></td>
<td><strong>1</strong></td>
<td><strong>57</strong></td>
<td><strong>8</strong></td>
<td><strong>65</strong></td>
<td><strong>-39</strong></td>
<td><strong>0.4</strong></td>
<td><strong> </strong></td>
</tr>
<tr class="even">
<td colspan="11"><p>Notes: Addresses are rounded to nearest 100
block</p>
<p>* No bus service at origin until 6:10 a.m.</p>
<p>** No bus service on connecting bus route at this hour</p>
<p>*** FR customers must transfer to Hammond Transit to complete this
trip</p></td>
</tr>
</tbody>
</table>

It should be noted that several of the ADA Complementary Paratransit
trips in this sample are regular trips either 1) to a destination within
another transit system's service area, which would require a transfer
from a GPTC bus to the other system's vehicle, or 2) at a time at which
the fixed route that would be needed for the trip is not in operation.
Both types of trips are beyond what GPTC is required to provide as part
of its ADA Complementary Paratransit service.

Findings

1.  The travel time analysis indicates that there are no capacity
    constraints related to ADA Complementary Paratransit trip length.

2.  Analysis of a sample of 155 trips provided in March 2003 indicated
    an average trip length of 24 minutes. Most trips (74%) were
    completed in 30 minutes or less; 99% were completed in 60 minutes or
    less. Of the 2 trips with travel times of more than 60 minutes, the
    first was completed in 65 minutes, the second in 70 minutes.

3.  When the actual travel times of 18 ADA Complementary Paratransit
    trips provided during March 2003 were compared to the estimated
    travel times for comparable fixed route trips, ADA Complementary
    Paratransit travel times were shorter in all cases. The average
    travel time for the sample of ADA Complementary Paratransit trips
    was 27 minutes, while the average fixed route travel time was 65
    minutes. Fixed route trips involved an average of 1 transfer and 8
    minutes of walking time to and from bus stops. ADA Complementary
    Paratransit travel times ranged from 20% to 90% of the fixed route
    travel time for comparable trips, or 40% on average.

4.  GPTC's travel time standard establishes a maximum ride time of 30
    minutes for a local trip and 60 minutes for an express trip (a trip
    to a destination within the ADA service area but outside of the City
    of Gary). This standard is based on scheduled fixed route travel
    times for each type of trip. Only 1 of the 18 trips in the sample,
    or 6%, exceeded the GPTC standard.

Recommendations

1.  GPTC should continue to use a standard for ADA Complementary
    Paratransit service travel time that is based on comparable fixed
    route travel time.

2.  As demand for ADA Complementary Paratransit service grows and more
    trips are grouped on vehicles, travel times may increase. GPTC
    should review travel time performance periodically to identify
    significantly long trips and assess trends. This review should be
    based on actual trip data recorded on driver manifests.

# Resources

The review team reviewed resources available to provide ADA
Complementary Paratransit services to assess their potential
contribution to service capacity constraints. The team reviewed GPTC's
history of funding ADA Complementary Paratransit services, labor, and
vehicle resources needed to deliver the service. This effort included a
review of GPTC's budget and funding and staff of drivers and the ADA
Complementary Paratransit passenger fleet.

Budget/Funding Levels

GPTC relies upon four sources for funding: (1) FTA grant-funds, (2)
Indiana state mass transportation funds which are raised through
gasoline taxes, (3) city property taxes, and (4) GPTC fare revenues.
Historically each of these funding sources has provided about 25% of
GPTC's funding. GPTC funding programmed for the years 2001 through 2003
appears in Table IX-1.

Table IX-1. GPTC Budget & Finance

  -------------- ----------------------- -------------- -------------- ----------------- ----------------- -----------------
  **Year**                               **1999**       **2000**       **2001**          **2002**          **YTD 2003**

  **Trips**                                                                                                

  Fixed Route                            NR             1,804,704      1,734,209                           
  Passenger                                                                                                
  Trips                                                                                                    

                 ADA Certified Riders    NR             NR             NR                NR                329

                 ADA Passenger Trips     NR             8,198          6,187             7,396             1,156

  **Budget**                                                                                               

                 Total                   \$9,685,395    \$7,805,381    \$7,851,670       \$6,136,737       NR

                 Transportation          \$2,882,609    \$2,969,200    \$2,966,200       NR                NR

  **Expended**                                                                                             

                 Total                   \$10,476,595   \$10,041,796   \$9,594,650       NR                NR

                 Transportation          \$3,215,228    \$3,072,573    \$3,450,293       NR                NR

  **Balance**                                                                                              

                 Total                   -\$791,200     -\$2,236,415   -\$1,742,980      NR                NR

                 Transportation          -\$332,619     -\$103,373     -\$484,093        NR                NR

  **Funding**                                                                                              

                 FTA                                    NR             \$2,319,066       \$1,664,476       \$1,900,000

                 State of Indiana                       \$1,635,393    \$2,027,402       \$1,566,619       \$1,210,900

                 City                                   \$1,881,535    \$2,637,538       \$2,203,554       \$2,372,100

                 GPTC Revenues                          NR             \$1,356,564       \$1,047,515       \$1,009,300

                 **Total**                              **NR**         **\$8,340,570**   **\$6,482,164**   **\$6,492,300**
  -------------- ----------------------- -------------- -------------- ----------------- ----------------- -----------------

In recent years GPTC has experienced a decline in funding. This decline
is reflected in a decline from almost \$10.5 million in expenditures in
1999 to a budget of \$6.1 million in 2002.

These early budgets include a line of credit of \$2 million in 1999 and
\$1.8 million in 2000. Even adjusting for this non-recurring cost GPTC's
expenditures have still declined from \$8.5 million to the present
budget of \$6.1 million in 4 years. During this period GPTC has
experienced significant service reductions. In the years 2001 and 2002
GPTC reduced it's staffing by 13 operators and 7 vehicle maintenance
personnel. Since that time any increase in drivers has been made through
reinstatement of drivers who were laid-off.

Service declines have contributed to a loss of ridership. Further
contributing to ridership decline is a shift in student travelers to the
City's school transportation system. Since 1999, the City Schools have
offered free service to all students. The ridership losses in turn have
contributed to a decline in fare revenues.

GPTC also reports limited public funding opportunity at city, state, and
federal levels as a result of slow growth in the economy and associated
limits in tax revenues.

In response to these financial pressures, GPTC is about to begin a route
analysis to consider improvements in efficiency, through reorganization,
and possible further service reduction.

GPTC does not have a separate account for ADA Complementary Paratransit
service. As a result, historical information on the cost of ADA
Complementary Paratransit service was not readily available. GPTC's ADA
Complementary Paratransit services have been included in its
Transportation Department accounts. As shown in Table IX-1, the
transportation budget has been stable from 2000 through 2002, with costs
exceeding budget. With the lay-offs at the end of 2002 a decline in
costs during 2003 would be expected. Actual costs for FY2003 were not
available at the time of the review. In 2003, GPTC established a
separate account to track costs for ADA Complementary Paratransit
services.

In 1996, GPTC began providing ADA Complementary Paratransit service
through a contract with Tradewinds Rehabilitation Center, Inc. In 2000,
Tradewinds discontinued providing contracted service to GPTC (although
it maintained transportation services for its own clients). At that time
Tradewinds was serving 435 weekday unlinked demand response trips with
30 peak period vehicles. GPTC contracted with another carrier for
approximately six months, but the contractor also discontinued GPTC
service. Since 2001 GPTC has provided the service with its
transportation staff. Currently, GPTC ridership is approximately 25
unlinked weekday trips with 87% of those trips recurring or subscription
trips. Many of those trips are for dialysis patients.

GPTC staff reported that other providers of service to people with
disabilities currently serve a number of Medicaid customers and other
clients who might be eligible for ADA Complementary Paratransit service.
GPTC also indicated that many of these other providers have limited
financial resources and could soon reduce or discontinue their services.
As a result there is potential for significant increase in demand for
GPTC services.

**Budget Process**

GPTC 's fiscal year corresponds to the calendar year. GPTC's budget
process begins in July of each year. The Director of Transportation
prepares the department's budget including the ADA Complementary
Paratransit budget. The Director indicated that he includes a
contingency in his budget for growth in demand in view of the potential
decline in alternative services for people with disabilities.
Additionally, GPTC anticipates that some FTA funding directed to these
other service providers would be redirected to GPTC should these
alternate providers discontinue service.

The budget is reviewed with the Chief Budget Officer and adjusted if
needed. The budget is submitted to GPTC's Board of Directors for
approval in August, and is subject to public review before adoption in
September. GPTC staff indicated support of ADA services from both the
Mayor and City Council.

Peer Review

The review team conducted a comparison of Gary's ADA Complementary
Paratransit ridership and operating costs to that of its peers. The
purpose of this review is to assess whether demand for service and
service levels approximate what would be expected for a comparable
service area.

The 10 peers used in the comparison represent transit systems with
similar population and service area sizes. All are cities in the
mid-west region of the country. The results of the peer analysis are
shown in Table III-1. The table includes data for FY 2001 (the most
recent year available), drawn from the Federal Transit Administration's
National Transit Database.

The table shows that Gary is about the peer average in terms of its
population (102,746 versus 113,496), size of the service area (38 square
miles versus 39), and number of unlinked fixed route bus trips (about
1.7 million annually). However, it should be noted that Gary provides
far fewer unlinked ADA Complementary Paratransit trips (6,187 for Gary
compared with the average of 43,393) and only one system -- Sioux City,
Iowa -- was lower at 4,562. As can be seen in the table, on average, the
other peer cities serve approximately seven times more ADA Complementary
Paratransit trips than Gary. Even an increase to 7,396 trips served by
GPTC in FY 2002 is considerably fewer than those served by peers.

At the same time, Gary's annual operating budget for fixed route bus
service appears to be highest among its peers (\$8 million compared to
\$5 million). It should be noted that, based on interviews with GPTC
staff, the bus operating budget includes the operating cost of providing
ADA Complementary Paratransit service, which was not reported
separately. Additionally, the vehicles available for maximum service
also appears to be quite a bit lower (28 compared to the fixed route
average of 35 and 2 compared to the paratransit average of 15).

As noted earlier in this report GPTC staff indicated that many ADA
Complementary Paratransit eligible individuals are using Tradewinds and
service of other local non-profit providers Accounting for the
relatively low passenger volumes.

Table III-1. Peer Analysis National Transit Database: 2001

+-------+------+-----+-----+-------+-------+------+--------+--------+
| **Sys | *    |     | *   |       |       | *    |        |        |
| tem** | *Ser |     | *Fi |       |       | *ADA |        |        |
|       | vice |     | xed |       |       | P    |        |        |
|       | Ar   |     | Ro  |       |       | arat |        |        |
|       | ea** |     | ute |       |       | rans |        |        |
|       |      |     | Bu  |       |       | it** |        |        |
|       |      |     | s** |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
|       | **   | **  | *   | A     | **Veh | **An | **An   | **Ve   |
|       | Popu | Squ | *An | nnual | icles | nual | nual** | hicles |
|       | lati | are | nua |       | A     | Unli |        | Av     |
|       | on** | M   | l** | *     | vail. | nked | **Ope  | ail.** |
|       |      | ile |     | *Oper | for   | Tri  | rating |        |
|       |      | s** | **U | ating | Max.  | ps** | Bu     | **for  |
|       |      |     | nli | Bud   | Serv  |      | dget** | Max.   |
|       |      |     | nke | get** | ice** |      |        | Ser    |
|       |      |     | d** |       |       |      |        | vice** |
|       |      |     |     |       |       |      |        |        |
|       |      |     | **T |       |       |      |        |        |
|       |      |     | rip |       |       |      |        |        |
|       |      |     | s** |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| M     | 72   | 18  | 1,3 | \     | 33    | 74   | \$1,0  | 11     |
| uncie | ,880 |     | 11, | $3,86 |       | ,769 | 28,093 |        |
| IN    |      |     | 081 | 1,360 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Ke    | 90   | 21  | 1,9 | \     | 44    | 19   | \$1    | 6      |
| nosha | ,153 |     | 46, | $4,25 |       | ,196 | 06,288 |        |
| WI    |      |     | 447 | 8,573 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Sioux | 96   | 64  | 1,2 | \     | 19    | 4    | \$2    | 9      |
| City  | ,234 |     | 41, | $2,11 |       | ,562 | 06,486 |        |
| IA    |      |     | 310 | 6,947 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Cedar | 97   | 22  | 1,0 | \     | 37    | 64   | \$7    | 20     |
| R     | ,716 |     | 78, | $4,77 |       | ,290 | 79,090 |        |
| apids |      |     | 789 | 3,909 |       |      |        |        |
| IA    |      |     |     |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| *     | **1  | **3 | *   | **\$8 | *     | *    | **In   | **2**  |
| *Gary | 02,7 | 8** | *1, | ,005, | *28** | *6,1 | cluded |        |
| I     | 46** |     | 734 | 230** |       | 87** | in     |        |
| N\*** |      |     | ,20 |       |       |      | FR**   |        |
|       |      |     | 9** |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Lafa  | 108  | 32  | 3,1 | \     | 48    | 24   | \$3    | 5      |
| yette | ,500 |     | 03, | $4,90 |       | ,661 | 92,358 |        |
| IN    |      |     | 734 | 1,452 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Ra    | 112  | 27  | 1,9 | \     | 26    | 30   | \$5    | 27     |
| cine- | ,100 |     | 58, | $5,26 |       | ,952 | 65,047 |        |
| Belle |      |     | 138 | 7,295 |       |      |        |        |
| WI    |      |     |     |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Evans | 126  | 41  | 1,3 | \     | 31    | 45   | \$5    | 22     |
| ville | ,597 |     | 11, | $3,98 |       | ,892 | 11,840 |        |
| IN    |      |     | 422 | 0,667 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Kala  | 143  | 70  | 2,3 | \     | 33    | 17   | \$4    | 7      |
| mazoo | ,000 |     | 26, | $6,75 |       | ,073 | 07,785 |        |
| MI    |      |     | 834 | 2,396 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| P     | 147  | 35  | 1,7 | \     | 42    | 92   | \$1,0  | 22     |
| eoria | ,126 |     | 81, | $7,42 |       | ,736 | 73,681 |        |
| IL    |      |     | 183 | 4,027 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| Green | 151  | 60  | 1,6 | \     | 39    | 97   | \$1,1  | 31     |
| Bay   | ,408 |     | 24, | $4,62 |       | ,000 | 61,209 |        |
| WI    |      |     | 840 | 4,097 |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| *     | **1  | **3 | *   | **\$5 | *     | **   | *      | **15** |
| *Peer | 13,4 | 9** | *1, | ,087, | *35** | 43,3 | *\$623 |        |
| Aver  | 96** |     | 765 | 814** |       | 93** | ,188** |        |
| age** |      |     | ,27 |       |       |      |        |        |
|       |      |     | 2** |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+
| So    |      |     |     |       |       |      |        |        |
| urce: |      |     |     |       |       |      |        |        |
| Nat   |      |     |     |       |       |      |        |        |
| ional |      |     |     |       |       |      |        |        |
| Tr    |      |     |     |       |       |      |        |        |
| ansit |      |     |     |       |       |      |        |        |
| Dat   |      |     |     |       |       |      |        |        |
| abase |      |     |     |       |       |      |        |        |
| FY    |      |     |     |       |       |      |        |        |
| 2001  |      |     |     |       |       |      |        |        |
|       |      |     |     |       |       |      |        |        |
| \*G   |      |     |     |       |       |      |        |        |
| ary's |      |     |     |       |       |      |        |        |
| A     |      |     |     |       |       |      |        |        |
| nnual |      |     |     |       |       |      |        |        |
| Oper  |      |     |     |       |       |      |        |        |
| ating |      |     |     |       |       |      |        |        |
| B     |      |     |     |       |       |      |        |        |
| udget |      |     |     |       |       |      |        |        |
| F     |      |     |     |       |       |      |        |        |
| igure |      |     |     |       |       |      |        |        |
| for   |      |     |     |       |       |      |        |        |
| Fixed |      |     |     |       |       |      |        |        |
| Route |      |     |     |       |       |      |        |        |
| Bus   |      |     |     |       |       |      |        |        |
| inc   |      |     |     |       |       |      |        |        |
| ludes |      |     |     |       |       |      |        |        |
| ADA   |      |     |     |       |       |      |        |        |
| Com   |      |     |     |       |       |      |        |        |
| pleme |      |     |     |       |       |      |        |        |
| ntary |      |     |     |       |       |      |        |        |
| Pa    |      |     |     |       |       |      |        |        |
| ratra |      |     |     |       |       |      |        |        |
| nsit. |      |     |     |       |       |      |        |        |
| The   |      |     |     |       |       |      |        |        |
| fi    |      |     |     |       |       |      |        |        |
| gures |      |     |     |       |       |      |        |        |
| could |      |     |     |       |       |      |        |        |
| not   |      |     |     |       |       |      |        |        |
| be    |      |     |     |       |       |      |        |        |
| split |      |     |     |       |       |      |        |        |
| out.  |      |     |     |       |       |      |        |        |
+-------+------+-----+-----+-------+-------+------+--------+--------+

Personnel

In addition to 32 total drivers (including fixed route) with full-time
route assignments, there are six drivers who have daily schedules as
"relief drivers." Relief drivers are scheduled to operate routes on the
regular driver's scheduled day off. Additionally, nine drivers are
assigned to extra board. These drivers are assigned to runs as needed.
They are first assigned to routes for unscheduled absences, such as sick
or vacation days. Then they are assigned to "protect" to respond to
unanticipated problems during the service day. If there is a problem and
there are no protect drivers available, the dispatcher will request a
driver to stay late or arrive early to cover a route assignment. If
there are no drivers available to work over time the dispatcher will
request a driver who has the day off to report to work based upon driver
seniority. In this event it may take up to an hour for a driver who is
called in to report to work.

GPTC operates two regular ADA routes and one part-time route each
weekday. These routes are covered by four operator runs or work
schedules. One driver comes in at 6:00 a.m. and a second at 6:30 a.m.
Each of the full-time driver works eight hours. Relief drivers cover the
extra run.

A review of driver assignments for the week of March 3-8, 2003,
indicated that available "protect" drivers ranged from 0 to 3 drivers at
any time during the day. Although this range does not appear
unreasonable in consideration of the size of the operator staff and the
need to balance adequate driver coverage with cost, GPTC may wish to
review its driver schedule to provide for availability of one protect
driver at all times.

Equipment

The entire GPTC fleet is lift-equipped. During the month of March 2003,
lifts on five of the 39 vehicles were repaired or serviced.

Two vehicles are dedicated to ADA Complementary Paratransit service
(vehicles #2106 and #2107). One vehicle is designated as a back-up for
ADA Complementary Paratransit service. If needed the back-up vehicle
(#2103) is pulled from fixed route service and reassigned to ADA.
Another fixed route vehicle is assigned to replace it on the fixed
route. If there is still an ADA vehicle shortage, three buses (#2102,
#2104 & #2105) and/or five vans are available for reassignment from
fixed route service to ADA.

ADA Complementary Paratransit service is given priority for equipment
over fixed route service. The total GPTC fleet consists of 39 vehicles
to cover daily operating requirements of 19 vehicles for both fixed
route and ADA Complementary Paratransit services. However, often fewer
than two spare vehicles are available for service during the day.
Because ADA Complementary Paratransit receives priority over fixed route
vehicle needs, the number of vehicles available for ADA Complementary
Paratransit service may be adequate (although using them could result in
a shortage of fixed route vehicles).

Although the number of vehicles appears adequate in the short-term, in
the long term there could be vehicle shortages. Given the relatively low
ADA Complementary Paratransit ridership, as discussed in the peer review
section of this chapter, and concerns that one or more of the
community-based non-profit agencies may cease providing service, Gary
could find itself without enough vehicles and drivers to cover the
demand for runs.

Finally, the vehicle design appears to be an impediment to use of the
service. During the\
rides on the vehicles, the review team members noted that the entry and
exit to the vehicles was difficult. The vans are raised roof
commuter-type vans modified to include a wheelchair lift and fare box.
The lift is located on the back of the vehicle (see Figure IX-1). The
passenger side front seat has been removed to allow passengers to enter
the vehicle by climbing up the steps, past the fare box, and into the
bench seat (see Figure IX-2). Up to three ambulatory passengers sit on
the bench seat behind the driver (up to three passengers can be
accommodated). The seat belt configuration makes it extremely difficult
for all three people to use the seat belts comfortably. Access to the
bench seat from the side doors also is difficult because the bench
extends all the way to the doorway to accommodate three passengers (see
Figure IX-3). If three people are seated in the bench seat, they may
have to get out of the vehicle to allow other passengers enough room to
board and alight.

![](media/image2.jpeg){width="4.020833333333333in"
height="3.026388888888889in"}Although the vehicle is designed to carry
two wheelchairs and three ambulatory passengers, the drivers pointed out
that it would be virtually impossible to secure two wheelchairs without
literally climbing over the bench seat, if the securements could be
reached at all. This vehicle configuration also makes it impossible to
accommodate ambulatory passengers who need to use the lift to board and
then ride in a passenger seat. It is not possible to ride up on the lift
and then move to a passenger seat

Figure IX-1. Back mounted wheelchair lift

![](media/image3.jpeg){width="4.020833333333333in"
height="3.032638888888889in"}

##  {#section .unnumbered}

Figure IX-2. Front door and fare box

![](media/image4.jpeg){width="4.020833333333333in"
height="3.032638888888889in"}

Figure IX-3. Bench seat and side door

Findings

1.  Within the limits of the overall transportation budget, financial
    support does not currently appear to be an impediment to the
    delivery of ADA Complementary Paratransit services. However, that
    could change if the demand for ADA Complementary Paratransit
    increases, as is expected.

2.  Current service appears to serve a small portion of the potential
    market for ADA Complementary Paratransit service. Service demand
    could rise sharply if other service providers reduce their level of
    service and the market becomes more aware of GPTC services.

3.  Driver assignments appear to be adequate to serve current demand for
    passenger service.

4.  The fleet assigned for use for ADA Complementary Paratransit
    Services appears to limit access for people who are ambulatory but
    have a mobility impairment. The design of the vehicle entrance makes
    entry and egress quite difficult and it is virtually impossible to
    secure two wheelchairs in the back of the van.

Recommendations

1.  GPTC should continue to plan for positioning itself for potentially
    substantial increases in ADA Complementary Paratransit services.

2.  GPTC should consider revising its driver scheduling so as to have
    one "protect" driver available at all times to address service
    emergencies and provide flexible capacity for ADA Complementary
    Paratransit services.

3.  GPTC should consider replacing the vehicles assigned to ADA
    Complementary Paratransit service with vehicles that are more
    readily accessible for ambulatory passengers.

**Attachment A**

**Response from GPTC**

**Attachment B**

**On-Site Review Schedule**

**ADA Complementary Paratransit Service Review**

Gary Public Transportation Corporation

**Gary, IN**

**April 22-25, 2003**

**On-Site Schedule**

+--------+----------------------------------+------------+------------+
| **     | **Activity**                     | **Who**    | **Where**  |
| Time** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| **Tu   |                                  |            |            |
| esday, |                                  |            |            |
| April  |                                  |            |            |
| 22,    |                                  |            |            |
| 2003** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 9:00   | Opening Conference               | Ms. Colvin | 100 W.     |
| a.m.   |                                  | & staff,   | 4^th^ Ave. |
|        |                                  | FTA,       |            |
|        |                                  | Review     |            |
|        |                                  | Team       |            |
+--------+----------------------------------+------------+------------+
| 9:30   | Review GPTC system design,       | Ms. Colvin | 100 W.     |
| a.m.   | service policies, procedures and | & staff,   | 4^th^ Ave. |
|        | standards, service statistics,   | Review     |            |
|        | service monitoring procedures    | Team       |            |
+--------+----------------------------------+------------+------------+
| 10:30  | Review financial/budgeting/trend | Mathias &  | 100 W.     |
| a.m.   | information                      | Kidston    | 4^th^ Ave. |
|        |                                  |            |            |
|        | Review customer comment          | Monahan    |            |
|        | procedure & files                |            |            |
+--------+----------------------------------+------------+------------+
| 1:00   | Tour operations facility         | All        | 2101 W.    |
| p.m.   |                                  |            | 35^th^     |
|        | Observe reservations, scheduling |            | Ave.       |
|        | & dispatch                       |            |            |
|        |                                  |            |            |
|        | Interview drivers at end of run  |            |            |
+--------+----------------------------------+------------+------------+
| **Wedn |                                  |            |            |
| esday, |                                  |            |            |
| April  |                                  |            |            |
| 23,    |                                  |            |            |
| 2003** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| Early  | Ride along for morning trips     | Monahan    | 2101 W.    |
| a.m.   |                                  |            | 35^th^     |
|        | Observe pullout                  | Mathias &  | Ave.       |
|        |                                  | Kidston    |            |
|        | Observe reservations,            |            |            |
|        | scheduling, dispatch             |            |            |
+--------+----------------------------------+------------+------------+
| 9:00   | Begin Data collection for        | Kidston    | 2101 W.    |
| a.m.   | on-time, travel time, denials,   |            | 35^th^ Ave |
|        | etc.                             | Mathias    |            |
|        |                                  |            |            |
|        | Review fleet records,            |            |            |
|        | maintenance records &            |            |            |
|        | procedures, paratransit          |            |            |
|        | staffing, training, pones        |            |            |
+--------+----------------------------------+------------+------------+
| 1:00   | Review ADA Eligibility process & | Mathias    | 2101 W.    |
| p.m.   | records                          |            | 35^th^ Ave |
|        |                                  | Monahan    |            |
|        | Collect data for travel time     |            |            |
|        | analysis                         | Kidston    |            |
|        |                                  |            |            |
|        | Continue data analysis           |            |            |
+--------+----------------------------------+------------+------------+
| **Thu  |                                  |            |            |
| rsday, |                                  |            |            |
| April  |                                  |            |            |
| 24,    |                                  |            |            |
| 2003** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 8:30   | Meet with customer service --    | Monahan    | 2101 W.    |
| a.m.   | develop fixed route itineraries  |            | 35^th^     |
|        | (trip length analysis)           | Mathias &  | Ave.       |
|        |                                  | Kidston    |            |
|        | Continue data analysis           |            |            |
+--------+----------------------------------+------------+------------+
| 1:00   | Review other service issues      | All        | 2101 W.    |
| p.m.   |                                  |            | 4^th^ Ave. |
|        | Continue data analysis &         |            |            |
|        | observations                     |            |            |
+--------+----------------------------------+------------+------------+
| **F    |                                  |            |            |
| riday, |                                  |            |            |
| April  |                                  |            |            |
| 25,    |                                  |            |            |
| 2003** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 10:00  | Exit Conference                  | All        | 100 W.     |
| a.m.   |                                  |            | 4^th^ Ave. |
+--------+----------------------------------+------------+------------+

**ADA Review Team:**

Rosemary Mathias, Multisystems, Team Leader

Don Kidston, Planners Collaborative, Surveyor

Patricia Monahan, Multisystems, Surveyor

Apri118, 2003

**Attachment C**

***Meeting the Transit Challenge***

**Rider's Guide**

**NOTE: THIS IS A WORD FILE -- THE ORIGINAL IS IN BOOKLET FORMAT.**

**COVER:**

**GPTC**

Gary Public Transportation Corp.

100 West 4^th^ Avenue

Gary, IN 46401 \* 885-7555

885-7555

2101 West 35^th^ Avenue

Gary, IN 46408 \* 884-6100

Meeting the Transit Challenge

**July 2002**

**Complementary Paratransit Service**

Introduction

This handbook has been prepared to familiarize you with GPTC's
complementary paratransit service for people with disabilites and to
answer your questions about paratransit service. Any questions which are
not addressed in the following pages should be directed to GPTC's ADA
coordinator at 884-6100 ext. 106.

Mission Statement

GPTC is committed to providing you with quality service by offering the
same safe, clean, reliable, efficient and courteous transportation
services that fixed route riders are afforded. Please call 884-6100
whenever you have a comment.

**Table of Contents**

Overview of Accessible Public Transit & the ADA 1

What is Paratransit? 1

Who operates the service? 2

How do I know if I am eligible for service? 2

Category I 2

Category II 3

Category III 3

Can I be eligible for Paratransit on a temporary basis? 3

What does It' cost to ride? 4

What are the hours of service? 4

Can I travel outside of Gary 4

Steps to Service 5

How do I apply to become a rider? 5

When will I know If I can use the service? 5

What Is an ADA Complementary Paratransit

Photo ID card 6

Scheduling a Trip 7

How should I schedule a trip? 7

What should I tell the ADA Coordinator? 7

What are the best time to schedule trip? 7

Types of Service 8

What types of service are available? 8

What is reservation service? 8

Using Reservation Service 8

When will I know if my reservation

has been confirmed? \...\...\...\...\...\...\...\...\...8

Tips for Reservation Riders 8

Traveling during off-peak hours 8

Let the dispatcher know your pickup location 9

Flexible Reservation Trip Request 9

Plan to be on the vehicle up to on hour 10

Schedule your pickup and return trips at least

one hour apart 10

Accept a one-way trip only if you can arrange the

Other ride 11

Missed Rides 11

What is a no-show? 11

What are the Penalties for no Show. 12

Cancellations 12

What is a cancellation? 12

How early should I make a cancellation? 13

Timely Arrivals and Departures 13

Will the driver wait if I am late? 13

What if the vehicle arrives early? 13

Will the driver wait if I am late? 14

What if the vehicle arrives early 14

What should I do if service is delayed? 14

What are the appeal procedures? 15

Service Guidelines 16

Introduction 16

Prompt Service 16

On-Time Arrivals 16

Personal Care Attendants/ Companions 16

Special Assistance 16

Packages 17

Obstacles 17

Seat Belts 17

Wheelchair Brakes 17

Scooters 18

Destinations 18

State Laws 18

Fare 18

Proper Conduct 19

**General Information**

**Overview of Accessible Public Transit & the ADA**

The American with Disabilities Act (ADA) was signed into law in July
1990. Title II of the Act refers to public transportation and requires
that all new fixed route buses purchased after July 1990 be accessible
to passengers in wheelchairs. In addition, complementary paratransit
service must be provided to passengers who are unable to use regular bus
service due to the limitations imposed by their disability.

Bus schedules are clearly marked to indicate times of the accessible
buses. Individuals with disabilities are encouraged to use regular bus
service as much as possible. Complementary paratransit service can be
used to reach destinations, which cannot be accessed by regular bus
service due to the nature of the individual's disability.

**What is Paratransit?**

Paratransit Service is complementary service provided by the Gary Public
Transportation Corporation (GPTC) to Gary residents who are unable to
use regular bus service due to a disability. Residents who are eligible
for Paratransit Service can ride to and from any location within GPTC's
service area. All Paratransit vehicles are accessible to people with
disabilities and have wheelchair lifts and sacrament devices.

Since 1992, GPTC has provided special transit services to residents of
Gary. Low-cost fares, simple trip reservations, reliable service and
convenient curb-to-curb transportation make Paratransit attractive to
residents who wish to be active in the community.

**Who operates the service?**

GPTC provides Paratransit Service as part of its overall transportation
services in the community.

**How do I know if I am eligible for service?**

To be eligible for service on Paratransit you must be determined
eligible under one of the following criteria:

***Category I***

**A**ny individual with a disability who is unable, as the result of a
physical or mental impairment (including a vision impairment), and
without the assistance of another individual (accept the operator of a
wheelchair lift or other boarding assistance device), to board, ride, or
disembark from any vehicle on the system which is readily accessible to
and usable by individuals with disabilities.

***Category II***

**A**ny individual with a disability who needs th assistance of a
wheelchair lift or other boarding assistance device and is able, with
such assistance, to board, ride, and disembark from any vehicle which is
readily accessible to and useable by individuals with disabilities if
the individual wants to travel on a route of the system during the hours
of operation of the system at a time, or within a reasonable period of
such time, when such a vehicle is not being used to provide designated
public transportation on the route.

***Category III***

**A**ny individual with a disability who has a specific
impairment-related condition which prevents such individiaul from
traveling to a boarding location or from a disembarking location on such
system.

**Can I be eligible for Paratransit on a Temporary Basis?**

**I**t s possible, in certain situations, for passengers to be approved
for basis? Partransit service on a temporary basis. Eamples include
period of physical therapy after hip replacement surgery, the time
during which an artifical limb is being fabricated, etc.

**T**emporary approval can range from 1 to 6 months. If the passenger
wishes to extend his/her temporary eligibility, a new Part II
professional certification form must be completed. Passengers will be
notified by mail before their eligibility period expires.

**What does it cost to ride?**

**T**he fare for one-way trips on Paratransit is \$2.50 within the City
of Gary Boundary and \$4.00 outside the city limits.

**What are the hours of service?**

**P**aratransit provides service during GPTC's regular hours of
operation:

Monday through Friday 4:50 a.m. -- 11:00 p.m.

Saturday 4:50 a.m. -- 11:00 p.m.

Requests for service can be made by calling Monday through Saturday,
8:00 a.m. -- 4:30 p.m.

**Can I travel outside of Gary**

**G**PTC's Service Area includes: Hammond, East Chicago 3 quarter of
amile area south of U.S. 30 between Taft St. and Pine Island
Apartments + 3 quarter of mile area west of Pine Island Apartments, 3
quarter of mile area south of 93rd avenue between the areas of Taft St.
and Broadway and; 3 quarter of mile area west of 93rd and Taft / 3
quarter of a mile East of 93rd and Broadway.

**Steps to Service**

**How do I apply to become a rider?**

Follow these steps to apply for Paratransit:

1\. Call GPTC's Customer Service Center at 884-6100 (voice) or 981-9696
to obtain a Paratransit application.

2\. As the applicant, complete Part I of the application. Ask the
licensed or certified professional most familiar with the limitations
imposed by your disability to complete Part II of the application.

3\. Send your completed application to:

ADA Coordinator

Gary Public Transportation Corp.

2101 West 35th Avenue

Gary, IN 46408

NOTE: There is no cost for processing the application.

**When will I know If I can use the service?**

Within 21 days of the date your application is received, you will be
notified in writing of approval or disapproval of your application. If
your application is approved, you should visit the GPTC's Customer
Service Office at 100 W. 4th Ave., 'third floor, weekdays between 8:30
a.m.- 4:00 p.m. to obtain a GPTC ADA Complementary Paratransit Photo ID
Card. If you do not receive notification within the 21-day time period,
you will be clarified eligible for Paratransit Service.

**What Is an ADA Complementary Paratransit Photo ID Card?**

GPTC issues ADA Complementary Paratransit Photo ID Cards, free of
charge, to all riders who are determined eligible for Paratransit. Your
ADA Card is a photo identification card. Please carry the card with you
at all times when using Paratransit. Note (that the ADA Card cannot be
used as a pass.

Certified Paratransit riders who are able to use GPTC's regular bus
service may present ADA Cards to drivers on GPTC's local and express
routes and ride for 60 cents each way plus a 10-cent transfer charge if
needed. Passengers with a GPTC unlimited ride monthly pass may use their
pass to ride on these GPTC routes, with no additional cost on our
express routes.

**Scheduling a Trip**

**How should I schedule a trip?**

Once you have obtained an ADA Card, you can begin using Paratransit by
telephoning 884-6100 ext. 104 or 981-9695 (TDD) to schedule your trips
24 hours a day- 7 days weekly.

**What should I tell the ADA Coordinator?**

At the time of your first call, you will be asked several questions
which will be used to established your record. Please give the time at
which you want to be picked up,the address of the pick up location, the
address of your drop-off location, where you can be contacted in case of
an emergency or delayed service, time of pick up for beginning and
return trip and any Information which might be helpful to a driver in
finding your pickup location (i.e. the door where you will be waiting,
details about the building, etc.).

**What are the best time to schedule trip?**

Heavy demands for service usually occurs weekdays between 5:30 a.m. and
9:00 a.m. and between 2:00 p.m. and 6:00 p.m. Requests for service
during these periods may be more difficult to accommodate than requests
during off­-peak hours. For your convenience, you should plan to travel
during off-peak hours whenever possible.

**Types of Service**

**What types of service are available?**

As an approved rider, it is important to know the different types of
transportation services that are available to you. Paratransit offers
-reservation services.

**What is reservation service?**

If you plan to travel to different destinations at varied times, you
should request to use Paratransit reservation service. Your request can
be made as early as 7

**[DAYS]{.underline}** in advance. Your request will be coordinated with
others to serve as many persons as possible.

**Using Reservation Service**

**When will I know if my reservation has been confirmed?**

A Paratransit dispatcher will contact you by phone to let you know the
status of your trip. If you do not hear from the Paratransit office, you
can call 884-6100 ext 104 or 981-9696 to request the status of your
trip.

**Tips for Reservation Riders**

**Traveling during off-peak hours**

Example:

Your doctor offers you an appointment at 3:00 p.m. Before accepting, ask
if you may visit the office between 9:00 a.m. and 2:00 p.m. Your request
for service has a better chance of being provided if scheduled during
Paratransit off-peak hours.

**Let the dispatcher know your pickup location**

Example:

You are waiting for a 1:00 p.m. pickup at the shopping center. Did you
let the dispatcher know the name of the store where you would be
waiting? If you did not and are not at the same location where the
Paratransit vehicle dropped you off, do not worry. All drives are
instructed to circle the shopping parking lot one time to locate you
before leaving. Please wait in an area where you can be easily spotted
by the driver. If the driver is unable to find you after this attempt,
you will be assessed a no-show.

**Flexible Reservation Trip Request**

To assist in scheduling your trip, you may request a flexible pickup
time within a 2-hour period. The pickup must occur during Paratransit
off-peak hours, between 9:00 a.m. and 2:00 p.m. weekdays and anytime
Saturdays. Another option is to call for a pick up with in an hour. By
requesting a flexible reservation pickup time, you give more options for
scheduling your ride.

Example:

You would like to go shopping at the Village Shopping next Friday
morning. You call and request a pickup between 10:00 a.m. and 12:00 p.m.
We contact you to let you know if your ride can be provided. You may be
offered a pickup time at 11:00 a.m. The confirmation of this trip may
have been made possible only because of your flexible reservation trip
request.

**Plan to be on the vehicle up to on hour**

Example:

You have scheduled a 10:00 a.m. appointment. Since your trip will be
coordinated with other passenger requests for service in the same area,
you may be on the vehicle up to one hour. Schedule a pickup as early as
9:00 a.m. to ensure a timely arrival.

**Schedule your pickup and return trips at least one hour apart**

Example:

The purpose of your trip may not require you to be at your destination
for more than 15 minutes. However, due to other passenger trips that
need to be completed, you should plan to be at your return trip at the
earliest possible time to accommodate your needs.

**Accept a one-way trip only if you can arrange the other ride**

Example:

You have made a round-trip request to travel to the theatre at 1:00 p.m.
and to return home at 5:30 p.m. When the dis­patcher calls to confirm or
deny your request for service, GPTC may only be able to offer you the
1:00 p.m. pickup. Please do not accept the pickup time if you know you
have no other way of returning home. If you want to be ­scheduled only
when both ways can be provided, have the reservation taker mark you on
the computer as 'round trip only".

**Missed Rides**

**What is a no-show?**

A no-show is defined as a trip in which the passenger is not present at
the confirmed pickup time and location when a Parartransit vehicle
arrives to provide service. The driver will contact the dispatcher who
will attempt to reach the passenger by telephone. After such attempts,
the driver will wait no longer than 5 minutes (under normal condi­tions)
past the passengers confirmed pickup time for the passenger to arrive.

If you have confirmed rides for a round trip (2 one-way trips) and you
are a no-show for the first leg of the trip, your return trip will not
be automatically cancelled unless you contact GPTC to do so. We will
assume that you still need your return trip. If you are not available
this will be another no show and you are responsible for the cost of
both trips.

**What are the Penalties for no Show.**

Passengers who accumulate more than four-(4) no shows per-forty-(40)
trips will be ineligible to use Paratransit service for 14 days. The
14-day suspension will begin 2 days after the date of the last no-show.
Any additional no-shows after the14-day suspension will result in a
30-day suspension of service on Paratransit.

After the fourth no-show is assessed, the passenger will be notified in
writing by GPTC that his/her ridership privileges are in jeopardy.

**Cancellations**

**What is a cancellation?**

A cancellation is defined as a trip which has been confirmed but the
passenger is unable to take. The passenger should make every effort to
contact the service provider and cancel his/her trip as soon as possible
up to an one hour notice. This will allow other passenger trips to be
accommodated. A trip will be considered a 'no-show'' if the vehicle has
already arrived at the pickup location.

**How early should I make a cancellation?**

You are encouraged to notify the service provider as soon as you know
you will be unable to make a scheduled trip up to 1 hour before
scheduled pickup. Cancellations and no-shows usually result in empty
spaces on Paratransit vehicle at times when other riders are available
to use the service.

**Timely Arrivals and Departures**

**Will the driver wait if I am late?**

After arriving within the 20-minute window, the driver will wait 5
minutes after the confirmed pickup time for the passenger. If the
passenger has not arrived after this time, he/she will be assessed a
no-show (see Missed Rides)

**What if the vehicle arrives early?**

All rides on Paratransit are scheduled prior to the start of the
driver's day. If a cancellation occurs while the driver is en route and
another trip cannot be scheduled in its place, the driver may arrive at
your pickup location earlier than scheduled.

If you are prepared to leave, you may board the vehicle at that time.
However, if you are not prepared to leave, the driver will adhere to the
20-minute window policy.

**Will the driver wait if I am late?**

After arriving within the 20-minute window, the driver will wait 5
minutes after the confirmed pickup time for the passenger. If the
passenger has not arrived after this time, he/she will be assessed a
no-show (see Missed Rides)

**What if the vehicle arrives early**

All rides on Paratransit are scheduled prior to the start of the drivers
day. If a cancellation occurs while the driver is en route and another
trip cannot be scheduled in its place, the driver may arrive at your
pickup location earlier than scheduled.

If you are prepared to leave, you may board the vehicle at that time.
However, if you are not prepared to leave, the driver will adhere to the
20-minute window policy.

**What should I do if service is delayed?**

Traffic congestion, impeding weather or highway construction may cause
delays in service. If the vehicle is more than 10 minutes late, call
'GPTC at 884-6100. A dispatcher will radio your driver and provide you
with the driver's anticipated arrival time. Please be patient, as these
incidents are limited and uncontrollable.

**What are the appeal procedures?**

Individuals may appeal decisions that affect their ability to use
Paratransit. All appeals must be submitted in writing or on cassette
tape to:

Gary Public Transportation Corporation

ADA Coordinator

2101 West 35th Avenue

Gary, IN 46408

This office is the first level of appeal. If denied at this level,
individuals may make a second appeal to the Accessible Transportation
Advisory, Committee, subcommittee (see Citizen Involvement) The appeal
will be discussed at a meeting of the ATAC subcommittee at which the
rider must be present. The individual whose ridership privileges are in
question will not be denied transportation on Paratransit to attend the
meeting. The subcommittee's decision on the appeal will be based on a
vote by the attending members.

**Service Guidelines**

**Introduction**

GPTC has developed the following guidelines, which will be helpful to
you as you travel on Paratransit vehicles.

**Prompt Service**

Please be ready to depart 10 minutes before the Paratransit vehicle is
scheduled to arrive.

**On-Time Arrivals**

Drivers may arrive 10 minutes before or 10 minutes after a confirmed
trip time and still be considered on time.

**Personal Care Attendants/ Companions**

If, during the application process, it is determined that you require a
Personal Care Attendant (PCA) when you travel, the PCA will not be
charged a fare. Each passenger is also allowed to travel with one
companion.

**Special Assistance**

Paratransit drivers are trained to assit you when boarding or exiting a
vehicle. Normal assistanec is provided immediately outside the vehcile
or at the curb. The assistance may include walking walkig support and
when possible, the maneuvering of a wheel-chair over the curb. Drivers
are not permitted to enter a building or your residence.

**Packages**

The driver may also assist you in carrying packages to and from the
vehicle. Packages should be limited to no more than what can be carried
in your lap.

**Obstacles**

Please keep ramps, sidewalks and driveways free of ice, snow, toys and
other obstructions which may present a safety hazard to you and the
driver offering assistance.

**Seat Belts**

All passengers are required to use the seat belts provided in the
vehicles. The driver will not start the vehicle until passengers are
secured. Exceptions will not be made.

**Wheelchair Brakes**

Wheelchairs should have fully functional brakes, which must be in lock:
position when the passenger is on the lift and when the vehicle is in
motion.

**Scooters**

Passengers who use battery powered scooters for mobility who cannot be
restrained may be asked by the driver to transfer to a seat and secured
with a seat belt, and the scooter will be secured, as a wheelchair
should be.

**Destinations**

Drivers are permitted to stop only at locations designated in the
reservation. Travel arrangements with more than one destination will be
treated as separate trips and must be scheduled as such. Please plan to
schedule the appropriate number of reservations.

**State Laws**

Smoking, eating, drinking and the playing of radios while in the vehicle
are prohibited by state law.

**Fare**

The fare for one-way trips on Paratransit is \$2.50 within the City of
Gary boundary and \$4.00 outside the city limits. Riders are asked to
purchase ADA Paratransit Multiple Ride Passes

20 Local Rides \$50.00

12 Non Local Rides \$48.00

Purchase passes at the Metro

Center, 100 West 4th, Ave

Gary, IN on the 3rd floor,

from 8:00 A.M. To 4:00 P.M.

**Proper Conduct**

All passengers are expected to exercise proper conduct on vehicles. GPTC
reserves the right to revoke riding privileges of riders who threaten
the health or safety of other passengers or the driver.

Minimum Age Requirement

Passengers five years of age and under must be accompanied by an adult,
and will not be charged a fare. However, the adult accompanying the
minor on board must pay a full fare.

This Publication is being made in accessible formats for persons upon
request.

**Attachment D**

**Sample Forms**

![](media/image5.png){width="6.497916666666667in" height="8.63125in"}

![](media/image6.png){width="6.497222222222222in"
height="8.354861111111111in"}

![](media/image7.png){width="6.492361111111111in"
height="8.99236111111111in"}

![](media/image8.png){width="6.496527777777778in"
height="8.194444444444445in"}

**Attachment E**

**Application for ADA Complementary Paratransit**

**Service Eligibility**

![](media/image9.png){width="7.290972222222222in" height="9.125in"}

![](media/image10.png){width="6.819444444444445in" height="9.875in"}

![](media/image11.png){width="5.941666666666666in" height="7.0in"}

![](media/image12.png){width="6.811111111111111in"
height="5.633333333333334in"}

![](media/image13.png){width="6.49375in" height="6.483333333333333in"}

![](media/image14.png){width="7.143055555555556in" height="9.875in"}

Page 2

Once the ID Card is obtained, the applicant can contact Mary L. Byndum
at

881-9696, Monday through Friday, between the hours of 8:20am and 4:00pm
for trip

reservations. All trips scheduled are for the next day operation. After
the hours listed above, please contact the dispatcher at 884-6100.

Sincerely,

Earnest P. Anderson

Director of Transportation

EPA:mlb

[^1]: Reuter, Robert, *Expert Report* filed in U.S. District Court,
    Northern District of Indiana Hammond Division, (November 27, 2002).

[^2]: Note: Although these trips were selected randomly and are intended
    to be representative of all trips, the small sample size limits its
    statistical validity.