**Suburban Mobility Authority for Regional Transportation (SMART)**

**Detroit, Michigan**

**Review of Reliability, Maintenance, and Operation of Accessible Fixed
Route Bus Service**

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**May 9--12, 2005**

***Summary of Observations***

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

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**Prepared by**

**Planners Collaborative, Inc.**

**with**

**TranSystems Corp.**

**Final Report: February 1, 2007**

**CONTENTS**

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

[2. Background 3](#background)

[3. Overview of the Review 5](#overview-of-the-review)

[4. Observations on Accessible Fixed Route Service Reliability,
Maintenance, and Operation
8](#observations-on-accessible-fixed-route-service-reliability-maintenance-and-operation)

[A. Consumer Input 8](#a.-consumer-input)

[B. SMART's Policies and Procedures
9](#b.-smarts-policies-and-procedures)

[C. Bus Operator Interviews 18](#c.-bus-operator-interviews)

[D. Review Team Observations 20](#d.-review-team-observations)

**5.** [**Findings and Recommendations
29**](#findings-and-recommendations)

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**List of Tables**

[Table 4.1 -- SMART Fixed Route Fleet as of April 2005
9](#__RefHeading___Toc146615910)

[Table 4.2 -- Summary of Accessible Fixed Route Service Complaints by
Type Received by SMART between March 2004 and March 2005
17](#__RefHeading___Toc146615911)

[Table 4. 3 -- Summary of Pullout Observations, SMART, May 10--11, 2005
24](#__RefHeading___Toc146615912)

[Table 4. 4 -- Repair Records for a Sample of 18 Vehicles Reported to
Need Ramp Repairs 27](#__RefHeading___Toc146615913)

**Attachments**

A SMART's Response

B FTA Notification Letter to SMART

C On-Site Review Schedule

D SMART's "Daily Physical Check" Form

E SMART Notices and Bulletins Regarding Accessible Fixed Route Service
Operation Policies and Procedures

F SMART's "W/C Lift Sheet" Form

G SMART's "Level B" Preventative Maintenance Checklist

H SMART's Five-Step Discipline Checklist

I Driver Interview Form

J Vehicle Specification Checklist

K Pullout Checklist

# 1. Purpose of the Review

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

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

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

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

In addition to the general maintenance provisions described above that
apply to all transportation providers, 49 CFR §37.163 requires public
entities to keep vehicle lifts[^1] (and/or ramps) in operative condition
as follows:

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

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

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

The U.S. DOT's ADA regulations also contain several requirements related
to the operation of accessibility features. Part 38 of the regulations
requires that accessible vehicles be equipped with mobility aid
securement systems and passenger restraint systems. Technical and
functional specifications for these securement and restraint systems are
included in Part 38. Section 37.165 requires that transit systems use
the securement system that is available on vehicles. This section also
requires that agency personnel assist individuals with disabilities with
the use of lifts, ramps and securement systems (and that they must leave
their seat if necessary to provide this assistance). Section 37.173 then
requires that transit agencies ensure that "personnel are trained to
proficiency, as appropriate to their duties, so that they operate
vehicles and equipment safely and properly assist and treat individuals
with disabilities who use the service in a respectful and courteous way,
with appropriate attention to the differences among individuals with
disabilities."

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

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This report includes the results of the review of lift reliability,
maintenance and operation at the Suburban Mobility Authority for
Regional Transportation (SMART), based in Detroit, Michigan, conducted
from May 9 to 12, 2005. This report summarizes the observations and
findings of the on-site review of SMART's fixed route bus service. A
description of key features of the fixed route bus service is first
provided. A description of the approach and methodology used to carry
out the review is then provided. Observations and findings related to
the ADA requirements are then described. The major findings of the
review are summarized at the end of this report. Recommendations of the
review team for addressing issues identified also are provided. SMART's
response to the review findings and recommendations is provided in
Attachment A.

# 2. Background

SMART was created in 1967 as the public transportation service provider
for Southeastern Michigan under Michigan Public Act 204. SMART provides
fixed route and demand responsive services in Macomb, Oakland, and Wayne
Counties, which includes the City of Detroit. Outside the City of
Detroit, SMART provides both local and regional transit services. Within
the City of Detroit, SMART coordinates the provision of transit services
with the Detroit Department of Transportation (DDOT). SMART generally
provides service to and from the downtown area from points in its
three-county service area that are outside the City limits. DDOT
provides local transit service to origins and destinations within the
City limits.

The three-county area served by SMART covers 1,108 square miles. The
total population within this area was reported in the 2000 Census to be
3,697,529.

SMART directly operates several types of transit services, including:

-   Fixed route ("linehaul") services, which serve fixed stops along an
    established route

-   ADA complementary paratransit service, which serves eligible
    individuals traveling within 3/4-mile of fixed route services during
    the days and hours that fixed route service is provided

-   "Connector" service, which is general public, curb-to-curb, advance
    reservation, demand responsive service

-   "Flexible Route Service," which is demand responsive service that
    operates within designated areas and serves designated stops as well
    as other locations that can be requested by riders

-   "Job Express" service, which provides service from fixed route stops
    to work sites within defined "Job Express Zones"

-   "Dial-A-Ride" service, which is immediate response, on-demand
    service provided in participating communities

SMART also has developed partnerships with several local communities and
supports the operation of "Community Transit" services in these areas.
Community Transit services are demand responsive services. SMART
provides vehicles, funding, and technical support to assist communities
with the operation of these services.

The fixed route service, which was the focus of this review, is operated
with a fleet of 284 buses. Fixed route service operates on 54 routes.
There are about 7,000 bus stops and 200 bus shelters in SMART's service
area. As reported in the National Transit Database, SMART provides
almost 12 million unlinked trips on the fixed route service and operates
12 million fixed route vehicle-revenue miles per year.

All fixed route buses are low-floor and ramp-equipped. Prior to 2001,
SMART operated lift-equipped fixed route buses. SMART managers reported
that maintenance and reliability problems developed as these
lift-equipped vehicles began to age. In 2000, SMART decided to move to a
100 percent low-floor, ramp-equipped bus fleet and to expedite the
retirement of the older, problematic lift-equipped vehicles. Since many
vehicles had not reached their federally defined useful life, SMART used
local capital funding to carry out this expedited changeover to
low-floor buses. Between 2001 and 2003, SMART replaced its entire fixed
route bus fleet. Thirty-seven low-floor buses were initially purchased
in 2001. Another 160 buses were obtained in 2002. The remaining 87 buses
in the 284 vehicle fleet were purchased in 2003.

SMART's headquarters building is located at 660 Woodward Avenue in
downtown Detroit. Planning services, customer service functions, and
other general administrative functions are housed at this headquarters
location. The fixed route service (as well as many demand responsive
services) is operated out of three garages---one in each of the three
counties that comprise the service area. The fixed route fleet is pretty
evenly divided between these three garages. The garage locations and the
number of fixed route buses assigned to and operated out of each garage
are listed below.

> Macomb Terminal 99 fixed route buses
>
> 22900 15 Mile Road
>
> Clinton Township, MI
>
> Oakland Terminal 94 fixed route buses
>
> 2021 Barrett Drive
>
> Troy, MI
>
> Wayne Terminal 91 fixed route buses
>
> 30000 Industrial Drive
>
> Inkster, MI

# 3. Overview of the Review

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This review focused on SMART's compliance with USDOT ADA regulatory
requirements related to the maintenance, reliability, and operation of
accessible fixed route vehicles and services. The specific regulatory
requirements that were the focus of the review are outlined in the first
section of this report.

Notification of the review was provided by FTA to SMART on April 4,
2005. A copy of the notification letter is provided in Attachment B.
This letter requested that SMART submit certain key service information
for review by the review team prior to the on-site visit. This
information included:

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-   A current fixed route system map

-   A complete set of schedules for each fixed route

-   Fixed route bus fleet and division/garage information

-   A description of ramp/lift maintenance procedures

-   An Operator's Manual

-   Notices, bulletins, and memoranda detailing ramp/lift use policies
    and procedures

-   Reports on ramp/lift monitoring

-   Recent service complaints regarding bus ramp reliability and
    maintenance

    The letter also requested an opening conference on Monday, May 9,
    2005, at 1 p.m., and an exit conference at 2 p.m. on Thursday, May
    12, 2005.

    Prior to the on-site visit, the review team conducted telephone
    interviews with several local riders and agency staff. This included
    riders with disabilities who use the system, as well as staff of
    disability organizations who assist individuals who use the service.
    Input on experiences in using the SMART fixed route service was
    requested.

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    Planners Collaborative, Inc. of Boston, Massachusetts, and
    TranSystems Corp. of Medford, Massachusetts, conducted the review.
    Russell Thatcher of TranSystems served as the team leader. Don
    Kidston and David Chia of Planners Collaborative assisted with the
    review. A schedule of the team's on-site review work is provided in
    Attachment C.

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The opening conference was conducted at 1 p.m. on Monday, May 9. In
attendance were:

  ---------------------- ------------------------------------------------
  Dan Dirks              General Manager, SMART

  Diane McGill           Director of Operations/Transportation, SMART

  Marisol Simon          Director, Administrative Services, SMART

  Michael Patten         ADA Coordinator, SMART

  Larry Luckett          Superintendent of Maintenance, SMART

  Jay Lamky              Technical Services Coordinator, SMART

  Russell Thatcher       TranSystems

  Don Kidston            Planners Collaborative

  David Chia             Planners Collaborative
  ---------------------- ------------------------------------------------

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In addition, Cheryl Hershey, ADA Team Leader from the Federal Transit
Administration's Office of Civil Rights, participated in the conference
by telephone.

Ms. Hershey thanked SMART for its cooperation with the review. She
described the purpose of the review as identifying whether people with
disabilities were receiving accessible fixed route services to which
they are entitled in accordance with the USDOT ADA regulations. She also
noted that the review was intended to offer assistance to SMART in
meeting the ADA's requirements. Ms. Hershey outlined the process that
would be followed for the review. She noted that preliminary findings
would be presented by the review team at the exit conference on
Thursday, May 12. The review team and FTA would then prepare a draft
report, which would be transmitted to SMART for review. Any errors
identified by SMART would be corrected and SMART's letter of response to
the draft report and findings would be incorporated into a final report.
Ms. Hershey noted that the final report with these corrections and
SMART's initial comments would become a public document subject to
requests under the Freedom of Information Act. After issuance of the
final report, SMART would be requested to provide progress reports on
completion of corrective actions for those findings that identify
potential for improvement. Progress reports will continue until FTA has
been satisfied that all findings have been adequately addressed by SMART
and releases SMART of this responsibility.

Russell Thatcher distributed a copy of the review schedule that had been
forwarded to SMART the prior week and reviewed the planned on-site
activities and meetings. He noted that the review would focus on the
working condition, maintenance, and use of the bus ramps and wheelchair
securement systems. Observations would be made at each of the garages
during the morning pullout. Vehicle inspection and maintenance records
would be reviewed. Driver training materials also would be reviewed and
several drivers at each garage would be interviewed. SMART's service
monitoring efforts, including the handling of complaints regarding
accessible fixed route service, would be reviewed. He noted that
in-service observations and "ride-alongs" also were planned.

Following the opening conference, the review team met with senior SMART
managers to discuss policies, maintenance and operating procedures,
fleet resources, and other data that SMART had forwarded in advance.
Internal complaint records related to accessible fixed route service
also were reviewed. The team also met with staff involved in bus stop
location to review efforts to ensure bus stop accessibility.

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On Tuesday, May 10, the review team visited the Wayne Garage. Team
members observed the morning pullout process, including the cycling of
ramps and checks of securement systems. Team members observed how SMART
personnel identified and handled ramp and securement problems. Following
pullout, team members met with garage maintenance staff to review recent
vehicle inspection and maintenance records. Drivers were also
interviewed throughout the day as they reported for duty or as they
completed their shifts. During the afternoon on May 10, Mr. Thatcher met
a rider who uses a wheelchair and regularly rides the SMART fixed route
service. Together they made several trips on the service during the
afternoon and noted the performance of the drivers and equipment.

On Wednesday, May 11, the review team visited the other two garages.
Russell Thatcher and Don Kidston observed pullout, inspected maintenance
records, and interviewed drivers at the Oakland Garage. David Chia
conducted a similar review at the Macomb Garage. A second pre-arranged
"ride-along" with a local rider who uses a wheelchair was also conducted
on Wednesday afternoon.

The team members spent Thursday morning analyzing the information they
collected and preparing for the exit conference.

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The exit conference took place at 2 p.m. on Thursday, May 12. The
following review team and SMART representatives attended the meeting:

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  ------------------------ ----------------------------------------------
  Dan Dirks                General Manager

  Diane McGill             Director of Operations/Transportation

  Marisol Simon            Director, Administrative Services

  Michael Patten           ADA Coordinator

  Larry Luckett            Superintendent of Maintenance

  Jay Lamky                Technical Services Coordinator

  Stephen Dobbins          Superintendent of the Oakland Garage

  Robert Granger           Superintendent of the Macomb Garage

  E. James Barton          Superintendent of Transportation, Macomb
                           Garage

  Curtis Sims              Superintendent of the Wayne Garage

  Ron Ristau               Director of Service Development

  Russell Thatcher         TranSystems

  Don Kidston              Planners Collaborative

  David Chia               Planners Collaborative
  ------------------------ ----------------------------------------------

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Cheryl Hershey from the FTA Office of Civil Rights participated via
conference call.

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The review team then presented observations and preliminary findings for
discussion with SMART officials. Mr. Thatcher summarized driver training
observations and the interviews with drivers at each garage. He also
reviewed SMART's service monitoring processes. Mr. Chia reviewed
observations on the vehicle pullout process and the working condition of
ramps and securement systems. Mr. Kidston reviewed findings related to
vehicle maintenance. Mr. Thatcher then reviewed some design issues
specific to one type of bus used by SMART.

Ms. Hershey thanked SMART for its cooperation throughout the review and
acknowledged the positive findings reported at the exit conference. Mr.
Dirks indicated that SMART would work with FTA on those items where
recommendations for improvement were made.

# 4. Observations on Accessible Fixed Route Service Reliability, Maintenance, and Operation

To determine SMART's current performance with respect to accessible
fixed route reliability, maintenance and operation, the review team
performed the following activities:

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-   Conducted telephone interviews with individuals who use wheelchairs
    who are regular riders of the SMART bus system and agency personnel
    who have clients who are regular riders

-   Reviewed SMART's recent bus procurements, current fleet
    accessibility, and bus stop accessibility efforts

-   Reviewed SMART's policies and procedures regarding the inspection of
    accessibility equipment

-   Reviewed SMART's policies and procedures regarding maintenance and
    repair of accessibility equipment

-   Reviewed policies and procedures related to the provision of
    accessible fixed route services

-   Reviewed operator training materials

-   Reviewed SMART's service monitoring, complaint process, and
    disciplinary practices

-   Interviewed bus operators to gauge their understanding of ramp and
    wheelchair securement use policies and procedures

Team member observations made during each of these review activities is
detailed below.

## A. Consumer Input

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The review team conducted six telephone interviews with individuals who
ride SMART's fixed route buses and staff members of local disability
organizations who work with riders who use the bus system. There was a
general consensus that the recent switch to low-floor, ramp-equipped
buses has been a significant improvement. Three people indicated that
there used to be problems with reliability of the lifts. These
individuals indicated that the ramps were much more reliable.

There also seemed to be a general understanding that the ramps do not
completely "fail" in service. It was noted that even if the ramps do not
deploy automatically, they are manually operated by the drivers.

One rider and one agency staff person noted some ongoing driver-related
issues. They indicated that drivers sometimes say the ramp is broken,
but will not try to deploy the ramp manually. The rider noted that a
driver stated that he did not have the "tool" needed to manually deploy
the ramp. That rider said that in these situations he tells drivers how
to use any kind of prying object to manually deploy the ramp. Both the
rider and agency staff member indicated that this was a "very
occasional" and an atypical experience.

Two riders also raised issues about securement. One said the drivers
sometimes do not want to leave their seats to secure riders who are
using wheelchairs. The other said that drivers could be "trained better"
in doing securement and that the attachments they make sometimes are not
that good.

One rider also noted an issue with the design of a recent order of
buses. He said that the securement areas are set up to be forward-facing
and that there is no room for him to turn around on the bus once he
enters. Therefore, he has to back up the ramp and back through the fare
collection area and down the aisle to the securement locations. He uses
a power scooter and said it is very difficult to do this. He said that
if he does not back up the ramp, it is very difficult to turn around
once in the vehicle to be secured forward-facing. He said it is
difficult to turn around even if no other riders with wheelchairs are on
board, and impossible to turn around once inside if one of the two
wheelchair securement locations is occupied.

One of the riders that the review team interviewed uses a walker. She
said the drivers are good about kneeling the bus for her and that she
did not have any problems using the low-floor buses.

It should be noted that there were no formal ADA complaints related to
the SMART fixed route service on file with FTA at the time of the
on-site review.

## B. SMART's Policies and Procedures

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Following is a description of policies and procedures adopted by SMART
regarding accessibility of the fixed route system and the provision of
accessible fixed route service.

**Fleet Roster**

As noted in Section 2 of this report, SMART's fixed route bus fleet is
100 percent accessible. Prior to 2001, buses were equipped with
hydraulic lifts. SMART had maintenance and reliability issues with these
lift-equipped buses as they began to age. To address these issues, SMART
developed and carried out an aggressive bus replacement program. Lift
buses were retired early (before their federally defined useful life)
and SMART replaced them with low-floor, ramp-equipped buses.

The entire fixed route fleet was replaced between 2001 and 2004. The
last lift-equipped vehicle was retired from service in October 2004.
Table 4.1 shows the number and types of vehicles purchased each year,
and their assignment by garage as of April 2005.

[]{#__RefHeading___Toc146615910 .anchor}Table 4.1 -- SMART Fixed Route
Fleet as of April 2005

  ---------- ---------------------- ------------ ------------- ------------ ------------
  **Model    **Manufacturer**       **Garage                                **TOTALS**
  Year**                            Assignment                              
                                    (April                                  
                                    2005)**                                 

                                    **Wayne**    **Oakland**   **Macomb**   

  **2001**   Gillig with Lift-U     14           11            12           **37**
             ramp                                                           

  **2002**   Gillig with Lift-U     53           51            56           **160**
             ramp                                                           

  **2003**   Gillig with Lift-U     24           32            31           **87**
             ramp                                                           

             **TOTAL**              **91**       **94**        **99**       **284**
  ---------- ---------------------- ------------ ------------- ------------ ------------

As indicated in Table 4.1, all buses have been purchased from the same
manufacturer and with the same type of ramp (Lift-U). This is reported
to have helped with maintenance and parts supply and stocking issues.

Ramps on all of these buses are designed to be automatically deployed by
the driver. In the event that the electro-hydraulic deployment system
fails, ramps can easily be manually deployed. Drivers simply lift and
fold out the ramp using a tool that is kept on board each bus. These
tools are permanently attached to the vehicles with a cable to prevent
them from being misplaced. Even without this special tool, it was noted
that drivers can use a key or other object for prying to manually deploy
the ramps. Manual deployment of the ramps is as quick (or even quicker)
than automatic deployment.

It was also noted that all SMART Road Supervisor vehicles are
ramp-equipped minivans. If there are in-service issues with the boarding
of a rider who uses a wheelchair, dispatchers are able to contact the
Road Supervisors, who can respond immediately and serve the riders with
these accessible minivans.

**Bus Stop Accessibility**

Section 10 of Appendix A to 49 CFR Part 37 requires that where new bus
stop pads are constructed at bus stops, bays, or other areas where a
lift or ramp is to be deployed they shall have a firm stable surface
96\"-deep (from the road edge) and 60\"-wide (along the road edge) and
shall be connected to sidewalks, paths, or streets by an accessible
path. New bus shelters shall have a clear floor area of 30\" by 48\" and
shall be connected to an accessible route. Section 10 also requires that
bus stop sites be chosen such that, to the maximum extent practicable,
the areas where lifts or ramps are to deployed have a firm stable
surface 96\" deep and 60\" wide.

SMART makes a positive effort to identify and maintain its bus stops and
promote ADA-compliant design of new bus stops and shelters. SMART has
identified and geo-coded the location of approximately 7,000 bus stops.
It plans to enter each of these stops into the SMART maintenance system
software database.

SMART addresses bus stop design in "SMART's Guide for Creating a Transit
Friendly Environment" (May 1996). Guidance for design of bus stops and
shelters in the document meets the requirements of the USDOT
regulations. SMART uses the document to guide road builders, developers,
and business operators in designing and building accessible bus stops
and shelters and other elements of a transit friendly environment. SMART
also employs a bus stop technician/coordinator who has the
responsibility of identifying locations for bus stops as part of bus
route design.

In addition, there is a page on SMART's website that permits customers
to report damage to bus stops and shelters, thereby helping SMART
identify stops and shelters in need of repairs. The web page provides an
opportunity to learn more from customers. For example, adding a question
on the use of stops, particularly by people who have disabilities, could
result in information that could help guide decisions on investing in
stop and shelter construction or upgrade.

**Ramp and Securement System Inspection**

[]{.mark}

SMART has established procedures to check the accessibility features of
fixed route buses in several ways. First, drivers are required to cycle
ramps and to check the working condition of securement systems at
pullout. A copy of the "Daily Physical Check" form used by drivers is
provided in Attachment D. Copies of notices distributed to drivers and
posted in driver lounges, as well as memoranda detailing SMART policies
in this area, are included in Attachment E.

If a driver identifies a problem with the ramp or securement systems (or
any other issues with the vehicle), he or she is instructed to contact
Central Dispatch by radio. Central Dispatch then instructs the driver to
either switch out the bus or continue on the route and report the
problem at the end of the shift. Drivers might be instructed to pull out
with the vehicle if the problem reported is minor and would not affect
actual delivery of service. For example, there may be a problem with the
automatic deployment of the ramp, but the ramp might still be able to be
operated manually.

A second inspection of the ramps is conducted at the end of each day. As
part of the process for fueling and preparing vehicles for the next day
of service, Coach Service Attendants (CSAs) cycle the ramps to check for
any defects. The CSAs complete a "W/C Lift Sheet," which is a checklist
indicating the status of ramps, on all vehicles at each garage which
they service (i.e., those that were in service that day). A copy of a
sample completed "W/C Lift Sheet" for the Wayne Garage for April 14,
2005, is provided in Attachment F. As shown, all 91 vehicles assigned to
the Wayne Garage are included on the master checklist. CSAs inspected
all 79 vehicles used in service that day.

Finally, ramps and securement systems are checked as part of the regular
preventative maintenance process. This is discussed in the next section.

**Preventative Maintenance and Repairs of Accessibility Equipment**

A complete preventive maintenance inspection is conducted every 8,000
miles. This is referred to by SMART as a "Level B Inspection." Mechanics
inspect all vehicle systems and complete a six-page inspection
checklist. A copy of the inspection checklist is provided in Attachment
G.

Items related to the wheelchair ramp, wheelchair securement systems, and
kneelers are listed on page 5 of this checklist. Electrical wiring,
hydraulic hoses, and proper operation of all systems are checked. The
ramp area and securement systems also are cleaned and moving parts are
lubricated.

Repairs are made as needed. Repairs may be initiated as a result of the
Level B inspection process. They also are initiated when drivers or CSAs
detect problems. As noted above, drivers inspect vehicles each day at
pullout. If a problem is identified, it is noted in the Daily Physical
Check form. If the problem is noted at pullout and Central Dispatch
instructs the driver to switch out the vehicle, the driver leaves the
vehicle in the "Write-Up Line," along with the completed Daily Physical
Check form. If a driver encounters problems with the ramp, securement
systems, or kneeler while in service, he or she adds this information to
a "Trip Trouble Report," attaches this report to the Daily Physical
Check form, and parks the vehicle in the Write-Up Line when he or she
returns to the garage. If CSAs note problems at the end of the day, a
similar process is used. Vehicles left in the Write-Up Line are then
repaired by mechanics before the vehicle is returned to the overnight
parking area for the next day of service.

Each garage is responsible for maintaining vehicles assigned to that
location. An inventory of parts, including parts for ramps, securement
systems, and kneelers also is maintained at each garage. A centralized
maintenance software program is used to track vehicle mileage and all
maintenance and repairs.

**Accessible Service**

SMART has developed formal policies and procedures related to the
provision of accessible transportation services. Attachment E includes
copies of bulletins and notices that are contained in SMART's Operator's
Manual, distributed to employees, and/or posted in garages. As these
bulletins and notices indicate, SMART has established the following
policies and procedures:

-   All drivers are required to cycle ramps at the start of every run
    (noted in several posted notices and bulletins in Attachment E).

-   Drivers are required to radio Central Dispatch each time they
    encounter a rider using a wheelchair. They are to inform Central
    Dispatch whether they have successfully boarded the rider, or if
    they have encountered a problem (see several posted notices in
    Attachment E, as well as "SMART Memoranda" dated October 9, 2001;
    September 19, 2000; and May 21, 1999). This notification allows
    Central Dispatch to immediately arrange for alternate service.

-   If a ramp malfunctions and cannot be manually deployed to board a
    rider who uses a wheelchair, dispatchers have several options. They
    can arrange to have a deadhead bus, or change-off bus sent to serve
    the rider. They can ask a Road Supervisor to respond immediately
    with an accessible Road Supervisor vehicle (ramp-equipped minivan).
    Or they can contact the driver on the following bus to determine if
    that vehicle has an operating ramp and let the driver know of the
    situation. The dispatcher selects the backup service option that
    will provide the quickest response for the rider. If all fixed route
    backup options fail, dispatchers also can arrange to have a
    Community Transit vehicle in the area dispatched to the stop to
    serve the rider (see "SMART Memorandum" dated September 26, 2001, in
    Attachment E).

-   Drivers are required to always use the kneeler to lower the bus when
    they deploy the ramp (see "SMART Memorandum" dated November 7, 2002,
    in Attachment E). This is done both to minimize the slope of the
    ramp and to remind the driver to stow the ramp before pulling away
    (as the bus must be raised to override the kneeler interlock).

-   Drivers are always required to secure wheelchairs to the vehicle.
    SMART has established a policy of requiring all wheelchairs to be
    secured. In addition to a bulletin notifying drivers of this policy,
    a notice is posted on all vehicles informing riders of this policy
    (see several posted notices and memoranda in Attachment E).

-   While wheelchairs must be secured, passengers using wheelchairs may
    elect whether or not they want to use the lap belt or shoulder belt
    (see "Fixed Route Service Requirements for Persons with
    Disabilities," dated September 9, 1998, in Attachment E).

-   Drivers are required to allow riders who do not use wheelchairs, but
    who have difficulty stepping onto or off of the bus to use the ramp
    to enter or exit (see "Fixed Route Service Requirements for Persons
    with Disabilities," dated September 9, 1998, in Attachment E).

SMART's practice of providing Road Supervisors with accessible minivans
to enable them to provide immediate assistance when ramp boarding issues
arise is particularly helpful. There are three Road Supervisors each at
the Wayne and Macomb Garages and six Road Supervisors at the Oakland
Garage.

While SMART has developed these detailed procedures for arranging backup
service, it is important to note that moving to a 100 percent
ramp-equipped, low-floor bus fleet has greatly reduced the need for
backup service. As noted above, drivers are able to easily operate the
ramps manually even if the automatic deployment system fails. There
might still be situations where the entire ramp is damaged and cannot be
deployed manually, but these situations would seem to be infrequent.

[]{.mark}

**Operator Training**

[]{.mark}

Bus operators at SMART must complete a seven-week intensive training
program. The training consists of two weeks of classroom instruction and
at least five weeks of supervised on-the-road instruction and
experience.

Classroom instruction includes two days (16 hours) of disability
awareness and passenger assistance training. On the first day, a speaker
from a local organization presents information and materials on
disability issues and assisting and communicating with riders with
disabilities, and engages participants in a discussion of ADA
requirements and common "myths" about disabilities. Trainees also travel
to a local disability organization that does job training and placement
for people with disabilities to meet and interact with individuals with
various types of disabilities at that agency.

On the second day, participants receive instruction on bus ramp
operation and proper use of securement systems. Trainers demonstrate the
proper techniques for securing various types of wheelchairs.
Participants must then demonstrate their ability to properly use the
securement systems on two different wheelchairs. They are observed doing
this and the instructor is required to sign off on their proficiency
with the use of the equipment.

In the first two weeks of on-the-road training, the trainee rides with
an experienced driver/trainer and observes correct operating procedures.
For the last three weeks of the on-the-road training, the trainee
operates the bus, assists riders, and is observed and graded by the
driver/trainer. Part of the evaluation during this portion of the
training includes proper use of the ramps, securement systems, and
kneelers, and appropriate passenger assistance.

SMART's "Linehaul Training Manual" (dated September 2002) includes 10
pages on "Special Passengers and the ADA." This section addresses the
issues related to serving riders with disabilities, as well as other
passengers such as seniors and schoolchildren. It includes good
descriptions of the basic goals of the ADA; a discussion about
"attitudes and understanding" and common myths about people with
disabilities; a discussion of types of disabilities that may not be
obvious ("hidden" disabilities); tips for communicating with and
assisting riders with various types of disabilities; and common mobility
aids used---including the many types of service animals that people with
disabilities may use.

Training staff indicated that in the "hands on" instruction regarding
the use of ramps and securement systems, operators are instructed to
provide assistance to riders entering or exiting the vehicle via the
ramps, as well as to assist with wheelchair securement and passenger
restraint systems. Drivers are instructed to physically assist riders
who use manual wheelchairs by helping push them up or down the ramps.
For riders who use power wheelchairs, drivers are instructed to offer
spoken guidance and directions as needed.

In addition to this initial instruction, SMART has been providing
frequent "refresher" training. Recently, this has included quarterly
refresher training in the operation of ramps and securement systems. At
these quarterly training sessions, two styles of buses (a 40-foot bus
and a 29-foot bus) are used to demonstrate proper equipment operation
and securement techniques. The most recent of these quarterly trainings
prior to the review team's on-site visit took place on February 17,
2005. The notice of the training indicated it was mandatory training for
all bus operators.

SMART also has purchased two manual wheelchairs that are used to provide
employees with "empathy training." This program started in 1999. All
employees are required to arrange to go to the Macomb Garage, where the
two wheelchairs are stored, and sign a wheelchair out for the day. They
then are assigned a "tour" by the Macomb dispatchers. The tour involves
riding several buses throughout the area. The employee must travel to
and from bus stops, ride the buses, and make transfers using the
wheelchair. This training has been provided to all employees, including
administrative staff, dispatchers, mechanics, Road Supervisors, and all
drivers.

SMART training staff also reported a good working relationship with
union representatives on accessibility issues. They have been working
together to stress the importance of accessibility to drivers.

**Service Monitoring and Enforcement of Policies and Procedures**

[]{.mark}

SMART regularly monitors accessible fixed route service operation
several different ways. These include:

-   Regular observations by Road Supervisors

-   Ongoing working relationship with riders with disabilities

-   Observations by National Transit Database (NTD) data checkers

-   Formal complaint process

Road Supervisors at each garage observe the pullout and ramp cycling
process at least once each week. This is done to ensure that all drivers
are cycling the ramps as required. Road Supervisors also randomly
observe driver performance on the road and will be directed to make
observations of particular drivers as part of the complaint
investigation process.

SMART administrators noted that they have a very active consumer
advisory committee that regularly provides feedback on system and
employee performance. Through the advisory committee, SMART has
requested that riders who use wheelchairs immediately call in to the
complaint line if a bus fails to stop to pick them up or if a driver
indicates that a ramp is not working and fails to board them. The staff
who manage the complaint line are instructed to immediately notify
Central Dispatch if calls of this type are received. In addition to
arranging to immediately assist the passenger, Central Dispatch will
also dispatch a Road Supervisor to check the ramp.

SMART staff presented information to the review team on an incident in
spring 2005 in which a Road Supervisor was dispatched and found nothing
wrong with the ramp. As a result, the driver was suspended for five
days. SMART staff reported that this process has been very effective in
helping them monitor driver "pass-bys."

SMART staff has also developed an ongoing working relationship with 10
riders with disabilities who use the transit service. These riders form
a kind of informal "secret rider" program. They regularly report on
their experiences using the fixed route service. Two of these riders who
use wheelchairs are paid by SMART to ride the system periodically and
report their experiences. SMART does not formally tabulate this
information, but uses it to focus its own monitoring on issues that
these riders identify.

Staff reported that NTD data checkers are also asked to observe and
report on service and driver performance. As they ride the system to
collect NTD data, they observe ramp boardings by riders with
disabilities. Again, this information is not formally tabulated, but is
used to focus retraining or other service monitoring efforts on drivers
who are observed not to be following policies or providing appropriate
assistance.

Finally, SMART uses the formal complaint process to monitor system
performance. Riders can call in to a central complaint phone line, or
can register comments and complaints on-line at SMART's website. All
complaints are maintained in a central database that can be accessed by
superintendents at the three garages. A central office staff person
enters complaints into the central system as they are received via
phone, as well as regularly watches for complaints received on-line. If
complaints are deemed "urgent" (such as the situation described above
where a rider might be stranded), this staff person immediately alerts
the appropriate garage staff. If complaints require immediate attention,
this person also places a call to the garage superintendent, alerts him
to the fact that the complaint has been received and is now in the
system, and asks for an immediate investigation and response.

As each complaint is investigated, the findings and actions taken are
entered by garage staff into the central system. If the complaint is
found to be valid and the driver violated policy or did not act
appropriately, the information is added to the driver's personnel file,
and appropriate action is taken.

SMART staff indicated that they have successfully negotiated with the
bus operator's union (ATU Local 1564) to allow valid and substantiated
complaints to be used in the disciplinary process. Three substantiated
complaints in a three-month period can lead to action by SMART. As part
of the process, riders making complaints might be asked to testify at
any arbitration hearings that might result from proposed disciplinary
actions.

Working cooperatively with the bus operator's union, SMART also has
established a detailed five-step disciplinary process for violations of
operating policies and procedures. A copy of a checklist showing the
types of disciplinary actions that can be taken for various types of
violations is presented in Attachment H. The five steps of discipline
used for some types of violations involve:

> Step 1 Written warning
>
> Step 2 One-day "working suspension" at 90 percent of standard pay
>
> Step 3 Three-day "working suspension" at 80 percent of standard pay
>
> Step 4 Five-day suspension without pay
>
> Step 5 Discharge

For violations that SMART considers more serious, the initial discipline
starts at a higher step than Step 1. More serious violations start with
suspensions rather than written warnings and include only two, three, or
four of the five steps of discipline.

"ADA Violations" are included in the disciplinary policy. Discipline can
be administered for the following violations:

-   Failure to notify Central Dispatch of a wheelchair passenger using
    the service

-   Failure to call out stops

-   Pass-by of a rider with a disability at a bus stop

-   Failure to pick up a passenger with a disability

-   Passing requested stops

-   Failure to properly secure a wheelchair

Discipline for three of these violations (failure to notify Central
Dispatch, failure to call out stops, and passing requested stops) begins
beyond Step 1. A first violation results in a Step 2 working suspension.
Drivers can be discharged after four documented incidents.

Failing to properly secure a wheelchair involves three steps of
discipline. A first violation calls for a Step 3 working suspension, and
drivers can be discharged after three documented incidents.

Two of the ADA violations (pass-bys of riders with disabilities, and
failure to pick up riders with disabilities) involve only the last two
steps of discipline. Drivers are suspended without pay for the first
violation (Step 4) and can be discharged for a second violation.

The team's review of recent complaint records and personnel files
indicated that SMART is actively following this disciplinary process.

**Rider Comments and Complaints Received by SMART**

The review team obtained and reviewed internal complaint records related
to the provision of accessible fixed route service for the 12-month
period from March 2004 through March 2005. A total of 24 complaints were
identified. Six of these were determined not valid (e.g., a complaint
about a driver action in accordance with current policy), and two did
not include enough information to allow the complaint to be properly
investigated (e.g., date and time, vehicle number).

Table 4.2 provides a tabulation of the issues cited in the 18 complaints
deemed valid. The table lists a total of 19 issues, as one complaint
involved two types of issues. As shown, the most frequent issue cited by
riders (in seven complaints) was that drivers either did not secure
their wheelchair or did not secure it properly. The second most common
type of complaint is lifts that did not work (four complaints). It
should be noted that all of these related to the old lift-equipped buses
that were in service until November 2004. Two complaints cited drivers
not wanting to deploy the ramps for riders who had disabilities but did
not use wheelchairs.

[]{#__RefHeading___Toc146615911 .anchor}Table 4.2 -- Summary of
Accessible Fixed Route Service Complaints by Type Received by SMART
between March 2004 and March 2005

  --------------------------------------------------------- --------------
  **Type of Complaint**                                     **Number of
                                                            Complaints**

  Driver didn't secure rider's wheelchair, or inadequate    7
  securement                                                

  Lift not working (old lift buses -- prior to 11/04)       4

  Driver refused to deploy ramp for person not using a      2
  wheelchair                                                

  Driver passed by rider using wheelchair waiting to use    2
  the service                                               

  Driver didn't see rider (waiting a short distance from    1
  bus stop and in a crowd) and drove away                   

  Driver refused to kneel bus                               1

  Driver let others board first and then couldn't           1
  accommodate rider using a wheelchair                      

  Driver was rude                                           1
  --------------------------------------------------------- --------------

Two incidents were reported of drivers passing by riders who were using
wheelchairs and waiting to board. Single incidents were reported of a
driver being rude; a driver refusing to kneel the bus; a driver allowing
passengers to board before a wheelchair user and then not being able to
accommodate the rider who used a wheelchair; and a driver not seeing a
rider using a wheelchair and driving away. For this last incident, the
database noted that there was a crowd at the bus stop and the rider was
waiting near but not right at the bus stop.

Team members discussed each of these substantiated and valid complaints
with supervisors at the three garages to determine what actions were
taken and to verify that the action was documented in the driver's
files. Appropriate actions were documented for 13 of the 18 complaints.
In five cases, though, there appeared to be an issue with notification
of and follow-up by the garage superintendents. In these cases, nothing
had been entered into the "Company Remarks/Action Taken" field in the
central database. The superintendent at the Wayne Garage searched his
past e-mail records, did not find a notification from the central office
of the complaint, and indicated that he may not have followed up because
of a lack of this separate notification (even though the complaint had
been entered into the central database). Three of the complaints that
did not indicate an action taken were at the Macomb Garage (#41651,
#40913, and #42291). The other two were at the Wayne Garage (#42008 and
#41841).

It is significant to note that no complaints about malfunctioning ramps
were identified. Also, as noted above, all four complaints regarding
malfunctioning equipment were related to the now-retired lift buses.

The analysis also showed that only six of the 24 complaints had been
received since October 2004 (following the retirement of the last
lift-equipped buses). Only two of the complaints since October 2004 were
substantiated and valid.

## C. Bus Operator Interviews

While at the three garages, the review team interviewed a total of 28
SMART bus operators. This included 10 operators at the Wayne Garage,
nine at the Oakland Garage, and nine at the Macomb Garage. The
interviewer explained the purpose of the review and told the drivers
that the information collected from the interviews would be kept
confidential. A copy of the form used in the interviews is presented in
Attachment I.

Bus operators were randomly selected and included a mix of operators
with varying years of service. This ranged from an operator with less
than one year of experience to several with more than 15 years of
experience.

All 28 operators indicated that they felt the training they received
adequately prepared them for the job and to assist riders with
disabilities. The vast majority (27 of the 28) rated the training as
good or very good. Several specifically cited the refresher training and
instruction provided on securing motorized scooters as very helpful. All
28 drivers confirmed that there was frequent refresher training,
indicating that they received refresher training on disability issues
"often," "several times a year," or "frequently."

All 28 operators were familiar with SMART's policy regarding the daily
cycling of ramps. All but three of the 28 operators indicated that they
do cycle the ramps each time they pull out a bus. One operator said she
cycles the ramp most of the time, but "not always." Two operators said
they only cycle the ramp at pull out for the first shift of the day, but
not between shifts (assuming it already has been checked for the day).

Most of the drivers indicated that if the ramp did not operate
automatically, but could still be manually operated, they typically
would pull out. Twelve drivers indicated that they call Central Dispatch
but still might end up pulling out and operating the ramp manually for
that shift. Eleven operators indicated that they typically pull out and
report the problem at the end of their shift. Five drivers indicated
that they radio Central Dispatch and then often take the vehicle to the
Write-Up Line and get a replacement bus. All of the operators indicated
that the ramps were very easy to operate manually and that they had no
difficulty serving riders who used wheelchairs even if they could not
deploy the ramp automatically.

There appeared to be some uncertainty about proper procedures for
assisting riders using wheelchairs who might have difficulty getting up
or down the ramp. Seventeen operators indicated that they would provide
assistance. Several noted that they had not experienced any problems to
date. Six operators, though, indicated that other passengers typically
help the rider negotiate the ramp. One operator said she was not allowed
to physically push someone up or down the ramp. Another operator
indicated that he might help "from his seat" by verbally providing
guidance. Another operator indicated that there had been "mixed
messages" about whether assistance should be provided and about the
exact type of assistance to be provided.

Eleven operators indicated that they had not observed riders having
difficulty navigating to the securement locations on the buses.
Seventeen operators did note, however, some issues with space on board.
In general, this was not a problem on the 35- or 40-foot buses. On these
buses, problems most often could be minimized by flipping up the seats
on both sides of the bus and/or asking riders in the area to make room
to allow the rider to maneuver. Several operators also noted that this
only was an issue with larger power wheelchairs or scooters that were
harder to turn. One operator indicated "a lot" of problems with space on
board the smaller 29-foot buses. He said he instructs riders to back up
onto the bus if they are able.

All 28 operators interviewed were familiar with SMART's policy requiring
that wheelchairs always be secured. Two operators indicated that if
riders refused, they might proceed with the riders not secured, but only
with dispatch approval.

Twenty-six of the 28 operators also understood that riders could refuse
to use the passenger restraint systems (seat and lap belts). Two
operators, though, indicated that use of the lap and shoulder belts also
was mandatory.

All 28 operators were familiar with the procedures to follow regarding
priority seating. All indicated that they would ask passengers using
those seats to allow a person with a disability to use them. There was a
general sense that passengers will move if the seat is needed by a
person with a disability. One operator said he had only once had another
rider complain.

Twenty-five of the 28 operators also were familiar with the fact that
not all service animals have an ID, harness, or cape. They indicated
that if the passenger indicated the animal was a service animal, they
would allow it to board. Several operators correctly added that the
animal needed to be "under control" and could not cause a problem. Three
operators, though, indicated that they would not allow a dog on board
unless it had a harness or the passenger "had a cane," or there was some
identification of the dog as a service animal.

These interviews indicated that, in general, operators were largely
familiar with ADA requirements and SMART operating policies and
procedures. However, some inconsistencies in bus operator understanding
of rider assistance policies and service animal policies were noted.

## D. Review Team Observations

In addition to interviewing riders and drivers and examining SMART's
policies, procedures, and internal records, the review team conducted
firsthand observations and follow-up in the following areas:

-   Inspected one of each type of fixed route bus purchased by SMART for
    compliance with ADA vehicle design (Part 38) standards

-   Reviewed fleet availability records

-   Observed operators performing vehicle inspections during morning
    pullout and recorded the results of these inspections

-   Reviewed maintenance records and dispatch logs

-   Conducted "ride-alongs" with consumers who use wheelchairs

The remainder of this section of the report summarizes these
observations.

[]{.mark}

**Vehicle Design**

As part of its review, the FTA team looked at representative buses from
the SMART fixed route fleet to see whether their designs met the
requirements of Subpart B of 49 CFR Part 38, "Americans with
Disabilities Act Accessibility Specifications for Transportation
Vehicles." This portion of the ADA regulations applies to all new, used,
or remanufactured buses. Vehicles used by entities that operate services
covered by the ADA, such as SMART, must comply with these
specifications.

A member of the review team inspected three buses at the Wayne Garage:
one each of the three designs in the SMART fleet. These included:

-   Gillig 40\' low floor with ramp

-   Gillig 35\' low floor with ramp

-   Gillig 29\' low floor with ramp

The types of specifications covered in the bus inspections included:

-   Ramp

-   Securement system

-   Other vehicle features, e.g., doors, steps, floors, handrails,
    communication devices

The review team member used a Specification Checklist to record the
observations for each bus. Attachment J includes a copy of this
checklist. Following are the key results of these inspections.

**Gillig 40\' low floor with ramp**

The review team inspected SMART vehicle #22389. This sample vehicle met
all specifications of 49 CFR Part 38.

**Gillig 35\' low floor with ramp**

The review team inspected SMART vehicle #22456. This sample vehicle had
the following compliance issue:

-   Sign designating the wheelchair securement locations was difficult
    to read unless illuminated from the outside, due to poor contrast
    (49 CFR §38.27(c)).

[]{.mark}

**Gillig 29\' low floor with ramp**

The review team inspected SMART vehicle #23362. This sample vehicle had
the following compliance issues:

-   Seats designated as priority seats for persons with disabilities
    were side facing, not forward facing (49 CFR §38.27(a)).

In addition, the review team inspected the interior layout and seating
configuration of this 29-foot Gillig. As mentioned earlier in this
report, riders who use wheelchairs who were contacted as part of the
review indicated difficulties using this particular type of vehicle. The
issue is that if riders board these vehicles by going up the entrance
ramps forward-facing, they must make a 180-degree turn into one of the
two wheelchair securement areas located just behind the front
wheelwells. It was reported (and observed) that this turn is difficult
for riders using certain types of wheelchairs. Adequate space appears to
exist for riders using manual wheelchairs or standard power wheelchairs.
However, riders who use power scooters, including scooters that are
within the maximum dimensions of a "common wheelchair" (e.g., no more
than 30 inches wide or 48 inches long) appear to have great difficulty
making this turn. One rider who used a power scooter took several
minutes to make this 180-degree turn in the vehicle. And during this
observation, there were no other passengers in the area and both
wheelchair securement locations were open. If another passenger using a
wheelchair had been in one of the securement locations, it did not
appear that adequate space would have existed for this rider to turn
around in this vehicle. If this rider needed to board a vehicle with one
securement space already occupied, he would have had to back up the ramp
and onto the vehicle. Backing up the ramp and backing through the fare
collection area could be very difficult for some riders.

The wheelchair securement areas on this style of vehicles occupy the
entire low-floor portion of the vehicle, from the front wheelwells to
the steps that lead to the raised rear seating area. Aisle-facing flip
seats are located on the driver-side wall and an enclosure for the fuel
tank takes up the space on the passenger side wall behind the right
front wheelwell. With the aisle-facing flip-seats in the "up" position,
the floor area in the two-position wheelchair securement area was 107
inches long and 57 inches wide. A pivoting bar, which is part of the
wheelchair securement system, is floor mounted in the middle of this
area. With this bar locked in place, the clear floor space in each
wheelchair securement area was 37 inches wide (allowing for a 20-inch
aisle) by 48 inches long. Technically, this meets the design
requirements of 49 CFR Part 38.

Functionally, though, as noted above, there is not enough clear floor
space for all common wheelchairs to turn around in this area. The
minimum space required to allow all common wheelchairs to turn around is
60 inches by 60 inches. This minimum turning area is required in other
parts of the ADA Accessibility Guidelines (ADAAG), but is not required
on buses.

These SMART buses therefore appear to technically meet the ADAAG
requirements concerning clear floor space in the wheelchair securement
areas. Functionally, though, SMART appears to have an issue with certain
riders and certain situations that could result in service delays or
difficulty for riders in the boarding process. Riders using power
scooters may have to back up the ramp when one of the securement spaces
is occupied. And, even if both wheelchair spaces are available, riders
using power wheelchairs who enter forward-facing may delay service as
they make the turn in the vehicle.

**Fleet Availability**

SMART has a total fleet of 284 buses for fixed route service. These
buses are assigned to the three garages for operations and maintenance:

-   Macomb 99

-   Oakland 94

-   Wayne 91

All SMART buses have ramps that the driver can deploy even if the ramp
has a mechanical or electrical problem. Therefore, a bus could be
available for service even if the ramp had to be manually deployed by
the driver.

The review team collected information on the number of vehicles required
for service and the number of vehicles available for service. Based on
analysis of this data, the review team found that SMART had a sufficient
number of vehicles available to meet its peak needs at all of its
garages. For example, during the week of April 25 to 29, 2005, the
Oakland Garage had a peak pullout requirement (both morning and
afternoon) of 68 buses. On each of these days, Oakland had more than 68
vehicles available for service.

**Pullout and Condition of Accessibility Equipment**

The review team observed the morning pullout at all three SMART garages
to determine the working condition of ramps and other accessibility
equipment, to observe procedures used by bus operators to cycle and
inspect equipment, and to determine if bus operators were familiar with
the operation of all access equipment. Three team members collected
pullout data at the Wayne Garage on Tuesday, May 10, 2005, for 38
vehicles. Two team members then collected pullout data for 32 buses at
the Oakland Garage on Wednesday, May 11, 2005. One team member collected
pullout data for 24 buses at the Macomb Garage on Wednesday, May 11,
2005.

As bus operators arrived in the garage, team members observed how they
conducted vehicle inspections and cycled/tested ramps and other
equipment. The working condition of the ramps and kneelers was noted.
Team members then entered the vehicle and examined the condition of
mobility aid securement systems and passenger restraint systems in the
wheelchair securement areas. The team members also noted the working
condition as well as the cleanliness of the securement and restraint
systems. Review team members used a standard form to record results of
the observations and inspections. A copy of this "Record of Lift
Cycling/Working Condition of Lifts and Access Features" form is included
in Attachment K.

A summary of these pullout observations is provided in Table 4.3. Note
that in some cases, not all items were observed and/or tested on every
bus. The total of the "Yes" and "No" columns therefore may not always
sum to the total number of buses observed at the garages.

As shown, the ramps deployed automatically on 85 of the 94 buses
observed. In the nine instances where the ramps did not automatically
deploy, operators were able to manually deploy the ramps. There were no
buses observed where the ramps would not deploy either automatically or
manually. In all nine instances where the ramps needed to be deployed
manually, operators pulled out on their runs and indicated that they
would note the issue on the defect cards that they submit at the end of
the day.

A check of whether the tool used to manually deploy the ramp was on
board was made on 93 of the 94 buses observed. The tool was noted to be
on board 92 of these buses. The tool could not be located by the
operator on one bus. It should be noted that while the tool was missing
on this bus, ramps can be manually deployed even without the tool by
using any available prying object (e.g., keys).

The kneelers were observed to be operational on all 94 buses that were
reviewed.

Team members inspected the mobility aid securement systems on all 94
buses. They also inspected passenger restraint systems on 90 of these
vehicles. In many cases, it did not appear that the operators routinely
inspected the working condition of the securement systems. Inspections
of the securement systems were typically done at the initiative or
request of the reviewers.

[]{#__RefHeading___Toc146615912 .anchor}Table 4. 3 -- Summary of Pullout
Observations, SMART, May 10--11, 2005

![](media/image1.wmf)

The securement systems were operational on 84 buses and the passenger
restraint systems were operational on 83 buses. Problems were noted with
one or more of the securement systems on 10 buses and problems were
noted with passenger restraint systems on seven buses. The problems
noted included securement system belts that were cut (the ends of the
belts and the hooks were missing), and retractors that were not
operating correctly. Six of the 10 buses with securement system issues
were located at the Oakland Garage. Three buses were at the Wayne Garage
and one was at the Macomb Garage. Four of the buses with passenger
restraint issues were at the Macomb Garage, two were at the Oakland
Garage, and one was at the Wayne Garage. In all 10 instances, the
problems were either fixed by yard mechanics on the spot, or the buses
were pulled into the Write-Up Line to be repaired and the operators were
assigned another bus.

Team members checked the cleanliness of securement and restraint systems
straps on 91 of the 94 buses. The straps were observed to be clean and
in good condition on 75 of these buses. On 16 buses, though, the
securement system or passenger restraint straps were not clean. Most of
the buses with dirty straps (14 of the 16) were observed at the Macomb
Garage.

Finally, 85 of the 94 drivers who were observed at pullout at the three
garages appeared to be familiar with all of the accessibility equipment
on the buses. Nine of the drivers, though, did not seem to be completely
familiar with the operation of the securement systems. The majority of
these drivers (eight of nine) worked out of the Macomb Garage.

**Ramp Repair Records**

Section 49 CFR 37.163(a) of USDOT's ADA regulations requires that
transit agencies keep accessibility of transit services in "operative
condition." Section 49 CFR 37.163(d) then requires transit agencies to
take vehicles with inoperative lifts out of service when discovered to
be inoperative and repair the lift before returning the vehicle to
service. Section 49 CFR 37.163(e) states that when there is no spare
vehicle to replace the vehicle with the inoperative lift, "the public
entity may keep the vehicle in service with an inoperable lift for no
more than . . . three days (if the entity services an area of over
50,000 population) from the day on which the lift is discovered to be
inoperative."

To determine SMART's compliance with these sections of the regulations,
the review team identified several instances when bus ramps were in need
of repair. The team then examined SMART's maintenance records to
determine if and when the repairs were made and if the vehicles were
placed back into service before the repairs were completed. The team
also reviewed data to identify patterns and potential causes of ramp
failures.

A sample of fixed route buses with ramps that were noted as needing
repairs was developed from several data sources. These included:

-   Daily inspection reports completed by drivers and CSAs on April 25,
    2005

-   Central Dispatch logs for the period from April 25 to 29, 2005

-   Maintenance Foremans' logs and records of ramp issues and ramps
    being repaired

From these various sources of information, the review team identified a
total of 18 vehicles as having ramps in need of repair. For each of
these 18 vehicles, the dates that ramp problems were reported was noted.
Team members then reviewed maintenance records with SMART maintenance
staff to determine when the final repairs were made. Table 4.4 shows the
results of this analysis. For each of the vehicles, the table includes
the garage and vehicle ID number.

The date that ramp issues were reported are then listed along with the
date that maintenance records showed the repair being completed (or
planned for completion). A column indicating the total number of days
between reported issues and final repairs is then included.

The table also includes a column that indicates whether the ramp could
be operated manually or not at all. This is important since it would be
acceptable to place vehicles back in service if the ramp could still be
manually operated by drivers.

Finally, for vehicles reported to have lifts that could not be manually
operated, the review team examined pullout records to see if the vehicle
was in service at any time prior to the date of the final repair. This
information is shown in the last column of Table 4.

As shown, of the 18 vehicles for which ramp repairs were tracked, 16
were reported to have ramps that could still be operated manually. Four
of these ramps were repaired on the same day. Eight were repaired within
one day, and two were repaired within two days. One was repaired within
eight days, and one took 15 days to repair.

The two remaining vehicles with failed ramps were identified by a
supervisor as having been damaged in an accident and inoperable both
mechanically and manually. Repairs were made or scheduled for the
vehicles 63 and 90 days from the date that the ramps were disabled. The
time required for completion of repairs resulted from the need to order
parts (new ramps). It is SMART's practice to keep one spare ramp in
stock. The lead time for replacement ramps is normally seven to 10 days
according to SMART equipment maintenance managers. Need for an unusually
high number of ramps and delay on receipt of replacement ramps appear to
have delayed replacement of ramps on these two vehicles.

SMART records show that both vehicles were used in service during the
period that they awaited repair. A review of pullout records indicate
that one vehicle, damaged on February 16, was listed on the AM pullout
sheet for May 11, even though the repair had not taken place. The second
vehicle was reported as damaged on March 9, but was listed on the PM
pullout sheet for April 29. SMART was repairing this vehicle on May 11,
the day of the observation. When the regulatory requirements for not
placing vehicles into service with inoperable lifts/ramps were brought
to the attention of SMART managers, they immediately issued a directive
to remove the first vehicle from service and rescheduled its repair to
May 12, the following day.

[]{#__RefHeading___Toc146615913 .anchor}Table 4.4 -- Repair Records for
a Sample of 18 Vehicles Reported to Need Ramp Repairs

![](media/image2.wmf)

**In-Service "Ride-Alongs"**

As part of the review, team members arranged to meet with local riders
who use wheelchairs to ride the SMART bus system. Several routes were
ridden on Tuesday and Wednesday, May 10 and 11. One rider used a power
wheelchair. Another used a power scooter. Both wheelchairs were of a
size and weight that made them "common wheelchairs" under the USDOT's
definition. While riding the SMART system, review team members also
observed one boarding at a major medical facility by another rider not
traveling with the team. For both the ride-alongs and the one random
observation, reviewers recorded whether the boarding and alighting
processes were successful, if the ramp was deployed automatically or
manually, and if the operator properly secured the rider's wheelchair.

A total of seven boardings and uses of the bus system were observed. In
all seven instances, drivers stopped, ramps were deployed successfully,
and the boarding and alighting processes were successful.

In five of the observations, drivers assisted with the securement of the
riders' wheelchair and the securement appeared to be done properly. In
the other two observations, however, the drivers did not appear to carry
out the proper procedures with the securements. In one case, involving
the rider who used a scooter, the driver only placed the shoulder belt
around the rider and did not secure the rider's scooter to the vehicle.
In the second case, involving the rider with a standard power
wheelchair, the straps were attached very loosely and did not retract to
keep the wheelchair firmly secured. The wheelchair moved during
transport and one of the rear straps disengaged.

## 5. Findings and Recommendations

This section presents the review team findings and recommendations,
based on the information collected and on-site observations. For each
numbered finding, there may be one or more corresponding
recommendations.

**Findings**

1.  Overall, SMART's fixed route bus service appears to be very
    accessible, reliable, and usable by persons with disabilities,
    including persons who use wheelchairs. SMART is to be commended for
    the numerous efforts it has made (detailed below) to make its fixed
    route service accessible and reliable.

2.  SMART operates a 100 percent accessible, low-floor, ramp-equipped
    fixed route fleet. SMART transitioned to this low-floor bus fleet
    between 2001 and 2003 by accelerating its capital replacement
    program and retiring older lift-equipped buses which had lifts that
    were becoming unreliable.

3.  The ramps on SMART's low-floor buses are designed to deploy and stow
    automatically. They also can be operated manually should the
    automatic system fail. Manual ramp operation is very quick and easy
    and was observed to present no significant delays in operations.
    Buses are therefore still usable and accessible even if the
    automated deployment system is not working. This manual backup
    option appears to have eliminated reliability issues related to
    fixed route service accessibility. Buses only become inaccessible if
    there is major damage to the ramp system (e.g., an accident). As a
    result, SMART is able to ensure that all vehicles in service are
    functionally accessible and reliable.

4.  Inspections of sample buses for each type of vehicle that make up
    the fleet found that the 40-foot Gillig buses appear to meet all
    ADAAG vehicle specifications. The 35-foot Gillig buses appear to
    meet all ADAAG specifications except for the signs designating the
    wheelchair securement locations. These signs, which have black text
    on a transparent background, do not have adequate contrast during
    evening hours when there is no back-lighting.

5.  The 29-foot Gillig buses appear to meet all ADAAG requirements
    except that the first set of forward-facing seats is not designated
    as a priority seating area.

6.  The inspection of the 29-foot Gillig buses also indicated a
    "functional" issue even though the bus is largely compliant with
    ADAAG specifications. Riders who use power scooters do not appear to
    be able to turn around inside the vehicle if one securement area is
    occupied, and can only turn around in the vehicle with great
    difficulty even if both securement locations are unoccupied. Because
    they cannot turn around inside the vehicle, riders using power
    scooters must back-up the ramp when entering the vehicle. This can
    be very difficult for some riders and could cause service delays.

7.  SMART has implemented inspection procedures that test the working
    condition of bus ramps at least twice each day, as well as during
    regular maintenance. Bus ramps are cycled by operators as part of
    the pullout process and the inspection forms used by operators
    specifically require checks of the ramp as well as the securement
    systems. Ramps are tested a second time each day by Coach Service
    Attendants (CSAs) as buses are returned to the garage. Ramps are
    also tested as part of the regular preventative maintenance program.

8.  SMART has established service policies and procedures that address
    ADA requirements. These include policies regarding the cycling of
    ramps, the use of wheelchair securement and passenger restraint
    systems, the provision of alternative backup service, the use of
    kneelers, and allowing riders with disabilities who are ambulatory
    to use the bus ramp as needed. All policies and procedures appear to
    be in compliance with ADA requirements.

9.  SMART has established detailed and effective procedures to ensure
    that alternative service is provided to riders with disabilities
    should the access features of a bus fail in service. These
    procedures have been effectively communicated to operators and
    dispatchers. In addition, SMART's use of accessible minivans as Road
    Supervisor vehicles allows these employees to quickly respond to any
    lift or ramp failures. Fortunately, with the ability to manually
    operate bus ramps, these alternative service procedures appear to be
    needed only on rare occasions.

10. SMART has developed and implemented a very thorough employee
    training program that provides comprehensive instruction on the use
    of accessibility equipment as well as on the provision of quality
    service to all riders, including riders with disabilities.
    Interaction with individuals with disabilities is part of the
    training. Employees also ride the fixed route service using mobility
    aids as part of the training to better understand the perspective of
    riders with disabilities.

11. While most SMART bus operators who were interviewed had a good
    understanding of accessibility policies and procedures, some
    operators were not aware of certain requirements for passenger
    assistance and accommodating service animals. Of the 28 bus
    operators interviewed, one said she was not allowed to physically
    push someone up or down the ramp. Another indicated that he might
    help "from his seat" by verbally providing guidance. Another
    indicated that there had been "mixed messages" about whether
    assistance should be provided and about the exact type of assistance
    to be provided. Three operators indicated that they would not allow
    a dog on board unless it had a harness or the passenger "had a
    cane," or there was some identification of the dog as a service
    animal.

12. SMART has developed a very positive working relationship with the
    bus operator union on issues related to service accessibility. The
    union appears to be a full partner in working toward an accessible
    and usable transit service for riders with disabilities. A thorough
    five-step disciplinary process also has been developed with the bus
    operator union. This process specifically includes discipline for
    violations of access policies. This innovative disciplinary process
    appears to have been aggressively implemented.

13. SMART has implemented a thorough complaint and service monitoring
    process to ensure maximum compliance with service policies and
    procedures. Monitoring involves informal "secret riders,"
    observations by National Transit Database (NTD) data checkers, as
    well as the formal complaint process. Constant monitoring of
    complaints, and rapid action on complaints, allows SMART to
    effectively monitor service quality and compliance with policies and
    procedures.

14. SMART also has developed an effective working relationship with
    riders with disabilities and appears to have an active and effective
    consumer advisory committee. This committee appears to be assisting
    in the monitoring of accessible service operations.

15. Observations of the pullout process and the working condition of
    ramps at each garage indicated that 85 of the 94 buses inspected (90
    percent) on May 10 and 11, 2005, had ramps that could be deployed
    and stowed automatically. The remaining nine could be operated
    manually. No buses observed in the pullout process had ramps that
    could not be easily operated in service.

16. Pullout observations on May 10 and 11 also indicated that all
    kneelers on the buses inspected were in good working condition.

17. Pullout observations on May 10 and 11 also indicated that all
    operators appeared to be familiar with the operation of the ramps
    and kneelers.

18. Pullout observations and bus inspections on May 10 and 11 indicated,
    however, that many operators do not appear to typically conduct a
    through inspection of the working condition of the securement and
    passenger restraint systems. Without prompting, few drivers checked
    the automatic retractors or other system features. Issues were also
    discovered with securement systems on 10 of the 94 buses inspected.

19. Team members' review of SMART's vehicle maintenance and operations
    records identified two instances during 2005 in which SMART kept
    vehicles in service with inoperable ramps for more than three days
    even though it had available accessible vehicles.

20. During seven "ride-alongs" by team members with riders who use
    wheelchairs, drivers deployed ramps and riders successfully boarded
    and traveled to their destinations. However, drivers did not always
    follow proper procedures for securements. In one case, the driver
    secured the passenger using the lap belt and shoulder harness, but
    did not secure the rider's wheelchair. In a second case, the driver
    did not properly secure the rear straps to the rider's wheelchair.

21. SMART has developed a "Guide for Creating a Transit Friendly
    Environment" that it distributes to local communities and developers
    to encourage transit-friendly design. This document provides
    guidance on accessible bus stop design. SMART also employs a bus
    stop technician/coordinator who reviews bus stop locations and
    accessibility as part of the bus route design process. These efforts
    are commendable and help ensure bus stop accessibility and usability
    of the service by riders with disabilities.

**Recommendations**

1.  SMART should replace the signage in the securement area on the
    35-foot Gilligs with signs that have proper background contrast.

2.  SMART should designate the first set of forward-facing seats on the
    29-foot Gilligs as priority seats. SMART may want to consider these
    as additional priority seats and still designate the aisle-facing
    seats in the low-floor portion of the vehicles as priority seats as
    well.

3.  SMART should consider ways to make the 29-foot Gillig buses more
    functionally usable by riders who use power scooters. This might be
    done by exploring alternatives to the floor-mounted securement bar
    in the middle of the securement area, so that move space for turning
    around can be provided.

4.  To further strengthen its already good policy concerning the
    provision of alternative, backup service, SMART should include more
    specific language requiring bus operators to inform riders of the
    exact arrangements being made to assist them when there is an
    in-service lift or ramp failure.

5.  SMART should instruct drivers to thoroughly inspect the working
    condition of securement and passenger restraint system as part of
    the pullout process. This inspection should include a check of the
    working condition of retractors. Any non-working securement systems
    noted in these inspections should then be repaired before buses are
    placed into service.

6.  SMART should establish and enforce a policy of removing from service
    any vehicle with an inoperable ramp until the ramp has been
    repaired.

7.  SMART should place additional emphasis in training, retraining, and
    service monitoring on the proper use of securement systems.
    Additional emphasis also should be given to policies related to
    assisting riders up and down ramps and on policies related to the
    accommodation of service animals.

8.  To strengthen its efforts to make bus stops accessible, SMART should
    consider adding to the bus stop portion of its website an item where
    riders with disabilities can indicate if there are bus stops that
    they would like to use that need accessibility improvements.

Attachment A

**SMART's Response**

Attachment B

**FTA Notification Letter to SMART**

Attachment C

**On-Site Review Schedule**

**ADA Fixed Route Lifts Service Review**

**Suburban Mobility Authority for Regional Transportation (SMART),
Detroit, MI**

**May 9--12, 2005**

**PROPOSED SCHEDULE**

+-------+------------------------------------+---------------+--------+
| **T   | **Activity**                       | **Who**       | **W    |
| ime** |                                    |               | here** |
+-------+------------------------------------+---------------+--------+
| **Mo  |                                    |               |        |
| nday, |                                    |               |        |
| May   |                                    |               |        |
| 9,    |                                    |               |        |
| 2     |                                    |               |        |
| 005** |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 1:00  | -   Opening Conference             | FTA, SMART,   | 660    |
| PM    |                                    |               | Wo     |
|       |                                    | Review Team   | odward |
|       |                                    |               | Ave.   |
+-------+------------------------------------+---------------+--------+
| 1:30  | -   Interview Director of          | Diane McGill, | Same   |
| PM    |     Transportation and ADA         |               | as     |
|       |     Coordinator. Review operating  | Michael       | above  |
|       |     policies and procedures, fleet | Patten,       |        |
|       |     information, service issues    |               |        |
|       |     and monitoring, and operator   | All Review    |        |
|       |     training.                      | Team Members  |        |
+-------+------------------------------------+---------------+--------+
| 2:30  | -   Interview Director of Service  | Ron Ristau,   | Same   |
| PM    |     Development. Review bus stop   |               | as     |
|       |     design and siting practices    | All Review    | above  |
|       |     and issues.                    | Team Members  |        |
+-------+------------------------------------+---------------+--------+
| 3:30  | -   Review details of recent       | Ron Ristau    | Same   |
| PM    |     ramp/accessibility related     |               | as     |
|       |     complaints.                    | All Review    | above  |
|       |                                    | Team Members  |        |
+-------+------------------------------------+---------------+--------+
| # T   |                                    |               |        |
| uesda |                                    |               |        |
| y, Ma |                                    |               |        |
| y 10, |                                    |               |        |
|  2005 |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 4:30  | -   Observe Ramp and Kneeler       | All Team      | Wayne  |
| AM    |     Cycling at Wayne Garage        | Members       | G      |
|       |                                    |               | arage, |
|       | -   Inspect Securement Systems     |               | 30000  |
|       |                                    |               | Indu   |
|       |                                    |               | strial |
|       |                                    |               | Drive, |
|       |                                    |               | I      |
|       |                                    |               | nkster |
+-------+------------------------------------+---------------+--------+
| 10:00 | -   Interview Maintenance          | All Team      | Same   |
| AM    |     Supervisor/Staff               | Members       | as     |
|       |                                    |               | above  |
|       | -   Review ramp maintenance        |               |        |
|       |     procedures and records         |               |        |
+-------+------------------------------------+---------------+--------+
| 11:   | -   Inspect Vehicles               | All Team      | Same   |
| 00AM- |                                    | Members       | as     |
|       | -   Interview Drivers              |               | above  |
| 2:00  |                                    |               |        |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 2:00  | -   Observe Service                | All Team      | NA     |
| PM    |                                    | Members       |        |
| 5:00  |                                    |               |        |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| # Wed |                                    |               |        |
| nesda |                                    |               |        |
| y, Ma |                                    |               |        |
| y 11, |                                    |               |        |
|  2005 |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 4:30  | -   Observe Ramp and Kneeler       | Don Kidston   | O      |
| AM    |     Cycling at Macomb and Oakland  | and Russell   | akland |
|       |     Garages                        | Thatcher at   | G      |
|       |                                    | Oakland       | arage, |
|       | -   Inspect Securement Systems     | Garage; David | 2021   |
|       |                                    | Chia at       | B      |
|       |                                    | Macomb Garage | arrett |
|       |                                    |               | Dr.,   |
|       |                                    |               | Troy   |
|       |                                    |               |        |
|       |                                    |               | Macomb |
|       |                                    |               | G      |
|       |                                    |               | arage, |
|       |                                    |               | 22900  |
|       |                                    |               | 15     |
|       |                                    |               | Mile   |
|       |                                    |               | Rd.,   |
|       |                                    |               | C      |
|       |                                    |               | linton |
|       |                                    |               | To     |
|       |                                    |               | wnship |
+-------+------------------------------------+---------------+--------+
| 10:00 | -   Interview Maintenance          | Same as       |        |
| AM    |     Supervisor/Staff               | above.        |        |
|       |                                    |               |        |
|       | -   Review ramp maintenance        |               |        |
|       |     records                        |               |        |
+-------+------------------------------------+---------------+--------+
| 11:   | -   Inspect Vehicles               | Same as       |        |
| 00AM- |                                    | above.        |        |
|       | -   Interview Drivers              |               |        |
| 2:00  |                                    |               |        |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 2:00  | -   Observe Service                | Same as       |        |
| PM    |                                    | above.        |        |
| 5:00  |                                    |               |        |
| PM    |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| # Th  |                                    |               |        |
| ursda |                                    |               |        |
| y, Ma |                                    |               |        |
| y 12, |                                    |               |        |
|  2005 |                                    |               |        |
+-------+------------------------------------+---------------+--------+
| 9:00  | -   Final data tabulations &       | Review Team   | 660    |
| AM    |     prepare for Exit Conference    |               | Wo     |
|       |                                    |               | odward |
|       |                                    |               | Ave.   |
+-------+------------------------------------+---------------+--------+
| 2:00  | -   Exit Conference                | FTA, SMART,   | Same   |
| PM    |                                    | Review Team   | as     |
|       |                                    |               | above  |
+-------+------------------------------------+---------------+--------+

Attachment D

**SMART's "Daily Physical Check" Form**

Attachment E

**SMARTS's Notices and Bulletins Regarding Accessible Fixed Route
Service Operation Policies and Procedures**

Attachment F

**SMART's "W/C Lift Sheet" Form**

Attachment G

**SMART's "Level B" Preventative Maintenance Checklist**

Attachment H

**SMART's Five-Step Discipline Checklist**

Attachment I

**Driver Interview Form**

**Interview of Drivers/Operators**

Transit Agency: [SMART]{.underline} Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Time: \_\_\_\_\_\_\_\_\_\_\_\_\_

Garage: Reviewer:

How long have you been a fixed route linehaul driver?

Did you receive training in operating the ramps and wheelchair
securement equipment and assisting riders with disabilities before you
began driving?

Do you feel it adequately prepared you to serve riders with
disabilities?

Have you received any updated, refresher training? When and how often?

When and how often do you test cycle the ramps?

What do you do if a ramp malfunctions when you are test cycling it?

Because the ramps can be manually operated even if they are
malfunctioning, do you sometimes pull-out with a bus that has a
malfunctioning ramp?

If you have a bus with a ramp that is not working automatically, what do
you do if you see a rider who is using a wheelchair waiting at a stop?

What do you do if a ramp malfunctions in service while you are
attempting to board a rider who is using a wheelchair?

What do you do if a rider is having difficulty getting up or down the
ramp? If you assist them, do you board them forward-facing or
rear-facing? Does the year/series of the bus make a difference in how
people are boarded? Do you assist riders with both manual or power
wheelchairs?

Have you experienced riders having difficulty getting to or positioning
themselves correctly in the securement area?

If someone using a three-wheeled "scooter" gets on the lift bus and
there are not the standard places to attach the securement system
straps, what do you do?

What do you do if a rider who is using a wheelchair refuses to let you
tie down the wheelchair?

What do you do if you start to put a seat belt on a rider who is using a
wheelchair and they refuse to wear the seat belt?

What do you do if a person with a disability gets on the bus and asks
for priority seating but the priority seats in the front are taken?

What would you do if you were boarding a rider who uses a wheelchair and
the rider wants to bring a dog on-board and says the dog is a service
animal (but the dog doesn't have a cape or harness)?

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

Attachment J

**Vehicle Specification Checklist**

Attachment K

**Pullout Checklist**

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

Transit Agency: [SMART]{.underline} Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Time: \_\_\_\_\_\_\_\_\_\_\_\_\_

Garage: Reviewer:

**Bus #:\_\_\_\_\_\_\_\_\_\_ Route #:\_\_\_\_\_\_\_\_\_\_ Lift Cycled By
(circle one): Driver / Mechanic / Starter**

**Lift/Ramp Worked?  Yes  No**

**Ramp Tool On Bus?  Yes  No**

**Kneeler Worked?  Yes  No**

ISA displayed near door?  Yes  No

Illuminated front and side destination signs?  Yes  No

Sign requesting passengers to vacate securement area upon request?  Yes
 No

**Securements available and functional?  Yes  No**

**Three-point passenger restraint available and functional?  Yes  No**

**Securements and passenger restraints clean?  Yes  No**

PA Worked?  Yes  No

Auditory & visual stop request?  Yes  No

**Operator Familiar with Equipment:  Yes  No
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

Comments:

**Bus #:\_\_\_\_\_\_\_\_\_\_ Route #:\_\_\_\_\_\_\_\_\_\_ Lift Cycled By
(circle one): Driver / Mechanic / Starter**

**Lift/Ramp Worked?  Yes  No**

**Ramp Tool On Bus?  Yes  No**

**Kneeler Worked?  Yes  No**

ISA displayed near door?  Yes  No

Illuminated front and side destination signs?  Yes  No

Sign requesting passengers to vacate securement area upon request?  Yes
 No

**Securements available and functional?  Yes  No**

**Three-point passenger restraint available and functional?  Yes  No**

**Securements and passenger restraints clean?  Yes  No**

PA Worked?  Yes  No

Auditory & visual stop request?  Yes  No

**Operator Familiar with Equipment:  Yes  No
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

[Comments:]{.underline}

[^1]: The word "lift" is used in the USDOT's ADA regulations to describe
    the accessibility feature for boarding and alighting riders using
    wheelchairs and others unable to use the steps of the vehicle.
    Similar requirements would apply to other boarding technologies and
    systems, such as ramps used on low-floor buses.