Alameda-Contra Costa Transit District

**&**

**San Francisco Bay Area Rapid Transit District**

**Oakland, CA**

Compliance Review

of

ADA Complementary Paratransit Service

February 24-28, 2003

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**Final Report: March 16, 2005**

**CONTENTS**

[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 12](#summary-of-findings)

[V. Service Parameters 16](#service-parameters)

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

[VII. Observations Regarding Telephone Capacity and Trip Reservations
30](#observations-regarding-telephone-capacity-and-trip-reservations)

[VIII. Observations Regarding Scheduling of Trip Requests
34](#observations-regarding-scheduling-of-trip-requests)

[IX. Observations Regarding Operations
39](#observations-regarding-operations)

[A. Analysis of On-Time Performance
48](#analysis-of-on-time-performance)

[B. Analysis of Trip Length 50](#analysis-of-trip-length)

[X. Resources 54](#resources)

[]{.mark}

*Attachment A* Response from Alameda-Contra Costa Transit District and
Bay Area Rapid Transit District

*Attachment B* *Riders' Guide to Paratransit Services*

*Attachment C* On-Site Review Schedule

*Attachment D* Application for ADA Complementary Paratransit Service

*Attachment E* Template for Request for Professional Verification

*Attachment F* *All About East Bay Paratransit*

*Attachment G* Sample Cover Page for Recertification Application

*Attachment H* Template for Denial Letter and Appeals Process

# 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 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 standards
and policies 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
patterns or practices of a significant number of trip denials; missed
trips; 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.

FTA conducted a review of ADA Complementary Paratransit service provided
for the Alameda-Contra Costa Transit District (AC Transit), in Oakland,
California. AC Transit has entered into an agreement with the San
Francisco Bay Area Rapid Transit District (BART) for provision of ADA
Complementary Paratransit service in the AC Transit service area. The
agreement between AC Transit and BART established the East Bay
Paratransit Consortium (EBP), which provides ADA Complementary
Paratransit service within the AC Transit service. As a result the
review addressed ADA Complementary Paratransit service provided for both
AC Transit and BART in the AC Transit service area. Planners
Collaborative, Inc., located in Boston, Massachusetts conducted the
on-site compliance review for the FTA Office of Civil Rights from
February 24 to 28, 2003. The review focused on compliance of AC
Transit's ADA Complementary Paratransit service, with one specific
regulatory service criterion: the "capacity constraints" criterion.
Section 37.131(f) of the DOT ADA regulations requires that ADA
Complementary Paratransit services be operated without capacity
constraints.

This report summarizes the observations and findings of the on-site
compliance review of Access Paratransit services provided by East Bay
Paratransit (EBP) on behalf of AC Transit and BART. First, the report
describes key features of EBP. 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. Please note that findings do
not necessarily denote deficiencies, but are statements of observations
made at the time of the compliance review. Recommendations for
addressing some of the findings are also provided.

Both AC Transit and BART received a draft copy of the report for review
and response. A copy of the correspondence received from AC Transit and
BART documenting the agencies' 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, service times, and fares

ADA Complementary Paratransit eligibility determinations were assessed
to ensure that eligible individuals were not adversely affected 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 review of key service
information prior to the on-site visit. This information included:

-   Description of the administrative structure of the ADA Complementary
    Paratransit service

-   Copies of the contracts with the broker and with the paratransit
    carriers

-   Riders' Guide to Paratransit Services (Attachment B)

-   Operator handbooks for each carrier

-   Summary of service standards

-   Summary of telephone call-handling standards

-   Sample driver manifests

-   Performance data for fiscal years 2001, 2002, and 2003

-   Budget data for fiscal years 2000, 2001, 2002, and 2003

-   Information about AC Transit and BART fixed route services

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

-   Completed applications, both accepted and denied, for ADA
    Complementary Paratransit service

-   Copies of completed driver manifests for recent months

-   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

-   Data from the broker's telephone call management systems

-   Written customer complaints

In addition to the review of data and direct observations, the review
team conducted telephone interviews with nine individuals who either use
the EBP service or work with EBP riders. The review team also reviewed
one complaint relating to ADA Complementary Paratransit service on file
with FTA.

**On-site Review**

The on-site review began with an opening conference, held at 9:00 AM on
Monday, February 24, at the AC Transit administrative offices at 1600
Franklin Street in Oakland. The following AC Transit, BART, FTA, EBP,
and Planners Collaborative staff attended the conference:

Doug Cross AC Transit

Kathleen Kelly AC Transit

Terry Green BART

Dorothy Dugger BART

Harley Goldstrom BART

Susan Sanderson BART

Anne Muzzini CGR Management Consultants

Mary Rowlands CGR Management Consultants

Mark Weinstein ATC

Derrin Jourdan FTA

Don Kidston Planners Collaborative

Brian Barber Planners Collaborative

David Chia Planners Collaborative

David Loutzenheiser Planners Collaborative

Don Kidston, David Chia, and Brian Barber, and David Loutzenheiser of
Planners Collaborative comprised the review team. Roberta Wolgast of the
Office of Civil Rights participated in the opening conference via
telephone.

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 AC Transit and BART staff for their 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 Thursday.

-   A report would be drafted and provided to AC Transit and BART for
    review and comment before being finalized as a public document. The
    final report would be available via the Freedom of Information Act.

Mr. Chia described the schedule for the on-site review and the
subsequent report. A copy of the review schedule appears in Attachment
C.

Following the opening conference, the team members met with AC Transit,
BART, and ATC/Vancom, Inc. (ATC) managers to discuss the organizational
structure and management of the East Bay Paratransit Consortium. ATC
serves as the broker for service provision through a three-party
contract with AC Transit and BART. The team members also asked about the
budget process and requested additional information concerning finances
and available resources. In the afternoon, the team moved to the ATC
office at 1720 Broadway in Oakland. Team members toured the facility,
then began to review the data provided by AC Transit and BART. Team
members also observed telephone reservations.

[]{.mark}

On Tuesday morning, February 25, team members visited the facilities of
two of four companies under contract to ATC to provide service: Friendly
Transportation, Inc. and First Transit, Inc., both in Oakland. At each
site, assessors toured the facility, interviewed managers, dispatchers,
and drivers regarding procedures, and observed dispatch. Team members
also collected data concerning each carrier's resources. In the
afternoon, one team member reviewed the eligibility process with the
certification manager. Other team members began analysis of the
telephone system, on-time performance, and service parameters (area,
fares, days and hours).

[]{.mark}

On Wednesday, February 26, two team members visited AC Transit's
paratransit operation in Oakland in the morning (in addition to the four
companies under contract to ATC, AC Transit is a fifth carrier, directly
providing a portion of the paratransit service). Two team members
visited MV Transportation, Inc. in San Leandro in the afternoon. The
assessors toured the facility, interviewed managers, dispatchers, and
drivers regarding procedures and observed dispatch. Team members also
collected data concerning each carrier's resources. Back at the broker's
office, team members continued to observe reservations and continued
their analysis of the data collected.

On Thursday, February 27, assessors reviewed the scheduling process,
observed reservations, conducted an analysis of trip lengths and
comparable fares, and on-time performance. As needed team members
conferred with BART, AC Transit, and ATC staff.

On Friday, February 28, the team members completed their on-site
analysis and prepared for the afternoon exit conference. During the exit
conference, the review team presented preliminary findings, and
discussed these findings and recommendations with AC Transit, BART, and
EBP staff. In attendance were:

Doug Cross AC Transit

Paul Sluis AC Transit

Terry Green BART

Dorothy Dugger BART

Harley Goldstrom BART

Susan Sanderson BART

Lee Davis BART

Anne Muzzini CGR Management Consultants

Mary Rowlands CGR Management Consultants

Mark Weinstein ATC

Rashida Kamara ATC

Derrin Jourdan FTA

Don Kidston Planners Collaborative

Brian Barber Planners Collaborative

David Chia Planners Collaborative

David Loutzenheiser Planners Collaborative

[]{.mark}

Cheryl Hershey of the Office of Civil Rights participated in the exit
conference via telephone.

The review team reviewed initial findings in the areas of:

-   Customer complaints

-   Service area, days and hours

-   Fares

-   Eligibility certification process

-   Telephone access

-   Trip reservations and scheduling

-   Operations and dispatch

-   On-time performance

-   Trip duration

-   Resources

Ms. Hershey emphasized that FTA was available to provide additional
technical assistance to

AC Transit, BART, and EBP.

# Background

There are two primary public fixed route operators in the East Bay of
the San Francisco-Oakland (CA) Urbanized Area. The Alameda Contra-Costa
Transit District (AC Transit) operates 150 bus routes in 13 cities and
adjoining unincorporated areas in western Alameda and Contra Costa
Counties, east of the San Francisco Bay. It also provides bus service
from the East Bay to downtown San Francisco. The San Francisco Bay Area
Rapid Transit District (BART) operates heavy rail in the AC Transit
service area, as well as in San Francisco, San Mateo County, and Contra
Costa County.

A seven-person board that is publicly elected (five by wards plus two at
large) governs

AC Transit. A nine-person board (nine districts), also publicly elected,
governs BART.

In calendar year 2002, AC Transit had a total fixed route ridership of
67.4 million and an average weekday ridership of 226,000. System-wide,
BART had a CY2002 fixed route ridership of 95.2 million and an average
weekday ridership of 307,700.

AC Transit has a fleet of over 800 buses. All are lift-equipped. All
BART cars and stations are accessible for persons who use wheelchairs.
AC Transit has six routes that run 24 hours every day. Many other routes
run from 5 AM to midnight on weekdays, with less service on Saturday and
Sunday. BART service begins at 4 AM on weekdays, 5:55 AM on Saturday,
and 7:49 AM on Sunday, with final service after 1 AM on all days.

The base fare on AC Transit is \$1.50. Transfers cost 25 cents (for
multiple buses within two hours). The fare for bus service from East Bay
to San Francisco ranges from \$3 to \$3.25. Fares on BART are
distance-based. The base fare is \$1.15, with a maximum one-way fare of
\$4.95.

Because these two agencies have overlapping service areas, they were
allowed by the DOT ADA regulations at 49 CFR 37.141 to submit a joint
plan to FTA for providing coordinated paratransit service. The joint
plan submitted by AC Transit and BART included the formation of the East
Bay Paratransit Consortium (EBP) in 1994. AC Transit and BART set policy
and perform administrative oversight of EBP. Costs for EBP are
allocated, 69% to AC Transit and 31% to BART. EBP contracts with a
broker for daily operation of ADA Complementary Paratransit service. At
the time of the review, ATC/Vancom, Inc. was the broker for EBP.

**Description of the ADA Complementary Paratransit Service**

EBP's staff consists of two consultants under contract to AC Transit.
Their primary responsibilities are to monitor service quality and
collect data on service, operations, and finances. In addition, BART and
AC Transit each have staff members who actively oversee ADA
Complementary Paratransit service. As the broker, ATC handles daily
operations. In turn, ATC works with the five carriers: four private
companies and AC Transit. Table III.1 lists these five carriers.

> Table III.1 -- Carriers for EBP's ADA Complementary Paratransit
> Service

+----------------------------------+-----------------------------------+
| AC Transit                       | 1100 Seminary Avenue              |
|                                  |                                   |
|                                  | Oakland, CA 94621                 |
+----------------------------------+-----------------------------------+
| A Paratransit Corporation        | 22990 Clawiter Road               |
|                                  |                                   |
|                                  | Hayward, CA 94545                 |
+----------------------------------+-----------------------------------+
| First Transit, Inc.              | 411 High Street                   |
|                                  |                                   |
|                                  | Oakland, CA 94601                 |
+----------------------------------+-----------------------------------+
| Friendly Transportation, Inc.    | 4849 E. 12th Street               |
|                                  |                                   |
|                                  | Oakland, CA 94601                 |
+----------------------------------+-----------------------------------+
| MV Transportation, Inc.          | 1944 Williams Street              |
|                                  |                                   |
|                                  | San Leandro, CA 94577             |
+----------------------------------+-----------------------------------+

Major responsibilities of ATC include:

-   Conducting eligibility determinations

-   Accepting trip requests

-   Scheduling trips and provide manifests to carriers

-   Taking all other service calls from riders

-   Monitoring service provided by carriers

The carriers have the following responsibilities:

-   Providing and training drivers and dispatchers

-   Providing and maintaining vehicles

-   Dispatching vehicles based on schedule manifests provided by ATC

EBP's service area includes the whole of AC Transit's service area,
which also encompasses BART's service area in the western parts of
Alameda and Contra Costa Counties. EBP's service area is 241 square
miles, with a population of 1,086,000 (FTA 2001 National Transit
Database). The EBP service area includes a 3/4-mile minimum area around
bus routes and rail stations. EBP also provides trips to and from the
East Bay and points in San Francisco. In addition, there are designated
points for EBP passengers to transfer to another ADA Complementary
Paratransit service provider in adjoining jurisdictions.

In FY2002, total EBP ridership was 661,413. Of this total, 81.4 percent
were ADA Complementary Paratransit service passengers; an additional
16.3 percent were attendants or escorts (guests) to the ADA-eligible
passengers. The other 2.3 percent were non-ADA passengers served through
contracts with local municipalities.

The existing fare structure is distance-based:

-   \$2.25 up to 8 miles

-   \$4.50 8 to 24 miles

-   \$6.75 more than 24 miles

There is also an 80-cent surcharge for trans-bay trips with either an
origin or destination that is more than 3/4-mile from a San Francisco
BART station. Riders can pay with cash or tickets.

Service is available 24 hours a day, seven days a week to portions of
the service area, to match AC Transit's bus service. Other parts of the
service area, have more limited service hours, consistent with the
comparable fixed route service in the area. ATC accepts reservations
from one to seven days in advance, from 7 AM to 7 PM. For next-day
trips, the deadline for reservations is 5 PM.

EBP provides "standing order" (subscription) service for riders who have
the same trip (time and destination) at least once per week. At the time
of the review, EBP had a waiting list for subscription trips during
weekday morning and afternoon peak periods.

As of early 2003, EBP had about 20,000 certified riders. The maximum
period for certification is three years.

**Policies and Service Standards Related to Capacity Issues**

AC Transit and BART have established service standards for telephone
hold time, trip denials, on-time performance, missed trips, and travel
time. The service standards are described below.

-   **Reservation Call Hold Time**: "Wait time on hold in queue for the
    customer service shall not exceed an average of two minutes." The
    current average is approximately two and one-half minutes.
    (Attachment A to Broker contract, page 8)

-   **On-time Performance**: For a 20-minute pickup window, the goal is
    93%. The broker and each carrier have incentives/disincentives
    related to this goal. EBP can provide a financial bonus for
    performance better than 93%, and a penalty for performance poorer
    than 89%. (Broker contract, pages 28-29)

> []{.mark}

-   **Trip Denials**: "It is the policy of EBP to avoid a pattern or
    practice of denials and not to have a substantial number of denials.
    To that end the Broker shall take appropriate measures to
    accommodate the demand of eligible riders through planning,
    budgeting, operational improvements, communication with the
    agencies, timely change order requests, or other methods."
    (Attachment A to Broker contract, page 16)

> []{.mark}

-   **Missed and Very Late Trips**: "All trips where the pickup time is
    60 minutes or more after the scheduled pickup time." (Broker
    contract, page 30)

-   **On-board Travel Time**: "Your paratransit ride will take
    approximately the same amount of time a similar trip on an AC
    Transit bus would take." (*Rider's Guide*, page 10) A letter from a
    BART manager to the review team stated, "There is no specific
    percentage goal for this standard. It is tracked by monitoring
    customer complaints."

**Consumer Comments**

The review team gathered information about the concerns of riders who
use EBP through three sources: written complaints to FTA; telephone
interviews with riders or professionals who work with riders; and
written and telephone complaints to EBP. The purpose of this review was
to identify areas and issues within the scope of the review that are of
concern to consumers.

**Summary of Complaints filed with FTA on Access Paratransit Services**

FTA's Office of Civil Rights had one complaint on file against AC
Transit or BART regarding ADA Complementary Paratransit service. This
complaint addressed a number of service issues. After its investigation,
including correspondence with AC Transit, BART, and EBP staff, FTA
responded to this complaint shortly before the on-site review (February
4, 2003).

Consumer Interviews

The review team interviewed nine riders or rider representatives of EBP
regarding service issues. Here is a summary of their comments:

-   Six of the riders interviewed said that they sometimes or usually
    had long hold times when trying to make a trip reservation.

-   Five said that they sometimes or often were late for appointments.

-   Five said that some of their trips were "excessively" long (more
    than 60 or 90 minutes).

-   Four said that their complaints were not properly handled.

Riders commented that the biggest problem is late pickups. Related to
this is a concern that the broker's customer service agents and
complaints staff are sometimes unresponsive. Several riders also stated
that they believe that there is some confusion about accepting and
providing standing order service.

Summary of Complaints Filed with Broker

EBP, through ATC, received 1451 complaints for the six months, July to
December 2002, an average of 242 per month (EBP also received 289
commendations). The two major categories of complaints were on-time
performance and driver behavior. Table III.2 presents a tabulation of
complaints received by EBP.

**Complaint Procedures.** ATC considers themselves an advocate for
consumers, representing their interests to the carriers. There is one
Complaints Clerk who works full-time, managing the complaint process.
The Complaints Clerk reports to the customer services manager, who also
manages the phone and reservations system. All reservationists are
trained to take customer complaints. Consumers can also leave complaints
as a voice mail on a separate phone line.

Table III.2 Summary of Complaints Filed with Broker: July-December 2002

  ------------------------------------- --------------- -----------------
  Complaint Category                    **Number**      **Percent**

  On-time Performance                   841             58.0%

  Driver Behavior                       376             25.9

  Reservations/Other Phone              168             11.6

  Scheduling                            38              2.6

  Vehicles/Other Equipment              8               0.6

  Other                                 20              1.4

  **Total**                             1451            100.0%
  ------------------------------------- --------------- -----------------

After an ATC call-taker receives a complaint, he/she sends it to the
complaint staff. Three staff members are dedicated to investigating the
complaints, and then calling back the complainant with the information
they receive in their investigations. Investigations usually include
calling the carrier to verify if what the complainant alleges really
happened, and if so, why. If EBP verifies the complaint and judges that
EBP's error was "substantial," ATC sends a letter of apology with free
ride tickets as compensation. A staff judgment is made whether to
include tickets with an apology letter. Sometimes it is felt that
sending free tickets only adds insult to injury.

ATC strives to respond to letters within 14 days. Return calls are made
within this time period also, with a target of returning calls before 14
days to allow time for a letter, if appropriate.

ATC has a voice mailbox for after-hours complaints and for riders who do
not want to speak with a call-taker. Many complaints are anonymous, thus
eliminating ATC's ability to respond.

EBP has a Service Review Advisory Committee (SRAC) comprised of
consumers and consumer representatives. A Service Quality Subcommittee
of the SRAC reviews the complaint process and advises EBP on service
quality issues. The subcommittee is composed of riders and rider
representatives and advocates who review a sampling of complaints, the
complaint process, and any public comments received about service. The
subcommittee also recommends corrective actions for resolving the
complaints.

There are 26 categories used to record complaints. Monthly summaries are
prepared with eight aggregated categories for the Subcommittee to
review. The eight aggregated categories are:

-   Timeliness -- Provider

-   Driver Complaints -- Provider

-   Equipment / Vehicle -- Provider

-   Scheduling -- Provider

-   Scheduling -- Broker

-   Phone Reservations - Broker

-   Other -- Provider

-   Other - Broker

# Summary of Findings

This section of the report summarizes the findings drawn from 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 the
following sections of this report. The findings should be used as the
basis for any corrective actions proposed by AC Transit and BART.
Recommendations are also included in the report for the consideration of
AC Transit and BART in developing corrective actions.

**A. Findings Regarding Service Parameters**

1.  EBP provides service to a strict 3/4-mile zone around AC Transit bus
    routes and BART rail stations in the East Bay. The ADEPT software
    that ATC uses to schedule trips has a geographic database that
    checks the requested origin and destination addresses to confirm
    that they are within the EBP service area.

2.  EBP has established a procedure to allow riders to transfer to ADA
    Complementary Paratransit providers in contiguous service areas.
    There are about 20 round trip regional transfers per weekday.

3.  EBP provides service during all days and hours when fixed route
    service operates.

4.  For trips of 8 miles or less, the paratransit fare of \$2.25 is less
    than two times the fare of a comparable fixed route trip by a
    typical user. For trips of 8 to 24 miles, it appears that the
    paratransit fare of \$4.50 can be more than two times the fare of a
    comparable fixed route trip, if the rider chooses to travel by the
    slower, but less expensive routing. For trips of more than 24 miles,
    the paratransit fare of \$6.75 appears to be less than two times the
    fare of a comparable fixed route trip by a typical user.

**B. Findings Regarding ADA Complementary Paratransit Eligibility**

1.  In general, the eligibility determination process used by ATC on
    behalf of AC Transit and BART does not seem to deny service to
    eligible individuals. In fact, ATC's approval rate for full or
    partial eligibility of 99% may indicate that its evaluation process
    may be granting eligibility to individuals who are able to use fixed
    route service.

2.  Applicants who are denied eligibility receive a letter from EBP that
    states the reason for the denial. The letter also includes a copy of
    EBP's appeals process and "Request for Appeal" form. Applicants who
    receive conditional or temporary eligibility receive a letter
    stating the reason for the limitations. Their letter refers to EBP's
    appeals process, but does not actually provide a copy of the
    process.

3.  EBP's "Request for Appeal" form includes, "I think I am eligible for
    ADA paratransit services because," followed by blank lines. All that
    is required of the appellant is a signed declaration, within the
    specified timeframe, that he/she is exercising his/her right to
    appeal.

4.  EBP has a suspension policy for riders in which three no-shows in a
    calendar quarter could result in a 30-day suspension. EBP has not
    suspended any riders for excessive no-shows for at least two years.
    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."

5.  Based on both the review team's review and EBP's own records, EBP
    does take more than 21 days to make some of its eligibility
    determinations. While the DOT ADA regulations do not require an
    agency to make an eligibility determination within 21 days, 49 CFR
    37.125(c) does require an agency to provide service to an applicant
    until the agency makes an eligibility determination. It is not
    apparent whether EBP is providing service to applicants for whom EBP
    has not made a decision within 21 days. In addition, none of the
    eligibility information provided to applicants mentions the
    availability of service after 21 days in the absence of an
    eligibility determination.

6.  EBP grants conditional eligibility for health, weather, terrain, or
    other conditions. The rider with conditional eligibility determines
    for each trip whether those conditions apply.

**C. Findings Regarding Telephone Capacity & Trip Reservations**

1.  Telephone access and the reservation process do not appear to be an
    impediment to customers in scheduling trips. Although customer
    interviews by the review team and complaints recorded by EBP both
    indicated consumer concern with telephone hold times, review team
    members did not observe any long hold times or long telephone
    queues.

2.  ATC has a goal in its contract with EBP of two minutes for its
    average hold time for telephone calls. Sample data from ATC's call
    management system yielded an average hold time of 2:15.

3.  ATC has a goal of one minute for its average call time. Sample data
    from ATC's call management system yielded an average call time of
    2:22.

4.  ATC's peak staffing for call-takers is from 1 PM to 3 PM. However,
    call management data indicates that the peak time for calls is from
    3 PM to 5 PM.

5.  When call-takers could not offer a trip within one hour of the
    requested time, sometimes they recorded these as trip cancellations
    or placed them on standby -- rather than recording them as trip
    denials. This practice results in understating the number of trip
    denials.

6.  Call-takers were consistent in giving callers a 20-minute window for
    the pickup time, rather than a specific time. This practice provides
    customers with a clear understanding of when to be ready for the
    vehicle to arrive.

7.  Call-takers were not consistent in authorizing a carrier to no-show
    a rider, primarily in terms of how long the driver had to wait at
    the pickup address; this varied from 5 to 15 minutes. This practice
    can delay drivers and contribute to them to be late in performing
    their schedule.

**D. Findings Regarding Scheduling of Trip Requests**

1.  The review team observed scheduled pickup times on vehicle manifests
    that were outside of the 20-minute pickup window.

2.  The vehicle manifests do not display the pickup window times or the
    negotiated pickup time. This can cause a driver to be unaware that
    he/she is late and cause miscommunication with customers.

3.  Subscription trips comprise nearly half of EBP's weekday trips
    requested. However, less than half of the subscription trips are
    pre-assigned to vehicle runs. The remaining subscription trips are
    placed on a "wait list" and are scheduled every day. Assigning all
    of the subscription trips to runs can reduce the effort required to
    assign demand trips. In addition more consistent runs can be refined
    as needed through driver feed back and facilitate operations thereby
    increasing operating efficiency.

4.  Much of the effort of ATC schedulers is devoted to assigning
    "standby" trips to vehicle runs, even though they comprise only five
    to six percent of EBP's total trips.

5.  Various parameters used in the scheduling software, including
    average vehicle speeds, may not be properly set. This may lead to
    unrealistic vehicle runs.

**E. Findings Regarding Operations**

1.  EBP appears to have a small, but consistent, number of trip denials
    and missed trips each day. Eleven additional potential denials were
    identified from ATC records for the sample day of January 15, 2003.
    This represents less than 0.4% of requested trips. The missed trips
    represents 1.2% of requested trips. EBP also reports a small number
    of trip denials and missed trips from its sampling of trip records.

2.  Based upon the sample day analyzed by the review team, some trip
    offers that were more than one hour from the time requested by the
    customer were not counted as denials. In addition, trips offered
    more than one hour from the initially requested time but turned down
    by the caller were counted as cancelled requests − rather than
    denials. More accurate accounting of these trips can assist in
    planning and scheduling service to eliminate denials.

3.  174 trips (7.6% of scheduled trips) were reported as late
    cancellations and customer no‑shows on the sample day. These
    cancellations and no-shows might provide capacity on the day of
    service to schedule and serve denied and missed trips.

4.  EBPT appears to have a small number of significantly late pickups.
    EBP reports approximately 0.2% pickups more than one hour late
    in 2002. Based on the one-day sample conducted by the review team,
    1.0% of pickups and 1.3% of drop-offs were more than one hour late.

5.  The definition of the 20-minute on-time window (0/+20) does not
    appear to be effectively communicated to service providers and
    drivers. The contracts between ATC and the service providers cite a
    contract penalty for pickups completed more than 30 minutes after
    the scheduled pickup time. As a result, the service providers'
    incentive is to pickup customers within 30 minutes of the scheduled
    pickup time (0/+30), not 20 minutes. Operator manuals do not address
    the on-time pickup window and only an estimated pickup time appears
    on the driver's manifests. Several observations were made of
    scheduled pickup times on driver manifests that were outside of the
    customer's 20-minute pickup window. Most drivers interviewed did not
    know what the pickup window is. As a result, the driver is usually
    unaware of what the customer is expecting for a pickup time. This
    can result in miscommunications between driver and customer and can
    contribute to late and early pickups.

6.  EBP does not have a standard for on-time performance for drop-offs
    for appointments and does not measure on-time performance for
    drop-offs.

7.  EBP does not appear to have a substantial number of significantly
    long ADA Complementary Paratransit trips. One trip from a sample of
    23 trips greater than one hour had a travel time that was
    significantly longer than that of a comparable fixed route trip.

8.  Three of the 23 long trips were on one route. This might indicate
    that the small number of long trips observed result from assignment
    of too many passenger trips to one route.

9.  Drivers do not appear to consistently understand "no-show"
    procedures.

**F. Findings Regarding Resources**

1.  Funding for EBP services appears to be adequate and does not appear
    to limit service capacity. Economic conditions may limit future
    funding.

2.  Comparison of EBP's ADA Complementary Paratransit passenger trip
    volumes with those of comparably sized transit operators indicates
    that there is potential for continued growth in the demand for
    service in the Oakland area.

3.  Operating resources, including drivers and vehicles, appear to be
    adequate to serve existing travel demand. Flexible capacity for some
    carriers may be insufficient to respond to absences, demand spikes,
    and real time scheduling of trips that are currently denied.

4.  The process for preparing budgets appears to adequately reflect
    service needs. An allowance for 7.5% ridership growth in 2003
    appears to adequately provide for the current small number of denied
    and missed trips and a reasonable level of ridership increase.

5.  Not explicitly including unserved, expressed demand for service − in
    the form of denials and missed trips − in the budgeting process
    could result in underestimation of projected ridership if the number
    of trip denials and missed trips were substantial.

# Service Parameters

The review team reviewed EBP service to determine whether it is
comparable with the fixed route service of AC Transit and BART in the
following areas with respect to the DOT ADA regulations as cited:

-   Service area (49 CFR 37.131(a))

-   Days and hours of service (49 CFR 37.131(e))

-   Fares (49 CFR 37.131(c))

The review team reviewed consumer complaints; reviewed information
distributed to riders; reviewed EBP policies regarding service area,
days and hours, and fares; interviewed ATC managers and AC Transit and
BART staff; and used an on-line trip planner for the Bay Area to analyze
fares for a sample of trips.

The one complaint on file with FTA does include a concern about regional
transfers between paratransit providers. The consumers interviewed by
the review team did not mention any concerns about service area, days
and hours, or fares. Among the complaints recorded by EBP that the
review team examined, service parameters were not an issue.

**ADA Complementary Paratransit Service Area**

According to the *Riders' Guide*, page 6 (Attachment B):

> The service area includes communities served by AC Transit in the East
> Bay, as well as San Francisco (See service map on pages 19 and 20). As
> a certified rider, you can travel anywhere within the service area,
> and can transfer to other paratransit services within the 9-county Bay
> Area region. . .
>
> You can travel directly from the East Bay service area to designations
> in San Francisco. If you are going farther than 3/4-miles from a San
> Francisco BART station, you must pay an additional 80 cents each way
> for this service.

The map displayed in the *Riders' Guide* shows the East Bay service area
as encompassing one uninterrupted area on the East Bay. AC Transit and
BART staff stated that the map is an approximation. In practice, EBP
limits its service area to a strict 3/4-mile zone around

AC Transit bus routes and BART rail stations in the East Bay. The ADEPT
software that ATC uses to schedule trips has a geographic database that
checks the requested origin and destination addresses to confirm that
they are within the EBP service area.

AC Transit operates a number of routes that travel from the East Bay to
the Transbay Terminal in downtown San Francisco. Based on the service
characteristics of these routes, one could categorize some of the
Transbay routes as "Commuter Bus Service," as defined in 49 CFR 37.3.
Requirements for ADA Complementary Paratransit service do not apply to
commuter bus service (49 CFR 37.121(c)). Consequently, ADA Complementary
Paratransit service would not be required for these AC Transit Transbay
bus routes.

However, because BART provides fixed route service between the East Bay
and San Francisco, BART has an obligation to provide ADA Complementary
Paratransit service between East Bay and San Francisco. Consequently,
while AC Transit may not be required to provide Transbay ADA
Complementary Paratransit service, BART is required.

Interregional Trips

The area served by EBP is contiguous to a number of other transit
providers' service areas, including: San Francisco; east of the hills in
Alameda and Contra Costa Counties; Santa Clara County; and Marin County.

EBP typically uses the following transfer locations for customer
transfers to other paratransit systems. The agency allows flexibility to
use different mutually agreed upon locations for transfers as necessary.

-   Orinda BART station

-   Dublin/Pleasanton BART station

-   Fremont BART station

-   Del Norte BART station

-   Pinole Shopping Center

-   Daly City BART station

In the policy set by the participating transit systems, the vehicle on
the first leg of a transfer trip waits for the second-leg vehicle to
arrive before transferring the passenger. Due to occasional long
wait-times, EBP is considering revising this policy to allow, with
passenger approval, a vehicle to drop off the passenger before the
transfer vehicle arrives.

To arrange an inter-regional trip, a rider calls the ADA Complementary
Paratransit service provider that serves the origin address. This
provider then coordinates with the destination provider regarding
transfers and times. Communication is primarily via fax and phone. The
origin provider confirms trip times and total fares with the rider.
According to broker staff, there are approximately 20 round trip
regional transfers per weekday.

**Days and Hours of Service**

The DOT ADA regulations require that ADA Complementary Paratransit
service be available during the same hours and days as fixed route
service (49 CFR 37.131(e)).

AC Transit has six routes (40, 51, 58, 62, 73, 82) that run 24 hours
seven days a week. Many other routes run from 5 AM to midnight on
weekdays, with less service on the weekend. BART runs from 4 AM to 1:30
AM on weekdays; 6 AM to 1:30 AM on Saturday; and 8 AM to 1:30 AM on
Sunday. Most carriers have regular runs scheduled from 4 AM to 1 AM. ATC
staff said that carriers provide service for trips between 1 AM and 4 AM
in the areas served by AC Transit or BART.

**Fares**

The DOT ADA regulations limit fares for ADA Complementary Paratransit
service to twice the full fare for a fixed route passenger for a
comparable trip (49 CFR 37.131(c)). EBP has a distance-based fare
structure. ADEPT is used to compute the distance used to determine the
fare for a particular trip by using a variation of the route network
mileage between the origin and destination addresses (rather than a
straight-line distance or actual driving distance). Table V.1 presents
the EBP fare schedule. Riders can pay by cash or pre-paid tickets.

**Table V.1 − East Bay Paratransit Fares**

  ----------------------------------- -----------------------------------
  **Trip Distance**                   **One-way Fare**

  0 to 8 miles                        \$2.25

  8 to 24 miles                       \$4.50

  24+ miles                           \$6.75
  ----------------------------------- -----------------------------------

AC Transit's base fare is \$1.50, with an additional 25 cents for
unlimited transfers within two hours. BART's base fare is \$1.15. BART
fares vary by the trip length. Table V.2 presents the range of fares for
AC Transit and BART for travel within the East Bay.

**Table V.2 − Fixed Route Fares for Travel in East Bay**

  ---------------------------------------- ------------------------------
  **Carrier**                              **One-way Fare**

  AC Transit, base fare                    \$1.50

  AC Transit, with transfer                \$1.75

  BART, minimum                            \$1.15

  BART, East Bay maximum                   \$3.70
  ---------------------------------------- ------------------------------

AC Transit and BART instituted the current fare structure with the three
mileage bands in 1995. The actual fares have been in place since 1997.
In 1995, the staff set forth the following guidelines for selecting a
fare structure for EBP:

-   Fare of the trip must be no more than twice the comparable trip on
    fixed-route public transit.

-   Fare of the trip is based on the transit system (BART and/or AC
    Transit) most likely to be used on the trip.

-   A distance-based fare was developed for ease of customer convenience
    and administrative feasibility.

According to Appendix D of 49 CFR 37.131(c), the determination of a
comparable paratransit fare should be made "to the mode on which a
typical fixed route user would make the particular trip, based on
schedule, length, convenience, avoidance of transfers, etc." The
comparable fixed route trip should therefore be based on the "typical
user" making the trip for a given origin and destination. Cost, travel
time, and transfers should be considered in identifying the comparable
trip. A service provider is given the discretion to define what the
itinerary that a "typical user" would take.

Analysis of Fares for Comparable Trips

The review team conducted an analysis of nine trips of lengths varying
from 3 miles to 31 miles within the East Bay. Using the
[transitinfo.org]{.underline} on-line trip planner, the review team
identified two routings for each origin-destination (O-D) pair: one for
the fastest trip, and the second for the lowest price trip. Table V.3
presents these nine sample trips, along with routings, fares, and travel
times for potential comparable fixed route trips

The trip origin-destination pairs were selected to provide a cross
section of shorter intercity trips and longer trips throughout the East
Bay. It should be noted that most north/south AC Transit bus routes
terminate in downtown Oakland. Therefore, a person who wants to travel
by bus in the East Bay from north of Oakland (e.g., Berkeley) to south
of Oakland (e.g., San Leandro) must change buses in downtown Oakland.

South of Hayward, most bus routes terminate at BART stations. Therefore,
if a typical person were to travel from Fremont (at the southern of the
AC service area) to Oakland, that person would likely use BART for a
portion of the trip. A bus-only trip is feasible in some cases, but
would require a change of several buses and more than three hours of
travel time between Fremont and Oakland.

In seven of the nine sample trips, the low cost trip involved AC Transit
bus routes only and no BART service. For the other two trips (trips #5
and #9), there was only one itinerary, with no feasible bus-only
routing. The fastest trip in eight of nine cases made use of BART for
part of the itinerary; the exception was for the shortest (three miles)
trip.

For the three-mile trip (#1), the paratransit fare is less than two
times the fares of both the low cost and the fast routings (\$2.25
versus \$3.00 and \$3.50). Also, the fare for a one-stop trip on BART is
\$1.15. The \$2.25 paratransit fare is less than double this minimum
BART fare.

For three of the trips in this sample between 8 and 24 miles long (#2,
#3, #4), the paratransit fare is more than two times the fares of the
low cost routings, but less than two times the fare for the fast
routings. It would be difficult to predict which travel choice the
"typical" rider would make on these trips.

-   For #2, the fare for the fastest routing is three times the low cost
    routing. The passenger saves \$3.40 for a trip that takes 41 minutes
    longer but has one fewer transfer.

-   For #3, the difference in fare is more than double, and the fastest
    routing requires a transfer, while the low cost routing does not.
    The customer saves \$1.70 for a trip that is 23 minutes longer but
    also has one fewer transfer.

For three of the trips in this sample that are more than 24 miles (#6,
#7, #8), the paratransit fare is more than two times the fares of the
low cost routings, but less than two times the fare for the fast
routings. Given the disparity in travel times between the low cost and
fast routings for these three trips, one could reasonably say that a
"typical user" would choose the higher cost faster routings.

Based on this analysis, the review team makes the following observations
about EBP's existing fare structure and scale:

1.  For trips of 8 miles or less, the paratransit fare of \$2.25 is less
    than two times the fare of a comparable fixed route trip by a
    typical user − whether the routing consists of AC Transit bus
    routes, BART rail, or some combination.

2.  For trips of 8 to 24 miles, it appears that the paratransit fare of
    \$4.50 can be more than two times the fare of a comparable fixed
    route trip by a typical user, if that user chooses to take the lower
    cost fixed route trip. However, the comparable paratransit fare for
    the same trip, if taken on the fastest routing, would be equal to or
    less than twice the fixed route fare.

3.  For trips of more than 24 miles, the paratransit fare of \$6.75
    appears to be less than two times the fare of a comparable fixed
    route trip by a typical user. This is because it is likely that a
    large segment of such long trips would be on BART, whose fares
    increase with the distance traveled.

**Table V.3 −** Sample Fixed Route Trips Used in Comparable Fare
Analysis

<table>
<colgroup>
<col style="width: 6%" />
<col style="width: 13%" />
<col style="width: 14%" />
<col style="width: 8%" />
<col style="width: 12%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 9%" />
<col style="width: 9%" />
</colgroup>
<tbody>
<tr class="odd">
<td rowspan="2"><strong>Trip #</strong></td>
<td rowspan="2"><strong>Origin</strong></td>
<td rowspan="2"><strong>Destination</strong></td>
<td rowspan="2"><strong>Type of Routing</strong></td>
<td rowspan="2"><strong>AC Routes/ BART</strong></td>
<td rowspan="2"><p><strong>F-R</strong></p>
<p><strong>Travel</strong></p>
<p><strong>Time</strong></p></td>
<td rowspan="2"><strong>Miles</strong></td>
<td colspan="2"><p><strong>Fixed Route</strong></p>
<p><strong>Fare</strong></p></td>
<td rowspan="2"><p><strong>Paratransit</strong></p>
<p><strong>Fare</strong></p></td>
<td rowspan="2"><p><strong>Paratransit Fare &lt; 2x</strong></p>
<p><strong>F-R Fare?</strong></p></td>
</tr>
<tr class="even">
<td><strong>Full</strong></td>
<td><strong>Double</strong></td>
</tr>
<tr class="odd">
<td rowspan="2">1</td>
<td rowspan="2"><p>Claremont Hotel,</p>
<p>Oakland </p></td>
<td rowspan="2"><p>Kaiser Hospital,</p>
<p>Oakland </p></td>
<td>Low Cost</td>
<td>6</td>
<td>0:58</td>
<td>3</td>
<td>$ 1.50</td>
<td>$ 3.00</td>
<td>$ 2.25</td>
<td>YES</td>
</tr>
<tr class="even">
<td>Fastest</td>
<td>7,51</td>
<td>0:31</td>
<td>3</td>
<td>$ 1.75</td>
<td>$ 3.50</td>
<td>$ 2.25</td>
<td>YES</td>
</tr>
<tr class="odd">
<td rowspan="2">2</td>
<td rowspan="2"><p>College &amp; Bancroft,</p>
<p>Berkeley</p></td>
<td rowspan="2"><p>Oakland Airport</p>
<p> </p></td>
<td>Low Cost</td>
<td>51, 58</td>
<td>1:56</td>
<td>11</td>
<td>$ 1.75</td>
<td>$ 3.50</td>
<td>$ 4.50</td>
<td><strong>NO</strong></td>
</tr>
<tr class="even">
<td>Fastest</td>
<td>F, BART, AirBart</td>
<td>1:15</td>
<td>11</td>
<td>$ 5.15</td>
<td>$ 10.30</td>
<td>$ 4.50</td>
<td>YES</td>
</tr>
<tr class="odd">
<td rowspan="2">3</td>
<td rowspan="2"><p>Hilltop Mall,</p>
<p>Richmond</p></td>
<td rowspan="2"><p>Downtown Oakland</p>
<p> </p></td>
<td>Low Cost</td>
<td>72</td>
<td>1:34</td>
<td>14</td>
<td>$ 1.50</td>
<td>$ 3.00</td>
<td>$ 4.50</td>
<td><strong>NO</strong></td>
</tr>
<tr class="even">
<td>Fastest</td>
<td>72, BART</td>
<td>1:11</td>
<td>14</td>
<td>$ 3.20</td>
<td>$ 6.40</td>
<td>$ 4.50</td>
<td>YES</td>
</tr>
<tr class="odd">
<td rowspan="2">4</td>
<td rowspan="2"><p>Downtown</p>
<p>Oakland </p></td>
<td rowspan="2"><p>Hayward</p>
<p> </p></td>
<td>Low Cost</td>
<td>82</td>
<td>1:17</td>
<td>15</td>
<td>$ 1.50</td>
<td>$ 3.00</td>
<td>$ 4.50</td>
<td><strong>NO</strong></td>
</tr>
<tr class="even">
<td>Fastest</td>
<td>BART</td>
<td>0:35</td>
<td>15</td>
<td>$ 2.25</td>
<td>$ 4.50</td>
<td>$ 4.50</td>
<td>YES</td>
</tr>
<tr class="odd">
<td>5</td>
<td><p>Downtown</p>
<p>Oakland </p></td>
<td><p>Civic Center,</p>
<p> Newark</p></td>
<td>[no trip by bus only]</td>
<td>BART, 233</td>
<td>1:30</td>
<td>23</td>
<td>$ 4.05</td>
<td>$ 8.10</td>
<td>$ 4.50</td>
<td>YES</td>
</tr>
<tr class="even">
<td rowspan="2">6</td>
<td rowspan="2"><p>Kaiser Hospital,</p>
<p>Oakland </p></td>
<td rowspan="2"><p>Kaiser Hospital,</p>
<p>Fremont </p></td>
<td>Low Cost</td>
<td>[4 Transfers]</td>
<td>3:45</td>
<td>25</td>
<td>$ 1.75</td>
<td>$ 3.50</td>
<td>$ 6.75</td>
<td><strong>NO</strong></td>
</tr>
<tr class="odd">
<td>Fastest</td>
<td>59, BART</td>
<td>1:07</td>
<td>25</td>
<td>$ 4.55</td>
<td>$ 9.10</td>
<td>$ 6.75</td>
<td>YES</td>
</tr>
<tr class="even">
<td rowspan="2">7</td>
<td rowspan="2"><p>Hilltop Mall,</p>
<p>Richmond</p></td>
<td rowspan="2"><p>Hayward</p>
<p> </p></td>
<td>Low Cost</td>
<td>72,82</td>
<td>2:39</td>
<td>29</td>
<td>$ 1.75</td>
<td>$ 3.50</td>
<td>$ 6.75</td>
<td><strong>NO</strong></td>
</tr>
<tr class="odd">
<td>Fastest</td>
<td>72, BART</td>
<td>1:35</td>
<td>29</td>
<td>$ 4.25</td>
<td>$ 8.50</td>
<td>$ 6.75</td>
<td>YES</td>
</tr>
<tr class="even">
<td rowspan="2">8</td>
<td rowspan="2">Richmond</td>
<td rowspan="2"><p>Fremont</p>
<p> </p></td>
<td>Low Cost</td>
<td>[5 Transfers]</td>
<td>3:51</td>
<td>34</td>
<td>$ 1.75</td>
<td>$ 3.50</td>
<td>$ 6.75</td>
<td><strong>NO</strong></td>
</tr>
<tr class="odd">
<td>Fastest</td>
<td>BART</td>
<td>1:05</td>
<td>34</td>
<td>$ 3.70</td>
<td>$ 7.40</td>
<td>$ 6.75</td>
<td>YES</td>
</tr>
<tr class="even">
<td>9</td>
<td>Downtown Oakland</td>
<td><p>Warm Springs,</p>
<p> Fremont</p></td>
<td>[no trip by bus only]</td>
<td>BART, 234</td>
<td>1:30</td>
<td>31</td>
<td>$ 4.30</td>
<td>$ 8.60</td>
<td>$ 6.75</td>
<td>YES</td>
</tr>
</tbody>
</table>

**Findings**

1.  EBP provides service to a strict 3/4-mile zone around AC Transit bus
    routes and BART rail stations in the East Bay. The ADEPT software
    that ATC uses to schedule trips has a geographic database that
    checks the requested origin and destination addresses to confirm
    that they are within the EBP service area.

2.  EBP has established a procedure to allow riders to transfer to ADA
    Complementary Paratransit providers in contiguous service areas.
    There are about 20 round trip regional transfers per weekday.

3.  EBP provides service during all days and hours when fixed route
    service operates.

4.  For trips of 8 miles or less, the paratransit fare of \$2.25 is less
    than two times the fare of a comparable fixed route trip by a
    typical user. For trips of 8 to 24 miles, it appears that the
    paratransit fare of \$4.50 can be more than two times the fare of a
    comparable fixed route trip, if the rider chooses to travel by the
    slower, but less expensive routing. For trips of more than 24 miles,
    the paratransit fare of \$6.75 appears to be less than two times the
    fare of a comparable fixed route trip by a typical user.

**Recommendations**

1.  EBP should revise the information that it provides to riders
    concerning service area. It should clarify that service is available
    in the East Bay within 3/4-mile of an AC Transit bus route or BART
    station, rather than the entire East Bay.

2.  EBP should carefully consider the basis for setting ADA
    Complementary Paratransit fares, particularly for trips of 8 to 24
    miles in length, in any review or revision of its fare structure.

# Observations Regarding ADA Complementary Paratransit Eligibility

The purpose of the review team's review of the eligibility process was
to identify any policies, procedures, or practices that prevent
individuals with disabilities from gaining timely access to ADA
Complementary Paratransit service. Review team members:

-   Interviewed consumers, regarding issues about the eligibility
    process

-   Interviewed the EBP certification manager

-   Collected and reviewed materials used in the certification process

-   Reviewed a sample of 61 completed applications and their respective
    eligibility determinations

-   Reviewed recent statistics related to eligibility processing time
    and determinations

**Consumer Comments**

The review team gathered information about the concerns of riders who
use the East Bay Paratransit service through three sources: telephone
interviews with riders or professionals who work with riders; written
complaints to FTA; and written and telephone complaints to ATC.

In the telephone interviews, review team members asked the riders if
they had any problems in obtaining eligibility for ADA Complementary
Paratransit service, or if the determination took more than 21 days.
None had any problems, and all said their determination was made within
21 days.

Neither the complaint filed with FTA nor any complaint recorded by ATC
dealt with eligibility or certification issues.

Eligibility Determination Procedures and Practices

At the time on the on-site compliance review, AC Transit and BART,
through EBP, had about 20,000 individuals certified for ADA
Complementary Paratransit service. To date, during FY2003, an average of
over 300 individuals received new eligibility per month and over 200
individuals received recertification. However, the total number of
eligible riders had decreased since the end of FY2002 (25,007). This is
probably due to previously eligible riders not recertifying.

From January to November 2002, EPB processed 5758 applications (3596
new, 2162 recertifications), for an average of 527 per month. Nearly 99
percent of the applicants (5697) received full or partial eligibility
for ADA Complementary Paratransit service.

ATC staff conducts eligibility determinations on behalf of AC Transit
and BART. ATC has a certification manager and six full-time
certification specialists. All certification staff receive training from
Orthopædic Hospital in Los Angeles, which specializes in evaluating
applicants for ADA Complementary Paratransit service.

**Application Process**. AC Transit and BART participate in the Bay Area
regional ADA Paratransit Eligibility program. There are 21 fixed route
systems that use a common application for ADA Complementary Paratransit
eligibility (Attachment D). These 21 systems also allow individuals
certified by any of the systems to use their ADA Complementary
Paratransit service -- without the need to apply for service after 21
days as a "visitor." The application is available by calling the EBP
broker's office. It is also available from other ADA Complementary
Paratransit service providers in the Bay Area, as well as from human
service agencies and medical facilities.

After filling out the application, the applicant mails it to ATC. An ATC
certification specialist reviews the application for completeness and
clarity. If the certification specialist reviewing the application has
some questions, she calls the applicant to resolve these questions. If
the applicant cannot be contacted by phone within one day, the
certification specialist mails the application back to the applicant,
pointing out the incomplete and/or unclear responses. The certification
manager stated that most applications (perhaps 90%) require follow-up in
this manner. ATC consider the application to be complete after any of
the following:

-   Receiving a complete application (all requested information
    included)

-   Completing a follow-up call with the applicant

-   Receiving requested information mailed back by the applicant

The application includes an "Authorization to Release Medical
Information." The certification manager stated that this authorization
is voluntary on the part of an applicant. The information from the
licensed professional (which may be a "doctor, therapist, social worker,
etc.") is meant to "amplify" the information provided on the
application. Attachment E presents the template for the letter that ATC
uses to request information from a professional. If an applicant
authorizes a professional to provide information on the applicant's
disability, but that professional does not respond to the certification
specialist, she asks the applicant to contact the professional. However,
ATC does not penalize the applicant for the professional's lack of
response and proceeds with the evaluation.

For a small proportion of applications, the certification staff may
complete the evaluation without any additional information. A majority
of applicants receive a "telephone assessment" in which a certification
specialist reviews the written application over the phone with the
applicant. This telephone assessment may be combined with the telephone
call that captures missing information. A small proportion of the
applicants − less than 10% − receive an in-person assessment. For these
individuals, the certification specialist arranges for the applicant to
come to the broker's office for an interview, and possibly a
demonstration of skills. According to the certification manager, the
experience and training of the certification specialists is the key
component in the evaluation process, whether for in-person or telephone
assessments.

There are four categories of eligibility determination:

-   **Full**: no limitation on use of EBP service

-   **Conditional**: applicant can use EBP service under certain
    conditions (e.g., weather, health); for each trip, the rider judges
    whether he/she needs to use EBP service

-   **Temporary**: eligibility for a period of time less than three
    years

-   **Denied**

For the full and conditional eligibility categories, eligibility is
valid for three years. The rider receives an ID card with all the
required information. ATC also provides the rider with the *Riders'
Guide* and a summary flyer, *All About East Bay Paratransit* (Attachment
F).

ATC sends a recertification application for ADA Complementary
Paratransit service to individuals about one month before their
eligibility expires. This application is identical to the one use for
initial certification, with the exception of the cover page (Attachment
G presents a sample cover page). The letter on the cover page includes a
deadline for submitting a completed application. The letter states that,
"If we do not receive this application by the \[deadline\], you may not
be able to schedule ADA paratransit trips until your application is
submitted."

[]{.mark}

EBP has special policies for eligibility for children under five years
old. Children under five can be certified for ADA Complementary
Paratransit service. However an adult personal care attendant must
accompany them. Children five years and older "may travel without an
accompanying adult [only if]{.underline} it can be demonstrated they
would be able, if not prevented by their disability, to use public
transit independently" (*Riders' Guide*, page 25).

**Appeals Process**. Applicants who are denied eligibility receive a
letter from EBP that states the reason for the denial. The letter also
includes a copy of EBP's appeals process. Attachment H includes a
template for a denial letter, plus the appeals process.

To file an appeal, an applicant must complete the "Request for Appeal"
form and send it to EBP within 60 days of receiving the denial letter.
The form includes, "I think I am eligible for ADA paratransit services
because," followed by blank lines. EBP should revise the form to make it
clear that answering this question is optional. All that is required of
the appellant is a signed declaration, within the specified timeframe,
that he/she is exercising his/her right to appeal. []{.mark}

After receiving this completed form, EBP sets the date for a hearing.
The panel that hears the appeal consists of five members:

-   A member of EBP's Service Review Advisory Committee (SRAC) who uses
    ADA Complementary Paratransit

-   A member of EBP's SRAC who may or may not use paratransit

-   A staff member from AC Transit who is not from paratransit

-   A staff member from BART who is not from paratransit

-   A medical professional with knowledge appropriate to applicant's
    disability

The applicant may bring an advocate to the hearing to help present
his/her case. The Appeals Panel has 30 days to make a decision, which is
considered final. If no decision is made within 30 days, the applicant
receives presumptive eligibility until a decision is made.

Applicants who receive conditional or temporary eligibility receive a
letter stating the reason for the limitations. The letter refers to
EBP's appeals process, but does not actually provide a copy of the
process.

In practice, EBP has a small number of eligibility appeals. For FY2002
and the first 5 months of FY2003 (a total of 17 months), EBP had only 19
appeals.

**Suspension Policy**. EBP has established three categories of behavior
that may lead to the suspension of a rider's ADA Complementary
Paratransit service:

-   **Obtaining or using paratransit services under false pretenses -**
    including making false statements on the application or letting
    someone else use the ID

-   **Abusive or disruptive behavior -** including threats to drivers or
    passengers, verbal abuse, and repeated intentional violation of
    riding rules

-   **No-shows -** three or more in a calendar quarter

After a rider's second verifiable no-show in a calendar quarter, EBP
sends a warning letter to the rider. After a third verifiable no-show in
a calendar quarter, EBP sends a letter to the rider stating the intent
to impose a 30-day service suspension. EBP has an appeals process for
any service suspension. A rider may continue to ride until the Appeals
Panel makes a decision. The exception to this is a suspension for
"seriously disruptive or violent behavior," for which the suspension
remains in effect until the Appeals Panel overturns the suspension.

Service suspensions have been infrequent. According to the ATC manager,
there have been about 10 suspensions for behavior over the previous
seven years. The suspension policy for no‑shows was suspended during
2001 during a transition in software. Since the policy was reinstated in
fall 2002, there have not been any suspensions for excessive no-shows.
Nevertheless, this policy's threshold for potential suspension may be an
overly restrictive interpretation of the DOT ADA regulations.

**Observations**

The review team looked a sample of 61 completed applications for ADA
Complementary Paratransit service. The purposes of the reviews were to:

-   Assess the timeliness of EBP's eligibility determination process

-   Assess the reasonableness of these determinations

**Processing Time**. The review team looked at 55 applications submitted
during 2002 for individuals who were determined eligible for service.
The team also looked at six applications from 2002 and early 2003 for
individuals who were determined to be ineligible for service. To analyze
the timeliness of making determinations, the team analyzed five sets of
dates for each application:

-   Date that EBP received an application

-   Date of follow-up call (if separate from telephone assessment)

-   Date that EBP received additional information in mail (either from
    applicant or professional)

-   Date of telephone or in-person assessment

-   Date that EBP mailed the determination letter

As stated earlier in this section, EBP has defined its eligibility
determination process such that the application is considered complete
after a follow-up call or mail-back of missing information. Any
telephone or in-person assessment (if an applicant receives such an
assessment) takes place after the application is complete.

Table V.1 provides a summary of the review team's analysis.

**Table V.1 −** Processing Time for Sample of Eligibility Applications

+-----------+----------+-----------+---------+--------+-------------+
|           | **Number | **P       | **Pro   | **%**  | *           |
|           | of       | rocessing | cessing |        | *Processing |
|           | Applic   | Time: 21  | Time:   | **\>   | Days for    |
|           | ations** | Days or   | \> 21   | 21     | A           |
|           |          | Less**    | Days**  | Days** | pplications |
|           |          |           |         |        | \> 21       |
|           |          |           |         |        | Days**      |
+-----------+----------+-----------+---------+--------+-------------+
| **A       | 55       | 48        | 7       | 12.7%  | 22, 24, 24, |
| pproved** |          |           |         |        | 24, 27, 28, |
|           |          |           |         |        | 43          |
+-----------+----------+-----------+---------+--------+-------------+
| *         | 6        | 2         | 4       | 66.7%  | 24, 59, 68, |
| *Denied** |          |           |         |        | 174         |
+-----------+----------+-----------+---------+--------+-------------+

The DOT ADA regulations do not require an agency to make an eligibility
determination within 21 days. However, 49 CFR 37.125(c) does require an
agency to provide presumptive eligibility to an applicant until the
agency makes an eligibility determination. It is not apparent whether
EBP is providing presumptive eligibility for applicants for whom EBP has
not made a decision within 21 days. In addition, none of the eligibility
information provided to applicants mentions that they may use the
service after 21 days of completing the application until a
determination of eligibility has been made.

**Determinations Outcomes**. Of the 61 applications that the review team
looked at, EBP granted full, conditional, or temporary eligibility to
55; and denied eligibility to 6. All of these determinations appeared
reasonable. One notable practice is how EBP handles the applicants to
whom its grants conditional eligibility. As stated earlier, EBP may
grant conditional eligibility for health, weather, terrain, or other
conditions. Furthermore, the rider determines for each trip whether
those conditions apply. For example, one determination letter for
conditional eligibility states:

> *The condition in this case is one of variations in your health.
> **This means that you may use paratransit whenever you are not feeling
> well enough to use AC Transit or BART*****.**

In practice, this rider may decide that he is "not feeling well enough"
to ever use fixed route and choose to use ADA Complementary Paratransit
service for all trips.

**Findings**

1.  In general, the eligibility determination process used by ATC on
    behalf of AC Transit and BART does not seem to deny service to
    eligible individuals. In fact, ATC's approval rate for full or
    partial eligibility of 99% indicates that its evaluation process may
    be granting eligibility to individuals who are able to use fixed
    route service.

2.  Applicants who are denied eligibility receive a letter from EBP that
    states the reason for the denial. The letter also includes a copy of
    EBP's appeals process and "Request for Appeal" form. Applicants who
    receive conditional or temporary eligibility receive a letter
    stating the reason for the limitations. Their letter refers to EBP's
    appeals process, but does not actually provide a copy of the
    process.

3.  EBP's "Request for Appeal" form includes, "I think I am eligible for
    ADA paratransit services because," followed by blank lines. All that
    is required of the appellant is a signed declaration, within the
    specified timeframe, that he/she is exercising his/her right to
    appeal.

4.  EBP has a suspension policy for riders in which three no-shows in a
    calendar quarter could result in a 30-day suspension. EBP has not
    suspended any riders for excessive no-shows for at least two years.
    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."

5.  Based on both the review team's examination of 61 eligibility
    applications, EBP takes more than 21 days to make some of its
    eligibility determinations. While the DOT ADA regulations do not
    require an agency to make an eligibility determination within 21
    days,\
    49 CFR 37.125(c) does require an agency to provide service to an
    applicant until the agency makes an eligibility determination. It is
    not apparent whether EBP is providing service to applicants for whom
    EBP has not made a decision within 21 days. In addition, none of the
    eligibility information provided to applicants mentions the
    availability of service after 21 days in the absence of an
    eligibility determination.

6.  EBP grants conditional eligibility for health, weather, terrain, or
    other conditions. The rider with conditional eligibility determines
    for each trip whether those conditions apply.

**Recommendations**

1.  EBP should review the process and criteria that it uses in making
    eligibility determinations to ensure that only those persons with
    disabilities who *cannot* independently use the fixed route system
    are found eligible for ADA Complementary Paratransit.

2.  EBP should include a copy of the appeals process and form in the
    letter sent to individuals who receive conditional or temporary
    eligibility.

3.  EBP should revise the "Request for Appeal" form to reflect that the
    only required information is to declare intent to appeal the
    eligibility decision.

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

5.  EBP should inform applicants that they are entitled to use the
    service when EBP takes more than 21 days to make an eligibility
    determination and ensure that service is provided.

6.  AC Transit and BART, through EBP, should consider refining the
    determination process to make more effective use of the conditional
    eligibility category.

# Observations Regarding Telephone Capacity and Trip Reservations

The purpose of the review team's review of the telephone system and trip
reservation process was to determine whether riders who use EBP service
can effectively reach call-takers and schedule their trips. Information
reviewed and observations made on telephone service and capacity and
reservations included:

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

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-   Review of EBP's policies and procedures for taking trip reservations
    for ADA Complementary Paratransit service

-   Call management data provided by ATC

-   Direct observations of call-taking practices at by ATC staff

**Consumer Comments**

Six of the nine consumers interviewed cited long hold times when making
trip requests. Making reservations or other telephone issues was the
third most common type of complaint received by EBP during the second
half of 2002 (11.6% of the total). The complaint filed with FTA did not
deal with telephone access.

**Telephone and Reservations Policies and Procedures**

EBP accepts requests for demand trips up to seven days in advance.
Regular hours for trip reservations are 7 AM to 7 PM, seven days a week.
EBP accepts a limited number of same-day trip requests. At the
discretion of the ATC supervisors, call-takers may allow certain
same-day medical trips and will-call trips. In addition, next-day
reservations are not taken after 5 PM to enable the schedulers to
complete the manifests and send them to the carriers by early evening.

Call-takers are on duty from 4 AM to about 1 AM (or whenever the last
trip of the service day is scheduled). Between 1 AM and 4 AM, riders can
leave trip cancellation requests on voice mail. Reservationists take
care of the voice mail requests for trip cancellations when they report
for work at 4 AM.

The call center at ATC has an Executone PBX telephone system with 52
lines to service 24 workstations for reservationists and customer
service representatives. Each workstation has three telephone lines.
Call-takers are trained in both taking reservations and providing
customer service. They log into their workstations each day with a
priority given by a supervisor for either reservations or customer
service. The priority for each call-taker can be changed quickly if
conditions require more of one or the other of the two services. At the
time of the on-site review, there was a roster of 44 people who served
as reservationists/customer service representatives. A maximum of 27 of
them were on duty during the review team's observations at peak
afternoon periods. Other workstations were available to supplement the
24 dedicated to reservations and customer service when 27 people were on
duty.

All calls are recorded with a voice-activated system that is available
for investigating any complaints involving phone use, and for evaluating
how well each call-taker performs. Call center supervisors have a
monitor that tells them how long calls have been on hold, and how long
each call-taker has been on the current call. The entire system has a
battery-powered backup in the case of electricity failure. The vender
for the phone system provides technical assistance as needed.

There is a standard recorded greeting with a menu for choices that
callers hear when they call the broker. There is an initial message that
is changed every several months on the system if calls are put on hold.
The message at the time of the on-site review thanked voters for their
support of the election issue that funded public transportation, and
reminded riders that they are expected to be ready for pickup any time
during the 20-minute window given to them for their reservation. In
addition, the initial message allows the caller to choose a call-taker
who speaks either Spanish or Chinese.

ATC call-takers have a standard script for taking calls and entering
data into the reservations database. The script covers the following
items:

-   Name of call-taker with the opening greeting

-   Request for caller's last name and first name

-   Request for caller's home address

-   Request for travel day

-   Request for pickup time

-   Request for appointment time

-   Request for return time

-   Request for destination address

-   Confirmation of home telephone number

-   Request for destination telephone number

-   Confirmation of ambulatory or wheelchair passenger

-   Request for information on other travelers (PCA or companions)

-   Fare each way

-   Statement of a 20-minute pickup window for each leg of trip and
    destination address

-   Request for caller's need for additional help

**Telephone Services Standards and Practices**

ATC has a target to two minutes for average hold times. This is
specified in its contract with

AC Transit and BART. Call management data for a 10-month period (May
2002 to

February 2003) indicates ATC achieved an average hold time of 2:15. ATC
also has an internal target of one minute for talk time to book
reservations. Data for a week analyzed by the review team (January 12 to
18, 2003) yielded an average talk time 2 minutes and 22 seconds. ATC's
call management system does not track maximum values for hold times or
talk times.

Call management data shows that the peak reservations demand period is 3
PM to 5 PM on weekdays. In contrast, schedules for call takers indicate
that ATC's peak staffing period is 1 PM to 3 PM. Appropriate adjustments
to call-takers' schedules could better match supply and demand
conditions.

**Observations of Paratransit Reservations Practices**

The review team members observed call taking at various times from
Monday, February 24 to Thursday, February 27. Team members recorded 171
incoming calls, of which 108 were for reservations and 63 were customer
service calls. Twenty-two of the customer service calls were "Where's my
ride?" calls, and 41were mostly trip cancellations,
confirmation/verifications. Call takers followed their scripts and
reminded callers they need to be ready for pickup at the beginning of
the 20-minute window given to them in their reservation. No long hold
times on the phones were noted during these observations.

The team members did observe several instances of trip denials, though
the call-takers did not classify them all as denials. For example:

-   One caller requested a trip with a pickup time of 6:30 PM. The
    call-taker offered a pickup window of 7:35 to 7:55 PM. When the
    caller declined this offer, the call-taker recorded this as a
    cancelled trip request.

-   Another caller requested a trip with a pickup time of 5:15 PM. The
    call-taker offered a pickup window of 7:05 to 7:25 PM. When the
    caller declined this offer, the call-taker placed the 5:15 request
    on "standby."

For another trip request, when the call-taker offered a time within one
hour of the requested time, but the caller turned it down, the
call-taker placed the trip on standby. Here are other observations of
the review team:

-   Riders who called for trips more than two days in advance usually
    got their requested times.

-   Call-takers were inconsistent in authorizing a carrier to no-show a
    rider, primarily in terms of how long the driver had to wait at the
    pickup address. This varied from 5 to 15 minutes.

-   Call-takers could authorize a "no-show: no fault," generally for
    riders who are not ready for a trip after a medical appointment,
    even if they did not call.

-   Call-takers did not have all five carriers' telephone numbers
    programmed into their system and had to dial to contact certain
    carriers.

-   One call-taker stated that she had the authority to call a taxi to
    handle a missed trip (no pickup within the window) for a passenger
    who uses a wheelchair.

-   One call-taker, in response to a question about the eligibility
    process, said that the certification process takes "21 business
    days".

**Findings**

[]{.mark}

1.  Telephone access and the reservation process do not appear to be an
    impediment to customers in scheduling trips. Although customer
    interviews by the review team and complaints recorded by EBP both
    indicated consumer concern with telephone hold times, review team
    members did not observe any long hold times or long telephone
    queues.

2.  ATC has a goal in its contract with EBP of two minutes for its
    average hold time for telephone calls. Sample data from ATC's call
    management system yielded an average hold time of 2:15.

3.  ATC has an internal goal of one minute for average call times.
    Sample data from ATC's call management system yielded an average
    call time of 2:22.

4.  ATC's peak staffing for call-takers is from 1 PM to 3 PM. However,
    call management data indicates that the peak time for calls is from
    3 PM to 5 PM.

5.  When call-takers could not offer a trip within one hour of the
    requested time, sometimes they recorded these as trip cancellations
    or placed them on standby -- rather than recording them as trip
    denials. This practice results in understating the number of trip
    denials.

6.  Call-takers were consistent in giving callers a 20-minute window for
    the pickup time, rather than a specific time. This practice provides
    customers with a clear understanding of when to be ready for the
    vehicle to arrive.

7.  Call-takers were not consistent in authorizing drivers to no-show
    riders, primarily in terms of how long the driver had to wait at the
    pickup address. This varied from 5 to 15 minutes. This practice can
    delay drivers and contribute to them to be late in performing their
    schedule.

**Recommendations**

1.  ATC's goal of one minute for average call times may be optimistic,
    given the amount of information to be provided by the caller and
    call-taker. ATC may wish to consider increasing the goal for average
    call time.

2.  ATC should review its staffing schedule for call-takers and adjust
    it to match the call volumes.

3.  ATC should train its call-takers to properly record trip denials.
    Call-takers may continue to place denied trip requests on standby
    and try to schedule them after the call or accept such trip requests
    to be scheduled in real time by dispatchers for the service
    providers in conjunction with provision of flexible operating
    capacity.

4.  ATC should establish consistent procedures for authorizing rider
    no-shows and train its\
    call-takers and other staff in the application of these procedures.

# Observations Regarding Scheduling of Trip Requests

The review team reviewed scheduling of EBP Paratransit trip requests.
Information reviewed and observations on scheduling included:

[]{.mark}

-   Consumer interviews, review of the complaint filed with FTA, and
    review of complaints filed with EBP

-   Review of EBP policies and procedures

-   Review of scheduling software, particularly parameters selected by
    ATC

-   Interviews with ATC managers, scheduling supervisors, and
    call-takers, and carrier managers, dispatchers, and drivers

**Consumer Comments**

The complaint on file with FTA cited late pickups and drop-offs.

Six of the nine consumers/consumer representatives interviewed by the
review team cited late drop-offs. All of them also noted that they had
to negotiate their pickup times. Late drop‑offs and the need to
negotiate pickup times could be a result of scheduling procedures.

Among complaints received by EBP from July to December 2002,
"scheduling" comprised 2.6% of the total. "On-time performance" was the
number one complaint category, comprising 58% of all complaints.

**Policies and Procedures**

At the time of the on-site review, EBP was receiving over 2500 trip
requests per weekday. By the day before service, the number of rides to
be scheduled would decrease due to early cancellations. In February
2003, the average number of scheduled ADA Complementary Paratransit
service trips was 2200 on Monday and Friday, and 2350 on the other
weekdays. There were 1100 to 1200 subscription trips each weekday.

ATC uses ADEPT software for its client database, trip requests,
scheduling, reconciling, reporting, and other recordkeeping. ADEPT is
installed at all of the call-takers' workstations, and trip requests are
entered directly into it. Consequently, the call-takers are the primary
schedulers of EBP's demand responsive trips. Based on the trip request
numbers cited in the previous paragraph, the call-takers receive 1300 to
1400 demand responsive trip requests for an average weekday.

When a call-taker receives a trip request, he/she enters the requested
pickup or drop-off time. ADEPT responds with a single vehicle run that
has capacity within the --60 minute/+60 minute negotiating window to
accommodate the trip request, or if no vehicle run is available within
the window, a single vehicle run that comes closest to the window. The
call-taker presents this trip (in terms of the estimated 20-minute
pickup window) to the caller. If the caller does not like the option
presented by the call-taker, then the call-taker can click on the
"Retry" button to get a second choice. However, the first vehicle run
presented to the call-taker by ADEPT is usually the one that best
matches the caller's requested time.

When scheduling a trip request, a rider can specify a preference for
"sedan only" or "lift only." A rider can also ask for a preferred
carrier. The scheduling supervisor said that this request is more often
stated as a negative (i.e., "not" a particular carrier). A rider can
state these preferences when making a trip request, or can ask that
these preferences be included in his/her data file. The call-takers and
schedulers try to accommodate these preferences; however, they are not
obligated to fulfill these rider preferences.

Call-takers and schedulers estimated that about half of the demand
responsive trips for a typical weekday are requested on the day before
service. The exception to this pattern is for Monday service, since the
day before is Sunday. A review by the review team of the distribution of
trip requests for a sample service day confirmed this. Table VIII.1
presents the distribution for a sample day, January 15, 2003.

**Table VIII.1 − Percent of Demand Responsive Trip Requests for January
15, 2003**

  ---------------------- ----------------------- -------------------------
  **Days Ahead**         **Day**                 **Percent of Demand
                                                 Responsive Trip
                                                 Requests**

  0 (Same Day)           Wednesday               2.4%

  1                      Tuesday                 48.9%

  2                      Monday                  18.5%

  3                      Sunday                  6.5%

  4                      Saturday                3.4%

  5                      Friday                  11.0%

  6                      Thursday                4.3%

  7                      Wednesday               4.9%
  ---------------------- ----------------------- -------------------------

Call-takers are not able to schedule all requests for demand trips
within the negotiation window. Such trip requests fit into one of the
following categories:

-   Trip requests withdrawn by caller - as stated in Section VI,
    call-takers sometime classify them as "cancelled" or "refused."

-   Trip requests altered by the caller - accepting a time outside the
    negotiation window of the originally requested time.

-   Trip requests not fulfilled and not altered - call-taker places them
    on "standby."

The scheduling supervisor said that for a typical weekday, there are 125
to 135 trip requests placed on standby. Scheduling of these standby
trips is one of the main activities of the ATC scheduling staff.

While 1100 to 1200 of the weekday trip requests are subscription trips,
ATC had placed less than half of them on regular vehicle runs. At the
time of the on-site review, 47.9% of weekday subscription trips were
"anchored," i.e., pre-scheduled on regular vehicle runs before demand
responsive trips were added to the schedule. The other subscription
trips were placed on that day's "wait list." The scheduling supervisor
said that the reason for not pre-scheduling all of the subscription
trips was to provide more flexibility in scheduling the demand trips.
These wait list trips were generally inserted into the schedule on the
day before service by the ATC schedulers.

Because of limited capacity, EBP was not accepting requests for new
subscription service on weekdays between 8:30 and 10 AM and between 2:30
and 4 PM. The exceptions to this were trips going to social service
centers if the trip could fit on a vehicle run already going to/from the
center, and trips for riders with developmental disabilities who had
difficulty in making calls to request demand trips.

The schedulers work to assign trip requests manually to vehicle runs
from the standby list and wait list. The primary goal is to assign all
trip requests from the standby and wait lists. ATC then transmits the
vehicle manifests to the respective carriers between 5:30 and 7:30 PM of
the evening before service. A scheduler stays in the office at least
until 8 PM. This allows the carriers time to call to request changes to
the schedules as the carriers do not have the capability to manipulate
their own schedules in ADEPT.

ATC does not have explicit allocations of trips among the carriers. For
each day's service, the software has the available vehicle service hours
for each of the five carriers, which sets potential maximum allocations.
The carriers do not have a minimum number of guaranteed trips or service
hours. The only allocation by geography is that one carrier (A
Paratransit) has a higher proportion of its trips in the southern
portion of the service area because it is located further south than the
other four carriers. The scheduling supervisor said that carriers
request certain anchored trips assigned to their runs because they tend
to influence ADEPT to assign the demand and wait list trips in a more
geographically compact manner.

Because carriers are paid by the vehicle revenue service hour, ATC has
an incentive to maximize vehicle productivity. In practice, the main
technique that the ATC schedulers use is to try to move trips from the
beginning or end of vehicle run to other runs, thereby reducing the
revenue hours. The scheduling supervisor said that the target
productivity is 2.0 passengers per revenue service hour (including PCAs
and companions, but before no-shows and cancellations after scheduling).
During FY02 and FY03, systemwide productivity by month has ranged from
1.5 to 1.7, with a slight upward trend from FY02 to FY03.

**Observations**

From July to November 2002, EBP recorded a total of 510 trip denials.
The monthly totals were increasing from 63 in June to 148 in November.
This represented 0.22%, or about 1 out of every 450 trip requests. In
addition, as noted in Section VI of this report, the review team
observed that some trip denials are not being recorded by ATC.

In general, ATC appeared to be making good use of the ADEPT software.
The review team observed some areas in which ATC could improve its
scheduling process. A significant issue is that the review team saw
trips with pickup times generated by ADEPT that were outside of the
20-minute pickup window. This issue is compounded by the information
displayed on the vehicle manifests. For pickup entries, the only time
displayed on the manifest is the estimated pickup time generated by
ADEPT. The manifest does not display the beginning or end points of the
pickup window. For example, a manifest may show a pickup time of 7:19
AM. The pickup window could be 7 to 7:20 AM, or it could be 7:15 to 7:35
AM. Without the negotiated pickup time or the window, a driver cannot
determine if she/he is on time.

Some of the ATC schedulers have the responsibility of assigning the wait
list trips to manifests. ATC could strive to anchor more of these
subscription trips to vehicle runs, thereby reducing the need to perform
this task on a daily basis. Since they are already in the system as
subscription trips with fixed negotiated pickup and appointment times,
they do not have much flexibility in terms of scheduling. Placing them
on regular runs would likely improve service by giving drivers more
regular trips and giving more riders regular carriers and drivers.

Currently, ATC does not leave any trips on an "open" run. All trip
requests are either assigned to runs or denied. Fitting the 125 to 135
daily standby trips in the manifests is a very labor-intensive process,
with each additional trip more difficult to assign. ATC could reduce
this effort considerably by changing its practice to leaving a small
number of trips unassigned until the day of service. As cancellations
and no-shows appear on manifests, these unassigned trips can be put in
their place. ATC can start conservatively, with a small portion left
unassigned. If this process is successful, it can increase the number of
unassigned trips. This set of unassigned trips can also incorporate some
of the denied trips − which have typically been in the single digits on
a given day)

The review team reviewed some of the parameters used in the ADEPT
scheduling module. Among these parameters are the estimated vehicle road
speeds. ADEPT allows the assignment different speeds by geographic zones
(including bridges) and by time of day. ATC used vehicle road speeds
that ranged by zone and time of day from 12 to 21 miles per hour. Given
comments by the carrier dispatchers and drivers concerning the
schedules, some of these speeds may be too high.

**Findings**

1.  The review team observed scheduled pickup times on vehicle manifests
    that were outside of the 20-minute pickup window.

2.  The vehicle manifests do not display the pickup window times or the
    negotiated pickup time. This can cause a driver to be unaware that
    he/she is late and cause miscommunication with customers.

3.  Subscription trips comprise nearly half of EBP's weekday trips
    requested. However, less than half of the subscription trips are
    pre-assigned to vehicle runs. The remaining subscription trips are
    placed on a "wait list" and are scheduled every day. Assigning all
    of the subscription trips to runs can reduce the effort required to
    assign demand trips. In addition more consistent runs can be refined
    as needed through driver feed back and facilitate operations thereby
    increasing operating efficiency.

4.  Much of the effort of ATC schedulers is devoted to assigning
    "standby" trips to vehicle runs, even though they comprise only five
    to six percent of EBP's total trips.

5.  Various parameters used in the scheduling software, including
    average vehicle speeds, may not be properly set. This may lead to
    unrealistic vehicle runs.

**Recommendations**

1.  ATC should have the scheduling software parameters adjusted so that
    scheduled pickup times are always within the pickup window given to
    the customer.

2.  ATC should amend the vehicle manifests to display the negotiated
    pickup time. ATC also should consider including the pickup window on
    the vehicle manifests.

3.  ATC should increase the proportion of subscription trips that are
    pre-assigned to vehicle runs. This will likely lead to better and
    more reliable service for these riders, as well as reduce scheduler
    effort.

4.  ATC should consider leaving some of the standby trips unscheduled
    until the day of service. They can still guarantee the trip and
    insert them into schedules as cancellations and no-shows occur. This
    technique also may reduce the number of EBP's trip denials.

5.  ATC should review the parameters used in ADEPT, and adjust them as
    necessary to make the vehicle schedules more realistic.

# Observations Regarding Operations

The review team reviewed the transportation operations of four of the
five service providers to determine whether requested trips are being
served in a timely fashion and are not excessively long, and if any
operational procedures or practices appear to cause or contribute to
service limits. Information reviewed and observations on operations and
service delivery included:

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

-   Review of EBP service policies and procedures

```{=html}
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```
-   Site visits to AC Transit, Friendly Transportation, MV
    Transportation, and First Transit

-   Interviews with service managers

```{=html}
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```
-   Observations of dispatch operations

-   Interviews with 18 drivers

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

-   Analysis of EBP service trip durations

#  {#section .unnumbered}

# Consumer Comments {#consumer-comments .unnumbered}

#  {#section-1 .unnumbered}

The review team looked at consumer comments regarding operations to help
to identify potential operational problems. Three sources of consumer
input were reviewed: complaints on file with the FTA, consumer
interviews conducted by the review team, and complaints on file with
EBP.

The complaint filed with FTA's Office of Civil Rights raised the
following issues related to operations:

-   Late pickups and drop-offs

-   Stranded passengers

-   Overcrowded vehicles

-   Poor coordination with adjoining ADA Complementary Paratransit
    service operators

-   Faulty equipment, unsafe lifts

-   Verbally abusive drivers

-   Tie-downs left on vehicle floor

Nine riders or rider representatives who were interviewed raised the
following operational issues:

-   Riders commented that the biggest problem is late pickups.

-   Five of the nine interviewed said that they sometimes or often were
    late for appointments.

-   Five said that some of their trips were "excessively" long (more
    than 60 or 90 minutes).

Of the 1451 complaints that EBP received through ATC for the six months,
July to December 2002, the two major categories of complaints were
on-time performance and driver behavior. Of EBP complaints, 58% cited
late pickups.

A common operational issue raised by all three groups was on-time
performance.

# Policies and Procedures {#policies-and-procedures .unnumbered}

**On-Time Service**. EBP considers a trip on time if the vehicle arrives
within the 20-minute pickup window negotiated with the customer (0/+20).
The Riders Guide also advises customers of this 20-minute pickup window.
EBP managers indicated that they are considering increasing the on-time
window to 30 minutes (0/+30). EBP's goal is to have 93% of completed
trips performed on time each month.

"ATC's Driver Standards and Duties," an attachment to ATC's contracts
with its service providers, indicates that passengers are to be picked
up at the time printed on the manifest. Times printed on the manifest
are scheduled pickup and drop-off times and customer appointment times.
Pickup windows negotiated with the customers do not appear on drivers'
manifests. The ATC subcontracts with service providers set 30 minutes
after the beginning of the pickup window as the trigger for contract
disincentives. EBP has contract incentives and disincentives to
encourage on-time performance. There are financial incentives for better
than 93% on-time performance, and disincentives for on-time performance
lower than 89%. The disincentive is a penalty of \$35 per occurrence
charged to the contractor. Disincentives are based upon two consecutive
months of poor performance. At the time of the review, EBP was not
invoking the contract disincentives due to unreliability of reported
performance. The performance measurement was considered unreliable due
to transition to new ADEPT scheduling software in August 2001.

Use of (0/+20) minute pickup window with customers and a (0/+30) window
with service providers could contribute to late pickups from 21 to 30
minutes after beginning of the pickup window. Additionally, not
displaying the starting and ending times of the pickup windows on
manifests could result in miscommunication with customers, efforts by
drivers to get customers to depart early, and contribute to late
pickups.

EBP has no stated policy for on-time service for drop-off times for
customer appointments.

EBP monitors on-time pickups by taking a 100% sample of trips from 4
weekdays and 1 weekend day each month. EBP counts pickups in four
categories as they relate to the time given to the customer:

-   On time,

-   1 to 20 minutes late

-   21 to 59 minutes late

-   60+ minutes late

**No Shows and Late Cancellations.** The *Riders' Guide* defines a
no-show as: failure to meet a reserved ride; customer not ready within
five minutes of vehicle arrival after the beginning of the pickup
window; or cancellation of the trip by the customer less than two hours
before the beginning of the pickup window. For purpose of performance
monitoring, EBP considers all cases where the customer did not take a
scheduled ride a no-show. This definition includes missed trips as
discussed above. EBP further breaks no shows down into five subsets:

-   **NS-C** -- Customer failed to appear at the pickup location to meet
    the vehicle during the pickup window.

-   **NS-NF** -- Responsibility for the no show could not be determined.

-   Three sub-categories of no-shows for which the service provider is
    responsible.

EBP's *Riders' Guide* indicates that when a driver arrives, he/she will
attempt to locate the customer. If the driver is unable to locate the
customer after five minutes, the driver will categorize the customer as
a no-show and leave. ATC's "Driver Standards and Duties," requires
drivers to try to contact customers and to allow customers five minutes
to board the vehicle.

During the review, ATC management was drafting a revised procedure for
declaring riders as "no-shows." Elements of the proposed procedure are:

-   The driver will attempt to locate the customer after arrival at the
    site and after the pickup time expected by the customer.

-   Dispatch will attempt to contact the rider by telephone.

-   The driver must allow customer at least five minutes after the
    beginning of the pickup window before a no show is declared.

-   If unable to reach the customer, or if the customer declines the
    trip, the customer will be declared a no-show.

This proposed procedure appears to provide the customer adequate
opportunity to respond to the arrival of the vehicle within the pickup
window, minimize potential miscommunication of pickup location, and
minimize delay to the driver in serving other customers.

**Missed Trips.** EBP defines missed trips as trips not completed due to
the fault of the service provider. If the vehicle arrives after the
pickup window and the customer no longer wants the trip, EBP classifies
this as a late trip. EBP's goal is zero missed trips. The contract
between the consortium and the broker defines a missed trip as when the
vehicle arrives more than

60 minutes after the scheduled pickup time. The contract invokes a
payment incentive for less than 0.2% missed and very late trips, and an
escalating penalty for more than 0.5% and 0.75% missed and very late
trips.

There are no policies or procedures in the service providers' operator's
manuals for missed trips, customer no-shows, on time performance or long
trip duration.

**Trip Duration.** The *Riders' Guide* advises customers that the EBP
trip "will take the same amount of time as an AC Transit bus would
take." EBP has no more specific standards for trip duration. ATC
monitors long trips through review of customer complaints.

# Observations of Operations {#observations-of-operations .unnumbered}

Review team members observed operations at four of the five service
providers: AC Transit, Friendly Transportation, MV Transportation and
First Transit. The team did not visit A Paratransit, the smallest
service provider. Observations of operating procedures and practices of
the service providers are summarized below.

MV Transportation. Members of the review team visited MV Transportation
on

February 25. MV receives schedules for the service day at 8:00 PM on the
day before service. The scheduler reviews the schedules to identify
first pickups for each run. He then calls drivers to advise them of
their schedule for reporting in the morning. The driver then reviews the
schedule to identify trips that cannot easily be performed on time. He
reassigns the trip to another MV run or route if possible. When
reassigning trips, the scheduler does not change the scheduled pickup
times listed on the manifests. If it is not possible to reassign a trip,
the scheduler will request ATC to take the trip request back for
reassignment. According to MV management, ATC takes approximately 30% of
the trips that MV refers back to ATC. The morning dispatcher also
reviews the schedules at about 3:00 AM. He may reassign some difficult
trips.

The scheduler indicated that the schedules are fair to good. He cited
some problem routes and some errors in geocoding.

When drivers report to work they get their manifests, keys to their
assigned vehicle, and cell phone. They do a pre-trip inspection of their
vehicle and check their manifest. In addition to general schedule
problems, drivers check their manifests to assure having sufficient
available wheelchair positions on the vehicle to accommodate more than
one person who uses a wheelchair at one time. A gate checker also checks
the vehicle, the driver, and his pre-trip inspection report.

Drivers are discouraged from operating their runs out of the sequence
described on the manifests. If they arrive before the scheduled pickup
time, they are to contact the dispatcher. The dispatcher will instruct
them to wait until the scheduled pickup time. At that time, the driver
is to knock on the door or ring the bell to let the customer know
his/her ride is there. If the customer does not respond the driver,
he/she calls the MV dispatcher who calls the ATC dispatcher who, in
turn, calls the customer. If unable to reach the customer, or the
customer is not taking the trip, the dispatcher designates the customer
a no-show and directs the driver to continue with his/her route.

If a driver is running late he/she is told to call the dispatcher. The
dispatcher reassigns trips as needed to help the driver to recover
his/her schedule. If the driver encounters a vehicle problem while on
the road, the dispatcher reassigns trips if one or two trips are
affected. If there are many passengers on the vehicle, a second vehicle
is dispatched with a standby driver.

A review team member observed MV dispatch. Dispatchers track trips on a
computer monitor. Runs that are running late appear in red. The
dispatcher tries to reassign trips from these runs if it will improve
service. The dispatcher also enters all trips as performed. If the trip
is performed on time, the dispatcher enters the time of the call from
the driver if on-time or early. The dispatcher enters the exact time if
the trip is late. The dispatcher enters both pickup and drop-off times.

While at MV, review team members also observed the following:

-   One pickup time (3:13 PM) on the driver manifest that was outside of
    the customer's pickup window (2:50 to 3:10 PM)

-   A trip for which the customer thought he had a 5:00 PM pickup
    (beginning of window) but was listed on the manifest for 4:30

-   A driver's schedule that had him scheduled to pick up a customer at
    a building that was closed. The driver described this as a repeat
    problem.

These incidents may indicate a problem in confirming information with
the customer when scheduling trips. They may also indicate schedule
changes subsequent to negotiation of an agreed upon window with the
customer, resulting in scheduled pickup times falling outside of the
window that the customer expects the driver to arrive.

[]{.mark}

**AC Transit.** The review team visited the paratransit operations of AC
Transit on

February 26. AC Transit has a paratransit division that provides a
portion of EBP's ADA Complementary Paratransit. AC Transit has
approximately 35 weekday runs, plus 18 on Saturday and 15 on Sunday.

The AC Transit dispatcher receives next day schedules between 6:30 and
9:00 PM. The night dispatcher prints the schedule without review and
telephones drivers to advise them of their starting times. The morning
dispatcher reassigns runs to accommodate absent drivers.

The driver manifests do not include the beginning and end times of
pickup windows. AC Transit management felt that drivers don't understand
the window, but that dispatchers use the window to complete pickups at
the times expected by customers.

AC Transit relies on drivers to review their runs for reasonableness and
to advise the dispatcher of any problems. AC Transit management
encourages drivers to adjust their runs to stay on time. If they are
running late, drivers are told to follow the sequence on their schedule
manifest. One dispatcher noted that schedules have improved.

Three dispatchers are on duty at one time. One addresses same-day trips
and trip reassignment and the other two monitor pickup and drop-off
times. Dispatchers communicate with drivers with radios. Dispatchers
indicated that the quality of the radios was poor. Drivers are supposed
to call in each pickup and drop-off.

AC Transit has no unassigned drivers to assist when problems arise.

**First Transit.** Review team members visited First Transit on February
25. One team member observed dispatch operations from 8:30 until 10:30
AM.

Schedules for the next day are delivered to First Transit between 6:00
and 8:00 PM. The night dispatcher reviews the schedules for driver start
times and tight runs. The dispatcher has the capacity to reassign trips
and merge runs. Changes are automatically sent to ATC via a T-1 line. If
the dispatcher sees problems in the schedule, he tries to be prepared to
address them by calling in additional drivers if needed. When the
schedule review is complete, the night dispatcher prints the next day
schedules. The dispatcher completes his review between 9:00 and 11:00
PM. Dispatchers described schedules as tight with some illogical
routing.

The morning dispatcher tries to assign the same vehicle to drivers at
pull out. He issues the drivers their keys and radio. Drivers map out
their schedule. Dispatchers assist new drivers in mapping their routes.
If drivers identify problems, they advise the dispatcher. First Transit
has one floater van to assist other drivers as needed.

There are three dispatchers working at one time. One dispatches the van
runs, a second dispatches the sedan runs, and the third monitors vehicle
location on GPS and assists the two other dispatchers. All three
dispatchers have access to GPS on their monitors.

Drivers call in each pickup, and dispatchers enter the time into the
scheduling system as the "manifest time." There is only one channel on
the radio system, making it difficult for drivers to call in pickup
times.

Dispatchers call customers to confirm no-shows if they have the
customer's phone number. As time permits, they also call customers to
advise them if their trip is late.

Dispatchers reassign trips as needed during the service day. On
occasion, they seek assistance from ATC in addressing service problems.

Friendly Transportation. Review team members visited Friendly
Transportation on February 25. Team members interviewed managers and
observed dispatch operations.

Friendly downloads two copies of manifests from ATC between 7:00 and
9:00 PM on the evening before the service day. One copy is for the
dispatcher; the other copy is for the driver. Typically Friendly is
assigned 46 to 47 runs per day with as many as 42 operating during the
peak period. On February 25, they were assigned 45 runs with 35
operating during the peak. Drivers are assigned to the same runs each
day with estimated start and end times. Driver start times are confirmed
by telephone on the evening before the service day. The night dispatcher
reviews the runs until 1:00 AM. If runs are tight, he will move trips
from one run to another but will not change times scheduled on the
manifests. Managers described schedules as tight with little dead time.
The dispatcher observed that anchored runs help service performance and
that there seemed to be a decline in the number of anchored runs.

Driver's review their runs at pull out and advise the dispatcher if they
see a problem. If the dispatcher agrees with the driver he/she will
reassign the trip.

The same vehicle is assigned to the driver each day. The driver performs
a pre-trip inspection before beginning his schedule. Vehicles are fueled
the night before the service day.

Friendly's procedure is for drivers to knock on the customer's door upon
arrival, assist the passenger in boarding the vehicle, and record the
customer fare and arrival time on the manifest. If delayed in departing
the driver is also to record the departure time.

If customers are determined to be no-shows on a going trip, the return
trip is cancelled with the customer's concurrence.

Drivers only contact dispatchers when they have a no-show or when
running late. The dispatcher's priority is locating customers that
drivers are unable to find. Driver's also try to spot check driver's
status once an hour and performs trips in the system based upon these
driver contacts. Dispatchers track late trips on their monitor. When
trips have not been performed after the pickup window, they appear as
red on the monitor.

**Driver Interviews.** During the visits to the service providers,
review team members interviewed 18 drivers. The purpose of the
interviews was to get an indication of the adequacy of resources
available to drivers to do their jobs and drivers' understanding of
operational procedures. Most drivers indicated that driver training was
good. Drivers indicated that they received a day or more of initial
sensitivity training, with refresher training at least annually.
Similarly, they generally described vehicle condition and maintenance as
good.

Drivers generally described schedules as poor, and almost all indicated
that they had discretion to modify their schedules.

Only 4 of the 18 drivers interviewed correctly identified the pickup
window as the period from the scheduled pickup time to 20 minutes after
the scheduled time (0/+20). Three drivers indicated that there is no
pickup window. Similarly, drivers did not think customers understood the
pickup window or thought the window was only for customers and not
drivers.

Drivers generally were aware that they were to wait until the schedule
time if they arrive early for a pickup.

All drivers knew that they were to contact the dispatcher if a customer
is a no-show. Some drivers indicated that they wait 15 minutes or more
before declaring a customer as a no-show. Drivers complained that once
they call dispatch, it can take up to 10 minutes to get a customer
declared a no-show. Some drivers had confusion on placing the no-show
hanger notice on the customer's door. Some drivers indicated that they
placed the hanger before the customer was declared a no-show.

**Trip Disposition**

The review team reviewed ATC's computerized records for all trips made
for one sample day, Wednesday, January 15, 2003. This day was chosen as
a typical weekday from a period recently preceding the site review. The
results of this review are summarized in Table VIII.1.

Table VIII.1 -- Trip Disposition for Wednesday, January 15, 2003

  ---------------------------------- ----------- ------------- ------------
  **Trip Status**                    **Number of **% of        **% of
                                     Trips**     Requested     Scheduled
                                                 Trips**       Trips**

  Requested                          2,757       100.0%        

  Requested, but not in Service Area 1           0.0%          

  Early Cancellations                447         16.2%         

  Refused by Customer                4           0.1%          

  Denied                             1           0.0%          

  Trips Scheduled                    2,304       83.6%         100.0%

  Customer No-shows & Late           174                       7.6%
  Cancellations                                                

  Missed Trips                       33                        1.4%

  Trips Served                       2,097                     91.0%
  ---------------------------------- ----------- ------------- ------------

*Requested trips* are all trip requests made to the broker at the
broker's call center. Requested trips include "Go-Backs." Go-Backs are
requests for same-day trips by customers who are unable to make their
initially requested return trip, e.g., dialysis patients whose condition
after completing treatment might prevent them from taking their
initially scheduled trip. Same-day requests are also accommodated for
special requests, such as illness, if space is available.

It is EBP's policy to avoid a pattern or practice of *denials* and to
not have a substantial number of trip denials. EBP defines denials as
occurring when no trip could be offered to the customer one hour before
or after the requested time.

When customers request appointments, the appointment time is entered
into the computer and the scheduling software generates an expected
pickup time.

If a customer calls to request a change in a trip, the trip is entered
into the system as a *cancellation* and a new trip is created in
response to the revised request.

As can be seen in the table, only one trip denial was recorded for this
sample day. The one denial was identified as a customer refusal of a
trip offer more than one hour from the requested pickup time.

The review team further reviewed trip offers that were more than one
hour from the time requested by the customer. The DOT ADA regulations
allow transit operators to "negotiate pickup times with the individual,
but the entity shall not require an ADA paratransit eligible individual
to schedule a trip more than one hour before or after the individual's
desired departure time." (49 CFR 37.131(b)(2)). For the purpose of this
review, when no trip offer is made within one hour of the customer's
requested time, it has been counted as a trip denial.

Of the 2,757 trip requests on January 15, 12 (0.4%) were offered times
more than one hour from that requested. One of these requests was
entered into ADEPT as a denial. Another of these requests was for
same-day service. The remaining ten trips were categorized as shown in

Table VIII.2.

#### Table VIII.2 − Coding of Trip Offers More than 1 Hour from Request {#table-viii.2-coding-of-trip-offers-more-than-1-hour-from-request .unnumbered}

  ---------- ----------------------------------------------- -------------
  **Code**   **Description**                                 **Number of
                                                             Requests**

  CX         Advance Cancel                                  2

  FA1        Client refused a scheduled ride (an offer made  3
             within 1 hour of request)                       

  NSB        Client did not have a trip which appeared on    1
             the provider\'s manifest                        

  S          Served                                          4
  ---------- ----------------------------------------------- -------------

When EBP is unable to offer a trip within one hour of the requested
time, EBP should record that trip request as a denial. If the customer
then accepts a trip more than one hour from the initially requested
time, EBP should treat it as a separate trip request. This will provide
EBP with a more accurate record of denials and assist in planning and
managing service delivery to eliminate denials.

The review team reviewed the 10 trip requests discussed above plus the
one reported denial to determine if there was any pattern of denials as
relates to how far in advance of the travel day the trip request was
made. The results of this review appear in Table VIII.3.

**Table VIII.3 Timing of Denied Trip Requests**

  --------------------------------- -------------------------------------
  **Days in Advance of the Service  **Denied Trip Requests**
  Day**                             

  1                                 5

  2                                 5

  3                                 1
  --------------------------------- -------------------------------------

ATC also reported 33 (1.4%) missed trips for the sample day. This
includes 29 requested trips that are in ATC's records but do not appear
on any of the provider's manifests. These 29 trips appear to indicate
that ATC schedulers are not scheduling all trip requests that are on the
standby list.

There were 174 reported late cancellations and no-shows for the sample
day, which equal 7.6% of scheduled trips. As suggested in Section VIII
of this report, these cancellations could provide ATC with the
opportunity for scheduling some trips in on the day of service, thereby
eliminating trip denials and, through rescheduling trips from routes
that are running late, reduce the number of missed trips and improve
on-time performance.

## Analysis of On-Time Performance

EBP managers reported on time performance for AC Transit fixed route
service at 69%.

EBP considers a trip as on time if the vehicle arrives during the
20-minute window negotiated with the customer (0/+20). EBP defines very
late trips as trips with pickup times more than one hour after the
beginning of the pickup window.

The *Riders' Guide* states (page 22) that riders do not have to board
the vehicle if the driver arrives before the beginning of the pickup
window negotiated with the customer.

Based on EBP's 100% sample of 4 weekdays and 1 weekend day each month,
on-time performance is presented in Table VIII.4.

####  Table VIII.4 - On Time Performance as Reported by EBP {#table-viii.4---on-time-performance-as-reported-by-ebp .unnumbered}

  ------------------------------------- ---------------------------------
  **Period**                            **Early and On-Time Pickups**

  January 1 -- December 31, 2001        87.9%

  January 1 -- June 30, 2002            89.4%

  July 1 -- November 30, 2002           89.4%
  ------------------------------------- ---------------------------------

EBP also produces a *Systemwide East Bay Paratransit Monthly Performance
Indicator Report*, which includes missed trips, on-time trips and late
trips by amount late as a percentage of total trips scheduled.
Performance information from this report for the last six months of 2002
appears in Table VIII.5.

### Table VIII.5 -- EBP Reported Service Performance, 2002 {#table-viii.5-ebp-reported-service-performance-2002 .unnumbered}

  ------------ ------------- ---------- ------------ --------------- ------------- -------------- --------------
                             **July**   **August**   **September**   **October**   **November**   **December**

  **Missed                   0.1%       0.1%         0.1%            0.2%          0.2%           0.3%
  Trips**                                                                                         

  **Early or                 90.4%      92.2%        87.8%           88.5%         87.9%          88.3%
  On-Time **                                                                                      

  **Late **                                                                                        

  ** **        **Total**     9.6%       7.8%         12.2%           11.5%         12.1%          11.7%

  ** **        **0 - 20      7.8%       6.2%         9.8%            9.1%          9.4%           9.1%
               Minutes**                                                                          

  ** **        **21 - 59     1.6%       1.5%         2.3%            2.2%          2.4%           2.4%
               Minutes**                                                                          

  ** **        **60+         0.2%       0.1%         0.2%            0.2%          0.2%           0.2%
               Minutes**                                                                          
  ------------ ------------- ---------- ------------ --------------- ------------- -------------- --------------

The review team randomly selected 30 routes and analyzed on-time
performance based upon ATC's computerized records for all trips made for
the sample day, Wednesday, January 15, 2003, along with pickup and
drop-off times recorded by hand on driver manifests. The review team
sampled a total of 299 pickups and 79 drop-offs. This corresponds to
14.3% of 2,097 completed pickups and 13.6% of 582 completed drop-offs,
respectively. The review team review of EBP on-time pickups for the
sample day of January 15 is summarized in

Table VIII.6.

#### Table VIII.6 -- Sampled Pickup Times {#table-viii.6-sampled-pickup-times .unnumbered}

  ----------- ----------- ---------------------- -------------- ------------ ------------
                                                 **Trips**                   **%**

  **Sampled                                      299                         100.0%
  Pick Ups**                                                                 

              **Early &                          266                         89.0%
              On-Time**                                                      

                          **Early**                             120          40.1%

                          **On-Time**                           146          48.8%

              **Late**                           33                          11.0%

                          **0-20 Minutes**                      25           8.4%

                          **21 - 40 Minutes**                   5            1.7%

                          **41 - 60 Minutes**                   0            0.0%

                          **60+ Minutes**                       3            1.0%
  ----------- ----------- ---------------------- -------------- ------------ ------------

[]{.mark}

The results from this sample are consistent with results of sampling
conducted by EBP and confirm EBP's reporting of on-time performance. In
both reports of on-time performance, there appears to be a small number
of trips (1% or less) that could be considered significantly late (more
than one hour after the end of the pickup window).

The results from the sample review for drop-off times appear in Table
VIII.7.

### Table VIII.7 -- Sampled Drop-offs {#table-viii.7-sampled-drop-offs .unnumbered}

  ------------- ------------- ---------------------------- ----------- ----------- -----------
                                                           **Trips**               **%**

  **Sampled                                                79                      100.0%
  Drop-offs**                                                                      

                **On-Time**                                69                      87.3%

                **Late**                                               10          12.7%

                              **0-20 Minutes**                         9           11.4%

                              **20-60 Minutes**                        0           0.0%

                              **60+ Minutes**                          1           1.3%
  ------------- ------------- ---------------------------- ----------- ----------- -----------

[]{.mark}

Based upon the sampled trips only one trip (1.3%) was more than one hour
late and could be considered significantly late. Nine trips (11.4%) were
0 to 20 minutes late. Although not late by a large amount, these trips
might be work trips or medical trips and could cause concerns for
customers if they miss medical appointments or are regularly late for
work because of late drop‑offs.

## Analysis of Trip Length

The *Riders' Guide* advises customers that an EBP trip "will take the
same amount of time as an AC Transit bus would take." There is no
standard for long trips. ATC monitors long trips through review of
customer complaints.

# According to ATC managers, nearly all complaints regarding long trips were due either to a lost driver or trying to accommodate same-day trip requests. {#according-to-atc-managers-nearly-all-complaints-regarding-long-trips-were-due-either-to-a-lost-driver-or-trying-to-accommodate-same-day-trip-requests. .unnumbered}

The review team analyzed trip duration for the purpose of assessing
potential service capacity constraints caused by substantial numbers of
significantly long trips

(49 CFR 37.131(f)(3)(i)(C)). Consistent with EBP's goal that EBP trips
will take the same amount of time that an AC Transit bus would take, the
review analysis compared EBP trips with AC Transit trips with the same
origin and destination at the same time of day.

A sample of long EBP trips was selected from 221 EBP trips completed on
Wednesday,

January 15. (The 221 trips are a subset of the sample used to assess on
time performance.) Of this sample, the review team identified a total of
23 EBP trips, or 10% of the trips in this sample, that exceeded one hour
in travel time.

A team member identified equivalent fixed route trips using the
[transitinfo.org]{.underline} on-line trip planner and recorded the
estimated travel times provided by the trip planner. When the trip
planner offered more than one travel path, the team member selected the
path with the shortest travel time. The total fixed route travel time
includes the actual stop-to-stop travel time, including time spent
transferring. Twenty minutes were added to the stop-to-stop time to
account for walking to and from the stops at either end of the trip and
the initial wait for the bus. The results of the analysis appear in
Table VIII.8.

Of the 23 long trips sampled, 8 trips (35% of the sampled long trips)
had a travel time that exceeded the equivalent fixed route travel time.
These are indicated in Table VIII.8 with shaded rows. Five of the 8
trips exceeded the travel time by more than 10 minutes. Only one of
those trips (4.3% of the sampled long trips) exceeded the fixed route
travel time by more than 30 minutes.

Three of the 23 long trips were on one route. This might indicate that
the small number of long trips observed result from assignment of too
many passenger trips to one route.

####  {#section-2 .unnumbered}

#### Table VIII.8 -- Analysis of Trip Duration for Long Trips {#table-viii.8-analysis-of-trip-duration-for-long-trips .unnumbered}

+-----+--------------------+------------------+----+---+---+---+------+
|     | **Origin**         | **Destination**  | *  | * |   |   | ##   |
|     |                    |                  | *E | * |   |   | ## ( |
|     |                    |                  | BP | F |   |   | EBP  |
|     |                    |                  | Tr | i |   |   | Time |
|     |                    |                  | ip | x |   |   | ) -- |
|     |                    |                  | Du | e |   |   |  (Fi |
|     |                    |                  | ra | d |   |   | xed  |
|     |                    |                  | ti | R |   |   | Rout |
|     |                    |                  | on | o |   |   | e Ti |
|     |                    |                  | ** | u |   |   | me)  |
|     |                    |                  |    | t |   |   | {#eb |
|     |                    |                  |    | e |   |   | p-ti |
|     |                    |                  |    | * |   |   | me-f |
|     |                    |                  |    | * |   |   | ixed |
|     |                    |                  |    | * |   |   | -rou |
|     |                    |                  |    | * |   |   | te-t |
|     |                    |                  |    | T |   |   | ime  |
|     |                    |                  |    | i |   |   | .unn |
|     |                    |                  |    | m |   |   | umbe |
|     |                    |                  |    | e |   |   | red} |
|     |                    |                  |    | * |   |   |      |
|     |                    |                  |    | * |   |   |      |
+-----+--------------------+------------------+----+---+---+---+------+
| **T |                    |                  |    | # | * | * |      |
| rip |                    |                  |    | # | * | * |      |
| I   |                    |                  |    | # | W | T |      |
| D** |                    |                  |    | # | a | o |      |
|     |                    |                  |    |   | l | t |      |
|     |                    |                  |    | T | k | a |      |
|     |                    |                  |    | r | * | l |      |
|     |                    |                  |    | a | * | * |      |
|     |                    |                  |    | n |   | * |      |
|     |                    |                  |    | s |   |   |      |
|     |                    |                  |    | i |   |   |      |
|     |                    |                  |    | t |   |   |      |
|     |                    |                  |    |   |   |   |      |
|     |                    |                  |    |   |   |   |      |
|     |                    |                  |    | { |   |   |      |
|     |                    |                  |    | # |   |   |      |
|     |                    |                  |    | t |   |   |      |
|     |                    |                  |    | r |   |   |      |
|     |                    |                  |    | a |   |   |      |
|     |                    |                  |    | n |   |   |      |
|     |                    |                  |    | s |   |   |      |
|     |                    |                  |    | i |   |   |      |
|     |                    |                  |    | t |   |   |      |
|     |                    |                  |    |   |   |   |      |
|     |                    |                  |    | . |   |   |      |
|     |                    |                  |    | u |   |   |      |
|     |                    |                  |    | n |   |   |      |
|     |                    |                  |    | n |   |   |      |
|     |                    |                  |    | u |   |   |      |
|     |                    |                  |    | m |   |   |      |
|     |                    |                  |    | b |   |   |      |
|     |                    |                  |    | e |   |   |      |
|     |                    |                  |    | r |   |   |      |
|     |                    |                  |    | e |   |   |      |
|     |                    |                  |    | d |   |   |      |
|     |                    |                  |    | } |   |   |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 1400 Buckingham    | 2100 Bancroft    | 1: | 1 | 0 | 1 | -    |
| 966 | Way, Hayward       | Av., San Leandro | 00 | : | : | : | 0:20 |
| 019 |                    |                  |    | 0 | 2 | 2 |      |
|     |                    |                  |    | 0 | 0 | 0 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 600 Madison St.,   | 15300 Wicks      | 1: | 0 | 0 | 1 | -    |
| 951 | Oakland            | Blvd., San       | 02 | : | : | : | 0:10 |
| 034 |                    | Leandro          |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 2 | 0 | 2 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 300 Broadmoor      | 1200 Huron Lane, | 1: | 0 | 0 | 1 | -    |
| 955 | Blvd., San Leandro | Hayward          | 04 | : | : | : | 0:11 |
| 834 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 5 | 0 | 5 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 800 Marina Bay     | 3800 Park Blvd   | 1: | 1 | 0 | 1 | -    |
| 967 | Pkwy., Richmond    | Way, Oakland     | 04 | : | : | : | 0:26 |
| 482 |                    |                  |    | 1 | 2 | 3 |      |
|     |                    |                  |    | 0 | 0 | 0 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 18900 Standish     | 300 17th St.,    | 1: | 0 | 0 | 1 | -    |
| 967 | Av., Hayward       | Oakland          | 05 | : | : | : | 0:10 |
| 222 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 5 | 0 | 5 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 3800 Lamoureux     | 25800 Carlos Bee | 1: | 1 | 0 | 1 | -    |
| 966 | St., San Leandro   | Blvd., Hayward   | 05 | : | : | : | 0:18 |
| 206 |                    |                  |    | 0 | 2 | 2 |      |
|     |                    |                  |    | 3 | 0 | 3 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 2600 Parkside Dr., | 15400 Foothill   | 1: | 1 | 0 | 1 | -    |
| 958 | Union City         | Blvd., San       | 06 | : | : | : | 0:21 |
| 233 |                    | Leandro          |    | 0 | 2 | 2 |      |
|     |                    |                  |    | 7 | 0 | 7 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 26700 Patrick Av., | 2000 Mowry Ave., | 1: | 0 | 0 | 0 | +    |
| 955 | Hayward            | Fremont          | 06 | : | : | : | 0:19 |
| 775 |                    |                  |    | 2 | 2 | 4 |      |
|     |                    |                  |    | 7 | 0 | 7 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 400 S 23rd St.,    | 100 York Dr.,    | 1: | 0 | 0 | 1 | -    |
| 967 | Richmond           | Piedmont         | 07 | : | : | : | 0:12 |
| 000 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 9 | 0 | 9 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 8000 Edgewater     | 700 Curtis St.,  | 1: | 0 | 0 | 1 | -    |
| 951 | Dr., Oakland       | Albany           | 08 | : | : | : | 0:09 |
| 527 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 7 | 0 | 7 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 18900 Standish     | 300 17th St.,    | 1: | 0 | 0 | 1 | -    |
| 967 | Av., Hayward       | Oakland          | 08 | : | : | : | 0:00 |
| 236 |                    |                  |    | 4 | 2 | 0 |      |
|     |                    |                  |    | 8 | 0 | 8 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 4000 Castro Valley | 400 24th St.,    | 1: | 1 | 0 | 1 | -    |
| 964 | Blvd., Castro      | Oakland          | 09 | : | : | : | 0:12 |
| 398 | Valley             |                  |    | 0 | 2 | 2 |      |
|     |                    |                  |    | 1 | 0 | 1 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 3000 Woodroe       | 39600 Sundale    | 1: | 0 | 0 | 1 | -    |
| 951 | Court, Hayward     | Dr., Fremont     | 09 | : | : | : | 0:03 |
| 476 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 2 | 0 | 2 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 100 Collins St.,   | 3100 Telegraph   | 1: | 0 | 0 | 1 | +    |
| 966 | Richmond           | Av., Oakland     | 10 | : | : | : | 0:03 |
| 282 |                    |                  |    | 4 | 2 | 0 |      |
|     |                    |                  |    | 7 | 0 | 7 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 40100 Paseo Padre  | 4700 Cerritos    | 1: | 0 | 0 | 1 | +    |
| 963 | Pkwy., Fremont     | Av., Fremont     | 10 | : | : | : | 0:05 |
| 397 |                    |                  |    | 4 | 2 | 0 |      |
|     |                    |                  |    | 5 | 0 | 5 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 9500 Mountain      | 300 Broadmoor    | 1: | 0 | 0 | 0 | +    |
| 951 | Blvd., Oakland     | Blvd., San       | 11 | : | : | : | 0:29 |
| 246 |                    | Leandro          |    | 2 | 2 | 4 |      |
|     |                    |                  |    | 2 | 0 | 2 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 8300 Olive St.,    | 2000 Dwight Way, | 1: | 0 | 0 | 1 | -    |
| 960 | Oakland            | Berkeley         | 13 | : | : | : | 0:05 |
| 650 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 8 | 0 | 8 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 1700 78th Av.,     | 500 Golden Gate  | 1: | 0 | 0 | 1 | +    |
| 966 | Oakland            | Av., San         | 16 | : | : | : | 0:10 |
| 041 |                    | Francisco        |    | 4 | 2 | 0 |      |
|     |                    |                  |    | 6 | 0 | 6 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 700 Central Av.,   | 1300 Ruus Lane,  | 1: | 1 | 0 | 1 | +    |
| 951 | Alameda            | Hayward          | 25 | : | : | : | 0:06 |
| 017 |                    |                  |    | 1 | 2 | 3 |      |
|     |                    |                  |    | 1 | 0 | 1 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 39600 Sundale Dr., | 200 Cherry Way,  | 1: | 0 | 0 | 1 | +    |
| 951 | Fremont            | Hayward          | 27 | : | : | : | 0:15 |
| 479 |                    |                  |    | 5 | 2 | 1 |      |
|     |                    |                  |    | 2 | 0 | 2 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 1300 Ruus Lane,    | 700 Central Av., | 1: | 1 | 0 | 1 | -    |
| 951 | Hayward            | Alameda          | 34 | : | : | : | 0:10 |
| 955 |                    |                  |    | 2 | 2 | 4 |      |
|     |                    |                  |    | 4 | 0 | 4 |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 2000 Milvia Set,   | 1300 Fairmont    | ** | * | * | * | *    |
| 967 | Berkeley           | Dr., San Leandro | 1: | * | * | * | *+0: |
| 748 |                    |                  | 45 | 0 | 0 | 1 | 44** |
|     |                    |                  | ** | : | : | : |      |
|     |                    |                  |    | 4 | 2 | 0 |      |
|     |                    |                  |    | 1 | 0 | 1 |      |
|     |                    |                  |    | * | * | * |      |
|     |                    |                  |    | * | * | * |      |
+-----+--------------------+------------------+----+---+---+---+------+
| 1   | 34900 Starling     | 2000 Dwight Way, | 1: | 1 | 0 | 1 | +    |
| 957 | Dr., Union City    | Berkeley         | 51 | : | : | : | 0:26 |
| 543 |                    |                  |    | 0 | 2 | 2 |      |
|     |                    |                  |    | 5 | 0 | 5 |      |
+-----+--------------------+------------------+----+---+---+---+------+

**Findings**

1.  EBP appears to have a small, but consistent, number of trip denials
    and missed trips each day. Eleven additional potential denials were
    identified from ATC records for the sample day of January 15, 2003.
    This represents less than 0.4% of requested trips. The missed trips
    represents 1.2% of requested trips. EBP also reports a small number
    of trip denials and missed trips from its sampling of trip records.

2.  Based upon the sample day analyzed by the review team, some trip
    offers that were more than one hour from the time requested by the
    customer were not counted as denials. In addition, trips offered
    more than one hour from the initially requested time but turned down
    by the caller were counted as cancelled requests − rather than
    denials. More accurate accounting of these trips can assist in
    planning and scheduling service to eliminate denials.

3.  174 trips (7.6% of scheduled trips) were reported as late
    cancellations and customer no‑shows on the sample day. These
    cancellations and no-shows might provide capacity on the day of
    service to schedule and serve denied and missed trips.

4.  EBP appears to have a small number of significantly late pickups.
    EBP reports approximately 0.2% pickups more than one hour late
    in 2002. Based on the one-day sample conducted by the review team,
    1.0% of pickups and 1.3% of drop-offs were more than one hour late.

5.  The definition of the 20-minute on-time window (0/+20) does not
    appear to be effectively communicated to service providers and
    drivers. The contracts between ATC and the service providers cite a
    contract penalty for pickups completed more than 30 minutes after
    the scheduled pickup time. As a result, the service providers'
    incentive is to pick customers up within 30 minutes of the scheduled
    pickup time (0/+30), not 20 minutes. Operator manuals do not address
    the on-time pickup window and only an estimated pickup time appears
    on the drivers' manifests. Several observations were made of
    scheduled pickup times on driver manifests that were outside of the
    customer's 20-minute pickup window. Most drivers interviewed did not
    know the correct pickup window. As a result, the driver is usually
    unaware of what the customer is expecting for a pickup time. This
    can result in miscommunications between driver and customer and can
    contribute to late and early pickups.

6.  EBP does not have a standard for on-time performance for drop-offs
    for appointments and does not measure on-time performance for
    drop-offs.

7.  EBP does not appear to have a substantial number of significantly
    long ADA Complementary Paratransit trips. One trip from a sample of
    23 trips greater than one hour had a travel time that was
    significantly longer than that of a comparable fixed route trip.

8.  Three of the 23 long trips were on one route. This might indicate
    that the small number of long trips observed result from assignment
    of too many passenger trips to one route.

9.  Drivers do not appear to consistently understand "no-show"
    procedures.

**Recommendations**

1.  When no service within one hour of the requested time can be
    identified for the customer, EBPT should consider accepting the trip
    request as an unscheduled trip and assign the trip to a route on the
    day of service using capacity made available by trip cancellations
    or using backup service capacity.

2.  If EBP continues to offer trip times more than one hour from the
    time requested by the customer and the customer accepts those times,
    the initial request should be recorded as a capacity denial and the
    agreed upon trip be entered as a separate trip request for the
    agreed upon time. This will provide EBT with a more accurate
    indication of capacity limitations in trip scheduling.

3.  AC Transit and BART should consider amending their contracts with
    ATC and the service providers to identify standards for on-time
    performance for both pickups and drop-offs for appointments that are
    consistent with those provided customers and used to measure
    performance. This can promote consistent understanding of service
    expectations and provide an incentive for operator performance that
    is consistent with customer expectations.

4.  The pickup windows given to customers also should be provided to
    drivers, perhaps through bulletins to assure that both drivers and
    customers share a common definition of what is on time.

5.  Driver manifests should be revised to include pickup times
    negotiated with customers and appointment times if and when
    customers request trips to meet appointments. If possible, pickup
    windows also should be included on driver manifests. This can help
    to minimize the potential for misunderstanding between drivers and
    customers and improve on-time performance.

6.  AC Transit, BART and EBP should consider adopting a standard for
    on-time performance for drop-offs for appointments and measure
    performance against this standard.

7.  EBP may want to consider monitoring assignment of trips to routes
    during the scheduling process to avoid assigning too many trips to
    one run, potentially resulting in long trip durations.

8.  EBP should adopt and communicate no-show procedures to the service
    providers and all drivers.

# Resources

The review team analyzed the resources provided by AC Transit and BART
for ADA Complementary Paratransit services operated on their behalf by
EBP. The purpose of this element of the analysis is to assess the
adequacy of resources to support effective service. The team interviewed
EBP and service provider staff and reviewed the EBP ADA Complementary
Paratransit service budget, staffing and equipment levels.

**Level of Service**

[]{.mark}

The review team compared the travel volume per capita for AC Transit
with four other transit operations of comparable size to provide an
indicator of how effectively AC Transit is reaching the market of ADA
Complementary Paratransit customers.

As of January 2003, approximately 20,000 people were registered as ADA
Complementary Paratransit eligible riders in the EBP service area. Based
on information provided by ATC, in FY2002, EBP served 646,372 ADA
Complementary Paratransit passenger trips.

[]{.mark}

As seen in Table X.1, EBP falls in the middle of the range of other
transit operators in the number of trips served per year per capita.
Since the demand of trips per capita can be influenced by the
demographics of the service area, it is not possible to draw firm
conclusions from this review. However, a relatively low rate of trips
per capita could indicate impediments to customers in accessing and
using the service. Additionally, lower rates of trips per year can
provide an indication of the potential for market growth.

[]{.mark}

EBP trips per capita are more than twice that of two comparably sized
systems and approximately 75% the number of two others. This may
indicate that there is potential for ridership growth by as much as 33%,
which should be considered when developing budgets.

[]{.mark}

**Table X.1 -- Comparison of Per Capita Eligible Riders and Per Capita
Trips**

For Selected Transit Systems

+------------------+---------+---------+---------+---------+---------+
| []{.mark}        | **Oa    | **At    | **Clev  | **Se    | **Por   |
|                  | kland** | lanta** | eland** | attle** | tland** |
|                  |         |         |         |         |         |
|                  | []      | **(M    | **(G    | **(King | **(Tri  |
|                  | {.mark} | ARTA)** | CRTA)** | Co.**   | -Met)** |
|                  |         |         |         |         |         |
|                  |         |         |         | **M     |         |
|                  |         |         |         | etro)** |         |
+------------------+---------+---------+---------+---------+---------+
| **Service Area   | 1,      | 1,      | 1,      | 1,      | 1,      |
| Population**     | 409,983 | 241,000 | 412,140 | 685,000 | 221,937 |
+------------------+---------+---------+---------+---------+---------+
| **ADA Eligible   | 20,000  | 2,811   | N/A     | 27,016  | 12,000  |
| Riders**         |         |         |         |         |         |
+------------------+---------+---------+---------+---------+---------+
| **% Persons      | 1.4%    | 0.2%    | N/A     | 1.6%    | N/A     |
| Registered**     |         |         |         |         |         |
+------------------+---------+---------+---------+---------+---------+
| **ADA Trips      | 646,372 | 166,858 | 310,894 | 991,464 | 735,850 |
| Provided/Year**  |         |         |         |         |         |
+------------------+---------+---------+---------+---------+---------+
| **Tri            | 0.46    | 0.13    | 0.22    | 0.59    | 0.60    |
| ps/Year/Capita** |         |         |         |         |         |
+------------------+---------+---------+---------+---------+---------+

## Policies and Procedures {#policies-and-procedures-1 .unnumbered}

Financing for EBP services has been established through the "Joint
Exercise of Powers Agreement Establishing the East Bay Paratransit
Consortium." In accordance with the Agreement, AC Transit is responsible
for 69% of the costs, BART for 31%. Both agencies use a variety of
sources to cover their portions:

-   Fare revenue -- revenues from EBP passenger fares

-   Transportation Development Act (TDA) Article 4.5 − State funds for
    community transit services including services for individuals, such
    as the disabled, who cannot use fixed route service

-   STA -- State Transit Assistance is provided through the two fixed
    route operators,\
    AC Transit and BART, and is administered through the Metropolitan
    Transit Commission

-   Measure B − funding for non-ADA service in Alameda County provided
    by EBP

EBP develops an annual budget based upon a July 1 through June 30 fiscal
year. The EBP budget development begins in December and is completed in
February. The EBP budget is incorporated into the budgets of the AC
Transit and BART Boards in April and submitted as a draft to the two
agencies' respective Boards of Directors. During May and June, the
budget is subjected to review, including a public hearing. The final
budget for the upcoming fiscal year is adopted before June 30.

The bases for budget projections are: straight-line projections of
passenger trips, estimated operating hours to serve the riders, and the
hourly rates of the service providers. The ridership projections are
based upon trips completed rather than total demand for trips. The
principal costs of services are paid to the broker, ATC/Vancom, through
a five-year contract. ATC has a five-year cost plus fixed fee contract
with a ceiling price. The period of the contract is 2002 through 2006.
Contracts between ATC and the service operators provide for payment base
on vehicle service hours provided. Contracts between ATC and service
providers include provision for cost escalation and adjustment for
unanticipated conditions. Contracts are adjusted annually.

## Budgets {#budgets .unnumbered}

In response to FTA's request, AC Transit provided the information on
budget and expenditures that appears in Table X.2.

**Table X.2 East Bay Paratransit Budget History**

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

  Passengers     610,394        660,691        695,867        646,372        

  Budget                                       \$19,559,538   \$22,083,730   \$25,154,051

  Expenditures   \$14,575,492   \$16,188,664   \$20,124,115   \$23,579,906   \$23,747,813\*

  Cost per       \$23.88        \$24.50        \$36.48        \$36.88        \$37.05
  passenger                                                                  

  \*FY03                                                                     
  expenditures                                                               
  projected                                                                  
  based on 6                                                                 
  months' data                                                               
  -------------- -------------- -------------- -------------- -------------- ----------------

EBP managers attributed recent declines in ridership to:

-   Service problems associated with transition to new software in 2001
    and new service providers in 2002

-   More accurate accounting of passenger trips

-   Reduction in travel associated with decline in the economy

-   Increased accessibility of the fixed route system

-   Increased use of fixed route service by customers who are
    conditionally eligible to use EBP service

-   Increase in local city paratransit services

As noted in the budget development procedures, the basis used for
projecting travel growth does not include unserved demand, as expressed
by trips denied or missed. Should the volume of such trips be
substantial, this approach could result in understating future demand
for service. Based upon review of EBP travel data, the number of such
unserved trips is small, constituting less than 2% of completed trips,
and does not appear to significantly impact projections for ridership.
Additionally, the EBP, AC Transit, and BART staff adjusted ridership
projections up by 7.5% and rounded up to accommodate growth and provide
a contingency. In consideration of potential market penetration and
recent impacts on ridership as described by managers, this allowance for
growth in ridership appears to be reasonable. Overall, funding for EBP
services appears to be adequate and does not appear to limit service
capacity.

Although costs and cost per trip rose sharply between 2000 and 2001,
projections for steady increases in costs appear reasonable.

For FY2003, AC Transit and BART requested a reduction in the EBP budget
to respond to decreased funding. This request was made with the
understanding that a mid-year budget increase might be required and
agreed that such a need would be addressed. Recent funding history and
projections for upcoming years are presented in Table X.3.

## Table X.3 -- EBP Funding Trends {#table-x.3-ebp-funding-trends .unnumbered}

  ------------- -------------- -------------- -------------- -------------- --------------
  **Fiscal      **2000**       **2001**       **2002**       **2003**       **2004**
  Year**                                                                    

  **Fare        \$1,419,001    \$1,498,889    \$1,551,440    \$1,584,000    
  Revenue**                                                                 

  **TDA 4.5**   \$2,900,000    \$2,900,000    \$4,381,367    \$3,052,320    

  **STA**       \$780,000      \$780,000      \$787,614      \$961,883      

  **Measure B** \$0            \$0            \$534,045      \$5,781,141    

  **AC          \$7,651,311    \$10,312,206   \$10,232,192   \$10,210,943   \$17,296,978
  Transit**                                                                 

  **BART**      \$3,437,796    \$4,633,020    \$4,597,072    \$4,963,764    \$7,771,106

  **Total**     \$16,188,664   \$20,124,115   \$22,083,730   \$26,554,050   \$25,068,084
  ------------- -------------- -------------- -------------- -------------- --------------

Steady increases in funding are expected from fare revenue and STA, with
stable funding from TDA 4.5, AC Transit and BART general funds. AC
Transit and BART staff anticipates a substantial increase in funds from
Measure B.

### Operating Resources {#operating-resources .unnumbered}

The review team also reviewed operating resources to identify adequacy
of the amount of resources, particularly drivers and vehicles to
accommodate the demand for service. The review team collected
information on resources from the four service providers visited during
the review. The providers visited were:

-   AC Transit

-   Friendly Transportation

-   MV Transportation

-   First Transit

Information was not collected for A Paratransit, the smallest of the
five providers.

Information collected on operating resources is presented in Table X.4.

# Table X.4 -- Operating Resources {#table-x.4-operating-resources .unnumbered}

<table>
<colgroup>
<col style="width: 4%" />
<col style="width: 12%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="2"><strong>Carrier</strong></td>
<td colspan="3"><strong>Friendly</strong></td>
<td colspan="3"><h1 id="mv" class="unnumbered">MV</h1></td>
<td colspan="3"><strong>First Transit</strong></td>
<td colspan="3"><strong>AC Transit</strong></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td>Vans</td>
<td>Sedans</td>
<td>Total</td>
<td>Vans</td>
<td>Sedans</td>
<td>Total</td>
<td>Vans</td>
<td>Sedans</td>
<td>Total</td>
<td>Vans</td>
<td>Sedans</td>
<td>Total</td>
</tr>
<tr class="odd">
<td colspan="14"><h1 id="runs" class="unnumbered">Runs</h1></td>
</tr>
<tr class="even">
<td></td>
<td>Total</td>
<td>0</td>
<td>45</td>
<td>45</td>
<td>24</td>
<td>27</td>
<td>51</td>
<td>21</td>
<td>31</td>
<td>52</td>
<td></td>
<td></td>
<td>35</td>
</tr>
<tr class="odd">
<td></td>
<td>Peak</td>
<td>0</td>
<td>35</td>
<td>35</td>
<td></td>
<td></td>
<td>35</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td colspan="14"><h1 id="drivers" class="unnumbered">Drivers</h1></td>
</tr>
<tr class="odd">
<td></td>
<td>Total</td>
<td></td>
<td>69</td>
<td>69</td>
<td></td>
<td></td>
<td>60</td>
<td></td>
<td></td>
<td>73</td>
<td></td>
<td></td>
<td>54</td>
</tr>
<tr class="even">
<td></td>
<td>Peak</td>
<td></td>
<td>44</td>
<td>44</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="odd">
<td colspan="14"><h1 id="vehicles" class="unnumbered">Vehicles</h1></td>
</tr>
<tr class="even">
<td></td>
<td>Total</td>
<td>0</td>
<td>41</td>
<td>41</td>
<td>22</td>
<td>26</td>
<td>48</td>
<td>21</td>
<td>29</td>
<td>50</td>
<td>41</td>
<td>0</td>
<td>41</td>
</tr>
<tr class="odd">
<td></td>
<td>Available</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>19</td>
<td>27</td>
<td>46</td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td></td>
<td>Spares</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2</td>
<td>2</td>
<td>4</td>
<td></td>
<td></td>
<td></td>
</tr>
</tbody>
</table>

**Runs.** During the period July 1 through December 31, 2002, EBP's
monthly average weekday ridership ranged from 2131 to 2303 passengers.
ATC schedulers assign these trips to runs, or routes, and in turn assign
the runs to the service providers. The number of runs assigned to each
service provider at the time of the review on a typical weekday is
presented in Table X.4.

MV Transportation operates 51 EBP runs, which include 56 routes. Drivers
assigned to split runs operate multiple routes. There are approximately
35 runs operated during the peak periods. Of the 51 runs, 24 runs are
operated with vans and the remaining 27 runs use sedans. Friendly
Transportation operates 45 runs per day, with 35 runs operating during
the weekday peak period between 8:30 and 11:00 AM. First Transit
operates 21 van and 31 sedan runs per day, and

AC Transit operates 35 scheduled runs per weekday.

**Drivers.** On weekdays, MV Transportation schedules 57 to 60 drivers
for its 51 runs, providing more than 10% extra drivers. The 6 to 9 extra
drivers provide cover for both EBP and other MV services in the Bay
Area. Some runs are unassigned because no drivers bid for them. These
runs are assigned to extra-board drivers. Extra-board drivers report for
all shifts for which they are assigned. If there is no immediate work,
they wait four hours and end their shift. According to MV managers,
there are usually about three unassigned drivers. In addition to
extra-board, there are four road supervisors and four managers who can
serve as backup drivers. MV management indicated that driver recruitment
and retention was not a problem. They indicated that it was a problem
two years ago, but with the economic decline, driver availability and
quality has improved.

Friendly Transportation assigns 52 of its 67 drivers to work on a
typical weekday. Of these 52 drivers, 39 are assigned to set runs
including six split runs. As a result, the 39 drivers cover 45 runs. The
remaining 13 scheduled drivers provide some backup capacity for the
assigned drivers. Friendly management indicated that they had no
problems with driver recruitment or retention.

First Transit has 73 drivers, of which 52 are assigned to regular runs
and 21 are backup drivers. Of 63 drivers on First Transit's seniority
list, 20 were hired in 2001, 36 in 2002, and seven in 2003. AC Transit
has 54 drivers, of whom 20 are assigned to regular runs. AC Transit
managers indicated that they had no backup capacity in the form of
drivers designated as "floaters."

In general, it appears that driver staffing appears adequate to serve
the current number of assigned runs, and that in the current economic
environment driver recruitment and retention do not appear to be a
problem. Limited flexible capacity as identified by one service provider
could impede performance, particularly if EBP accepts all trip requests
with the intent of scheduling them to runs during the service day.

**Fleet.** All service providers own and maintain their own vehicles.
MV's fleet consists of 22 vans and 26 sedans to cover approximately 35
peak runs. The 48-vehicle fleet provides a spares ratio of approximately
37%. Managers indicated that there are no problems with the fleet. All
but one vehicle is a 2001 model or newer. Seventeen of the 26 sedans are
year 2003 vehicles.

First Transit has 21 vans and 29 sedans in its vehicle fleet. Of the 21
vans, 2 are assigned as backup vehicles, 16 are assigned to runs and 3
are available for unassigned use. Two sedans are also assigned as
backup, leaving 25 assigned to routes on the busiest weekdays and two
unassigned vehicles available for use. The vans are 2001 and 2002 models
and the sedans are all 2002 models.

AC Transit's fleet is comprised of 41 accessible vans and Friendly's
fleet is comprised of 41 sedans.

In general, the vehicle fleets of the EBP carriers appear to include an
adequate number of vehicles and spares to cover peak operating
requirements. The fleets appear to be fairly new and drivers indicated
few, if any, problems with vehicles.

**Findings**

1.  Funding for EBP services appears to be adequate and does not appear
    to limit service capacity. Economic conditions may limit future
    funding.

2.  Comparison of EBP's ADA Complementary Paratransit passenger trip
    volumes with those of comparably sized transit operators indicates
    that there is potential for continued growth in the demand for
    service in the Oakland area.

3.  Operating resources, including drivers and vehicles, appear to be
    adequate to serve existing travel demand. Flexible capacity for some
    carriers may be insufficient to respond to absences, demand spikes,
    and real time scheduling of trips that are currently denied.

4.  The process for preparing budgets appears to adequately reflect
    service needs. An allowance for 7.5% ridership growth in 2003
    appears to adequately provide for the current small number of denied
    and missed trips and a reasonable level of ridership increase.

5.  Not explicitly including unserved, expressed demand for service − in
    the form of denials and missed trips − in the budgeting process
    could result in underestimation of projected ridership if the number
    of trip denials and missed trips were substantial.

**Recommendations**

1.  AC Transit and EBP should review capacity of service providers to
    assure that they all have adequate flexible capacity to respond to
    demand fluctuations including serving requested trips that are now
    denied.

2.  In developing the baseline for EBP ridership projections, AC Transit
    and BART should explicitly include denials and missed trips to avoid
    potential underestimation of projected ridership.

    **Attachment A**

**Response from**

**Alameda-Contra Costa Transit District**

**and**

**Bay Area Rapid Transit District**

**Attachment B**

***Riders' Guide to Paratransit Services***

**Attachment C**

**On-Site Review Schedule**

**ADA Complementary Paratransit Service Review**

**Alameda Contra Costa Transit (AC Transit)/**

**Bay Area Rapid Transit (BART)**

**Oakland, California**

**February 24 - 28, 2003**

Schedule

+---------+-----------------------------------+----------+------------+
| *       | **Activity**                      | **Who**  | **Where**  |
| *Time** |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| **      |                                   |          |            |
| Monday, |                                   |          |            |
| F       |                                   |          |            |
| ebruary |                                   |          |            |
| 24,     |                                   |          |            |
| 2003**  |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| 9:00 AM | -   Opening Conference            | All      | AC Transit |
+---------+-----------------------------------+----------+------------+
| 10:00   | -   Review policies & procedures  | All      | AC Transit |
| AM      |     with East Bay Paratransit     |          |            |
|         |     Consortium (EBP) managers and | All      |            |
|         |     Broker                        |          |            |
|         |                                   |          |            |
|         | -   Review Budget Process         |          |            |
+---------+-----------------------------------+----------+------------+
| 11:00   | -   Tour Broker Offices           | All      | ATC        |
| AM      |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| 1:00 PM | -   Review operations &           | Kidston  | ATC        |
|         |     performance data provided on  |          |            |
|         |     site                          | Loutz    |            |
|         |                                   | enheiser |            |
|         | -   Review service parameters:    |          |            |
|         |     days & hours, fares, area,    | Barber   |            |
|         |     transfers                     |          |            |
|         |                                   | Chia     |            |
|         | -   Review complaints             |          |            |
|         |                                   |          |            |
|         | -   Review eligibility process    |          |            |
+---------+-----------------------------------+----------+------------+
| 3:00 PM | -   Observe reservations          | Chia,    |            |
|         |                                   |          |            |
|         | -   Review performance monitoring | Loutz    |            |
|         |     procedures                    | enheiser |            |
|         |                                   |          |            |
|         |                                   | Kidston  |            |
+---------+-----------------------------------+----------+------------+
| T       |                                   |          |            |
| uesday, |                                   |          |            |
| F       |                                   |          |            |
| ebruary |                                   |          |            |
| 25,     |                                   |          |            |
| 2003    |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| 7:00 AM | -   Observe Dispatch              | Kidston, | Friendly   |
|         |                                   |          | Tran       |
|         | -   Interview Drivers             | Loutz    | sportation |
|         |                                   | enheiser |            |
|         | -   Interview Manager             |          | First      |
|         |                                   | Chia,    | Transit    |
|         |                                   |          |            |
|         |                                   | Barber   |            |
+---------+-----------------------------------+----------+------------+
| 11:00   | -   Review procedures & resources | Chia,    | ATC        |
| AM      |     with Broker manager           |          |            |
|         |                                   | Kidston  |            |
|         | -   Observe reservations          |          |            |
|         |                                   | Loutz    |            |
|         | -   Continue review of complaints | enheiser |            |
|         |                                   |          |            |
|         |                                   | Barber   |            |
+---------+-----------------------------------+----------+------------+
| 1:00 PM | -   Review telephone system       | Barber   | ATC        |
|         |                                   |          |            |
|         | -   Interview scheduler/review    | Chia     |            |
|         |     scheduling                    |          |            |
|         |                                   | Loutz    |            |
|         | -   Assess trip length            | enheiser |            |
|         |                                   |          |            |
|         | -   Assess on-time performance    | Kidston  |            |
+---------+-----------------------------------+----------+------------+
| 3:00 PM | -   Observe reservations          | Kidston, | ATC        |
|         |                                   |          |            |
|         |                                   | Barber   |            |
+---------+-----------------------------------+----------+------------+

+---------+-----------------------------------+----------+------------+
| **Wed   |                                   |          |            |
| nesday, |                                   |          |            |
| F       |                                   |          |            |
| ebruary |                                   |          |            |
| 26,     |                                   |          |            |
| 2003**  |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| 7:00 AM | -   Observe dispatch              | Chia,    | AC Transit |
|         |                                   |          |            |
|         | -   Interview drivers             | Barber   | (pa        |
|         |                                   |          | ratransit) |
|         | -   Interview manager             |          |            |
+---------+-----------------------------------+----------+------------+
| 8:00 AM | -   Observe reservations          | Kidston, | ATC        |
|         |                                   |          |            |
|         |                                   | Loutz    |            |
|         |                                   | enheiser |            |
+---------+-----------------------------------+----------+------------+
| 11:00   | -   Continue on-time performance  | Kidston  | ATC        |
| AM      |     assessment                    |          |            |
|         |                                   | Loutz    |            |
|         | -   Continue trip length          | enheiser |            |
|         |     assessment                    |          |            |
|         |                                   | Barber   |            |
|         | -   Continue review of            |          |            |
|         |     complaints, telephones        | Chia     |            |
|         |                                   |          |            |
|         | -   Continue review of scheduling |          |            |
+---------+-----------------------------------+----------+------------+
| 1:00 PM | -   Observe dispatch              | Kidston, | MV         |
|         |                                   |          | Tran       |
|         | -   Interview drivers             | Loutz    | sportation |
|         |                                   | enheiser |            |
|         | -   Interview manager             |          | ATC        |
|         |                                   | Barber   |            |
|         | -   Continue review of telephone  |          |            |
|         |     system                        | Chia     |            |
|         |                                   |          |            |
|         | -   Continue review of            |          |            |
|         |     eligibility process           |          |            |
+---------+-----------------------------------+----------+------------+
| **Th    |                                   |          |            |
| ursday, |                                   |          |            |
| F       |                                   |          |            |
| ebruary |                                   |          |            |
| 27,     |                                   |          |            |
| 2003**  |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| 7:00 AM | -   Continue on-time performance  | Kidston  | ATC        |
|         |     assessment                    |          |            |
|         |                                   | Loutz    |            |
|         | -   Continue trip length and fare | enheiser |            |
|         |     analysis                      |          |            |
+---------+-----------------------------------+----------+------------+
| 8:00 AM | -   Observe reservations          | Chia,    | ATC        |
|         |                                   |          |            |
|         |                                   | Barber   |            |
+---------+-----------------------------------+----------+------------+
| 1:00 PM | -   Continue data analysis        | All      | ATC        |
+---------+-----------------------------------+----------+------------+
| **      |                                   |          |            |
| Friday, |                                   |          |            |
| F       |                                   |          |            |
| ebruary |                                   |          |            |
| 28,     |                                   |          |            |
| 2003**  |                                   |          |            |
+---------+-----------------------------------+----------+------------+
| 8:00 AM | -   Prepare materials for Exit    | All      | ATC        |
|         |     Conference                    |          |            |
+---------+-----------------------------------+----------+------------+
| 1:00 PM | -   Exit Conference               | All      | AC Transit |
+---------+-----------------------------------+----------+------------+

**Attachment D**

**Application for ADA Complementary Paratransit Service**

**Attachment E**

**Template for Request for Professional Verification**

**Attachment F**

***All About East Bay Paratransit***

**Attachment G**

**Sample Cover Page for Recertification Application**

**Attachment H**

**Template for Denial Letter and Appeals Process**