Connecticut Department of Transportation/

Greater Hartford Transit District

**Hartford, Connecticut**

Assessment

of

ADA Complementary Paratransit Service

Capacity Constraints

June 25-28, 2001

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**with**

**Multisystems, Inc.**

**Final Report: December 20, 2001**

**CONTENTS**

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

[II. Overview of the Assessment 3](#overview-of-the-assessment)

[III. Background 7](#background)

[IV. Summary of Findings 10](#summary-of-findings)

[V. Observations Regarding ADA Complementary Paratransit Eligibility &
Other Service Access Issues
14](#observations-regarding-ada-complementary-paratransit-eligibility-other-service-access-issues)

[VI. Observations Regarding Telephone Capacity & Trip Reservations
24](#observations-regarding-telephone-capacity-trip-reservations)

[VII. Observations Regarding Scheduling and Service
28](#observations-regarding-scheduling-and-service)

[[A.]{.smallcaps} [Scheduling]{.smallcaps} 29](#scheduling)

[[B.]{.smallcaps} [Dispatch and Operations]{.smallcaps}
33](#dispatch-and-operations)

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

[2. Analysis of Trip Length 38](#analysis-of-trip-length)

[VIII. Resources 42](#resources)

*Attachment A* Response from ConnDOT and GHTD

*Attachment B* On-Site Assessment Schedule

*Attachment C* Transportation under the Americans with Disabilities Act

*Attachment D* GHTD Application Form for ADA Complementary Paratransit
Service and Cover Letter

*Attachment E* Community Transportation Consortium: What Every Rider
Should Know

*Attachment F* ADA Complementary Paratransit Certification Card

*Attachment G* Form Letter for Persons Determined Ineligible for ADA
Complementary Paratransit Service

*Attachment H* Sample Pages from Completed Driver Manifest

*Attachment I* Sample On Time Performance Reports

# Purpose of the Assessment

Public entities that operate fixed route transportation services for the
general public are required by the U.S. Department of Transportation
(USDOT) regulations implementing the Americans with Disabilities Act of
1990 (ADA) to provide ADA Complementary Paratransit service for persons
who, because of their disability, are unable to use the fixed route
system. These regulations (49 CFR Parts 27, 37, and 38) include six
service criteria, which must be met by ADA Complementary Paratransit
service programs. Section 37.135(d) of the regulations requires that ADA
Complementary Paratransit services meet these criteria by January 26,
1997.

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

The purpose of the review is to assist the transit agency and FTA in
assessing whether capacity constraints exist in ADA Complementary
Paratransit services. The compliance assessment 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 assessment considers
whether there are patterns or practices of a significant number of trip
limits; trip denials; early or late pickups or arrivals after desired
arrival (or appointment) times; long trips; or long telephone hold times
as defined by established standards (or typical practices if standards
do not exist). The examination of patterns or practices includes looking
not just at service statistics, but also at basic service records and
operating documents, and observing service to determine whether records
and documents appear to reflect true levels of service delivery. Input
also is gathered from local disability organizations and customers.
Guidance is provided that will assist the transit service provider in
ensuring that service can be effectively monitored by transit agencies
for capacity constraints.

An on-site assessment of ADA Complementary Paratransit service provided
by the Greater Hartford Transit District (GHTD) was conducted from June
25 to 28, 2001. GHTD provides this service on behalf of the Connecticut
Department of Transportation (ConnDOT). Planners Collaborative, Inc.,
located in Boston, Massachusetts, and Multisystems, Inc., located in
Cambridge, Massachusetts, conducted the compliance assessment for the
FTA Office of Civil Rights. The assessment focused on compliance of
GHTD's ADA Complementary Paratransit service, with one specific
regulatory service criterion: the "capacity constraints" criterion.
Section 37.131(f) of the regulations requires that ADA Complementary
Paratransit services be operated without capacity constraints.

This report summarizes the observations and findings of the on-site
assessment of GHTD's ADA Complementary Paratransit service. First, a
description of key features of the ADA Complementary Paratransit service
is provided. Then, a description of the approach and methodology used to
conduct the assessment is provided. Observations and findings related to
each element of the capacity constraint criteria are then summarized.
The major findings of the assessment are summarized in Section 4 of this
report. Recommendations for addressing some of the findings are also
provided.

ConnDOT and GHTD received a draft copy of the report for review and
response. A copy of the November 27, 2001 correspondence from ConnDOT
that documents the agencies' combined response to the draft report is
included as Attachment A.

# Overview of the Assessment

This assessment focused on compliance with the ADA Complementary
Paratransit capacity constraints requirements of the 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
assessment focused on observations and findings regarding:

-   Trip denials and "wait-listing" of trips

-   On-time performance

-   Travel times

The assessment team also made observations and findings related to two
other policies and practices that can affect access to ADA Complementary
Paratransit service:

-   ADA Complementary Paratransit service eligibility process

-   Telephone capacity

ADA Complementary Paratransit eligibility determinations were assessed
to ensure that the system use was not impacted by inappropriate denials
of eligibility for the service or unreasonable delays in the eligibility
process. Telephone capacity was assessed because access to reservations
and customer service staff is a critical to using any ADA Complementary
Paratransit service.

**Pre-assessment**

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

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

```{=html}
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-   A copy of the request for proposal (RFP), which provides a
    description of all of GHTD's paratransit programs (dial-a-ride and
    ADA Complementary Paratransit), service standards (on-time
    performance, trip denials, travel times), information on the
    calltaking equipment, scheduling software, and vehicle fleet.

-   A copy of the current service provider contract.

-   Flyer summarizing all GHTD services and flyer describing ADA
    Complementary Paratransit service.

-   Sample driver manifests.

-   Data on ridership and trip denials for fiscal years 1998, 1999, and
    2000.

-   Budget data for fiscal years 1998, 1999, and 2000.

-   System map for Connecticut Transit, the area's fixed route operator.

Additional information was requested to be available during the on-site
visit. This information included:

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

-   Copies of completed driver manifests for recent months.

```{=html}
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```
-   Service data from selected sample days and months, including the
    number of trips requested, scheduled, denied, canceled, no-shows,
    missed trips, and trips provided

-   A breakdown of trips requested, scheduled, and provided.

-   Detailed information about trips denied for selected sample days and
    months, including origin and destination information, day and time
    information, and customer information.

-   Detailed information about trips identified for selected sample days
    and months with long travel times.

-   Written customer complaints.

[]{.mark}

In addition to the review of data and direct observations, the
assessment team conducted telephone interviews with six individuals who
use the ADA Complementary Paratransit service. The assessment team also
reviewed one complaint on file with FTA. This complaint was filed in
1999.

**On-site Assessment**

The on-site assessment began with an opening conference, held at 11:00
a.m. on Monday,

June 25, 2001. GHTD Executive Director Arthur Handman and Interim
Paratransit Director

Pat Williams attended the meeting. Adrienne Hileman, paratransit
operations manager for Double A Charter Services, also attended. Anthony
Arcari and Richard Gray represented Connecticut DOT's (ConnDOT) Bureau
of Public Transportation.

Don Kidston and David Chia of Planners Collaborative, and Russell
Thatcher of

Multisystems, Inc., along with Margaret Griffin of FTA's Office of Civil
Rights, comprised the assessment team. Cheryl Hershey, also of the
Office of Civil Rights, participated in the opening conference via
telephone.

[]{.mark}

Ms. Hershey opened the meeting by emphasizing that the purpose of the
ADA compliance assessments is to help transit properties provide
effective ADA Complementary Paratransit service.

[]{.mark}

She also thanked GHTD and Double A staff for their cooperation in the
conduct of the assessment. Ms. Hershey 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 GHTD and ConnDOT for
    review and comment before being finalized as a public document.

Mr. Kidston described the schedule for the on-site assessment and the
subsequent report. A copy of the assessment schedule appears in
Attachment B. GHTD and Double A indicated that they were willing to
provide any information and assistance to the assessment team. GHTD
provided a room for the assessment team to work.

Mr. Handman explained the relationship between GHTD and ConnDOT. In the
Hartford region, ConnDOT is the entity that provides fixed route service
(via Connecticut Transit), and therefore is responsible for providing
ADA Complementary Paratransit service in the region. GHTD is a
"municipal corporation" whose business is to manage paratransit service
in the Hartford region. Currently, GHTD manages the ADA Complementary
Paratransit service, as well as dial-a-ride services for the cities of
Hartford and East Hartford and the town of Wethersfield. It also has a
contract to manage some Medicaid transportation services in the region.

In the afternoon, the assessment team posed some initial questions
concerning the budgeting process for ADA Complementary Paratransit. Then
the assessment team met with Ms. Williams and Ms. Hileman to review the
additional reports and information supplied on site. Afterwards, two
members of the assessment team met with Ms. Williams to discuss GHTD's
procedures for service eligibility and reviewed a sample of completed
applications for service.

On Tuesday morning, June 26, the assessment team visited the offices of
Double A Charter Services in Rocky Hill, Conn. Two members of the
assessment team observed vehicle dispatch and discussed daily operating
procedures with the dispatcher. Two other members of the assessment team
conducted interviews with drivers. The entire assessment team then met
with Ms. Hileman. The primary topics included trip scheduling, driver
training, and the current vehicle fleet. In the afternoon, the
assessment team returned to the GHTD office in Hartford. They
interviewed the head scheduler and observed her preparing vehicle
schedules. Then two assessment team members observed calltakers as they
accepted trip requests from riders. The other members of the assessment
team analyzed service information provided by GHTD.

On Wednesday, June 27, one of the team members visited the Hartford
office of Connecticut Transit to collect information needed to compare
trip lengths of ADA Complementary Paratransit and fixed route trips.
Other assessment team members observed calltakers again. In the
afternoon, all team members organized their observations and analyzed
the information collected during the site visit.

On Thursday, June 28, the assessment team held an exit conference with
GHTD, Double A, and ConnDOT staff. During the exit conference, the
assessment team presented preliminary findings, and discussed these
findings and recommendations with GHTD and ConnDOT staff. Attending the
exit meeting were: Arthur Handman, Pat Williams, and Ken Goldberg of
GHTD; Adrienne Hileman of Double A Charter; Anthony Arcari and Richard
Gray of ConnDOT; and the FTA assessment team. Cheryl Hershey of the FTA
Office of Civil Rights, along with Arthur Andrew Lopez, the Director of
the Office of Civil Rights, participated in the closing conference via
telephone.

[]{.mark}

The assessment team reviewed initial findings in the areas of:

-   Customer complaints

-   Service eligibility

-   Trip reservations and scheduling

-   On-time performance

-   Trip duration

-   Resources

[]{.mark}

Mr. Lopez and Ms. Hershey emphasized that FTA was available to provide
additional technical assistance to GHTD and ConnDOT.

# Background

In Hartford and surrounding towns of central Connecticut, the
Connecticut Department of Transportation is the provider of public
transportation. ConnDOT has separate operators for its fixed route and
specialized transit services. Connecticut Transit (CTTransit) operates
the fixed route buses in the region. CTTransit's Hartford division has a
fleet of 228 buses, all of which are equipped with wheelchair lifts. In
FY2000 (ending June 30, 2000), The Hartford division provided 14.9
million passenger trips with operating expenses of \$32.5 million.

The Greater Hartford Transit District provides specialized transit,
including ADA Complementary Paratransit service. GHTD, a municipal
corporation that was formed in 1971, consists of 16 communities,
including the city of Hartford and 15 surrounding communities. GHTD is
run by an executive director, who reports to a 27-member board. The
board is made up of representatives of the 16 member communities. GHTD
provides ADA Complementary Paratransit service in part or all of 12 of
these communities (in addition, ADA Complementary Paratransit service is
available in portions of five adjoining, non-member towns). The precise
service region is defined by CTTransit's corresponding fixed route
service. The total population of the member municipalities is 573,000
(2000 US census). The population of the 17 towns that receive ADA
Complementary Paratransit service is 570,000.

In addition to ADA Complementary Paratransit service, GHTD provides
non-ADA "dial-a-ride" services to residents of Hartford, East Hartford,
and Wethersfield. Under state statute, GHTD has the broad authority "to
acquire, operate, finance, plan, develop, and maintain all forms of land
transportation. It may also develop and maintain transportation centers
and parking facilities." GHTD manages Hartford's Union Station, an
intermodal transportation center used by CTTransit, Amtrak, intercity
buses, and other private carriers.

[]{.mark}

**Description of the ADA Complementary Paratransit Service**

GHTD contracts with Double A Charter Services to provide ADA
Complementary Paratransit service. Double A has its administrative
office and garage in Rocky Hill, south of Hartford. GHTD provides the
vehicles, fuel, radio system, computer system for client information and
trip scheduling (hardware and software), telephone system for accepting
reservations, and office space in Hartford. Double A maintains the
vehicles, and provides the drivers, mechanics, and office staff
(calltakers, schedulers, dispatchers) needed to operate service.

The fleet consists of 56 vehicles, all vans or minivans. All vehicles
have wheelchair lifts and two wheelchair positions.

GHTD staff certifies passenger eligibility for ADA Complementary
Paratransit service. GHTD staff also determine whether an eligible rider
can receive subscription service. Currently, GHTD is not adding riders
to its subscription list.

GHTD's ADA Complementary Paratransit service is structured to meet
ConnDOT's obligation to provide transit services to persons with
disabilities who are not able to use the fixed route system. ADA
Complementary Paratransit service is offered during the same days as
CTTransit on a route-by-route basis. ADA Complementary Paratransit
service is available from 6 a.m. to 10 p.m. The fare for a one-way trip
is \$2.00, twice the base cash fare of a one-way trip on CTTransit.
Personal care attendants ride for free. Companions pay the \$2.00 fare.

Trips can be reserved from one to 14 days in advance of the travel day.
GHTD accepts reservations over the phone every day from 8 a.m. to 4 p.m.
The calltaker tries to confirm the trip reservation at the time of the
call. Some trip requests are put on standby. In this situation, a
calltaker calls the rider making the request at a later time to confirm
the trip. As a policy, GHTD does not accept requests for same-day trips.
If a rider cancels a trip less than two hours before the scheduled
pick-up time, GHTD considers this as a "no-show."

A copy of *Transportation under the Americans with Disabilities Act*,
GHTD's flyer describing its ADA Complementary Paratransit service, is
included in Attachment C.

Ridership on GHTD's ADA Complementary Paratransit service has increased
significantly in recent years. ADA ridership in FY1999 (ending June 30,
1999) was 75,103. The projected ridership for FY2001 (based on a
projection of the fiscal year's first 11 months) was 90,565: an increase
of 20.5 percent in two years. There are approximately 2,000 individuals
who are registered for ADA service.

Double A also operates GHTD's dial-a-ride services. Rider eligibility,
fares, trip purposes, service areas, hours and days, and reservation
procedures are different for each service. However, daily operations for
all services are mingled. The same vehicles and staff serve riders of
all services. Table III.1 highlights some of the differences among the
demand responsive services.

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

GHTD has established service standards for trip denials, on-time
performance, travel time, and telephone capacity, but has not
established standards for missed trips. The service standards are
described below.

> []{.mark}

-   ***Telephone Capacity***: GHTD policy states that callers should be
    on hold for no longer than one minute.

-   ***Trip Denials***: GHTD policy states that the contractor "shall be
    guided by the ADA and the requirement that no pattern of denials
    shall be established." There is no quantitative standard for trip
    denials.

-   ***On-Time Performance***: Trips are considered to be on time if
    passengers are picked up between 15 minutes before and 15 minutes
    after the scheduled pickup time. GHTD's standard for meeting this
    goal is 92 percent or more of all trips.

-   ***Missed Trips***: GHTD has no standard for missed trips.

-   ***Travel Time***: GHTD policy is that "no one rider shall spend
    more than the amount of time a person without a disability would
    reasonably be expected to spend making the same trip on a local
    fixed route bus during a one-way trip."

Table III.1 Comparison of GHTD Demand Responsive Services

+----------+-----------+------+-----------+-----------+-------------+
| **S      | **Elig    | **Fa | **Days &  | **Service | **Trip      |
| ervice** | ibility** | re** | Hours**   | Area**    | Purpose**   |
+==========+===========+======+===========+===========+=============+
| **ADA**  | Based on  | \$   | G         | Within    | No priority |
|          | ability   | 2.00 | enerally, | 3/4-mile  | or          |
| **       | to use    |      |           | of any    | r           |
| Compl.** | fixed     |      | 6 am to   | CTTransit | estrictions |
|          | route     |      | 10 pm;    | bus route |             |
| **Parat  |           |      | varies by |           |             |
| ransit** |           |      | bus route |           |             |
+----------+-----------+------+-----------+-----------+-------------+
| **       | Hartford  | \$20 | 8 am to 6 | Hartford  | Medical     |
| Hartford | resident, | dona | pm, M-F   | and 7     | trips have  |
| Dial-    | plus      | tion |           | ne        | top         |
| a-Ride** | "         | per  | 8:15 am   | ighboring | priority.   |
|          | permanent | year | to 5pm,   | towns     | On          |
|          | di        |      | Sat       |           | weekends,   |
|          | sability" |      |           |           | *only*      |
|          | or at     |      | 8:15 am   |           | medical,    |
|          | least 60  |      | to 3 pm,  |           | grocery,    |
|          | years old |      | Sun       |           | nutrition,  |
|          |           |      |           |           | religious   |
|          |           |      |           |           | services    |
+----------+-----------+------+-----------+-----------+-------------+
| **East   | East      | Free | 8 am to   | East      | Medical     |
| Hartford | Hartford  |      | 4:30 pm,  | Hartford  | trips have  |
| Dial-    | resident, |      | M-F       | and 5     | top         |
| a-Ride** | plus      |      |           | ne        | priority;   |
|          | "         |      |           | ighboring | grocery and |
|          | permanent |      |           | towns     | nutrition   |
|          | di        |      |           |           | have next   |
|          | sability" |      |           |           | priority    |
|          | or at     |      |           |           |             |
|          | least 60  |      |           |           |             |
|          | years old |      |           |           |             |
+----------+-----------+------+-----------+-----------+-------------+
| **Weth   | Wet       | Free | 8 am to 5 | Weth      | Medical     |
| ersfield | hersfield |      | pm, M-F   | ersfield, | trips have  |
| Dial-    | resident, |      |           | and "when | top         |
| a-Ride** | plus      |      | 8 am to   | av        | priority;   |
|          | "         |      | 6pm, Sat  | ailable," | grocery and |
|          | permanent |      |           | 7         | nutrition   |
|          | di        |      | 8 am to 2 | ne        | have next   |
|          | sability" |      | pm, Sun   | ighboring | priority    |
|          | or at     |      |           | towns     |             |
|          | least 60  |      |           |           |             |
|          | years old |      |           |           |             |
+----------+-----------+------+-----------+-----------+-------------+

**Consumer Comments**

The assessment team gathered information about the concerns of GHTD
riders through three sources: telephone interviews with GHTD riders;
written complaints to FTA; and written complaints to GHTD.

A member of the assessment team conducted telephone interviews with six
individuals who ride GHTD's ADA Complementary Paratransit service. These
individuals were referred to the assessment team through agencies that
work with individuals with disabilities, including ADAPT and
Independence Unlimited.

Over the past two years, FTA has received one written complaint
concerning GHTD's ADA Complementary Paratransit service. Over the past
two years, GHTD has received 14 written complaints about its ADA
service. The GHTD files include the original complaints, as well as
copies of the responses.

# Summary of Findings

The following summarizes the findings drawn from the assessment. These
findings include observations, supported by fact, of areas where GHTD is
performing well, as well as areas where improvements could be made. 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 ConnDOT and GHTD. Recommendations are also included
in the report for the consideration of ConnDOT, GHTD and Double A
Charter in developing corrective actions. They should be considered as
advisory only.

**Findings Regarding ADA Complementary Paratransit**

**Eligibility**

1.  GHTD appears to be limiting ADA Complementary Paratransit
    eligibility to persons who are prevented from using fixed route bus
    service, in accordance with the DOT ADA regulations. Eligibility for
    service appeared clear in 29 of 30 records of approved applicants.

2.  Unconditional eligibility is granted to all approved applicants.
    Based on the review of 30 approved applications, 20 percent of ADA
    Complementary Paratransit eligible persons appeared to be able to
    use fixed route buses at least some of the time. These individuals
    would be potential candidates for conditional eligibility.

3.  A review of recent denials of eligibility indicated that denials are
    based largely on responses to information in the application form
    with limited confirmation through follow-up with applicants or named
    professionals. A few of the denials seemed to be based on
    inconsistencies in the answers to the questions in the application.
    These individuals could have misunderstood the questions or could
    have had difficulty completing the form. Follow-up with the
    applicant or named professionals would probably have been helpful
    making an accurate eligibility determination in these cases.

4.  Applications appear to be processed quickly. None of the 60
    application files examined showed a processing time longer than 20
    calendar days, and most (72 percent) were processed in seven days or
    less.

5.  The documentation of eligibility provided to approved applicants
    does not indicate if the person is authorized to travel with a PCA,
    as required by the DOT ADA regulations (49 CFR §37.125(e)).

6.  The use of a denial letter to return *incomplete* applications could
    discourage some applicants from completing and returning the
    application form.

7.  The form letter used to inform applicants that ADA Complementary
    Paratransit eligibility has been denied does not provide specific
    reasons for the determination. The letter includes only a general
    statement that the person does not have a disability that prevents
    use of the fixed route bus. This could impede the applicant from
    pursuing a legitimate appeal to the determinant.

8.  Far fewer than expected persons have dual eligibility. An
    examination of Hartford Dial-a-Ride client applications indicated
    that perhaps a third might be ADA Complementary Paratransit
    eligible. However, only about 12 percent of Hartford Dial-a-Ride
    applicants are also ADA Complementary Paratransit eligible. In
    recent years, the percentage of applicants granted dual eligibility
    also appears to have fallen. In Wethersfield, only two percent of
    recent dial-a-ride applicants are also ADA Complementary Paratransit
    eligible, compared to 35 percent in past years. In Hartford, the
    rate of dual eligibility has fallen from 18 to 10 percent in recent
    years, and in East Hartford the rate has fallen from 17 to 6
    percent. These numbers and percentages suggest that applicants
    either may not fully understand the benefits of being eligible for
    both programs or may be directed to only one program when they may
    be eligible for both services. The confusion could result in
    applicants who are otherwise eligible for ADA Complementary
    Paratransit service not applying for the service.

**Findings Regarding Other Service Access Issues**

1.  ADA Complementary Paratransit service is not available throughout
    the same service hours and days of CTTransit fixed route service.

[]{.mark}

[]{.mark}

**Findings Regarding Telephone Capacity & Trip Reservations**

1.  GHTD appears to answer all incoming calls without long hold times.

2.  GHTD's public brochure and after-hours telephone message do not
    inform riders that they can make trip requests seven days a week.
    The rider likely gains the impression that they can make trip
    requests on weekdays only.

3.  Some calltakers do now know that trip requests for ADA Complementary
    Paratransit service can be made seven days a week.

4.  GHTD's call management system is inactive, preventing continuous
    monitoring of reservations center telephone performance.

5.  Calltakers do not record all incoming trip requests, which leads to
    understating the number of capacity denials.

6.  Some dial-a-ride clients whose requests are denied are not advised
    that they may be eligible for these same trips under ADA
    Complementary Paratransit service.

7.  The "0-bookng" list is a waiting list and is prohibited by the DOT
    ADA regulations, 49 CFR §37.131(f)(2).

**Findings Regarding Scheduling**

1.  GHTD denied 4.7 percent of ADA Complementary Paratransit trip
    requests in FY2000 and 3.9 percent of ADA Complementary Paratransit
    trip requests in FY2001 (11 months).

2.  There appears to be a pattern of trip denials, with the probability
    of being denied a trip increasing the closer to the service day the
    trip request is made.

3.  While GHTD service mingles dial-a-ride and ADA Complementary
    Paratransit riders, the schedulers try to give priority to ADA
    riders. This is accomplished in part by creating the 0-booking list,
    and trying to fit the ADA trip requests from the 0-booking onto
    vehicle schedules. The operations manager also has the authority to
    add vehicle runs.

4.  More than 50 percent of GHTD's ADA Complementary Paratransit trips
    are subscription trips. This includes trips during the peak travel
    periods, when GHTD denies trip requests.

5.  Based on assessment team observations and interviews with Double A
    drivers, the scheduling process appears to work well, but the
    resulting schedules are tight and often require "real time"
    adjustments.

6.  If a no-show occurs on the first half of a round trip, GHTD has a
    policy of canceling the return trip, unless the rider calls to
    confirm the return trip. A round trip represents two independent
    one-way trips, and the passenger has an independent right to each of
    these trips. To automatically cancel a return trip as a result of a
    no-show for the outgoing leg of the trip would undermine this right.

**Findings Regarding Dispatch and Operations**

1.  Double A has a fleet of 56 vehicles of which 46 are normally
    available for daily service. Ten vehicles or 18 percent of the
    available vehicles are normally assigned to maintenance.

2.  The staff of 42 regular and 19 additional drivers appears to be
    sufficient to meet service needs.

3.  As a whole, the drivers are experienced, well trained, and seem
    dedicated to their jobs.

4.  Drivers generally believe that they have tight schedules. They have
    the flexibility, within the 30-minute pickup windows, to adjust
    their schedule and even change the order of stops.

**Findings Regarding Resources**

1.  Projections of demand for ADA Complementary Paratransit passenger
    trips for budgeting purposes are less than current expressed demand,
    as reflected by trips served plus trips denied. Projections of
    passenger demand do not appear to provide for market growth, which
    was 25 percent between 1999 and 2001.

2.  Vehicle productivity levels appear to correspond directly with trip
    denials: 1.4 passenger trips per hour with 3,000 plus annual trip
    denials, and 1.25 trips per hour with 300 annual trip denials.

3.  The annual budget for FY2002 does not appear to provide sufficient
    funds to serve the FY2001 levels of ADA Complementary Paratransit
    passenger demand, plus allow for growth in demand.

4.  The productivity levels assumed in the FY2002 budget do not appear
    to provide sufficient service capacity to serve all requested ADA
    Complementary Paratransit passenger trips.

5.  Driver staffing levels appear to be adequate to meet passenger
    demand.

6.  The amount of service scheduled in a given day appears to be fixed
    at approximately 46 runs and appears to be based upon the number of
    vehicles available for service.

# Observations Regarding ADA Complementary Paratransit Eligibility & Other Service Access Issues 

The process used to determine ADA Complementary Paratransit eligibility
was assessed to be sure that GHTD is making determinations in a way that
accurately reflects the functional ability of applicants. The assessment
team also reviewed the timeliness of the processing of requests for
eligibility. The assessment team performed the following activities:

-   Interviews with riders to gain their views about the eligibility
    determination process.

-   Interviews of GHTD staff and a review of application materials to
    develop an understanding of the handling and review of applications.

-   A review of eligibility determination outcomes.

-   An examination of records for 33 recently reviewed applications, and
    a calculation of the processing time for each.

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-   Other service access issues were reviewed including:

    -   Service area

    -   Service hours

    -   Restrictions on service use

**Consumer Comments**

The eligibility determination process was discussed in interviews with
several riders. None of the riders mentioned any problems with the
eligibility determination process.

Eligibility Determination Procedures and Practices

[]{.mark}

As indicated previously, the GHTD provides two different demand
responsive transportation services: local dial-a-ride services for the
communities of Hartford, East Hartford, and Wethersfield, and ADA
Complementary Paratransit service. There are different eligibility
criteria and applications for these programs. GHTD staff determines
eligibility for the ADA Complementary Paratransit service and the
Hartford Dial-a-Ride service. The communities of Wethersfield and East
Hartford determine eligibility for their respective dial-a-ride
programs.

When an individual calls to inquire about registering for service, the
GHTD staff determines which program the person might be eligible for and
best meet his/her needs. This is done by asking about the person's age,
disability, and types of trips they expect to make. If GHTD determines
that the person needs ADA Complementary Paratransit service, they mail
the application form for this program to this person. If they determine
that the person would qualify for dial-a-ride service and lives in
Hartford, a dial-a-ride application is mailed. If the person would
qualify for dial-a-ride and lives in either East Hartford or
Wethersfield, he/she is referred to staff in those communities.

Some guidelines cited by the GHTD staff that are used to determine
whether a dial-a-ride application, an ADA Complementary Paratransit
application, or both are sent are listed below:

-   If the person specifically asks for an ADA Complementary Paratransit
    application, it is sent.

-   If the person is 60 years of age or older and needs in-town medical
    or shopping transportation, a dial-a-ride application is sent.

-   If the person indicates a need for out-of-town transportation, an
    ADA Complementary Paratransit application is sent, since the
    dial-a-ride programs provide limited service to other towns.

-   If the person needs transportation for other than shopping or
    medical purposes, an ADA Complementary Paratransit application is
    sent, since the dial-a-ride programs provide mainly medical and
    shopping transportation.

-   If the person has a variety of travel needs, is a senior, and
    reports having a disability, both applications are sent.

The GHTD eligibility coordinator estimated that she sends out two to
three ADA Complementary Paratransit applications per week, less than one
Hartford Dial-a-Ride application per week, and one or two packages with
both an ADA Complementary Paratransit application and a Hartford
Dial-a-Ride application. She also noted that when both applications are
sent, she typically receives both of them back only about 50 percent of
the time. She noted that the dial‑a‑ride programs are more attractive in
terms of rider fares. The Wethersfield and East Hartford Dial-a-Ride
services are free. In Hartford, a \$20 donation is requested, which then
makes the rider eligible for trips for a year.

ADA Complementary Paratransit eligibility is determined based on a paper
application, with occasional telephone follow-up as needed. The
application form is six pages long. A one-page program description is
attached to the front and a one-page tracking form is attached to the
back of the application. A cover letter explaining ADA Complementary
Paratransit eligibility criteria and the eligibility determination
process is also sent with the application. A copy of the application
form and cover letter is provided as Attachment D.

The application form asks for general information, information about the
applicant's disability and travel limitations, frequently made trip
information, travel training information, and the name of a medical
professional who can be contacted if necessary to verify the person's
disability or travel needs. The form also asks the applicant to sign a
release that would allow GHTD to receive information from the named
professional.

When GHTD receives the form, the GHTD eligibility coordinator
date-stamps it. She then reviews the information in the application and
makes a determination of eligibility based largely on the answers in the
application. Occasionally, she will call the applicant if some questions
are not completed or to get clarifying information. She very
occasionally calls named professionals to get verification of claimed
disabilities or travel limitations.

All persons determined eligible are given "unconditional eligibility."
GHTD does not make determinations of "conditional eligibility," i.e.,
identifying conditions under which individuals might be able to
sometimes use fixed route service. Also, for most applicants, there is
currently no date on which their eligibility expires. If applicants
indicate that they have a permanent disability, permanent eligibility is
granted. An expiration date is given only if an applicant indicates
she/he has a temporary disability and identifies how long the condition
is expected to last.

Persons determined eligible are sent a "Certification of Eligibility for
ADA Paratransit Service" card. They also receive a copy of the GHTD's
*Community Transportation Consortium: What Every Rider Should Know*
brochure (Attachment E) that provides information on how to use the
service and an explanation of important service policies. They also
receive a small magnet that has the service reservations and information
phone number. Attachment F presents a copy of the front and back of the
ADA Complementary Paratransit certification card.

The "Certification of Eligibility for ADA Paratransit Service" card
provides most of the required documentation of eligibility. It has the
person's name, the name of the issuing transit agency, and the name and
phone number of the director of paratransit services. It gives an
expiration date only for those with a temporary disability. It does not
identify conditions of eligibility since all determinations are for
unconditional eligibility. Finally, it does not indicate if the person
is eligible to travel with a personal care attendant (PCA). The need for
a PCA is requested in the application form and is entered in the
customer file in the automated reservations/scheduling system.

Persons determined ineligible for ADA Complementary Paratransit service
are sent a form letter (see Attachment G). The form letter lists three
reasons for denial of the application:

##### The application is incomplete.

##### The person does not have a disability that prevents use of the fixed route service.

##### ADA Complementary Paratransit service is provided only in areas where there is fixed route service and lack of bus service is not a reason for eligibility.

One or more of these boxes is checked off for the specific applicant.
The letter also notes that to appeal the decision, the applicant should
call the GHTD to receive information about the appeal process.

A review of the denial letter raised several possible issues. First, by
using the denial form letter to return incomplete applications,
applicants may feel that they are not eligible and may not follow up
with a complete application. Second, the letter is not specific enough
about the reasons for denial. A statement that the applicant does not
have a disability that prevents bus use is too general and does not give
the applicant an indication of what additional documentation might be
helpful in an appeal. In Appendix D of the USDOT's ADA regulations, the
requirements of 49 CFR §37.125(d) are explained as follows:

...in the case of a denial, the reasons must be specified. The reasons
must specifically relate the evidence in the matter to the eligibility
criteria of this rule and of the entity's process. A mere recital that
the applicant can use fixed route transit is not sufficient.

> \[***Federal Register***, 9/6/91, page 45747\]

Third, the fact that there is not local bus service in the area where
the applicant lives should not be a reason for denial of eligibility.
Persons who live outside the service area who could not use bus service
if they were to visit Hartford should be granted eligibility. The GHTD
could then explain that while they are eligible, service is only
provided in corridors around bus routes.

Finally, while the letter indicates that information about the appeal
process will be mailed if requested, the eligibility coordinator was not
aware of any available material that could be sent and was not aware of
how appeals would be handled. She noted that there have not been any
appeals in recent years.

**Determination Outcomes**

A review of records indicated that the GHTD receives about 77 ADA
Complementary Paratransit applications per month. The vast majority of
these (94 percent) are approved. About six percent of all applications
are denied. As noted above, all those determined eligible are given
unconditional eligibility.

A member of the assessment team reviewed a random sample of 30 recent
applications that were approved and discussed them with the GHTD
eligibility coordinator. Twenty-nine of these determinations seemed
clear-cut and appropriate. In one case, the applicant indicated a
physical disability (had undergone leg surgery), but noted in the
application that she could walk more than 3/4-mile and currently used
the fixed route buses. However, six of the applicants indicated that
they currently use the fixed route bus system for some of their trips.
These persons did have disabilities that prevented bus travel at some
times, but clearly could use fixed route service under certain
conditions.

The assessment team member also reviewed a random set of 15 recent
denials (between January and June 2001) with the GHTD eligibility
coordinator. Again, most denial determinations appeared appropriate. In
three cases, though, the decision was based in part on information in
the application that appeared to be inconsistent to the reviewer. There
was no evidence, though, of follow-up with the applicant or professional
to clarify these inconsistencies. In these cases, additional follow-up
would have been helpful.

**Multiple Eligibility Issues**

To ensure that persons requesting service were being directed
appropriately to the two different services, the assessment team
conducted a review of eligibility for both dial-a-ride service and ADA
Complementary Paratransit service. A random sample of Hartford and East
Hartford Dial‑a‑Ride applications were reviewed to estimate the number
and percentage of persons in the dial‑a‑ride program who had
disabilities that might prevent use of fixed route service. The master
database of all dial-a-ride customers was also reviewed to determine the
types of eligibility granted. This approach to determining the extent of
single versus dual eligibility was necessary, as GHTD could not generate
a summary report of total riders and riders by different types of
eligibility.

The assessment team reviewed 100 Hartford Dial-a-Ride applications. This
review suggested that about 74 percent of the persons who were
dial-a-ride eligible had a disability. Fourteen percent reported using a
wheelchair, 23 percent used other mobility aids such as walkers or
canes, and nine percent indicated that they need to travel with an
escort. Based on this review, it was estimated that about a third of the
applicants appeared to have a significant disability that likely would
have prevented fixed route bus use.

A review of the computerized rider files showed, however, that a much
smaller percentage of dial-a-ride riders have ADA as well as dial-a-ride
eligibility. A total of 326 rider records were examined. This review
showed that 13 percent of all dial-a-ride riders also have ADA
Complementary Paratransit eligibility. Seventeen of 144 Hartford
Dial-a-Ride riders reviewed (or 12 percent) had dual eligibility. Nine
of 90 East Hartford records (10 percent) showed dual eligibility.
Fifteen of 92 Wethersfield riders (16 percent) had dual eligibility.

The rate of multiple eligibility also appeared to vary significantly
when recent versus older determinations were examined. Records with some
of the lowest ID numbers versus the recent (highest) ID numbers were
examined. Table V.1 shows the result of this analysis. As shown, the
number and percentage of applicants being granted both dial-a-ride and
ADA Complementary Paratransit eligibility appears to be much smaller in
recent years. The difference is most pronounced in East Hartford and
Wethersfield. While determinations in Wethersfield several years ago
resulted in 35 percent dual eligibility, recently only two percent of
applicants are made eligible for both programs. In East Hartford, the
rate of dual eligibility has dropped from 17 percent to six percent. And
in Hartford, the rate of dual eligibility has dropped from 18 percent to
10 percent.

**Table V.1 Single Versus Multiple Eligibility for 326 Randomly Selected
Dial-a-Ride Riders, Showing Differences for Recent Versus Older
Determinations**

  ------------------------------------- -------------- ------------ ------------------
                                        **Hartford**   **East       **Wethersfield**
                                                       Hartford**   

  **Determinations from Several Years                               
  Ago**                                                             

  Number or Rider Records Examined      40             36           40

  Number and Percent of Riders Only     33 (83%)       30 (83%)     26 (65%)
  Dial-a-Ride Eligible                                              

  Number and Percent of Riders Both     7 (18%)        6 (17%)      14 (35%)
  Dial-a-Ride and ADA Complementary                                 
  Paratransit Eligible                                              

  **Recent Determinations**                                         

  Number or Rider Records Examined      104            54           52

  Number and Percent of Riders Only     94 (90%)       51 (94%)     51 (98%)
  Dial-a-Ride Eligible                                              

  Number and Percent of Riders Both     10 (10%)       3 (6%)       1 (2%)
  Dial-a-Ride and ADA Complementary                                 
  Paratransit Eligible                                              
  ------------------------------------- -------------- ------------ ------------------

**Review of Application Processing Times**

[]{.mark}

The assessment team selected a random set of 60 processed applications
from the GHTD files. The date stamp on the application was then compared
to the date when eligibility was granted (as indicated on the tracking
form attached to the back of the application).

Table V.2 shows the results of this review. Of the 60 applications
examined, the longest time taken to complete a review was 20 days. GHTD
processed 43 applications in seven days or less. Fourteen applications
were processed in 8 to 14 days, and three applications took between 15
and 21 days.

**Table V.2 - Processing Time for 60 Randomly Selected Applications**

  ---------------------------------- ------------------------------------
                                     **\# of
                                     Applications/Determinations**

  Review Completed in 1-7 Days       43

  Review Completed in 8-14 Days      14

  Review Completed in 15-21 Days     3

  Determinations Made After 21 Days  0

  **TOTAL**                          **60**
  ---------------------------------- ------------------------------------

[]{.mark}

[]{.mark}

**Other Service Access Issues**

**ADA Complementary Paratransit Service Area**

GHTD defines the ADA Complementary Paratransit service area as required
by the DOT ADA regulations (49 CFR §37.125(a)). The service area
consists of a 3/4-mile corridor on each side of a CTTransit bus route,
excluding express routes. The scheduling software does not have
automatic address checking to determine if an address is within a
3/4-mile corridor. Instead, each calltaker has a notebook with a
directory for each town that is not fully covered by the ADA
Complementary Paratransit service. This directory lists the streets for
these towns that are eligible origins or destinations for ADA service.

[]{.mark}

Based on the assessment team's observations of calltakers, they seemed
to be aware of the proper service area for ADA Complementary Paratransit
service. This has the potential to be a concern in GHTD's operations,
since calltakers accept trips requests for the non-ADA dial-a-ride
services as well, each of which has its own service area.

There were no consumer complaints concerning the ADA Complementary
Paratransit service area.

[]{.mark}

**Days and Hours of Service**

[]{.mark}

GHTD's brochure for ADA service, *Transportation under the Americans
with Disabilities Act*, states that "service operates 7 days a week
during the same hours that CTTransit buses operate. While there are some
exceptions, the service is generally open from 6:00 am to 10:00 pm." The
RFP for Double A's current contract has the same information. DOT ADA
regulations (49 CFR §37.131(e)) require that ADA Complementary
Paratransit service be available throughout the same hours and days as
the entity's fixed route service. However, a review of the CTTransit bus
schedules shows that many of CTTransit's routes start service before 6
a.m. and/or end service after 10 p.m. In fact, as seen Table V.3,
service on some routes starts as early as 4:30 a.m. and other routes run
past 1 a.m. The times in **bold** indicate fixed route service that
extends beyond 6 a.m. and 10 p.m.

Table V.3 - Hours of Operation for Selected CTTransit Bus Routes

  -------------------------------------------------------------------------------------
  **Route**   **Weekday                  **Saturday              **Sunday    
              Hours**                    Hours**                 Hours**     
  ----------- ----------- -------------- ------------ ---------- ----------- ----------
              **Start**   **End**        **Start**    **End**    **Start**   **End**

  A           **5:55      **1:24 a.m.**  6:12 a.m.    6:38 p.m.  8:00 a.m.   6:57 p.m.
              a.m.**                                                         

  B           **5:14      **10:35 p.m.** 6:47 a.m.    **10:35    8:00 a.m.   7:19 p.m.
              a.m.**                                  p.m.**                 

  B2          **5:25      6:23 p.m.      6:40 a.m.    5:25 p.m.  none        
              a.m.**                                                         

  E           **5:10      **12:55 a.m.** 6:45 a.m.    **11:25    7:32 a.m.   7:47 p.m.
              a.m.**                                  p.m.**                 

  E3          **5:50      9:34 p.m.      6:30 p.m.    9:25 p.m.  none        
              a.m.**                                                         

  E6          **5:40      7:26 p.m.      7:30 a.m.    5:40 p.m.  none        
              a.m.**                                                         

  F           **5:18      **11:20 p.m.** 7:21 a.m.    7:21 p.m.  none        
              a.m.**                                                         

  F1          **5:20      **12:00 m**    6:45 a.m.    **11:00    none        
              a.m.**                                  p.m.**                 

  F3          **5:50      6:35 p.m.      7:20 a.m.    5:45 p.m.  none        
              a.m.**                                                         

  H1          **5:30      6:20 p.m.      7:30 a.m.    6:03 p.m.  none        
              a.m.**                                                         

  H2          **5:50      5:49 p.m.      8:30 a.m.    4:47 p.m.  none        
              a.m.**                                                         

  K           7:05 a.m.   **1:21a.m.**   6:46 a.m.    **11:40    7:44 p.m.   8:05 p.m.
                                                      p.m.**                 

  K1          **4:58      **11:55 p.m.** 7:00 a.m.    **10:56    none        
              a.m.**                                  p.m.**                 

  K2          **4:40      9:35 p.m.      6:45 a.m.    8:33 p.m.  none        
              a.m.**                                                         

  K3          **4:59      **11:59 p.m**. 7:15 a.m.    **12:35    none        
              a.m.**                                  a.m.**                 

  K4          **5:39      7:06 p.m.      none                    none        
              a.m.**                                                         

  K5          **5:50      6:12 p.m.      8:09 a.m.    6:32 p.m.  none        
              a.m.**                                                         

  L           **10:05     **10:24 p.m.** 10:05 p.m.   **10:24    7:00 p.m.   7:19 p.m.
              p.m.**                                  p.m.**                 

  L2          6:56 a.m.   **10:52 p.m.** 7:11 a.m.    **10:52    6:58 a.m.   7:50 a.m.
                                                      p.m.**                 

  M           **5:42      6:50 p.m.      none                    none        
              a.m.**                                                         

  N           **5:57      9:04 p.m.      9:02 a.m.    7:00 p.m.  none        
              a.m.**                                                         

  N2          **5:50      6:43 p.m.      7:20 a.m.    6:37 p.m.  none        
              a.m.**                                                         

  N5          **5:38      8:49 a.m.      none                    none        
              a.m.**                                                         

  O           **5:36      **12:27 a.m.** 6:53 a.m.    7:10 p.m.  none        
              a.m.**                                                         

  O2          **5:15      7:18 p.m.      6:25 a.m.    6:01 p.m.  none        
              a.m.**                                                         

  P           **5:30      7:55 p.m.      7:00 a.m.    6:33 p.m.  none        
              a.m.**                                                         

  P1          **5:10      7:20 p.m.      6:45 a.m.    6:56 p.m.  none        
              a.m.**                                                         

  Q           6:41 a.m.   **11:25 p.m.** 5:27 p.m.    **10:30    8:07 a.m.   8:20 p.m.
                                                      p.m.**                 

  Q3          **5:15      5:53 p.m.      none                    none        
              a.m**.                                                         

  Q4          6:11 a.m.   **11:01 p.m.** 8:00 a.m.    6:42 p.m.  none        

  S           **5:30      7:05 p.m.      6:31 p.m.    7:22 p.m.  none        
              a.m.**                                                         

  S1          **5:22      6:26 p.m.      6:50 a.m.    6:51 p.m.  none        
              a.m.**                                                         

  T           **4:50      **1:21 a.m.**  **5:29       **11:29    7:10 a.m.   8:54 p.m.
              a.m.**                     p.m.**       p.m.**                 

  T1          **5:29      5:50 p.m.      7:10 a.m.    5:45 p.m.  none        
              a.m.**                                                         

  T2          **5:44      5:51 p.m.      None                    none        
              a.m.**                                                         

  T3          6:38 a.m.   **12:35 a.m.** 7:55 a.m.    **10:55    none        
                                                      p.m.**                 

  T4          **5:15      9:52 p.m.      8:10 a.m.    5:46 p.m.  none        
              a.m.**                                                         

  T5          **5:22      6:20 p.m.      8:50 a.m.    5:38 p.m.  none        
              a.m.**                                                         

  T6          7:30 a.m.   **12:03 a.m.** 5:14 p.m.    **11:04    none        
                                                      p.m.**                 

  T7          **5:51      6:03 p.m.      7:35 a.m.    4:38 p.m.  none        
              a.m.**                                                         

  T8          **5:47      7:15 p.m.      7:05 a.m.    3:23 p.m.  none        
              a.m.**                                                         

  U           **5:42      **11:17 p.m.** 5:17 p.m.    **11:17    none        
              a.m.**                                  p.m.**                 

  U3          6:05 a.m.   **10:02 p.m.** 7:15 a.m.    9:37 p.m.  none        

  U4          **5:55      7:39 p.m.      none                    none        
              a.m.**                                                         

  W           **5:35      7:05 p.m.      8:25 a.m.    5:43 p.m.  9:45 a.m.   5:10 p.m.
              a.m.**                                                         

  X           6:19 a.m.   **10:57 p.m.** 7:27 a.m.    **10:57    8:21 a.m.   7:29 p.m.
                                                      p.m.**                 

  YM          **4:30      8:35 p.m.      7:12 a.m.    7:30 p.m.  7:00 a.m.   7:25 p.m.
              a.m.**                                                         

  YM1         **5:55      6:30 p.m.      6:55 a.m.    6:34 p.m.  none        
              a.m.**                                                         

  YM2         **4:55      7:53 p.m.      6:25 a.m.    6:52 p.m.  none        
              a.m.**                                                         

  YS          **5:48      7:00 p.m.      8:38 a.m.    6:10 p.m.  none        
              a.m.**                                                         

  YS6         **5:50      2:35 p.m.      10:10 a.m.   4:31 p.m.  none        
              a.m.**                                                         

  Z           **5:39      **10:32 p.m.** 7:35 a.m.    **10:32    7:55 a.m.   7:10 pm.
              a.m.**                                  p.m.**                 

  Z1          **5:05      7:06 p.m.      none                    none        
              a.m.**                                                         

  Z3          6:21 p.m.   **10:04 p.m.** 9:15 p.m.    10:00 p.m. none        
  -------------------------------------------------------------------------------------

**Findings**

1.  GHTD appears to limit ADA Complementary Paratransit eligibility to
    persons who are prevented from using fixed route bus service, in
    accordance with the regulations. Eligibility for service appeared
    clear in 29 of 30 records of approved applicants.

2.  Unconditional eligibility is granted to all approved applicants.
    Based on the review of 30 approved applications, 20 percent of ADA
    Complementary Paratransit eligible persons appeared to be able to
    use fixed route buses at least some of the time. These individuals
    would be potential candidates for conditional eligibility.

3.  A review of recent denials of eligibility indicated that denials are
    based largely on responses to information in the application form
    with limited confirmation through follow-up with applicants or named
    professionals. A few of the denials seemed to be based on
    inconsistencies in the answers to the questions in the application.
    These individuals could have misunderstood the questions or could
    have had difficulty completing the form. Follow-up with the
    applicant or named professionals would probably have been helpful
    making an accurate eligibility determination in these cases.

4.  Applications appear to be processed quickly. None of the 60
    application files examined showed a processing time longer than 20
    calendar days, and most (72 percent) were processed in seven days or
    less.

5.  The documentation of eligibility provided to approved applicants
    does not indicate if the person is authorized to travel with a PCA,
    as required by the DOT ADA regulations (49 CFR §37.125(e)).

6.  The use of a denial letter to return *incomplete* applications could
    discourage some applicants from completing and returning the
    application form.

7.  The form letter used to inform applicants that ADA Complementary
    Paratransit eligibility has been denied does not provide specific
    reasons for the determination. The letter includes only a general
    statement that the person does not have a disability that prevents
    use of the fixed route bus. This could impede the applicant from
    pursuing a legitimate appeal to the determinant.

8.  Far fewer than expected persons have dual eligibility. An
    examination of Hartford Dial‑a‑Ride client applications indicated
    that perhaps a third might be ADA Complementary Paratransit
    eligible. However, only about 12 percent of Hartford Dial-a-Ride
    applicants are also ADA Complementary Paratransit eligible. In
    recent years, the percentage of applicants granted dual eligibility
    also appears to have fallen. In Wethersfield, only two percent of
    recent dial-a-ride applicants are also ADA Complementary Paratransit
    eligible, compared to 35 percent in past years. In Hartford, the
    rate of dual eligibility has fallen from 18 to 10 percent in recent
    years, and in East Hartford the rate has fallen from 17 to 6
    percent. These numbers and percentages suggest that applicants
    either may not fully understand the benefits of being eligible for
    both programs or may be directed to only one program when they may
    be eligible for both services. The confusion could result in
    applicants who are otherwise eligible for ADA Complementary
    Paratransit service not applying for the service.

9.  ADA Complementary Paratransit service is not available throughout
    the same service hours and days of CTTransit fixed route service.

[]{.mark}

**Recommendations**

1.  To help get more information about applicants' specific travel
    issues, the GHTD should consider adding a question to the
    application such as, "Please explain how this disability prevents
    you from using the public bus system." Also, the application should
    have more space for the last question in Part 3 to encourage
    applicants to explain travel issues in their own words.

2.  If the GHTD finds that it might not be able to meet all of the
    demand for ADA Complementary Paratransit service, consideration
    should be given to granting conditional eligibility to persons who
    indicate that they are able to use fixed route buses some of the
    time. Trips made by these persons (or at least, frequent or
    subscription trips) could then be reviewed and fixed route service
    could be offered when appropriate.

3.  If there are inconsistencies in responses to questions in the
    application form, or if applicants appear to have had difficulty
    completing the form, GHTD staff should follow up with the applicant
    by phone before denying eligibility based on these inconsistencies
    or incomplete responses.

4.  In the next printing of the ADA Complementary Paratransit
    eligibility card, information about authorization to travel with a
    PCA should be added.

5.  GHTD should revise the letter its uses to inform applicants that
    they have been denied ADA Complementary Paratransit eligibility. A
    specific statement that details the reason(s) for the determination
    should replace the three check boxes and standard statements.

6.  GHTD should have a separate letter informing applicants that their
    application is incomplete -- rather than using the denial form
    letter.

7.  To avoid potential confusion to applicants who are eligible for ADA
    Complementary Paratransit service, GHTD should consider the use of a
    consolidated application for all of GHTD's demand-responsive
    transportation services. GHTD staff should be instructed to review
    and make ADA Complementary Paratransit service determinations for
    all applicants, and dial-a-ride applicants as appropriate.

8.  GHTD should clarify its language on the days and hours of service.
    In its public brochure, it can add statements such as, "Hours of
    service are the same as hours of service of CTTransit bus routes in
    the area. ADA service may start as early as 5 a.m. or continue as
    late as 1 a.m." GHTD should include information on days and hours of
    service to the calltakers' existing street directories, so that the
    information is readily available when they receive a trip request.

# Observations Regarding Telephone Capacity & Trip Reservations

The purpose of the assessment team's review of the telephone system and
trip reservation process was to determine whether riders who use GHTD's
ADA Complementary Paratransit service can effectively reach GHTD
calltakers and have their trip requests scheduled. 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 GHTD.

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

-   Direct observations of calltaking practices in the reservations
    office.

**Consumer Comments**

During the telephone interviews, one rider (out of six interviews)
complained about making trip reservations. This rider, who makes four to
five round trips per month, said that he often was put on hold for a
long time, and sometimes could not get through. The other riders
interviewed, when specifically asked about making trip reservations, had
no problems. One written complaint (of 14) submitted to GHTD cited
reservations as "hard to book." Another written complaint to GHTD
concerned the denial of a trip request. The single written complaint
about GHTD service submitted to FTA did not involve making trip
reservations.

**Review of GHTD Reservations Policies and Procedures**

GHTD accepts requests for ADA trips seven days a week, from 8 a.m. to 4
p.m. On weekdays, reservations are taken by calltakers at GHTD's
Hartford office. On Saturday and Sunday, dispatchers at Double A's
office in Rocky Hill take ADA Complementary Paratransit service trip
reservations. Riders can make requests for ADA Complementary Paratransit
service from one to 14 days in advance of the travel day. (Trip requests
for dial-a-ride service are not accepted on the weekend, and policies
for calling ahead vary by dial-a-ride program.) Depending on the time of
day, there may be as many as five calltakers working. Several calltakers
are bilingual to serve both Spanish and English speaking customers.
According to the supervisor of the calltakers, the peak period for trip
requests is 8 to 10 a.m. on weekdays. GHTD does have a call management
system that tracks information such as call duration, number and
duration of calls on hold, calls currently in the queue, but it is not
currently installed. The supervisor said that she monitors the queue of
incoming calls "in real time." She believes that they are meeting GHTD's
stated goal of no calls on hold for more than one minute.

GHTD's most recent RFP for paratransit service lists the following
information on expected call volume and characteristics:

-   380 to 400 calls per day

-   50 to 80 calls during the peak hour

-   On average, 2 calls on hold

-   2 to 4 minutes for a single call

For callers on hold, the calltakers "will return to on-hold callers
every 30-45 seconds informing them of the status of their trip request."
In addition, the RFP provides some suggested greetings that the
calltaker can use when talking to a caller.

During weekdays, calltakers accept trip requests for both dial-a-ride
and ADA Complementary Paratransit service. GHTD uses Trapeze paratransit
software for trip requests and its client database, as well as for
scheduling and report generation. Once a caller says that he/she wants
to make a trip reservation, the calltaker first verifies that he/she is
a registered rider and checks the funding source (ADA or one of the
town's dial-a-ride programs). For ADA Complementary Paratransit service,
the calltaker then asks for the trip's origin and destination. Then the
calltaker asks for a pickup time or appointment time for the first leg
of the trip, and for a round trip, the pickup time for the return trip.
According to GHTD policy, calltakers can negotiate either or both of the
requested times, up to one hour earlier or later. They might do this in
order to fit the trips into the already existing vehicle runs. In a
majority of requests -- with or without negotiating -- the calltaker is
able to schedule and confirm the requested trips during the phone call.
The RFP states that "riders shall not be given a specific pickup time;
rather, the rider will be informed of a 1/2-hour window for their
pickup."

Subscription trips are already included in vehicle runs before
calltakers add the demand-responsive trips to the schedules. GHTD is not
accepting further requests for subscription service at this time.

In some cases, however, the calltaker is not able to schedule the
requested trip during the phone call. The trip is then placed in the
"0-booking" for the date of the requested trip. Two Double A staff
members, a full-time scheduler and the paratransit operations manager,
schedule all trips placed into the 0-booking. Calltakers keep a manual
list of the trip requests they place into 0‑bookings. They periodically
check the schedule to see if these trips have been placed on a vehicle
schedule. If so, they call the riders to confirm the trip reservation.
Riders can also call to find out if their trip has been scheduled.
According to the supervisor and one of the calltakers, the calltakers do
not turn down trips because of capacity constraints -- that authority is
left to the schedulers.

Calltakers receive calls for several other reasons. Riders call to
confirm trips previously booked, to temporarily suspend subscription
service, or to cancel trips. GHTD considers it acceptable to cancel a
trip up to one day in advance. If the rider calls less than two hours
before the scheduled pickup, GHTD considers this as a "no-show."
Calltakers also provide general information about the GHTD services.

**Observations of GHTD Reservations Practices**

[]{.mark}

Assessment team members observed calltakers for two periods during their
visit to the GHTD office: from 2:45 to 4 p.m. on Tuesday, June 26, and
from 8:15 to 10:30 a.m. on Wednesday, June 27. During both periods,
three calltakers were working, along with their supervisor. During both
periods, the call volume seemed moderate to light. At any given time,
usually one or more of the calltakers was not on the phone. During the
morning observations, one calltaker commented that there were fewer
calls than she expected for that time of day. Since the call management
system was not installed, it was not possible to determine if there were
calls on hold and the length of time that the calls were on hold. But
since at least one of the calltakers was available during most of the
observation periods, it is likely that few, if any, callers were put on
hold.

While GHTD policy states that riders can make trip requests for ADA
Complementary Paratransit seven day a week, there is little attempt to
let riders know this. The public brochure for ADA Complementary
Paratransit service does not mention the separate weekend telephone
number at the Double A dispatch office. The after-hours message on the
Hartford office reservations telephone line does not refer callers to
Double A's telephone number. Some of the calltakers did not know that
riders can make ADA Complementary Paratransit trip requests on the
weekend. One calltaker told a caller that the reservation days were
Monday through Friday.

During the assessment team observations, about 60 percent of the calls
related to ADA Complementary Paratransit service; the remainder of the
calls, dial-a-ride services. One ADA Complementary Paratransit trip
request was turned down because it was not within the service region.
The calltaker referred to her street directory and also checked with the
supervisor to confirm this. Another ADA Complementary Paratransit trip
was turned down because it was requested 22 days ahead; the calltaker
told the rider to call back the following week. Neither of these
requests was entered into the computer.

During their observations, the team members did not see a calltaker try
to negotiate any trip request time by more than 30 minutes. If a rider
could not get a trip based on his/her dial-a-ride eligibility, the
calltaker did not suggest that the rider request an ADA Complementary
Paratransit trip (when the rider had dual eligibility) or suggest that
the rider apply for ADA Complementary Paratransit eligibility.

The assessment team observed several instances of calltakers not able to
confirm ADA Complementary Paratransit trips requests. The number of days
ahead varied: trip requests for 2, 5, 9, 12, and 14 days ahead all had
to be placed on standby (the 0-booking). For one request, the outgoing
trip but not the return trip could be confirmed. For another request,
neither leg of a Sunday round trip request could be confirmed. In every
case, the calltaker asked the rider to call back to confirm the trips.
One trip request for the next day was not entered into the computer when
the calltaker indicated to the rider that it was unlikely that he could
receive the trip.

As mentioned above, when a calltaker is not on the phone, she checks her
list of 0-bookings with the updated vehicle schedules to see if
reservations have been confirmed. The calltakers follow this procedure
for both ADA Complementary Paratransit and dial-a-ride trip requests.

**Findings**

1.  GHTD appears to answer all incoming calls without long hold times.

2.  GHTD's public brochure and after-hours telephone message do not
    inform riders that they can make trip requests seven days a week. It
    is likely that riders gain the impression that they can make trip
    requests on weekdays only.

3.  Some calltakers do now know that trip requests for ADA Complementary
    Paratransit service can be made seven days a week.

4.  GHTD's call management system is inactive, preventing continuous
    monitoring of reservations center telephone performance.

5.  Calltakers do not record all incoming trip requests, which leads to
    understating the number of capacity denials.

6.  Some dial-a-ride clients whose requests are denied are not advised
    that they may be eligible for these same trips under ADA
    Complementary Paratransit service.

7.  The "0-bookng" list is a waiting list and is prohibited by the DOT
    ADA regulations, 49 CFR §37.131(f)(2)).

**Recommendations**

1.  GHTD should ensure that calltakers tell callers that they can make
    ADA Complementary Paratransit trip requests seven days a week. GHTD
    should also revise its brochures to tell ADA Complementary
    Paratransit service clients that they can make trip reservations
    seven days a week. The brochure should include the telephone number
    for weekend calls.

2.  While the assessment team did not observe any delays in responding
    to incoming calls, GHTD should install the call management system so
    that supervisors can monitor performance in responding to telephone
    calls.

3.  Calltakers should record all trip requests, even those that are not
    eligible for service. GHTD can develop codes to indicate that some
    trip denials are for ineligible requests, and not due to capacity
    constraints.

4.  If riders with dual eligibility who request a dial-a-ride trip are
    turned down, calltakers should inform them that they may be eligible
    for the trip under the ADA program.

5.  GHTD should develop and implement a program to eliminate wait lists
    by increasing service capacity as expeditiously as possible.

# Observations Regarding Scheduling and Service

The assessment team reviewed scheduling and service of GHTD trips to
determine whether requested trips are being served in a timely fashion
and are not excessively long. Information reviewed and observations on
scheduling and service delivery included:

-   Consumer interviews, review of complaint filed with FTA, and review
    of complaints filed with GHTD.

-   Review of GHTD's service policies and procedures.

-   Interviews with the GHTD schedulers and review of scheduling
    procedures.

-   Observations of dispatch operations.

-   Interviews with 11 drivers.

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

-   Analysis of ADA Complementary Paratransit and fixed route trip
    duration.

**Consumer Comments**

Most consumer complaints and comments related to service delivery. Three
of the six riders interviewed by the assessment team cited some issue
with actual service. The concerns they mentioned included early pickups
or the driver not waiting long enough for the rider at the pickup
address. The one written complaint submitted to FTA pertained to the
vehicle not having a child seat. This is not a requirement under the DOT
ADA regulations. GHTD provides a child seat if the rider requests one in
advance.

Of the 14 written complaints sent to GHTD, 13 cited some issue related
to service delivery. Four riders complained about excessive ride times.
Three riders wrote that the GHTD missed their trip completely. Two
riders complained about pickups either too early or too late. Two other
riders wrote because they did not understand the pickup windows built
into the vehicle schedules. And two riders complained about rude
drivers.

**GHTD Service Policies and Procedures**

GHTD's policy for trip denials is that it "strives to deny as few trips
as possible." In response to FTA's pre-assessment written question
concerning its standard for trip denial, GHTD stated that it follows the
DOT ADA regulations and the guidance provided in FTA's *ADA Paratransit
Handbook*. In its RFP, GHTD states that "for the ADA Service, a trip is
denied when the Service cannot provide a requested trip within an hour
before and an hour after a requested trip time." GHTD does not have a
policy for "missed trips."

GHTD has a clear standard for on-time performance. It requires Double A
to deliver at least 92 percent of the trips within the 30-minute pickup
windows established in the scheduling.

GHTD has a fairly ambitious standard for trip lengths. The RFP states
that "no one rider shall spend more than the amount of time a person
without a disability would reasonably be expected to spend making the
same trip on a local fixed route bus during any one-way trip." For
example, a trip that would take 30 minutes on CTTransit buses --
including any transfers, waiting time, and the walk to and from the bus
stops -- should take no more than 30 minutes on ADA Complementary
Paratransit.

GHTD also has a standard for vehicle productivity. Double A "will
maintain at an average minimum of 2.1 passenger trips per service hour."
This service standard, along with the standards for on-time performance
and trip lengths, applies to the ADA Complementary Paratransit service
as well as the dial-a-ride programs.

[]{.mark}

There are two situations in which a rider is counted as a no-show. GHTD
considers any call to cancel a trip less than two hours from the
beginning of the pickup window as a no-show. Second, if a rider does not
appear within five minutes of the arrival of the vehicle, when the
vehicle arrives within the 30-minute pickup window, this is also
considered a no-show. If the no-show occurs on the first half of a round
trip, GHTD will cancel the return trip, unless the rider calls to
confirm the return trip.

##  Scheduling

**Overview**

Double A Charter is responsible for preparing the vehicle schedules. As
discussed in Section 6 of this report, GHTD provides the Trapeze
paratransit software for use by Double A staff. GHTD and Double A staff
at the Hartford office (including calltakers, schedulers, data entry
personnel, and supervisors) and Double A staff at the Rocky Hill office
(dispatchers and operations manager) have workstations with access to
Trapeze. The calltakers, schedulers, and operations manager collectively
develop the daily vehicle schedules. Riders from the ADA Complementary
Paratransit service and dial-a-ride programs are mingled on vehicle
schedules.

Passenger trips consist of demand-responsive trips and subscription
trips. Subscription trips are maintained in a subscription template in
the software. They are placed in the daily vehicle schedule by the
scheduler or operations manager prior to inserting the demand-responsive
trips. During the first 11 months of FY2001, subscription trips
comprised 53 percent of all ADA Complementary Paratransit trips. Many
subscription trips occur during the peak travel periods.

Calltakers start to accept trip requests 14 days ahead of the travel
date. They can enter either a requested appointment (dropoff) time or a
requested pickup time into the scheduling software. While on the phone
with the rider, they view partially built vehicle schedules on their
screen and insert the trip in one of the schedules; for a round trip,
they repeat this process for the return trip. A calltaker may negotiate
with the rider for alternate times within an hour of the originally
requested times. If a calltaker successfully schedules the trip, the
30-minute window is provided to the rider.

The trips that calltakers cannot schedule in real-time are placed into
the 0-booking file for the date of the trip request. According to the
lead scheduler, the peak travel times are weekdays, 8 to 10 a.m. and 3
to 6 p.m. The schedulers and operations manager generally start to
review the 0‑bookings several days ahead of the travel day. They insert
trips from the 0-booking into the day's vehicle schedule. They have the
flexibility of adjusting the pickup and dropoff times of other trips,
just as long as they stay within their 30-minute windows provided to the
riders. The operations manager also has the authority to add vehicle
runs on a specific day, thus creating more capacity to deliver trips.

The schedulers and operations manager review the vehicle schedules,
making adjustments to the computer-generated pickup or dropoff times. On
the driver manifests, each pickup and dropoff has a pickup/dropoff time
and a "rider expects" time (the "rider expects" time is the mid-point of
the 30-minute window). See Attachment H for sample pages of a completed
driver manifest. The operations manager said that the computer-generated
time is often not realistic. The drivers use them as a guide, but they
use their judgment and make use of the 30-minute windows.

GHTD denies trips every day because of lack of capacity, both for ADA
Complementary Paratransit and dial-a-ride clients. Some of these trip
denials are for trips requested during the peak travel periods. For 11
months of FY2001 (July 2000 to May 2001), GHTD denied 3,074 ADA
Complementary Paratransit service trip requests: 3.9 percent of all such
trip requests. In FY2000, GHTD denied 3,965 ADA Complementary
Paratransit service trip requests, or 4.7 percent. On the day before the
requested trip, calltakers call all riders (ADA Complementary
Paratransit and dial-a-ride) whose trips are denied. The operations
manager indicated that she would need additional vehicles in the fleet
(compared to the existing fleet of 56) to serve the current level of
trip requests.

**Observations**

The calltakers, schedulers, and operations manager were all generally
satisfied with the Trapeze software. They were aware of its limitations
and appeared to know how to use it for scheduling. The schedulers and
operations manager know when the computer-generated times are not
realistic, based on driver performance.

The operations manager said that the 0-bookings were necessary, given
the limitations of GHTD's current operations capacity. While she has the
authority to add extra vehicle runs, she still has to operate with the
existing fleet. She said that the use of a standby list allows Double A
to give some priority to ADA Complementary Paratransit trips over
dial-a-ride trips. Without the 0-booking, if trips were scheduled
strictly in order of the time of the trip request, earlier dial-a-ride
trip requests would preclude serving later ADA Complementary Paratransit
trip requests. On the afternoon that the assessment team interviewed the
lead scheduler, she said that there were still 120 trips on the
0-booking for the following day -- out of a weekday average of about 800
passenger trips.

However, even with the 0-booking lists, trips requested closer to the
travel day are much more likely to be denied. In Table VII.1, the
assessment team looked at a sample of 33 denials of ADA Complementary
Paratransit trip requests from March 2001. Forty-two percent of denials
were for trips requested one day ahead. Another 55 percent were for
trips requested two to seven days ahead.

Table VII.1 Distribution of ADA Complementary Paratransit Trip Denials

  ------------------------------------ ----------------------------------
  **Days Ahead Requested**             **% of Sample**

  1 day                                42.4

  2 to 7 days                          54.5

  8 to 14 days                         3.0
  ------------------------------------ ----------------------------------

The assessment team also looked at the number of days ahead that trips
were requested for a sample day, March 20 (Tuesday). Table VII.2 shows
the distribution of the 894 trip requests.

Table VII.2 Distribution of Trip Requests

  --------------- ---------------------------- --------------------------
  **Days Ahead    **% of Sample**              
  Requested**                                  

                  ***All Trips:                ***Demand-Responsive Trips
                  Demand-Responsive and        only***
                  Subscription***              

  0 or 1 day      10.0                         20.0

  2 to 7 days     17.5                         35.0

  8 to 14 days    72.5                         45.0
  --------------- ---------------------------- --------------------------

The two tables are not directly comparable because Table VII.2 includes
both dial-a-ride and ADA Complementary Paratransit trips; among
dial-a-ride trips, only medical trips can be requested 14 days ahead.
However, the general conclusion that one can draw is that trip requests
made close to the trip date are denied disproportionately -- especially
trip requests made one day ahead -- to trip requests made more than a
week ahead.

The Double A scheduler and operations manager believed that, within the
existing vehicle capacity, it would not be possible to decrease the
number of ADA Complementary Paratransit trips denials (60 to 75 per
week) by displacing currently provided dial-a-ride trips (about 1600 per
week). Double A and GHTD should conduct a further analysis of the ADA
Complementary Paratransit trip denials and the dial-a-ride trips
provided, both by time and by geography, to determine whether this is
accurate.

During the assessment team's interviews, all but two of the drivers
described the schedules as tight. Some indicated that schedules were
tight about half of the time; others indicated that they were tight
during the morning and evening rush hours. Two drivers complained of
multiple pickups at different locations being scheduled for the same
time. One driver indicated that he could keep to the schedule if he ran
early. Another indicated he uses the schedule flexibly. One driver
indicated that customers are not aware of the 30-minute pick-up window.

[]{.mark}

Drivers also indicated that they reviewed their manifests before they
began their runs and alerted the dispatcher of trips they felt they were
unable to make. The dispatcher would then reassign those trips.

As stated earlier, if a no-show occurs on the first half of a round
trip, GHTD has a policy of canceling the return trip, unless the rider
calls to confirm the return trip. Furthermore, in the discussion of
no-shows in GHTD's Scope of Services for the current contract with
Double A, GHTD "requires the Contractor to fill the cancellation and
no-show time slots with trip requests for same-day service whenever
possible."

**Findings**

1.  GHTD denied 4.7 percent of ADA Complementary Paratransit trip
    requests in FY2000 and 3.9 percent of ADA trip requests in FY2001
    (11 months).

2.  There appears to be a pattern of trip denials, with the probability
    of being denied a trip increasing the closer to the service day the
    trip request is made.

3.  While GHTD service mingles dial-a-ride and ADA Complementary
    Paratransit riders, the schedulers try to give priority to ADA
    riders. This is accomplished in part by creating the 0‑booking list,
    and trying to fit the ADA Complementary Paratransit trip requests
    from the 0‑booking onto vehicle schedules. The operations manager
    also has the authority to add vehicle runs.

4.  More than 50 percent of GHTD's ADA Complementary Paratransit trips
    are subscription trips. This includes trips during the peak travel
    periods, when GHTD denies trip requests.

5.  Based on assessment team observations and interviews with Double A
    drivers, the scheduling process appears to work well, but the
    resulting schedules are tight and often require "real time"
    adjustments.

6.  If a no-show occurs on the first half of a round trip, GHTD has a
    policy of canceling the return trip, unless the rider calls to
    confirm the return trip. A round trip represents two independent
    one-way trips, and the passenger has an independent right to each of
    these trips. To automatically cancel a return trip as a result of a
    no-show for the outgoing leg of the trip would undermine this right.

**Recommendations**

1.  GHTD should develop and implement a program to eliminate capacity
    trip denials and the use of a wait list (0-booking) by increasing
    service capacity.

2.  GHTD should give absolute priority to ADA Complementary Paratransit
    trips when creating its vehicle schedules. One potential procedure
    to help carry this out is to wait until one day before the travel
    day to confirm dial-a-ride trips. GHTD might consider wait-listing
    all dial‑a‑ride trips until one day before the service day and
    scheduling and confirming those trips after scheduling all ADA
    Complementary Paratransit trips.

3.  GHTD should continue to decline requests for subscription service
    until it eliminates capacity trip denials, or until the number of
    subscription trips falls below 50 percent of the total trips served.

4.  GHTD, within input from Double A, should try to adjust the
    scheduling parameters in Trapeze so that the computer-generated
    pickup times are more realistic.

5.  GHTD should develop procedures to ensure that trips recorded as a
    no-show on an outgoing trip are not automatically cancelled for the
    return trip.

## Dispatch and Operations

**Overview**

The GHTD fleet consists of 56 vehicles. The standard peak fleet is 46
vehicles; three vehicles per day are usually out for monthly
preventative maintenance, and seven vehicles are available as spares or
are out for other maintenance. As of May 2001, Double A had a staff of
61 drivers; 42 have regular schedules and 19 serve as backups. Usually,
three to six of the backup drivers work every weekday, filling in for
absent drivers or available for extra runs and afternoon will-call
trips.

The drivers check in at the Double A office in Rocky Hill. They receive
their vehicle assignments and trip manifests from the dispatcher on
duty. They review their schedules and return trips to the dispatcher for
reassignment, if necessary. They conduct pre-trip vehicle inspections
and return the completed inspections forms to the dispatcher. While on
their runs, the drivers fill in the information on the manifests for
each pickup or dropoff: actual time of pickup/dropoff, fare paid, and
notations for a no-show or cancellation. Drivers also write in the
information for trips added to their run (see Attachment H).

Drivers are expected to radio the dispatcher if a rider does not appear
within five minutes, as long as the driver arrives within the pickup
window. Drivers also radio the dispatcher to say they are behind
schedule, to get directions, or to report unexpected problems. A driver
has the flexibility to change the order of the stops, as listed on the
manifest, if the pickup/dropoff times all stay within their respective
30-minute windows.

**Observations**

**Drivers.** The assessment team interviewed 11 Double A drivers. They
asked about procedures the drivers use during operations. When drivers
arrive early (more than 15 minutes before the "rider expects" time) for
a pickup, most indicated that they wait until the beginning of the
pickup window before hailing the customer. Some indicated that they
would contact the rider, particularly if they know the customer does not
mind leaving early.

When the rider does not respond, most drivers (5 of 7) indicated that
they would contact the dispatcher and wait to be released by the
dispatcher before recording the rider as a "no-show." Two drivers
indicated that they would wait five minutes after the scheduled pick-up
time, record the rider as a no-show and leave. They said they would
sometimes call the dispatcher. One driver indicated that he leaves a
sticker message on the rider's door that to say he had been there to
pick up the rider.

Drivers generally described training as adequate to good. All indicated
that they had received both driver and sensitivity training. All
indicated that supplementary training occurs frequently.

Almost all drivers cited periodic problems with vehicles. Most problems,
such as poor suspension or inoperable air conditioning would not prevent
the vehicle from being used. Drivers noted that there were some
in-service breakdowns. Two drivers said that in-service repairs were
performed quickly, while one indicated that they took as much as four
hours. Four drivers cited problems with radios and two noted problems
with lifts. Drivers indicated that they sometimes have to operate lifts
manually when the automated operation fails.

**Dispatch.** The assessment team interviewed the lead dispatcher for
Double A and observed his activities on the morning of June 26, from
6:30 to 9:30 a.m. He assigned vehicles to drivers and handed them their
manifests. If drivers called in sick or were late, he assigned their
runs to standby drivers.

Once the vehicles get on the road, his main tasks include:

-   Reassigning trips if drivers fall behind on their schedules.

-   Assigning will call-trips to drivers.

-   Receiving calls on late cancellations and relaying the information
    to drivers.

-   Responding to calls from riders asking about the whereabouts of
    vehicles.

-   Handling vehicle service calls.

**Findings**

1.  Double A has a fleet of 56 vehicles of which 46 are normally
    available for daily service. Ten vehicles or 18 percent of the
    available vehicles are normally assigned to maintenance.

2.  The staff of 42 regular and 61 total drivers appears to be
    sufficient to meet service needs.

3.  As a whole, the drivers are experienced, well trained, and seem
    dedicated to their jobs.

4.  Drivers generally believe that they have tight schedules. They have
    the flexibility, within the 30-minute pickup windows, to adjust
    their schedule and even change the order of stops.

**Recommendations**

1.  GHTD should increase its vehicle fleet to increase its capacity to
    serve the trips it currently denies.

2.  GHTD should standardize the procedures for drivers for handling
    riders who are potential no-shows, e.g., those who do not appear
    within five minutes of the arrival of the vehicle.

### Analysis of On-Time Performance

In analyzing on-time performance, the assessment team reviewed GHTD's
policies and procedures, as well as its reporting of on-time
performance.

**Policies and Procedures**

GHTD's brochure, *Community Transportation Consortium: What Every Rider
Should Know* (Attachment F), indicates that customers will be given "a
1/2-hour period during which your ride will arrive. You will not be
given a specific time. You must be ready at any time during this
1/2-hour period." GHTD's RFP defines on-time service as pickup of a
rider within 15 minutes before or after the scheduled pickup time.
GHTD's on-time performance standard is 92 percent; that is, 92 percent
or more of all pickups should be made within 15 minutes of the scheduled
pickup time. This standard is built into GHTD's contract with Double A
Charter. In addition, the contract requires the reporting of on-time
performance on or before the 10th calendar day of each month.

Drivers record the actual pickup and dropoff times on their manifests.
The manifest also lists the "customer expects" time for pickup and the
scheduled pickup time. Double A enters the driver data into electronic
format, tabulates the data, and produces two "On Time Performance
Reports." Samples of these reports appear in Attachment I. One report
presents performance for each route on each day, and the other report
presents daily summaries for all routes. The summary report includes the
number of early, on-time, and late pickups for scheduled trips. The
detailed report also includes early and late pickups for will call (or
unscheduled) trips and late dropoffs for scheduled appointments.

**Performance Analysis**

The assessment team reviewed the monthly totals from the two different
report formats for the period November 2000 through March 2001. These
statistics cover both ADA Complementary Paratransit and dial-a-ride
services. As can be seen in Table VII.3, the totals in the two reports
do not match. However, the variations in totals do not appear
significant in assessing on-time performance. As can be seen, pickups
were late for 12 to 13 percent of the passenger trips during this
seven-month period. Or conversely, 87 to 88 percent of pickups were
either on time or early.

Table VII.3 -- Comparison of Route and Daily On-time Performance Reports

  ---------------------------------------------------------------------------------
              **Route                            **Daily                    
              Report**                           Report**                   
  ----------- --------------- ---------- ------- --------------- ---------- -------
  **Month**   **Passenger                **%**   **Passenger                **%**
              Trips**                            Trips**                    

              **Scheduled**   **Late**           **Scheduled**   **Late**   

  Nov. 2000   14,361          1,871      13.0    15,224          1,991      13.1

  Dec.        13,167          1,598      12.1    13,924          1,819      13.1

  Jan. 2001   15,024          1,785      11.9    15,806          2,213      14.0

  Feb.        13,211          1,756      13.3    13,974          1,916      13.7

  Mar.        14,772          1,809      12.3    15,514          1,909      12.3

  Apr.        15,060          1,847      12.3    15,879          2,001      12.6

  May         15,664          1,809      11.6    16,388          1,930      11.8

                                                                            

  **Total**   101,259         12,475     12.3    106,709         13,779     12.9
  ---------------------------------------------------------------------------------

In addition to pickups, the assessment team reviewed on-time performance
for dropoffs as reported by Double A for the period from November 2000
through May 2001. The results are summarized in Table VII.4.

Table VII.4 On-Time Performance for Pickups and Dropoffs

  -------------------------------------------------------------------------------------------------------------------
                             **2000**              **2001**                                              **Totals**
  -------------- ----------- ---------- ---------- ---------- ---------- ---------- ---------- --------- ------------
                             **Nov.**   **Dec.**   **Jan.**   **Feb.**   **Mar.**   **Apr.**   **May**   

  **Pickups**                                                                                            

                 **Total**   14,361     13,167     15,024     13,211     14,722     15,060     15,664    101,209

                 **Late**    1,871      1,598      1,785      1,756      1,809      1,847      1,809     12,475

                 **% Late**  13.0 %     12.1 %     11.9 %     13.3 %     12.3 %     12.3 %     11.6 %    12.3 %

  **Dropoffs**                                                                                           

                 **Total**   1,671      1,621      2,016      1,851      2,403      2,677      2,708     14,947

                 **Late**    380        300        299        323        387        454        417       2,560

                 **% Late**  22.7 %     18.5 %     14.8 %     17.5 %     16.1 %     17.0 %     15.4 %    17.1 %

  **Totals**                                                                                             

                 **Total**   16,032     14,788     17,040     15,062     17,125     17,737     18,372    116,156

                 **Late**    2,251      1,898      2,084      2,079      2,196      2,301      2,226     15,035

                 **% Late**  14.0 %     12.8 %     12.2 %     13.8 %     12.8 %     13.0 %     12.1 %    12.9 %
  -------------------------------------------------------------------------------------------------------------------

On-time performance for dropoffs (17.1 percent late) is not as good as
with pickups (12.3 percent late). Including dropoffs in the on-time
performance measurement results in slightly poorer overall performance.
Unlike pickups, for which a trip is considered on-time if the passenger
is picked-up within 15 minutes of the "rider expects" or scheduled time,
Double A counts a dropoff as late if it is later than the scheduled
time, even if by a minute. This standard reflects the importance to the
customer of meeting appointments on time.

To verify the accuracy of Double A's on-time performance report, the
assessment team reviewed 149 passenger trips for March 20, 2001. The
results appear in Table VII.5.

Table VII.5 -- Sample of Pickup Times from Driver Manifests

+----------------+---------------+--------------------+---------------+
|                | **Minutes**   | **Number within    | **% of        |
|                |               | Sample**           | Sample**      |
+================+===============+====================+===============+
| **LATE**       | 0:15          | 8                  | 5.4           |
|                |               |                    |               |
| **\>**         |               |                    |               |
+----------------+---------------+--------------------+---------------+
|                | 0:30          | 11                 | 7.4           |
+----------------+---------------+--------------------+---------------+
|                | 1:00          | 2                  | 1.3           |
+----------------+---------------+--------------------+---------------+
| **EARLY**      | 0:15          | 24                 | 16.1          |
|                |               |                    |               |
| **\>**         |               |                    |               |
+----------------+---------------+--------------------+---------------+
|                | 0:30          | 4                  | 2.7           |
+----------------+---------------+--------------------+---------------+
| **On-Time      |               | 100                | 67.1          |
| (within        |               |                    |               |
| 0:15)**        |               |                    |               |
+----------------+---------------+--------------------+---------------+
| **On-Time or   |               | 128                | 85.9          |
| Early**        |               |                    |               |
+----------------+---------------+--------------------+---------------+
| **Total        |               | 149                | 100.0         |
| Sample**       |               |                    |               |
+----------------+---------------+--------------------+---------------+

For comparable performance measures, the results from Double A's On-time
performance report for March 20 are: 78.1 percent on-time and 91.5
percent on-time or early. The variation in the results may be caused by
passenger trips that are transferred from one route to another during
the service day. It appears that Double A's reports generally reflect
actual on-time performance.

**Findings**

1.  GHTD does not have a policy or definition for "missed trip."

2.  Double A's reports appear to reflect actual on-time performance.

3.  Approximately 87 percent of passenger pickups were on time during
    the period from November 2000 through May 2001.

4.  Approximately 83 percent of dropoffs were on time for the same
    period.

5.  Double A's two different "On Time Performance Reports" appear to be
    inconsistent with each other.

**Recommendations**

1.  GHTD should develop a policy for "missed trips." This policy should
    include a definition of a missed trip, a standard for the allowable
    percent of missed trips, and what actions that GHTD and the
    contractor should take in response to an individual missed trip and
    to patterns of missed trips.

2.  Double A should review its method for preparing "On Time Performance
    Reports" to assure consistent and accurate reporting of performance.

[]{.mark}

### Analysis of Trip Length

As described previously, GHTD's policy for ADA Complementary Paratransit
trips is that "no one rider shall spend more than the amount of time a
person without a disability would reasonably be expected to spend making
the same trip on a local fixed route bus."

The Trapeze software system has been programmed to schedule trips that
are no more than 90 minutes long. The maximum ride time parameter is set
at 90 minutes and trips with longer ride times will be highlighted by
the system as being too long.

In addition to the review of policies and consumer comments, the
assessment team analyzed GHTD's travel time performance in the following
ways:

-   Reviewed "Ride Length Reports" for March, April, and May 2001.

-   Analyzed completed driver manifests for March 21, 2001, to determine
    the travel times of trips on that sample day.

-   Compared the on-board times of a sample of 22 ADA Complementary
    Paratransit trips made from March 21 to 23, 2001, with the estimated
    travel time for fixed route trips from the same origin to the same
    destination traveling at the same time of day.

**GHTD Travel Time Records**

The Trapeze software system that GHTD uses can generate "Ride Length
Reports" that provide detailed information about all trips with long
ride times. GHTD does not typically print these reports or track the
number and percentage of trips with long ride times. GHTD staff prepared
reports for the prior six months and made them available for review as
part of the assessment.

The reports showed all trips with travel times of 95 minutes or more.
This time period was selected to show all trips exceeding the 90-minute
maximum ride time parameter used in scheduling, plus provide an
allowance for a five-minute wait time at the pickup.

A review of the reports showed numerous trips in the system with
recorded travel times of more than 95 minutes. For example, the March
2001 report suggested that 379 trips took 95 minutes or more (about five
percent of all trips). It also showed travel times of over two to three
hours for a significant number of trips.

When the assessment team investigated these report times and compared
them to recorded times on the completed driver manifests, they
discovered that many of the times entered in the system were incorrect.
Erroneous times were found when trips were recorded as no-shows or when
trips were rescheduled by the rider.

**Analysis of Ride Times for March 21, 2001**

In place of using the "Ride Length Reports," the assessment team
analyzed completed driver manifests for the randomly selected day of
March 21, 2001, to get an idea of typical travel times. They compared
the actual pickup and dropoff times and calculated the total time
on-board for all trips that were completed. Travel times for a total of
316 trips were calculated. Table VII.6 below shows the results of this
analysis. As shown, 60 percent of all trips were less than 30 minutes,
and 87 percent of all trips had travel times of 60 minutes or less.
Twelve percent of all trips examined had ride times of 61 to 90 minutes.
Only three trips (one percent) had ride times of more than 90 minutes
(95, 95, and 110 minutes).

Table VII.6 Distribution of Ride Times for ADA Complementary Paratransit
Trips on March 21, 2001

  -------------------------------------------------------------------------
  **Ride Times**    **Number of        **% of Trips**     **Cumulative %**
                    Trips**                               
  ----------------- ------------------ ------------------ -----------------
  1-30 minutes      190                60                 60

  31-60 minutes     85                 27                 87

  61-90 minutes     38                 12                 99

  91+ minutes       3                  1                  100

  **TOTAL**         316                100                
  -------------------------------------------------------------------------

The assessment team noted that ADA Complementary Paratransit trips tend
to be inter-town trips. The community dial-a-ride programs provide many
of the shorter in-town rides. The ADA Complementary Paratransit service
is used for longer rides. A review of origin and destination information
for the month of March 2001 showed that 81 percent of all ADA
Complementary Paratransit trips were "out-of-town" trips.

Comparison of ADA Complementary Paratransit and Fixed Route Travel Times

A sample of 22 trips with long scheduled ride times was selected to
compare ADA Complementary Paratransit and fixed route travel times.
Trips were selected from the "Ride Length Report" for March 2001. Actual
travel times were then verified by reviewing completed manifests for
March. Table VII.7 shows the date and run number for each trip, the
origin and destination, the time of day the trip was made, the actual
travel times on the paratransit system, and the estimated travel time by
fixed route. The number of transfers that would be required if the trip
were made by fixed route is also shown. Where transfers would be
required, the wait time for the second vehicle is included in the total
travel time. The table also includes footnotes where long walking
distances to or from bus stops were identified.

The differences between ADA Complementary Paratransit travel times and
the fixed route travel times are then shown (second column from right).
Fixed route travel times were estimated by working with CTTransit fixed
route customer information staff to generate travel itineraries for each
trip.

**Table VII.7 - Comparison of Travel Times on ADA Complementary
Paratransit Versus Fixed Route for 22 Selected Trips**

+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **A  | * | **Origin**   | **De        | *    | *   | **  | *   |
| * | DA** | * |              | stination** | *ADA | *Fi | Tra | *\# |
| T |      | G |              |             | Co   | xed | vel | of  |
| r | **Co | H |              |             | mpl. | Ro  | T   | Fi  |
| i | mpl. | T |              |             | Par  | ute | ime | xed |
| p | Par  | D |              |             | atra | Tra | Dif | Ro  |
| D | atra | R |              |             | nsit | vel | fer | ute |
| a | nsit | u |              |             | Tr   | T   | enc | Tr  |
| t | Trip | n |              |             | avel | ime | e** | ans |
| e | Tim  | \ |              |             | Time | (m  |     | fer |
| * | es** | # |              |             | (mi  | inu | **  | s** |
| * |      | * |              |             | nute | tes | (PT |     |
|   |      | * |              |             | s)** | )** | -FR |     |
|   |      |   |              |             |      |     | )** |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 7    | 4 | 349 Bidwell  | 130 South   | 39   | 60  | -21 | 1   |
| / | :12- | 2 | St., Man.    | St., WH     |      |     |     |     |
| 2 | 7:51 | 2 |              |             |      |     |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 6    | 7 | 900 Cottage  | 21 Potter   | 75   | 89  | -14 | 1   |
| / | :00- | 5 | Grove Rd.,   | Crossing,   |      |     |     |     |
| 2 | 7:15 | 0 | Blmd         | Weth.       |      |     |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 8    | 9 | 10 Catherine | 900 Asylum  | 75   | 54  | +21 | 1   |
| / | :00- | 0 | Dr., RH      | Ave., Hart. |      | *(  |     |     |
| 2 | 9:15 | 6 |              |             |      | 1)* |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 1    | 9 | 9 Waddell    | 85          | 65   | 43  | +22 | 1   |
| / | 0:40 | 0 | Rd., Man.    | Jefferson   |      |     |     |     |
| 2 | -11: | 6 |              | St., Hart.  |      |     |     |     |
| 1 | 45am |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 8    | 7 | 63 Harvest   | 225 Asylum  | 54   | 33  | +21 | 0   |
| / | :00- | 0 | Ln., Wind.   | St., Hart.  |      | *(  |     |     |
| 2 | 8:54 | 4 |              |             |      | 2)* |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 2    | 9 | 1 Farm Glen  | 9 Heather   | 115  | 80  | +25 | 1   |
| / | :35- | 1 | Blvd., Fgt.  | Rd., EH     |      | *(  |     |     |
| 9 | 4:30 | 5 |              |             |      | 3)* |     |     |
|   | pm   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 7    | 9 | 70 Shepard   | 900 Asylum  | 95   | 100 | -5  | 1   |
| / | :50- | 0 | Rd., WH      | St., Hart.  |      |     |     |     |
| 2 | 9:25 | 7 |              |             |      |     |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 7    | 4 | 32 Thompson  | 20 Sargeant | 74   | 55  | +19 | 1   |
| / | :02- | 1 | Rd., Man.    | St., Hart.  |      |     |     |     |
| 2 | 8:16 | 7 |              |             |      |     |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **3  | * | **20         | **279 Elm   | **1  | *   | *   | **  |
| * | :30- | * | Sargeant     | St., WL**   | 05** | *60 | *+4 | 1** |
| 3 | 5:15 | 7 | St., Hart.** |             |      | *   | 5** |     |
| / | pm** | 5 |              |             |      | (4) |     |     |
| 2 |      | 0 |              |             |      | *** |     |     |
| 2 |      | * |              |             |      |     |     |     |
| * |      | * |              |             |      |     |     |     |
| * |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 5    | 7 | 1101 Kennedy | 88 Brittany | 48   | 80  | -32 | 1   |
| / | :45- | 5 | Rd., Wind.   | Farms Rd.,  |      |     |     |     |
| 2 | 6:33 | 0 |              | NB          |      |     |     |     |
| 8 | pm   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 9:55 | 9 | 178 Lyndall  | 1 Abrahms   | 95   | 90  | +5  | 1   |
| / | -11: | 0 | St., Man.    | Blvd., WH   |      |     |     |     |
| 2 | 30am | 9 |              |             |      |     |     |     |
| 2 |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 2    | 3 | 85 Seymour   | 3 Revere    | 95   | 71  | +24 | 1   |
| / | :00- | 0 | St., Hart.   | Dr., Blfd   |      |     |     |     |
| 2 | 3:35 | 7 |              |             |      |     |     |     |
| 2 | pm   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 6    | 4 | 96 School    | 130 South   | 90   | 75  | +15 | 1   |
| / | :45- | 2 | St., Man.    | St., WH     |      |     |     |     |
| 2 | 8:15 | 2 |              |             |      |     |     |     |
| 2 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 7    | 7 | 282 Trout    | 3580 Main   | 78   | 54  | +24 | 1   |
| / | :32- | 0 | Brook Rd.,   | St., Hart.  |      |     |     |     |
| 2 | 8:50 | 1 | WH           |             |      |     |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 6    | 7 | 101 Belle    | 376 West    | 65   | 75  | -10 | 1   |
| / | :50- | 0 | Woods Dr.,   | Middle      |      | *(  |     |     |
| 2 | 7:55 | 2 | Gls.         | Tpke., Man. |      | 5)* |     |     |
| 2 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **7  | * | **130        | **3580 Main | **   | *   | *   | **  |
| * | :25- | * | Hillcrest    | St.,        | 95** | *57 | *+3 | 1** |
| 3 | 9:00 | 7 | Ave., WH**   | Hart.**     |      | *   | 8** |     |
| / | am** | 0 |              |             |      | (6) |     |     |
| 2 |      | 1 |              |             |      | *** |     |     |
| 0 |      | * |              |             |      |     |     |     |
| * |      | * |              |             |      |     |     |     |
| * |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **7  | * | **10 Morgan  | **350       | **1  | *   | *   | **  |
| * | :55- | * | Pl., Fgt.**  | Church St., | 19** | *60 | *+5 | 1** |
| 3 | 9:54 | 7 |              | Hart.**     |      | *   | 9** |     |
| / | am** | 0 |              |             |      | (7) |     |     |
| 2 |      | 3 |              |             |      | *** |     |     |
| 0 |      | * |              |             |      |     |     |     |
| * |      | * |              |             |      |     |     |     |
| * |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **7  | * | **963 Elms   | **3580 Main | **1  | *   | *   | **  |
| * | :15- | * | Common Dr.,  | St.,        | 05** | *54 | *+5 | 1** |
| 3 | 9:00 | 9 | RH**         | Hart.**     |      | *   | 1** |     |
| / | am** | 0 |              |             |      | (8) |     |     |
| 2 |      | 1 |              |             |      | *** |     |     |
| 0 |      | * |              |             |      |     |     |     |
| * |      | * |              |             |      |     |     |     |
| * |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **1  | * | **263        | **25        | **1  | **7 | *   | **  |
| * | 0:40 | * | Farmington   | Hillcrest   | 10** | 7** | *+3 | 1** |
| 3 | am-1 | 9 | Ave., Fgt.** | Ave.,       |      |     | 3** |     |
| / | 2:30 | 4 |              | Blmd.**     |      |     |     |     |
| 2 | pm** | 0 |              |             |      |     |     |     |
| 0 |      | * |              |             |      |     |     |     |
| * |      | * |              |             |      |     |     |     |
| * |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 7    | 9 | 130 South    | 992 Ridge   | 60   | 57  | +3  | 1   |
| / | :40- | 0 | St., WH      | Rd., Weth.  |      |     |     |     |
| 2 | 8:40 | 5 |              |             |      |     |     |     |
| 1 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| 3 | 7    | 3 | 1206 W       | 184 Windsor | 62   | 57  | +5  | 1   |
| / | :15- | 0 | Middlesex    | Ave., Wind. |      |     |     |     |
| 2 | 8:17 | 3 | Tpke., Man   |             |      |     |     |     |
| 2 | am   |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+
| * | **4  | * | **85         | **1 Abrahms | **   | **2 | *   | **  |
| * | :20- | * | Jefferson,   | Blvd., WH** | 60** | 9** | *+3 | 1** |
| 3 | 5:20 | 9 | Hart.**      |             |      |     | 1** |     |
| / | pm** | 1 |              |             |      |     |     |     |
| 2 |      | 5 |              |             |      |     |     |     |
| 2 |      | * |              |             |      |     |     |     |
| * |      | * |              |             |      |     |     |     |
| * |      |   |              |             |      |     |     |     |
+---+------+---+--------------+-------------+------+-----+-----+-----+

*(1) ¾ mile walk to bus stop from origin. (2) ¾ mile walk to bus from
origin; ¼ mile walk at destination.*

*(3) ¾ mile walk from bus to destination. (4) 1 ¼ mile walk from bus to
destination.*

*(5) 1 mile walk to bus stop from origin. (6) ½ mile walk to bus stop
from origin.*

*(7) ¾ mile walk to bus stop from origin. (8) ½ mile walk to bus stop
from origin.*

TOWNS

  -------- ------------------- -------- ------------------- ---------- --------------
  Blmd.:   Bloomfield          Hart.:   Hartford            Weth:      Wethersfield

  EH:      East Hartford       Man:     Manchester          WH:        West Hartford

  Fgt.:    Farmington          NB:      New Britain         Wind:      Windsor

  Gls.:    Glastonbury         RH:      Rocky Hill          WL:        Windsor Locks
  -------- ------------------- -------- ------------------- ---------- --------------

Given that riders using the fixed route service would need to walk to
and from bus stops, an allowance ranging from 20 to 25 minutes was used
in all cases. Where significant walking distances were noted, additional
time was allowed. Taking walking time into consideration, Table VII.7
shows that the travel time on ADA Complementary Paratransit would be
comparable to fixed route travel time (within 25 minutes) for 11 of the
22 trips, would be less than fixed route for five trips, and would be
significantly longer for six trips. The trips with significantly longer
ADA Complementary Paratransit travel times are highlighted in bold text.

**Findings**

1.  Overall, very short travel times were noted. The great majority of
    ADA Complementary Paratransit trips (87 percent) took less than 60
    minutes. Only one percent of ADA Complementary Paratransit trips
    were longer than 90 minutes. These systemwide statistics are
    particularly good, given that the ADA Complementary Paratransit
    service tends to be used by riders for the longer trips in the
    system, with about 81 percent of all ADA Complementary Paratransit
    rides being "out-of-town" trips.

2.  There are a small number of ADA Complementary Paratransit rides that
    are significantly longer than similar rides on the fixed route
    system. These rides tend to be for the same people who are the first
    to board and the last to alight on group runs. A review of manifests
    for the month of March 2001 showed long group trips on Runs 307,
    417, 420, 701, 703, 750, 902, and 906.

**Recommendations**

1.  GHTD should review group runs that show long on-board travel times.
    The travel times for persons who are picked up first and dropped off
    last should be compared with fixed route travel times for similar
    trips. When this analysis shows that the ADA Complementary
    Paratransit ride time is significantly longer than the fixed route
    ride time, the run should be split to reduce the longest travel
    times.

2.  GHTD should review the procedure used to do the final edit of trip
    times and dispositions so that final records of trips show accurate
    travel times. In particular, GHTD should review the handling of
    no-shows, rescheduled trips, and other incidents. This will allow
    GHTD staff to run meaningful "Trip Length Reports" and use the
    reports to monitor long trips.

# Resources

**Policies and Procedures**

Operating costs for ADA Complementary Paratransit services provided by
GHTD are financed with state funds through ConnDOT. ConnDOT's budget is
appropriated by the state legislature on a biennial basis using a July 1
through June 30 Fiscal Year (FY). The fiscal years 2000 and 2001
comprise the two-year budget cycle in effect during the compliance
assessment. In developing its statewide budget, ConnDOT requests input
six to nine months before the end of the fiscal year from GHTD and other
contract service providers. ConnDOT staff indicated that ConnDOT has
sufficient flexibility to supplement GHTD's budget as necessary to
comply with ADA requirements.

ConnDOT and GHTD are parties to a long-standing contract for GHTD to
provide ADA Complementary Paratransit service in CTTransit's Hartford
service area. Addenda to the contract are executed annually to extend
the contract duration and provide funding for service for the upcoming
year. In April or May of each year, GHTD provides ConnDOT with an
estimate of its operating expenses for the ensuing fiscal year. ConnDOT
and GHTD then execute the annual addendum to the contract.

Capital funding for equipment procurement is provided through grants
from FTA, with matches by local funds. Local funds are drawn from GHTD's
enterprise fund. This fund receives revenue from parking fees,
concessions, and other sources. GHTD indicated that the resources
available from this fund are sufficient to match federal grants

GHTD entered into a five-year contract with Double A Charter that
commenced on July 1, 2000 to provide ADA Complementary Paratransit
Service. Through this contract Double A also provides dial-a-ride
service to Hartford, East Hartford, and Wethersfield. Contract payment
is based upon hours of revenue service provided by Double A, plus
reimbursement for major equipment repairs. The RFP for the current
contract requires an average monthly minimum of 2.1 passenger trips per
vehicle service hour. The payment rates for the first three years of the
contract were established prior to contract execution. The rates for the
last two years will be subject to renegotiation.

**Observations**

The assessment team reviewed budget and expenditures for ADA
Complementary Paratransit service for the period July 1, 1999 through
May 31, 2001 (one year plus 11 months) in relation to "expressed demand"
for ADA Complementary Paratransit service. Expressed demand equals the
total number of trips requested: the sum of trips served and trips
denied. Results of this analysis appear in Table VIII.1.

**Table VIII.1 GHTD Budget and Ridership Summary for ADA Complementary**

> Paratransit Service, FY1999-FY2002

  ----------------------------------------------------------------------------------------------
                     **1999**      **2000**      **2001^(a)^**   **2001^(b)^**   **2002^(c)^**
  ------------------ ------------- ------------- --------------- --------------- ---------------
  **Trips Served**   75,103        83,605        83,018          90,565          86,905

  **Trips Denied**   281           3,965         3,074           3,353           0

  **Trips            75,384        87,570        86,092          93,918          86,905
  Requested**                                                                    

  **Increase in      19.2%         16.2%                         7.2%            -7.5%
  Trips Requested                                                                
  from Previous                                                                  
  Year**                                                                         

  **Vehicle Hours**  59,775        62,141        56,310          61,429          62,075

  **Trips per        1.25          1.35          1.47            1.47            1.40
  Vehicle Hour**                                                                 

  **Cost per Vehicle \$25.62       \$26.05       \$27.35         \$27.35         \$28.71
  Hour**                                                                         

  **Cost per trip    \$23.67       \$22.59       \$19.62         \$19.62         \$22.92
  served**                                                                       

  **Original         \$1,777,811   \$1,716,635                   \$1,888,635     \$1,992,264
  Budget**                                                                       

  **Final Budget**                 \$1,888,635                                   

  **Expenditures**   \$1,777,811   \$1,760,851   \$1,629,059     \$1,777,155     
  ----------------------------------------------------------------------------------------------

\(a\) 11 months, July 2000 -- June 2001

\(b\) First 11 months extrapolated to year

\(c\) GHTD Budget projection for FY2002

For comparison purposes, data for the first eleven months of FY2001 was
extrapolated to a 12-month period. Additionally, the table includes
GHTD's expenditure estimates for FY2002.

Growth in expressed demand probably results from diversions from other
services, as well as from increased market awareness of the availability
of GHTD's ADA Complementary Paratransit. As GHTD's ADA service expands,
other service providers may discontinue their service, "shedding" trips
and diverting passengers to GHTD. Also, people with disabilities may see
service in their area or hear about the service by word of mouth and
become new customers. In addition to growth from demand and public
awareness, there is potential for growth in demand associated with
expanded capacity. That is, some potential customers may have previously
stopped trying to use the service because of capacity constraints. With
expanded capacity, these customers may add to the total demand for the
service.

As can be seen in Table VIII.1, market demand grew precipitously in 1999
and 2000 and has continued to grow in 2001. During this three-year
period, expressed demand has grown by approximately 25 percent.
Continued growth at the seven percent level experienced in 2001 would
result in demand of approximately 100,500 passenger trips in 2002, 15
percent greater than projected by GHTD.

During this same period, vehicle hours increased by about three percent
and expenditures were unchanged. Overall, trip denials have risen almost
twelve-fold during this period. Trip denials have remained fairly
constant since 2000. As an explanation for the discrepancy between
growth in demand and level operations, the assessment team looked at
productivity in the form of passenger trips per vehicle hour. Table
VIII.1 shows that, from 1995 to 2001, productivity has increased from
1.25 trips/hour to 1.47 trips/hour, or by 18 percent. The increased
productivity appears to correspond to the increase in trip denials. In
this instance, it appears that productivity increases are the result of
constraining the amount of peak period service. To serve travel demand
without denying trip requests may lead to productivity levels similar to
those that existed in 1999. In 1999, there were 281 capacity denials.
Serving 100,500 trips with a productivity rate of 1.25 would require
80,400 hours of service -- rather than the 62,075 hours projected by
GHTD with a 1.40 trip/hour productivity rate. At \$28.71 per vehicle
hour the resultant operating budget would be \$2,308,000 --
approximately 16 percent above the \$1,992,264 currently budgeted for
FY2002.

From 1999 through 2001, state appropriations for statewide ADA
Complementary Paratransit service remained constant at \$7,420,669.
State appropriations increased by 5.5 percent to \$7,828,806 for FY2002.
ConnDOT and GHTD officials indicated that they would provide funding in
excess of the current budget as needed to operate service levels that
comply with ADA requirements.

**Personnel**

As of May 2001, Double A had a roster of 61 drivers. Of this number, 42
were regularly scheduled drivers and 19 were stand-by drivers. In
addition to the regularly scheduled drivers, three to six of the
stand-bys are assigned to work each day to cover for absent drivers and
to drive on unassigned runs. According to the Double A Manager, 25 to 67
percent of trainees fail to last through training. Of those who become
drivers, the turnover rate is about four to ten drivers per year, or 7
to 17 percent. Driver's hourly pay rate starts at \$10 per hour, with a
top rate of \$12.50 per hour. Double A offers a 401(K) program, medical
insurance, and holiday and vacation pay.

**Equipment**

GHTD has a fleet of 56 passenger vehicles that is operated and
maintained by Double A. These vehicles are listed in Table VIII.2.

The vehicle life is approximately four to five years and 100,000 miles.
GHTD acquires replacement vehicles in most years. GHTD did not acquire
any new vehicles during FY2001.

According to the Double A operations manager, the amount of service
scheduled is limited by the size of the available fleet. There are
sufficient drivers and funds to provide additional service. Double A,
GHTD, and ConnDOT all indicated that funds could be made available for
additional service.

Table VIII.2 -- Fleet Roster

  -----------------------------------------------------------------------------------
  **Year**      **Make**     **Model**   **Seats**   **Wheelchairs**   **Quantity**
  ------------- ------------ ----------- ----------- ----------------- --------------
  1993          Ford         E350        8           2                 2

  1996          Ford         Econoline   12          1                 2

  1997          Ford         E350        10          2                 17

  1997          Ford         E450        12          2                 1

  1998          Ford         E350        12          2                 14

  1999          Ford         E350        10          2                 10

  1999          Ford         E350        14          2                 3

  1999          Ford         E350        16          2                 2

  2000          Ford         E350        14          2                 5

  **Total**                                                            **56**
  -----------------------------------------------------------------------------------

Based upon productivity levels in recent years, each vehicle available
for service has been able to serve from 1,630 to 1,970 annual passenger
trips (the low end of this range corresponds to 1.25 trips per hour, and
the high end to 1.47 passenger trips per hour). Applying this same ratio
to annual passenger demand of 100,500 would require 51 to 62 vehicles be
available for daily service. Two or three additional vehicles might be
made available for service from the existing fleet by accelerating
maintenance and reducing the number of vehicles out of service for major
repairs. A spares ratio of 16 percent would increase the number of
vehicles available for daily service from 46 to 49. If the spares ratio
could be reduced to about 15 percent, a vehicle fleet of 59 to 71
vehicles would be required to have 51 to 62 vehicles available for daily
service. The appropriate fleet size depends on productivity levels that
balance efficient service delivery with the requirement to serve all
trip requests. Based upon GHTD's recent history, the appropriate fleet
size is probably between 59 and 71.

**Findings**

1.  Projections of demand for passenger trips for budgeting purposes are
    less than current expressed demand, as reflected by trips served
    plus trips denied. Projections of passenger demand do not appear to
    provide for market growth, which has been 25 percent between 1999
    and 2001.

2.  Vehicle productivity levels appear to correspond directly with trip
    denials: 1.4 passenger trips per hour with 3,000 plus annual trip
    denials; and 1.25 trips per hour with 300 annual trip denials.

3.  The annual budget for FY2002 does not appear to provide sufficient
    funds to serve the FY2001 levels of ADA Complementary Paratransit
    passenger demand, plus allow for growth in demand.

4.  The productivity levels assumed in the FY2002 budget do not appear
    to provide sufficient service capacity to serve all requested ADA
    Complementary Paratransit passenger trips.

5.  Driver staffing levels appear to be adequate to meet passenger
    demand.

6.  The amount of service scheduled in a given day appears to be fixed
    at approximately 46 runs and appears to be based upon the number of
    vehicles available for service.

**Recommendations**

1.  ConnDOT and GHTD should consider increasing the FY2002 funding to
    serve the FY2001 levels of passenger demand, plus an allowance for
    growth in demand without capacity denials of requested trips.

2.  GHTD should revise its budget estimation procedure to include
    passenger trips served, passenger trips denied, plus an allowance
    for market growth, or change.

3.  GHTD should revise its budget estimation process based upon
    productivity levels that are consistent with serving all trip
    requests.

4.  GHTD should assess its fleet needs to assure adequate fleet
    availability to meet passenger trip demands without trip denials. It
    should expand the available fleet size through the acquisition of
    additional vehicles and possibly, by increasing the number of spare
    vehicles available for service.

5.  GHTD and Double A should review maintenance procedures to determine
    if additional vehicles in the existing fleet can be made available
    for service and reduce the spares ratio.

    **Attachment A**

**Response from ConnDOT and GHTD**

**Attachment B**

**On-Site Assessment Schedule**

**ADA Complementary Paratransit Service Assessment**

**ConnDOT/Greater Hartford Transit District (GHTD)**

**Hartford, Connecticut**

**June 25-28, 2001**

Schedule

+---------+----------------------------------+------------+----------+
| *       | **Activity**                     | **Who**    | *        |
| *Time** |                                  |            | *Where** |
+---------+----------------------------------+------------+----------+
| **      |                                  |            |          |
| Monday, |                                  |            |          |
| June    |                                  |            |          |
| 25,     |                                  |            |          |
| 2001**  |                                  |            |          |
+---------+----------------------------------+------------+----------+
| 11:00   | -   Opening Conference           | All & FTA  | GHTD     |
| a.m.    |                                  |            |          |
+---------+----------------------------------+------------+----------+
| 1:00    | -   Review information requested | All & FTA  | GHTD     |
| p.m.    |     & policies & procedures with |            |          |
|         |     GHTD Manager                 |            |          |
+---------+----------------------------------+------------+----------+
| 2:30    | -   Review eligibility           | Thatcher,  | GHTD     |
| p.m.    |     determination process        | Chia & FTA |          |
|         |                                  |            | GTHD     |
|         | ```{=html}                       | Kidston    |          |
|         | <!-- -->                         |            |          |
|         | ```                              |            |          |
|         | -   Review budget                |            |          |
+---------+----------------------------------+------------+----------+
| 3:30    | -   Review budget                | Kidston &  | GHTD     |
| p.m.    |                                  | FTA        |          |
|         | -   Review eligibility           |            | GHTD     |
|         |     determination process        | Thatcher & |          |
|         |                                  | Chia       |          |
+---------+----------------------------------+------------+----------+
| **T     |                                  |            |          |
| uesday, |                                  |            |          |
| June    |                                  |            |          |
| 26,     |                                  |            |          |
| 2001**  |                                  |            |          |
+---------+----------------------------------+------------+----------+
| 6:30    | -   Observe dispatch             | Thatcher & | Double A |
| a.m.    |                                  | Chia       |          |
|         | -   Interview drivers            |            | [        |
|         |                                  | Kidston &  | ]{.mark} |
|         |                                  | FTA        |          |
+---------+----------------------------------+------------+----------+
| 10:00   | -   Meet with Double A           | All & FTA  | GHTD     |
| a.m.    |     paratransit manager          |            |          |
+---------+----------------------------------+------------+----------+
| 11:00   | -   Review scheduling            | All & FTA  | GHTD     |
| a.m.    |                                  |            |          |
+---------+----------------------------------+------------+----------+
| 2:00    | -   Observe trip reservations;   | Chia & FTA | GHTD     |
| p.m.    |     record trip request          |            |          |
|         |     information                  | Kidston    | GHTD     |
|         |                                  |            |          |
|         | -   Review on-time performance   | Thatcher   | GHTD     |
|         |                                  |            |          |
|         | -   Eligibility analysis         |            |          |
+---------+----------------------------------+------------+----------+
| **Wed   |                                  |            |          |
| nesday, |                                  |            |          |
| June    |                                  |            |          |
| 27,     |                                  |            |          |
| 2001**  |                                  |            |          |
+---------+----------------------------------+------------+----------+
| 8:00    | -   Observe trip reservations;   | Thatcher,  | GHTD     |
| a.m.    |     record trip information      | Chia & FTA |          |
+---------+----------------------------------+------------+----------+
| 10:00   | -   Review on-time performance   | Kidston    | GHTD     |
| a.m.    |                                  |            |          |
|         | -   Review trip duration         | Thatcher   | C        |
|         |                                  |            | TTransit |
+---------+----------------------------------+------------+----------+
| 1:30    | -   Continue data analysis       | All        | GHTD     |
| p.m.    |                                  |            |          |
+---------+----------------------------------+------------+----------+
| **Th    |                                  |            |          |
| ursday, |                                  |            |          |
| June    |                                  |            |          |
| 28,     |                                  |            |          |
| 2001**  |                                  |            |          |
+---------+----------------------------------+------------+----------+
| Morning | -   Complete preliminary data    | All & FTA  | [        |
|         |     analysis & remaining detail  |            | ]{.mark} |
|         |     work                         | []{.mark}  |          |
|         |                                  |            |          |
|         | ```{=html}                       |            |          |
|         | <!-- -->                         |            |          |
|         | ```                              |            |          |
|         | -   Prepare materials for        |            |          |
|         |     debriefing session           |            |          |
+---------+----------------------------------+------------+----------+
| 1:00    | -   Exit Conference              | All & FTA  | GHTD     |
| p.m.    |                                  |            |          |
+---------+----------------------------------+------------+----------+

**Attachment C**

**Transportation under the**

**Americans with Disabilities Act**

**Attachment D**

**GHTD Application Form**

**for**

**ADA Complementary Paratransit Service**

**Attachment E**

**Community Transportation Consortium:**

**What Every Rider Should Know**

**Attachment F**

**ADA Complementary Paratransit Certification Card**

**Attachment G**

**Form Letter for Persons Determined Ineligible for ADA Complementary
Paratransit Service**

**Attachment H**

**Sample Pages from Completed Driver Manifest**

**Attachment I**

**Sample On Time Performance Reports**