Merrimack Valley Regional Transit Authority

**Haverhill, MA**

ADA Complementary Paratransit Service

Compliance Review

March 15--18, 2005

*Summary of Observations*

**Prepared for**

**Federal Transit Administration**

**Office of Civil Rights**

**Washington, DC**

**Prepared by**

**Planners Collaborative, Inc.**

**with**

**TranSystems Corporation**

**Final Report: December 26, 2006**

CONTENTS

1

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

[**2.** **Overview** 3](#overview)

[**3.** **Background** 7](#background)

[**4.** **Summary of Findings** 11](#summary-of-findings)

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

[**6.** **Observations Regarding ADA Complementary Paratransit
Eligibility**
19](#observations-regarding-ada-complementary-paratransit-eligibility)

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

[**8.** **Observations Regarding Scheduling of Trip Requests**
42](#observations-regarding-scheduling-of-trip-requests)

[**9.** **Observations Regarding Operations**
46](#observations-regarding-operations)

> [9.1 Analysis of On-Time Performance
> 52](#analysis-of-on-time-performance)
>
> [9.2 Anaysis of Trip Length 58](#analysis-of-trip-length)

[10. Resources 65](#resources)

*Attachment A* Response from Merrimack Valley Regional Transit Authority

*Attachment B* On-Site Review Schedule

*Attachment C* Application Material for MVRTA EZ Trans Eligibility

*Attachment D* New Form for EZ Trans Eligibility (Proposed)

*Attachment E* *More Information Documentation* Form

*Attachment F* *EZ Trans Reviewer's Determination Page*

*Attachment G* Sample Letter Templates for Categories of EZ Trans
Eligibility

*Attachment H* *ADA Customer Manual*

*Non-ADA Customer Manual*

*Attachment I* Appeal Process

# 1. Purpose of the Review

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

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

The purpose of the review is to assist the transit agency and FTA in
assessing whether capacity constraints exist in ADA complementary
paratransit services. The compliance review examines service standards
and policies related to issues of capacity constraints, such as
telephone hold times, trip denials, on-time performance, on-board travel
time, and any other trip-limiting factors. The review considers whether
there are patterns or practices of a significant number of trip denials;
missed trips; early or late pickups or arrivals after desired arrival
(or appointment) times; long trips; or long telephone hold times as
defined by established standards (or typical practices if standards do
not exist). The examination of patterns or practices includes looking
not just at service statistics, but also at basic service records and
operating documents, and observing service to determine whether records
and documents appear to reflect true levels of service delivery. Input
also is gathered from local disability organizations and consumers.

FTA conducted a review of ADA complementary paratransit service provided
by the Merrimack Valley Regional Transit Authority (MVRTA), in
Haverhill, Massachusetts. Planners Collaborative, Inc., located in
Boston, Massachusetts, along with TranSystems Corp. of Medford,
Massachusetts, conducted the on-site compliance review for the FTA
Office of Civil Rights from March 15 to 18, 2005. The review focused on
compliance of MVRTA's ADA complementary paratransit service with one
specific regulatory service criterion: the "capacity constraints"
criterion. Section 37.131(f) of the DOT ADA regulations requires that
ADA complementary paratransit services be operated without capacity
constraints.

This report summarizes the observations and findings of the on-site
compliance review of "EZ Trans" paratransit service provided by MVRTA.
First, the report describes key features of EZ Trans. The report then
outlines the approach and methodology used to conduct the review. There
is a summary of observations and findings related to each element of the
capacity constraint criteria. The major findings of the review are
summarized in Section 4 of this report. Please note that findings do not
necessarily denote deficiencies, but are statements of observations made
at the time of the compliance review. Recommendations for addressing
some of the findings are also provided.

MVRTA received a draft copy of the report for review and response. A
copy of the correspondence received from MVRTA on November 7, 2006,
documenting the agency's response to the draft report is included as
Attachment A.

# 2. Overview

This review focused on compliance with the ADA complementary paratransit
capacity constraints requirements of the DOT ADA regulations. These
regulations identify several possible types of capacity constraints.
These include "wait-listing" trips, having caps on the number of trips
provided, or recurring patterns or practices that result in a
significant number of trip denials, untimely pickups, or excessively
long trips. Capacity constraints also include other operating policies
or practices that tend to significantly limit the amount of service to
persons who are ADA complementary paratransit eligible.

To assess each of these potential types of capacity constraints, the
review focused on observations and findings regarding:

-   Trip denials and "wait-listing" of trips

-   On-time performance

-   Travel times

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

-   Service area, service times, and fares

-   ADA complementary paratransit service eligibility process

-   Telephone capacity

ADA complementary paratransit eligibility determinations were assessed
to ensure that eligible individuals were not adversely affected by
inappropriate denials of eligibility for the service or unreasonable
delays in the eligibility process. Telephone capacity was assessed
because access to reservations and customer service staff is critical to
effective use of any ADA complementary paratransit service.

**Pre-review**

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

-   Description of the administrative structure of the ADA complementary
    paratransit service

-   Contract with one of the paratransit carriers

-   Rider guide to paratransit services

-   Operator handbook

-   Summary of service standards

-   Telephone call-handling standards

-   Sample driver manifests

-   Performance data for FY 2002, 2003, and 2004

-   Budget data for FY 2001, 2002, 2003, and 2004

-   MVRTA fixed route service information

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

-   Completed applications, both accepted and denied, for ADA
    complementary paratransit service

-   Copies of completed driver manifests for recent months

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

-   Data from MVRTA's telephone call management systems

-   Written consumer complaints

In addition to the review of data and direct observations, the review
team conducted telephone interviews with five individuals who either use
EZ Trans service or have clients who are EZ Trans riders.

**On-site Review**

The on-site review began with an opening conference, held at 10 a.m. on
Tuesday, March 15, 2005, at the MVRTA office at 85 Railroad Avenue in
Haverhill, Massachusetts. The following MVRTA, Planners Collaborative,
and TranSystems staff attended the conference:

Joe Costanzo MVRTA Administrator

William Hoff Merrimack Valley Area Transportation Co. (MVATC) General
Manager

Monica Anderson MVATC Assistant General Manager, Special Services

Peggy Griffin Federal Transit Administration, Region 1

Noah Berger Federal Transit Administration, Region 1

David Chia Planners Collaborative

Russell Thatcher TranSystems

Patricia Monahan TranSystems

David Chia of Planners Collaborative; Russell Thatcher and Patricia
Monahan of TranSystems; and Margaret Griffin and Noah Berger of FTA
comprised the review team. David Knight of the FTA Office of Civil
Rights participated in the opening conference via telephone.

Mr. Knight opened the meeting by emphasizing that the purpose of the ADA
compliance reviews is to help transit properties provide effective ADA
complementary paratransit service. He also thanked MVRTA staff for their
cooperation in the conduct of the review. Mr. Knight explained that:

-   Preliminary findings and an opportunity to respond would be provided
    at a closing meeting on Friday.

-   A report would be drafted and provided to MVRTA for review and
    comment before being finalized as a public document. The final
    report would be available to the public upon request under the
    Freedom of Information Act. The report will also be available on
    FTA's ADA website.

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

Following the opening conference, the team members talked with
MVRTA/MVATC managers about the history of MVRTA's special transportation
services. Team members and managers also discussed the current
arrangement of existing special transportation services and reviewed the
material provided by MVRTA prior to the site visit.

In the afternoon, the team members conducted various tasks at the MVRTA
office, including reviewing the eligibility process, the available
budget and resources, and the internal complaint system. Some team
members listened to call-takers take reservations at the end of the work
day.

On Wednesday morning, March 16, two team members visited the office of
Assist Medical Transportation Specialists in Methuen, Massachusetts.
They observed call-taking, trip scheduling, and dispatching. They also
interviewed Assist Medical's managers and drivers. Team members at the
MVRTA office continued to collect other data and observe call-taking,
scheduling, and dispatching. They also interviewed EZ Trans drivers. In
the afternoon, team members began to analyze the data collected.

On Thursday morning, March 17, team members continued their analysis of
data. This included reviewing on-time performance, trip duration, and
telephone performance. Team members also continued to review MVRTA's
eligibility certification process.

On Friday, March 18, the team members completed their on-site analysis
and prepared for the afternoon exit conference. During the exit
conference, the review team presented preliminary findings, and
discussed these findings and recommendations with MVRTA staff. In
attendance were:

Joe Costanzo MVRTA Administrator

William Hoff MVATC General Manager

Monica Anderson MVATC, Assistant General Manager, Special Services

David Chia Planners Collaborative

Russell Thatcher TranSystems

Patricia Monahan TranSystems

Cheryl Hershey (in Washington, DC) and Peggy Griffin (in Region 1) of
the FTA Office of Civil Rights participated in the exit conference via
telephone.

The review team presented initial findings in the areas of:

-   Consumer complaints

-   Service area, days and hours, and fares

-   Telephone access

-   Trip reservations and scheduling

-   Operations and dispatch

-   On-time performance

-   Trip length

-   Budget and resources

-   Eligibility certification process

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

# 3. Background

The Merrimack Valley Regional Transit Authority is a regional transit
authority that provides public transportation services to nine towns and
cities in the northeast portion of Massachusetts. Massachusetts state
law requires regional transit authorities (with the exception of the
Massachusetts Bay Transportation Authority) to use private contractors
to operate its services. MVRTA's administrator and several other MVRTA
administrative staff are direct employees of MVRTA. All other staff are
employees of the Merrimack Valley Area Transportation Company (MVATC), a
subsidiary of First Transit, Inc.

MVRTA's office and garage are located at 85 Railroad Avenue, Haverhill,
Massachusetts. MVRTA operates 24 fixed routes that serve the following
municipalities:

-   Andover

-   Amesbury

-   Haverhill

-   Lawrence

-   Merrimac

-   Methuen

-   Newburyport

-   North Andover

-   Salisbury

Some MVRTA fixed routes share bus stops with Lowell Regional Transit
Authority (LRTA) fixed routes in Lowell, enabling riders to connect from
one service to the other. MVRTA also has one commuter route that travels
between the MVRTA service area and downtown Boston (about 45 miles to
the south). MVRTA's service area is 99 square miles, with a population
of 172,406 (2000 U.S. census). The fixed route fleet consists of 30
buses, all of which are accessible to persons with disabilities.
Approximate daily ridership in FY 2004 (July 2003 to June 2004) was
5,000; total FY 2004 bus ridership was 1,354,758.

Fixed route bus service is generally available from 5 a.m. to 7:30 p.m.
on weekdays. Saturday service generally operates from 7:40 a.m. to 6
p.m. No service is provided on Sunday and certain holidays. MVRTA
maintains a website with service information at www.mvrta.com.

Base fare for MVRTA is \$1.00. Transfers are free.

**Description of the ADA Complementary Paratransit Service**

Special Transportation Services, Inc. (STS), a subsidiary of MVATC,
operates MVRTA's non-fixed route services. These include:

-   EZ Trans ADA complementary paratransit service

-   EZ Trans non-ADA service

-   "Ring and Ride" dial-a-ride services

All of these STS services are part of an integrated operation, using the
same drivers, same fleet of vans, and same call-takers, schedulers, and
dispatchers. Riders for all services are served jointly. Eligibility,
service area, days and hours, fares, and reservation policies vary for
these special services. For example, the EZ Trans ADA complementary
paratransit service follows all the ADA requirements. The non-ADA EZ
Trans service provides trips beyond the ADA service area. The non-ADA
service is available to ADA-certified riders and other individuals 60 or
older. The Ring and Ride service is actually a series of seven separate
dial-a-ride services, each with its own service area, eligibility
requirements, and days and hours of operation.

MVRTA uses two subcontractors to deliver a portion of the EZ Trans (ADA
and non-ADA) trips:

> **Assist Medical Transportation Specialists, Inc.**
>
> 455 Market Street
>
> Lawrence, MA 01843
>
> Assist Medical Transportation is a private, family-operated
> transportation provider that has been serving Merrimack Valley
> communities for a number of years. Assist Medical has provided both
> ADA and non-ADA EZ Trans service to Methuen residents since 2002.
> Previously it was under contract to MVRTA to operate the Dial-A-Ride
> and Weebus services (predecessor programs to EZ Trans). In addition to
> EZ Trans service, the company's contract work includes transportation
> services for Elder Services of the Merrimack Valley and for the
> Andover public school system.
>
> **Andover Livery**
>
> 4 Peabody Road Annex
>
> Derry, NH 03038
>
> Andover Livery is a subcontractor for limited peak overflow EZ Trans
> service. It provides only sedan service, transporting passengers who
> are ambulatory.

EZ Trans ADA complementary paratransit service provides curb-to-curb
service within 3/4-mile of an MVRTA fixed route. The fare for a one-way
ADA trip is \$2.00. Riders may pay in cash or with pre-purchased tickets
(no discount for tickets). Service is generally available from 5 a.m. to
7:30 p.m. on weekdays and from 8 a.m. to 6 p.m. on Saturdays. There is
no service on Sunday and certain holidays (same as fixed route). Riders
who want to go beyond 3/4-mile, but within the nine cities or towns, can
request the non-ADA service; these trips are not guaranteed (though
denials are infrequent). The fares for non-ADA are higher than the ADA
fare, ranging from \$3.00 to \$9.00.

In FY 2004, MVRTA served a total of 38,161 ADA complementary paratransit
trips. This compares with 40,857 ADA trips in FY 2003---a decrease of
6.6 percent. For the first six months of FY 2005, ADA ridership was
18,012.

MVRTA accepts reservations for ADA complementary paratransit service
from one to 14 days in advance. On weekdays, call-takers accept trip
requests from 8 a.m. to 4:30 p.m. These call-takers accept requests for
service provided by STS. Riders who call on Sundays or holidays can
leave a voice recording on the MVRTA phones. Individuals who want to
reserve a trip with Assist Medical call Assist Medical directly. MVRTA's
policy is not to accept any same-day trip requests or changes. Likewise,
riders must schedule times for return trips. If a rider has an uncertain
departure time for a trip, such as for returning from a medical
appointment, the rider is still required to schedule the trip for a
specific time.

As of March 2005, there were 1,782 individuals certified by MVRTA for
ADA complementary paratransit service.

**Policies and Service Standards**

MVRTA has established service standards for on-time performance, trip
denials, and travel time. The service standards are described below.

-   **On-time Performance.** Trips are considered on time when the
    vehicle arrives within 15 minutes (-15/+15) of the time agreed to
    with the rider. This 30-minute period is the "pickup window." Assist
    Medical and Andover Livery have performance targets in their
    contracts that at least 90 percent of trips each month be within the
    pickup window. STS does not have a target for trips that it
    provides.

> There is no standard for on-time drop-offs.

-   **Trip Denials.** MVRTA states that it has had no denials for ADA
    trips since FY 2003.

-   **On-board Travel Time.** MVRTA has a travel time standard that no
    EZ Trans passenger be on a vehicle for more than 60 minutes.

**Consumer Comments**

The review team gathered information about the concerns of riders who
use the ADA complementary paratransit service through three sources:
telephone interviews with riders or professionals who work with riders;
and written and telephone complaints to MVRTA.

The review team interviewed five individuals who use the ADA
complementary paratransit service or have riders who are clients (e.g.,
transportation coordinators at agencies and hospitals). The issues
brought up by these individuals concerning EZ Trans service include:
on-time pickups; eligibility recertification and conditional
eligibility; and standby policy. MVRTA had on file five complaints from
2002 and 2003. Individuals cited unjustified no-shows, the suspension
policy, and rude drivers.

FTA had one complaint on file concerning MVRTA's EZ Trans service, which
was filed in December 2003 by the Northeast Independent Living Program,
a social service agency in the Merrimack Valley. This complaint covered
several topics, including:

-   Application for ADA complementary paratransit service

-   Appeal process

-   Pickup window

-   Suspension policy

MVRTA and the FTA Regional Office have been working to resolve the
issues in the complaint. Remaining issues are being addressed as part of
this compliance review.

**Complaint Procedures**

The MVRTA Office of Special Transportation Services is the repository
for complaints and compliments on service provided by STS and the two
subcontractors. The EZ Trans ADA Customer Manual---a brochure describing
the ADA complementary paratransit service---encourages riders to contact
the office with complaints or compliments, and includes MVRTA's address,
phone number, and e-mail address. When MVRTA receives a formal
complaint, the Assistant General Manager for Special Services sends a
letter to the customer, informing him or her that the matter will be
investigated and MVRTA will respond to the customer within 10 days.

For complaints involving STS service, the Assistant General Manager for
Special Services investigates the incident with the appropriate STS
driver or other staff member. For complaints involving service provided
by Assist Medical or Andover Livery, the Assistant General Manager for
Special Services types a summary of the complaint and forwards the
information to the contractor.

The Assistant General Manager for Special Services reported that some
issues raised by customers do not require an investigation but rather an
explanation of EZ Trans policies, which is handled over the phone. Very
few written complaints are received; only one complaint had been filed
since the current director assumed her position in June 2004. That
complaint involved rude behavior and a lack of passenger assistance on
the part of an Assist Medical driver. After meeting with the Assistant
General Manager for Special Services, Assist's management immediately
removed the driver from that route, and the adult day program personnel
who filed the complaint were notified of the action by phone within
several days of the complaint date.

# 4. Summary of Findings

This section of the report summarizes the findings drawn from the
review. Please note that findings do not necessarily denote
deficiencies, but are observations related to potential capacity
constraints made at the time of the compliance review. The bases for
these findings are addressed in the following sections of this report.
The findings should be used as the basis for any corrective actions
proposed by MVRTA. Recommendations are also included in the report for
the consideration of MVRTA in developing corrective actions.

**A. Findings Regarding Service Parameters**

1.  MVRTA's EZ Trans service appears to meet regulatory requirements
    regarding service area, trip purpose, and fares.

2.  On Saturdays, MVRTA does not appear to meet regulatory requirements
    regarding comparable days and hours of service. Fixed route service
    is in operation on five routes starting at 7:40 a.m., while EZ Trans
    does not make its first pickup until 8 a.m. Route 51 runs until 7:22
    p.m. and Route 1 runs until 6:25 p.m. on Saturdays, whereas the last
    drop-off for EZ Trans ADA complementary paratransit service on
    Saturdays is scheduled for 6 p.m.

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

1.  Most individuals who apply to MVRTA for ADA complementary
    paratransit service receive unconditional eligibility. For 185
    determinations made during the first six months of FY 2005, 162 of
    185 applicants (87.6 percent) received unconditional eligibility.
    Only four applicants (2.2 percent) were determined not eligible.

2.  A review of recent denials indicated that in some cases the reasons
    used to deny eligibility were not appropriate. Two applicants were
    denied eligibility because they lived outside the ADA complementary
    paratransit service area. Also, it appears that staff may be
    inappropriately considering vehicle ownership and the ability to
    drive as factors in ADA complementary paratransit eligibility
    determinations. Two applicants were incorrectly sent denial
    letters---rather than requests for more information---because they
    had submitted incomplete applications.

3.  MVRTA appears to be encouraging use of its accessible fixed route
    services and is granting conditional eligibility to applicants who
    are able to use fixed route bus services some of the time. In the
    first six months of FY 2005, 10.3 percent of applicants were granted
    "ADA conditional" or "ADA conditional and Non-ADA" eligibility. For
    several individuals, MVRTA granted conditional eligibility only for
    "extreme weather," while other barriers such as travel distances
    to/from bus stops and path-of-travel barriers (i.e., accessible and
    safe paths of travel) were not fully considered. One applicant
    received conditional eligibility for a specific trip purpose (trips
    to dialysis) rather than on the more appropriate functional issue
    (when severe fatigue prevents use of the fixed route service).

4.  As of the time of the review team's site visit, MVRTA was not
    enforcing conditional eligibility and was providing trips to riders
    with conditional eligibility as if they had full ADA complementary
    paratransit service eligibility.

5.  MVRTA's application form for paratransit service appears to be
    potentially confusing to applicants. MVRTA has been working to
    revise the current EZ Trans application form in response to concerns
    raised by local riders and a local disability agency. A proposed new
    application form was developed and forwarded to FTA in July 2004.
    This proposed new application form does appear to address several of
    the concerns raised. However, some information included in the
    application packet still appears to be potentially confusing to
    applicants. Certain questions in the proposed application are too
    narrow, while other questions do not address issues related to an
    applicant's functional abilities.

6.  A review of 144 randomly selected applications found that MVRTA made
    all eligibility determinations within 21 days of the receipt of
    completed applications. Most decisions (89 percent) were made in 14
    days or less.

7.  MVRTA's current "Service Disruptions" policy does not appear to
    comply with Section 37.125(h) of the DOT ADA regulations. This
    section allows for a suspension of service, for a reasonable period
    of time, for a "pattern or practice of missing scheduled trips." The
    practice of suspending riders for no-showing or late canceling only
    three trips in 60 days may not always constitute a true "pattern or
    practice." For a rider who travels only a few times each month,
    missing three trips in 60 days might be a pattern or practice. For
    riders who travel on a daily basis, however, three trips in 60 days
    would be less than 4 percent of their total scheduled trips.

8.  The types of "service disruptions" included in MVRTA's policy also
    do not all appear to be consistent with Section 37.125(h) of the
    regulations. This section of the regulations allows suspensions of
    service for a pattern or practice of "missing scheduled trips." A
    passenger's providing a wrong address or failing to inform MVRTA of
    an address change does not necessarily lead to a trip being missed.
    If it did, this disruption would be covered as a no-show. Also,
    while MVRTA has a right to refuse to provide a trip to a rider who
    refuses to pay the fare, the regulations do not provide for a
    suspension of future service for failure to pay a fare.

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

1.  Both MVRTA and Assist Medical schedule an adequate number of
    call-takers to handle the volume of calls received promptly. Review
    team members observed virtually no calls that were placed on hold.
    There does not appear to be a pattern of excessively long hold times
    that would discourage riders from attempting to use the EZ Trans
    service.

2.  MVRTA does not have a standard for telephone performance.

3.  MVRTA accepts trip requests via voicemail on weekends and holidays
    before service. However, its public information states that trip
    requests are accepted only on weekdays. One of the call-takers
    stated that reservations can be made only on weekdays.

4.  Some riders did not get a confirmed pickup window at the time of
    their call. MVRTA asks them to call back to get the pickup window.
    However, MVRTA does guarantee the requested trips to all riders.

5.  Call-takers were consistent in confirming the scheduled pickup time
    in terms of a 30-minute window, rather than a precise time.

6.  Call-takers were not consistent in confirming other components of
    the trip request, such as addresses, telephone numbers, use of
    mobility devices, and need for a personal care attendant (PCA).

7.  MVRTA riders who want to travel to the Lowell Transit Center
    sometimes need to transfer to LRTA's Road Runner ADA complementary
    paratransit service. When they need to make this transfer, the rider
    is responsible for booking the second stage of the trip.

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

1.  Scheduling of trip requests does not appear to contribute to missed,
    late, or long trips.

2.  At the time of the review, Special Services was scheduling about 200
    passenger trips per weekday, and 30 to 50 passenger trips per
    Saturday. About half of Special Services trips are subscription
    service.

3.  MVRTA schedulers assign 0 to 40 trips per day to Andover Livery, all
    ambulatory passengers. Andover Livery creates schedules for these
    trips.

4.  Assist Medical takes reservations for the trips that it provides,
    and prepares its own vehicle schedules. About 80 percent of its
    trips are subscription. It is able to create its schedules with the
    help of an Excel spreadsheet.

**E. Findings Regarding Operations**

1.  MVRTA has EZ Trans service standards for trip denials, on-board
    travel time, missed trips, and passenger no-shows.

2.  MVRTA has a standard for on-time pickups for Assist Medical and
    Andover Livery, but not for trips provided in-house. There is no
    standard for on-time drop-offs.

3.  The review team did not observe any practice by EZ Trans dispatchers
    that limited or denied service to its riders. One limitation in the
    existing design of the technology, however, was the lack of
    connection between the mobile data terminals (MDTs) and the ADEPT
    software used by the dispatcher. Dispatchers must manually transfer
    information from one system to the other.

4.  MVRTA uses Andover Livery as a subcontractor for EZ Trans service.
    Andover Livery provides about 25 ambulatory trips per day.

5.  MVRTA also uses Assist Medical as a subcontractor for EZ Trans
    service. Assist Medical's operations are independent of MVRTA's
    in-house operations. Assist Medical provides 40 to 50 trips per
    weekday.

**E.1. On-Time Performance**

1.  MVRTA does not appear to have any substantially late pickups or
    drop-offs.

2.  On-time performance for MVRTA's paratransit services is very good.
    Based on an analysis of selected trips performed during the week of
    February 14 to 18, 2005, pickups were on time or early 97.1 percent
    of the time. Drop-offs also were on time or early 96.4 percent of
    the time. Less than 1 percent of pickups were more than 10 minutes
    late and less than 1 percent of drop-offs were more than 15 minutes
    late. Very early pickups and drop-offs also did not appear to be an
    issue. In almost all cases, it appears that early pickups and
    drop-offs were the result of riders completing their business early
    and calling to arrange for pickups earlier than originally
    scheduled.

3.  While on-time performance appears to be very good, data collection
    and performance monitoring among the three service providers vary.
    Assist Medical does not record actual pickup and drop-off
    information for trips assigned to non-MVRTA vehicles. Andover Livery
    records only drop-off times and not pickup times. Also, Assist
    Medical does not record appointment times.

4.  While on-time arrival performance appears very good, MVRTA does not
    regularly monitor drop-off times for trips that have appointment
    times.

E.2. Trip Length

1.  EZ Trans does not appear to operate any significantly long ADA
    complementary paratransit service trips.

2.  An analysis of the 168 trips provided by MVATC on February 16, 2005,
    indicated an average trip length of 20 minutes. Most trips (79
    percent) were completed in 30 minutes or less. Virtually all trips
    were completed in 60 minutes or less. Only one trip in the sample
    took longer than 60 minutes.

3.  Analysis of the 126 EZ Trans trips provided by Assist Medical on
    February 15, 16, and 17, 2005, showed an average trip length of 11
    minutes. The maximum trip length during these three days was 33
    minutes.

4.  When the actual travel times of 11 long EZ Trans trips (45 minutes
    or longer) served by MVATC on February 16, 2005, were compared with
    the estimated travel times for comparable fixed route trips, EZ
    Trans travel times were shorter in all cases but one. The average
    travel time for the sample of EZ Trans trips was 53 minutes, while
    the average fixed route travel time was 80 minutes. Fixed route
    trips involved an average of 1.6 transfers, and 24 minutes of
    walking time to and from bus routes.

5.  Only one of the 11 trips in the review team's sample exceeded the
    MVRTA standard of 60 minutes.

6.  Trip duration for Andover Livery could not be analyzed because the
    carrier does not record pickup times.

**F. Findings Regarding Resources**

1.  MVRTA provides sufficient financial resources to serve all demand
    for ADA complementary paratransit service.

2.  In projecting the required resources and developing the budget,
    MVRTA looks at EZ Trans ADA and non-ADA service as a single
    operation. MVRTA estimates the costs of its ADA complementary
    paratransit service by prorating the total EZ Trans costs by the
    proportion of ADA ridership.

3.  MVRTA has sufficient staff and equipment to meet all demand for EZ
    Trans service.

4.  The availability of Assist Medical and Andover Livery provides MVRTA
    with the flexible capacity to handle the existing demand for EZ
    Trans service.

# 5. Service Parameters

The review team compared EZ Trans service with MVRTA's fixed route
service to determine whether it meets the DOT ADA regulations with
respect to the following areas:

-   Service area (49 CFR 37.131(a))

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

-   Fares (49 CFR 37.131(c))

The review team analyzed consumer complaints; assessed information
distributed to riders; reviewed EZ Trans policies regarding service
area, days and hours, and fares; and interviewed MVRTA/MVATC staff.

The consumers interviewed by the review team did not mention any
concerns about service area, days and hours, or fares. Among the
complaints recorded by MVRTA that the team reviewed, service parameters
were not an issue.

**ADA Complementary Paratransit Service Area**

Section 37.131(a) of the DOT regulations implementing the ADA requires
that complementary paratransit service be provided, at a minimum, in all
areas that are within 3/4-mile of non-commuter public fixed route
services.

MVRTA's stated ADA complementary paratransit service area, which
consists of a 3/4-mile corridor on each side of a fixed bus route, meets
the regulatory requirement. MVRTA bus service operates in the
communities of Amesbury, Andover, Haverhill, Lawrence, Merrimac,
Methuen, Newburyport, North Andover, and Salisbury. Service is also
provided to the Stateline Plaza in Plaistow, New Hampshire (on Route 13)
and to the Lowell Regional Transit Authority's (LRTA) Lowell Transit
Center (on Route 41). Fixed route service operates "closed door" (i.e.,
no stops for passengers to board or alight) between the MVRTA service
area boundary and Lowell. As noted earlier, non-ADA EZ Trans service is
provided beyond the 3/4-mile corridor in these communities.

When ADA-eligible riders make a trip request, the ADEPT software system
used by call-takers checks the coordinates of the origin and destination
to ensure that both are within the ADA service area. If either the
origin or the destination is outside the ADA area, a pop-up window
alerts the call-taker; if the call-taker proceeds with booking the trip,
the non-ADA fare for the trip is displayed. (When booking a trip,
call-takers are also able to display a map that shows the 3/4-mile area
around the origin and destination points, and the bus routes in
operation in those areas.)

ADA complementary paratransit service is provided to destinations within
3/4-mile of Stateline Plaza in Plaistow, New Hampshire. Service to the
Lowell Transit Center is provided either directly, or by means of a
transfer at a designated spot on the Methuen/Dracut line to Road Runner,
LRTA's paratransit service. The rider is responsible for booking the
second stage of the trip with Road Runner. In the past, MVRTA has tried
to help coordinate vehicle transfers; however, MVRTA managers said that
this has been hindered by communication difficulties that LRTA has had
with its paratransit fleet.

**Days and Hours of Service**

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

MVRTA fixed route service generally operates from 5 a.m. until 7:30 p.m.
on weekdays. Route 1 runs until 7:40 p.m.; Route 51 runs until 7:52 p.m.
On Saturdays, fixed route service generally operates from 7:40 a.m.
until 6 p.m. on Saturdays. Route 1 runs until 6:25 p.m. on Saturdays and
Route 51, a regional route that operates between Haverhill and
Newburyport, is in service until 7:22 p.m. on Saturdays.

On weekdays, MVRTA provides EZ Trans service during these same days and
hours. On Saturdays, EZ Trans service does not provide trips at the
beginning and end of the fixed route service hours.

MVRTA's ADA Customer Manual states that EZ Trans service is available
between 5:30 a.m. and 7:30 p.m. on weekdays. The first available pickup
window on weekdays is 5 to 5:30 a.m., and the last drop-off is scheduled
for 8 p.m. On Saturdays, EZ Trans operates between 8 a.m. and 6 p.m. On
Saturdays, the first available pickup window is between 8 and 8:30 a.m.,
and the last drop-off is scheduled for 6 p.m.

Assist Medical Transportation, which serves ADA-eligible and non-ADA
residents of Methuen traveling to the communities of Andover, Lawrence,
Methuen, and North Andover, provides service between the hours of 5 a.m.
and 8 p.m. on weekdays only. Most of Assist's customers are longstanding
users of MVRTA paratransit service in Methuen. They have been traveling
with Assist Medical since it operated Dial-A-Ride and Weebus service for
MVRTA in the 1980s and 1990s. Assist Medical's customers are informed
that they can reserve trips for Saturdays by calling the MVRTA Office of
Special Services.

**Fares**

Section 37.131(c) of the DOT ADA regulations requires that complementary
paratransit service fares be no more than twice the base, non-discounted
fixed route fare for a comparable trip.

The one-way fare on the MVRTA fixed route system is \$1.00. The one-way
fare for an EZ Trans ADA complementary paratransit trip is \$2.00,
exactly two times the fixed route fare.

**Trip Purpose**

Section 37.131(d) of the DOT ADA regulations requires that there be no
restrictions or priorities based on trip purpose in the provision of ADA
complementary paratransit service.

The MVRTA EZ Trans ADA Customer Manual makes no mention of eligible or
priority trip purposes. Observations by review team members of the
reservations and scheduling functions at STS and Assist Medical did not
indicate that staff are prioritizing trips in any way. No consumer who
was contacted prior to the review noted that trip purpose restrictions
are an issue.

**Findings**

1.  MVRTA's EZ Trans service appears to meet regulatory requirements
    regarding service area, trip purpose, and fares.

2.  On Saturdays, MVRTA does not appear to meet regulatory requirements
    regarding comparable days and hours of service. Fixed route service
    is in operation on five routes starting at 7:40 a.m., while EZ Trans
    does not make its first pickup until 8 a.m. Route 51 runs until 7:22
    p.m. and Route 1 runs until 6:25 p.m. on Saturdays, whereas the last
    drop-off for EZ Trans ADA complementary paratransit service on
    Saturdays is scheduled for 6 p.m.

**Recommendations**

1.  On Saturdays, MVRTA should provide EZ Trans service to ADA-eligible
    individuals beginning at 7:40 a.m. Along the corridors served by
    Route 1 and Route 51, MVRTA should extend EZ Trans service hours on
    Saturdays until the end of fixed route service hours.

# 6. Observations Regarding ADA Complementary Paratransit Eligibility

As detailed in Section 3 of this report, MVRTA provides several types of
paratransit service, including ADA complementary paratransit service,
service for persons 60 years of age or older, and general public demand
responsive service. The EZ Trans program serves the first two types of
riders: those who are ADA paratransit eligible and those 60 years of age
or older. A single application form is used by MVRTA to determine
eligibility for the EZ Trans program. This single form is used to
qualify applicants as either "ADA eligible" or "Non-ADA eligible."
Persons who apply based solely on age are considered "Non-ADA eligible."

The team reviewed the process used to determine EZ Trans paratransit
eligibility and the timeliness of the processing of requests for
eligibility to ensure that determinations of ADA paratransit eligibility
are being made in accordance with the regulatory criteria and in a way
that accurately reflects the functional ability of applicants. The team
also looked at MVRTA's no-show policy and the application of this
policy. Team members conducted the following activities to review
eligibility and no-show policies and practices:

-   Assessed current eligibility materials, public information, and
    interview questions used by eligibility determination staff to
    understand the current eligibility determination process and no-show
    policies

-   Gathered information about the number of individuals certified for
    each type of paratransit service from the master rider files

-   Reviewed the paratransit eligibility determination outcomes for 898
    applications received between July 1, 2003 and December 31, 2004

-   Reviewed no-show suspension records for the period from January 1,
    2004 to March 11, 2005

-   Reviewed the application files of 25 recent applicants who had been
    granted conditional ADA paratransit eligibility or who had been
    denied ADA paratransit eligibility

-   Reviewed a random selection of 78 recent files and noted the elapsed
    time between the receipt of a completed application and the final
    determination letter

**Consumer Comments**

MVRTA's ADA paratransit eligibility determination process was the
subject of a complaint filed with the FTA in 2002. This complaint
(#02-0089) claimed several problems with the eligibility determination
process.

First, the complaint claimed that the application form used by MVRTA to
determine ADA paratransit eligibility was overly complex, detailed,
intrusive, and vague. Questions related to current fixed route use,
recent travel, and frequently made trips were claimed to be unrelated to
determining ADA paratransit eligibility. Questions about the applicant's
living situation were seen as intrusive. Questions about the need to
travel with a personal care attendant (PCA) were seen to not address all
possible types of assistance needed. And questions in the application
form about the effects of weather on the applicant's travel abilities
were portrayed as vague and inconsistent.

Second, the complaint also claimed that eligibility was being
inappropriately limited to only "extreme weather" conditions while
applicants also had travel limitations for other reasons.

Third, the complaint claimed that the documentation sent to persons
determined eligible did not clearly explain conditional eligibility,
such as eligibility related to "extreme weather." It was also claimed
that the information provided did not note that service would be
provided if an appeal was filed and not decided in a timely manner.

Finally, the complaint claimed that appeals of eligibility
determinations were being handled in an "ad hoc" fashion and that
in-person hearings were not being provided. It also claimed that appeal
decisions were being communicated orally (by phone) rather than in
writing as required by the DOT ADA regulations.

As noted in the "Overview" section of this report, to prepare for the
site visit, team members had phone conversations with five riders,
advocates, and disability agencies to discuss MVRTA's paratransit
programs and services. Several of these individuals raised the issue of
eligibility being granted only for "extreme weather" conditions. They
did not, however, have other concerns about the eligibility
process---such as the application form or the appeals process.

Other than the formal complaint on file with FTA, a review of internal
complaints on file with MVRTA did not identify other rider concerns
about the eligibility determination process.

**Overview of the Eligibility Determination Process and Materials**

The following paragraphs describe each part of MVRTA's ADA paratransit
eligibility determination process, including initial determination, the
types of eligibility granted, determination letters and documentation,
appeals, and recertification.

**Initial Determination Process**

Persons looking for general information about MVRTA's paratransit
services, or who are interested in applying to be eligible for the
services, typically call the main Office of Special Services number.
Call-takers or other operations staff who handle these calls provide
general information about the services and send application materials if
requested. Callers interested in applying for paratransit eligibility
are sent a packet that includes:

-   Cover letter

-   Two pages of questions and answers about ADA complementary
    paratransit eligibility

-   One-page "optional form"

-   10-page application form

Copies of this initial application material are provided in Attachment
C.

The brief cover letter informs potential applicants that MVRTA's EZ
Trans service follows the guidelines set forth in the DOT ADA
regulations. It references an enclosed two-page flyer, "Frequently Asked
Questions Regarding Services for Persons with Disabilities." The main
purpose of the cover letter is to provide prospective applicants with
background information about ADA paratransit eligibility and to
encourage them to read the information before completing the application
form.

The "Frequently Asked Questions" flyer explains the nature of ADA
paratransit eligibility and describes recent trends in eligibility
determination---specifically the trend toward use of in-person
functional assessments by transit agencies. The questions and answers
were taken from the website of Easter Seals Project ACTION. While the
information accurately describes ADA paratransit eligibility, the
language is somewhat sophisticated and written more for transportation
professionals than potential applicants. For example, the description of
the recent trend toward functional assessments might appear confusing to
some applicants since MVRTA's eligibility process does not involve
functional assessments. The information does clearly stress, though,
that ADA paratransit eligibility is based on functional abilities
related to fixed route use and not just on a particular type of
disability.

The one-page "optional form" invites applicants to describe in
open-ended responses why they might qualify for ADA paratransit
eligibility. The form presents the two main categories of eligibility
that apply in the MVRTA area. The third regulatory
category---accessibility of fixed routes---is not included since all
MVRTA vehicles are accessible. The form includes regulatory language
regarding the categories of eligibility and applicants are asked to
indicate why they meet one or both of the criteria. The instructions at
the top of the form explain that the responses to questions are
"optional and in addition to your completed application" and are "only
intended to help you explain why you feel you should be ADA eligible."
Again, this part of the application packet appears to be intended to
stress the fact that ADA paratransit eligibility is related to a
functional inability to use the fixed route service.

The required application form includes several sections. The first page
provides general information and instructions for completing the form.
These instructions describe MVRTA's EZ Trans program and explain that
applicants can qualify for the service as either "ADA eligible" or
"Non-ADA eligible." They then note that individuals seeking ADA
eligibility must complete all parts of the form while those seeking
"Non-ADA" eligibility only need to complete Parts A and C. The
instructions note that "the MVRTA will process the application within 21
days of receipt. An incomplete application will be returned to you,
which could delay the processing of your application." Finally, a phone
number is provided should individuals have questions or need assistance.

Part A of the application form is to be completed by all applicants. It
requests general information such as name, address, phone number, and an
emergency contact. The applicant's age also is requested since this is
the main piece of information used to qualify applicants based on age as
"Non-ADA eligible." It also asks if the applicant uses any mobility aids
and whether the person already has an EZ Trans ID card (i.e., is seeking
recertification).

Part B of the application form is then only to be completed by persons
applying for ADA eligibility. It is three pages and includes 21 required
questions and one optional question. These questions ask about current
modes of travel, types of mobility aids used, prior experiences using
the MVRTA fixed route service, and several questions related to
functional ability (e.g., maximum walking distance, ability to stand and
wait for a bus, ability to follow written or oral instructions, ability
to communicate with the bus driver, ability to climb bus steps, and to
get from a bus stop to a final destination). This part of the
application also asks about the need for a PCA, whether the applicant's
disability is permanent or temporary, and if the applicant's disability
is affected by the weather. Finally, it asks if the applicant lives
alone, for information about the applicant's housing arrangement, and
for very detailed information about what types of trips the applicant
makes and how often he or she makes each type of trip (this last
information is "optional").

Part C of the application is a signature page. The applicant is
requested to sign an "agreement" that acknowledges that an incomplete
application will be returned and could delay the review process, that
the information provided is true to the best of the applicant's
knowledge, that incorrect information could result in eligibility being
revoked, and that the applicant will abide by the policies of the EZ
Trans program. If the application form is completed by a third party,
that person's name, address, and phone number are requested. A signature
from that person indicating that the information provided is correct is
also requested. This part of the application also provides information
about the appeal process. This description of the appeal process notes
that appeals must be filed within 60 days and that service will be
provided if a decision is not made within 30 days of the receipt of the
appeal.

Finally, Part D of the application form requests "professional
verification" of disability and functional abilities by a "health care
professional." This part of the application must be completed if the
applicant is requesting ADA eligibility. The first page of this part of
the application provides instructions to the professional. It explains
the nature of ADA paratransit eligibility and stresses that it is based
on an applicant's inability to use the fixed route bus service. The
professional is then asked 10 questions about the applicant's
disability, functional abilities related to fixed route bus use, types
of mobility aids used, and need to travel with a PCA.

MVRTA has been working to improve the current application form to
address the concerns raised in the formal complaint received by FTA. A
new, revised application form was developed and forwarded to FTA in July
2004. The new form makes changes to one of the questions regarding the
need for a PCA, deletes the questions about personal living situation
and specific types of trips by trip purpose, and broadens the questions
about how weather affects travel to be more general and to ask about any
conditions that might affect travel. A copy of the proposed new form is
provided in Attachment D. MVRTA has not started to use the new form. It
has requested input from FTA before finalizing the changes and printing
new forms.

When the Office of Special Services receives an application, EZ Trans
staff first reviews it for completeness. If minor omissions are noted
(e.g., a subpart of a question is not completed), this information is
requested by phone as part of the review. If there are major omissions,
such as an incomplete professional verification or missing signatures in
Part C, the application form is copied, a copy is kept on file, and the
original is returned with a cover letter noting that the application was
considered incomplete. The incomplete portions of the application are
highlighted and the cover letter is attached.

Completed forms are forwarded to the Director of Paratransit Operations.
She reviews all applications and makes all final determinations. The
director noted that she often contacts either the applicant or the
professional providing verification if the information provided in the
application form is unclear or inconsistent. She estimated that
follow-up telephone contact is made for about a third of the
applications. These follow-up contacts are documented on a "More
Information Documentation" form (see Attachment E).

Based on information provided in the application and obtained through
follow-up contacts, the Director of Paratransit Operations then
completes an "EZ Trans Reviewer's Determination Page" (see Attachment F)
which summarizes the eligibility determination. This form summarizes the
key information regarding the applicant's ability to get to/from bus
stops, get on/off fixed route buses, and "travel on the fixed route
system" (i.e., navigate the system). At the bottom of the form, the
director notes the type of eligibility to be granted, provides notes on
any conditions of eligibility to be established, and signs the form.

Support staff in the Office of Special Services then prepare eligibility
determination letters and packets using the completed "Reviewer's
Determination Page" forms.

MVRTA also has developed a database to track applications through the
process and to record final eligibility determinations. This database
includes the date that application material is sent out, applicant
information (name and address), the date the application was first
received, the type of current eligibility (for applicants reapplying),
the type of eligibility to be granted based on the review, the date the
final decision was made, and the new eligibility expiration date based
on the latest review.

**Types of Eligibility Granted**

MVRTA grants the following types of eligibility for EZ Trans service.

-   **ADA.** This eligibility is granted to applicants who are
    determined to need ADA complementary paratransit service under all
    conditions. These individuals can use the EZ Trans service on a
    "next day" basis, during all hours of operation, throughout the
    service area, without restrictions, and at the ADA fare.

-   **ADA Conditional.** This eligibility is granted to applicants who
    can use the fixed route bus under some conditions but who need ADA
    complementary paratransit service at other times. Eligibility for
    service can be restricted to those times that the stated conditions
    apply. However, as of the on-site review, MVRTA was not enforcing
    the conditions of eligibility when riders were making trip requests.

-   **Non-ADA.** This eligibility is granted to persons who are 60 years
    of age or older and who either have not requested ADA eligibility or
    have been found not to qualify for ADA eligibility. These people
    must request trips at least two days in advance, pay a higher
    non-ADA fare, and receive service during more limited hours of
    operation. Non-ADA service also is not guaranteed and trip requests
    for these riders can be denied (although the review indicated that
    both ADA and non-ADA services were being provided without
    constraints).

-   **ADA Conditional and Non-ADA.** This type of combined eligibility
    is granted if applicants are determined to be "ADA conditional" and
    are also 60 years of age or older. People receiving this type of
    eligibility can use the EZ Trans service on a "next day" basis at
    the ADA fare and during all hours of operation when their "ADA
    conditional" eligibility applies. They also can then use the service
    as non-ADA riders (at a higher fare and during more limited hours)
    at times when their ADA conditions of eligibility do not apply.
    However, since MVRTA has not been enforcing conditional eligibility,
    people currently receiving this eligibility status have been
    receiving full ADA service.

-   **Temporary.** This eligibility is granted if applicants indicate
    that their disability is not permanent, or if their functional
    abilities are expected to change in the short-term. Otherwise,
    eligibility is granted in each of the above categories for a period
    of three years.

As noted in the "Consumer Comments" earlier in this section, one of the
major concerns expressed in the formal complaint, as well as by riders
and advocates contacted in advance of the on-site visit, was the use of
"extreme weather conditions" as a condition of eligibility. The issue
was discussed with MVRTA staff, who confirmed that "extreme weather" is
one of the more prevalent types of eligibility conditions that MVRTA
applies. They acknowledged that this condition of eligibility is not
well defined. Letters of determination that include this condition do
not appear to define what constitutes "extreme weather." The term also
is not defined in the ADA Customer Manual or other eligibility
materials. MVRTA staff noted that "extreme weather" is defined
internally as any type of severe weather condition that could affect
travel, including snow, ice, rain, severe heat, or severe cold. There
was general agreement that this broad definition could not easily be
implemented and that if trip eligibility were to be pursued, more
specific weather-related conditions appropriate to each applicant would
need to be identified.

**Eligibility Determination Documentation**

MVRTA sends final letters of determination to all applicants.
Individuals determined "ADA eligible" or "ADA conditional" receive a
letter and an ADA Customer Manual. Persons determined "Non-ADA eligible"
receive a letter and a Non-ADA Customer Manual. Persons determined both
"ADA conditional" and "Non-ADA eligible" receive a letter and both
customer manuals.

Individuals who are determined not eligible for ADA complementary
paratransit service receive a letter and a copy of MVRTA's ADA Appeal
Process. The third paragraph of the letter is customized to indicate the
specific reason or reasons for the determination. The letter then
informs applicants of their right to appeal, notes that appeals must be
filed within 60 days, and refers applicants to the enclosed appeal
process information. The appeal process information also notes that
applicants have a right to be heard in person and to have others attend
and speak on their behalf. If an in-person appeal is requested, the
appeal process information notes that MVRTA will provide transportation
at no cost to the applicant. Finally, the letter encourages applicants
found not eligible to consider applying for an "Access Pass," which
allows for reduced fare travel on fixed route service. The appeal
process information page notes the required timeline for appeals and
also indicates that service will be provided if an appeal decision is
not made within 30 days of the date the appeal request is received.

Applicants whose eligibility is conditioned (either "ADA conditional" or
"ADA conditional and Non-ADA") also receive copies of the appeal process
information. The letters to these individuals also request that they
"contact the MVRTA Office of Special Services as soon as possible so
that corrections can be made" if they do not agree with the
determination.

Sample templates for each type of determination letter are presented in
Attachment G. Attachment H includes the EZ Trans ADA Customer Manual and
Non-ADA Customer Manual. A description of the appeal process appears in
Attachment I.

**Appeal Process**

The MVRTA policy on appeals of initial determinations requires that
applicants file a written request for an appeal within 60 days of the
date of the initial determination letter. When MVRTA receives a request
for appeal, the Director of Paratransit Operations first conducts an
informal review of the initial determination. This informal review will
consider any additional documentation or information presented in the
appeal request. If this informal review suggests that the initial
determination should be changed and the applicant found to be fully ADA
eligible, the applicant is called, informed of the change, and sent a
new eligibility determination letter.

If the informal review does not find the applicant should have full ADA
eligibility, the appeal request, along with the complete application
file, is forwarded to the MVRTA's Appeal Officer. The Appeal Officer is
an individual under contract with MVRTA to consider and make
determinations on appeals. She is a certified occupational therapist
with a degree in psychology and a clinical professor in occupational
therapy, physical therapy, and health and rehabilitation services at
Boston University. MVRTA has given her the final decision on appeals.

After reviewing the application file, the Appeal Officer will call the
applicant. She will offer to either meet in-person with the applicant or
to discuss the appeal on the phone. If the applicant opts to conduct the
appeal by phone, the Appeal Officer will allow the person to provide
additional information about his or her travel limitations and to
explain why the applicant feels the initial determination was not
correct. She also will ask follow-up questions about the information
presented or the information in the application file. A determination on
the appeal is then made based on this telephone call.

If the applicant would like to meet with the Appeal Officer in person, a
date and time is set. As appropriate and at the discretion of the Appeal
Officer, the applicant also may be asked to participate in a functional
assessment at the time of the in-person hearing.

MVRTA staff indicated that in some cases, an in-person meeting cannot be
arranged within 30 days of the date of the appeal request. In these
cases, MVRTA grants full ADA eligibility---based on the recommendation
of the Appeal Officer---until the hearing/meeting can be arranged.

Once the Appeal Officer has either met with the applicant or discussed
the appeal by phone, she will make a determination and will notify the
Office of Special Services staff of her decision. The applicant is then
sent a letter informing him or her of the decision.

**Recertification**

The process for recertification is similar to that used for initial
determinations. All riders are required to re-apply at the end of their
period of eligibility. Re-applying involves submitting a new application
form (with an updated professional verification). Riders whose
eligibility is about to expire are notified by mail. Notices are sent
out about 60 days prior to the date of expiration of eligibility. The
letter informs riders that their eligibility is about to expire and that
they need to resubmit an application, and instructs them to contact the
Office of Special Services to obtain a new application form.

**Reported Determination Outcomes**

As of mid-March 2005, a total of 1,782 individuals were certified as
eligible for MVRTA paratransit services. This included 950 persons who
had been granted full ADA eligibility. Another eight persons were
certified as "ADA conditional" and 824 persons who were "Non-ADA
eligible." MVRTA's reporting system did not allow an exact count of the
number of riders certified as both "ADA conditional" and "Non-ADA
eligible." Based on recent reported monthly determination outcomes, it
was estimated that about 12.5 percent of persons who were "Non-ADA
eligible" were also "ADA conditional." Table 6.1 summarizes the
estimated number of riders by type of eligibility.

**Table 6.1 -- MVRTA EZ Trans Riders by Type of Eligibility,**

**March 14, 2005**

  ------------------------------ --------------------- -------------------
  **Type of Eligibility**        **\# of Registered    **% of Total
                                 Riders**              Riders**

  ADA Eligible                   950                   53.3%

  ADA Conditional only           8                     0.4%

  ADA Conditional and Non-ADA    103\*                 5.8%

  Non-ADA only                   721                   40.5%

  **TOTAL**                      1,782                 100%
  ------------------------------ --------------------- -------------------

> *\*It is estimated that of the 824 total "Non-ADA" riders, about 12.5%
> are also "ADA conditional." The 12.5% estimate is based on
> determination outcomes from July 1, 2004 through December 31, 2004,
> which showed that 19 of 152 persons who were "Non-ADA" were also "ADA
> conditional."*

Table 6.2 shows the number of applications received and determination
outcomes for all types of EZ Trans eligibility for FY 2004 as well as
outcomes for the first half of FY 2005 (July 1, 2004 to December 31,
2004).

**Table 6.2 -- EZ Trans Eligibility Determination Outcomes: All
Applicants,**

**FY 2004 and 6 Months, FY** 2005

+--------------------------+--------+----------+-----------+---------+
|                          | **FY   |          | **YTD FY  |         |
|                          | 2004** |          | 2005**    |         |
|                          |        |          |           |         |
|                          | *      |          | **(July   |         |
|                          | *(July |          | 2004-     |         |
|                          | 2003   |          | -December |         |
|                          | --June |          | 2004)**   |         |
|                          | 2      |          |           |         |
|                          | 004)** |          |           |         |
+--------------------------+--------+----------+-----------+---------+
|                          | **Nu   | **%**    | *         | **%**   |
|                          | mber** |          | *Number** |         |
+--------------------------+--------+----------+-----------+---------+
| ADA Eligible             | 333\*  | 57.4     | 162       | 50.9    |
+--------------------------+--------+----------+-----------+---------+
| ADA Conditional          | (no    |          | 0         | 0       |
|                          | data)  |          |           |         |
+--------------------------+--------+----------+-----------+---------+
| Non-ADA Eligible         | 228\^  | 39.3     | 133       | 41.8    |
+--------------------------+--------+----------+-----------+---------+
| ADA Conditional and      | (no    |          | 19        | 6       |
| Non-ADA                  | data)  |          |           |         |
+--------------------------+--------+----------+-----------+---------+
| Not Eligible             | 19     | 3.3      | 4         | 1.3     |
+--------------------------+--------+----------+-----------+---------+
| **TOTAL DETERMINATIONS** | *      | *        | **318**   | **100** |
|                          | *580** | *100.0** |           |         |
+--------------------------+--------+----------+-----------+---------+
| Appeals                  | 9      |          | 0         |         |
+--------------------------+--------+----------+-----------+---------+

*\* Includes persons determined "ADA conditional"*

*\^ Includes persons determined "ADA conditional and Non-ADA"*

In FY 2004, MVRTA reviewed a total of 580 applications (about 48 per
month). Of these, 333 applicants (57.4 percent) were determined "ADA
eligible." An additional 228 applicants (39.3 percent) were determined
"Non-ADA eligible." Nineteen applicants (3.3 percent) were found not
eligible for either type of service. Note that in FY 2004, MVRTA did not
maintain a separate breakout of persons determined "ADA conditional" or
"ADA conditional and Non-ADA." Starting in FY 2005, MVRTA kept a more
complete tabulation of all types of eligibility determinations. In the
first six months of FY 2005, a total of 318 applications (53 per month)
were reviewed. Of these, 162 applicants (50.9 percent) were determined
to have full ADA eligibility. No applicants were determined only "ADA
conditional." Another 133 applicants (41.8 percent) were determined
"Non-ADA eligible." Nineteen applicants (6.0 percent) were found both
"ADA conditional" and "Non-ADA eligible." The remaining four applicants
(1.3 percent) were found not eligible for either type of service.

Table 6.3 shows determinations for the first six months of FY 2005 for
only those applicants who requested ADA complementary paratransit
eligibility. Of the total of 185 applications for persons seeking ADA
complementary paratransit eligibility, 162 (87.6 percent) were
determined fully eligible. None were considered only "ADA conditional."
Nineteen (10.3 percent) were determined to have both "ADA conditional"
and "Non-ADA" eligibility. Four (2.2 percent) were determined not
eligible.

**Table 6.3 -- Eligibility Determinations: ADA Applicants Only,**

**July 1** to December 31, 2004

  ----------------------------- ------------------------- ----------------
                                **Eligibility             **%**
                                Determinations**          

  ADA Eligible                  162                       87.6

  ADA Conditional               0                         0

  ADA Conditional and Non-ADA   19                        10.3

  Not Eligible                  4                         2.2

  **TOTAL DETERMINATIONS**      **185**                   **100**

  Appeals                       0                         
  ----------------------------- ------------------------- ----------------

As also shown in Tables 6.2 and 6.3, relatively few appeal requests are
reported. In FY 2004, MVRTA received a total of nine appeals. In the
first half of FY 2005, no appeals had been received.

**Review of Application Processing Times**

The DOT regulations implementing the ADA state that applicants must be
treated as eligible if a determination of eligibility cannot be made
within 21 days of the receipt of a completed application (49 CFR
37.125(c)). The review team examined policies and practices regarding
the timely processing of applications. The team also tabulated the
processing times for a random sample of recently reviewed applications.

When MVRTA receives an EZ Trans application form, the date of receipt is
written on the first page of the application. Incomplete applications
are returned (as discussed in the "Initial Determination Process"
section above). Completed applications are forwarded to the eligibility
coordinator for review. Applications under review are organized by date
of receipt. This way, staff is always aware of the date by which the
review of all applications in a particular file should be completed.
When the review is completed, the date that the decision is made is
entered into the eligibility database.

MVRTA staff indicated that if a final decision is not made within 21
days, EZ Trans service would be extended to the applicant. They noted
that if the applicant was a current rider and was applying for
recertification, the eligibility expiration date would be changed in the
rider file. For new applicants, a rider file with a short period of
eligibility would be created until a final decision is made.

The cover letter to the application includes the statement that "the
MVRTA will process your application within 21 days of receipt." It does
not, however, specifically state what happens if the determination takes
longer and that applicants can use the service if the determination
takes more than 21 days.

The team reviewed the processing time information in the eligibility
database for 144 randomly selected determinations made between May 11,
2004 and October 8, 2004. The date the application was received ("Date
Rcvd") was compared with the final determination date ("Date Done") in
the database. The elapsed time was then calculated.

Table 6.4 shows the results of this analysis. As shown, 47 percent of
all determinations for this sample were made within seven days of the
receipt of the application. Another 42 percent were made in 8 to14 days.
Eleven percent of determinations took between 15 and 21 days. None of
the determinations in this sample of 144 took more than 21 days.

**Table 6.4 -- Processing Time for 144 Eligibility Determinations**

**Made from May 11 to October 8, 2004**

  ------------------------------- ------------------- -------------------
  **Number of Days from Receipt   **Number of         **% of All
  of Application to Final         Determinations**    Determinations**
  Determination**                                     

  0--7 days                       68                  4

  8--14 days                      60                  42

  15--21 days                     16                  11

  22+ days                        0                   0

  **TOTAL**                       **144**             **100**
  ------------------------------- ------------------- -------------------

**Process Observations and Reviews of Recent Determinations**

To review the appropriateness of determinations, particularly
determinations that limited or denied eligibility, several recently
reviewed applications were randomly pulled from the files, examined by
the review team, and discussed with MVRTA staff. This included all 13
denials of eligibility and another five riders who had been granted "ADA
conditional and Non-ADA" eligibility between January 2004 and March
2005. It also included seven of the eight riders in the system who have
only "ADA conditional" eligibility.

This review of specific eligibility determinations identified some
issues with these recent determinations. Seven of the 13 denials of
eligibility since January 1, 2004, appeared to be appropriate. In the
other six cases, though, the decisions did not appear to be appropriate,
or were questionable, for a variety of reasons. The specific issues with
these six determinations are described below.

-   In two cases, applicants appeared to have functional limitations
    that would prevent them from using fixed route service, but
    applications stated that they lived outside the service area. MVRTA
    staff confirmed that these applicants were denied because they did
    not live in the service area. A review team member noted that
    residency should not be considered in ADA complementary paratransit
    eligibility determinations, and that these applicants should have
    been found eligible but informed that service did not extend to the
    area where they lived, but they could travel on their own to a
    pickup location within the service area.

-   In another two cases, the application files showed that the
    professional verification portion of the applications had not been
    completed. The applications were returned to the applicants with a
    letter that indicated that they had been found to not be eligible
    because the information in the application was not complete. Neither
    applicant resubmitted completed applications. MVRTA staff noted that
    it appeared the wrong letter had been sent to these applicants.
    Instead of the standard letter used to return incomplete
    applications, the denial letter had been sent.

-   In a fifth case, the applicant indicated that she used a power
    wheelchair. This should have given her consideration for eligibility
    at least when snow or ice prevented travel to or from bus stops, or
    when the lack of a safe, accessible path of travel prevented her
    from getting to or from bus stops. She also indicated in her
    application that she drove, owned an accessible van, and was seeking
    eligibility when her van was being repaired. MVRTA staff indicated
    that the fact that she drove appeared to have influenced the
    decision to deny eligibility. It was noted that driving ability
    should not have been a factor in the decision.

-   In a sixth case, the applicant indicated that he had arthritis, used
    crutches, and could not walk more than one or two blocks. The
    professional also indicated a maximum walking distance of two
    blocks. The professional also, however, answered "No" to the
    question in Part D that asks, "Would the applicant's condition
    prevent him/her from using the public fixed route service?" MVRTA
    staff indicated that the applicant was denied primarily because of
    the answer to this one question. Staff agreed, however, that the
    information was inconsistent with other information from the
    professional and applicant, that the question could have been
    misunderstood by the professional, and that follow-up with the
    professional would have been appropriate. There was no evidence in
    the file that follow-up had been conducted. In general, it was noted
    that where there is inconsistent information, follow-up should
    always be done before eligibility is denied.

The review of the 12 determinations of "ADA conditional" or "ADA
conditional and Non-ADA" found that in six cases the determinations
appeared to be consistent with the information in the file. In six
instances, though, the determinations did not appear to correctly
identify all of the conditions under which riders appeared unable to use
the fixed route system. The specific issues identified are noted below.

-   In one case, the applicant indicated that she sometimes used a
    walker and at other times used a manual wheelchair. The professional
    indicated that the applicant had problems standing and waiting for
    buses or walking long distances (a maximum of two blocks was
    indicated). The determination granted conditional eligibility as
    follows: when not using a wheelchair the applicant was granted
    eligibility if the distance to/from the bus was more than four
    blocks; and, when using a wheelchair, the applicant was granted
    eligibility only at times of "extreme weather." The maximum distance
    established in the determination did not appear to be consistent
    with the information provided. And the determination did not appear
    to consider path-of-travel barriers (the lack of a safe, accessible
    path of travel), which would seem to be appropriate given the types
    of mobility aids used. It also was possible that the applicant (who
    reported having had a stroke) might not be able to travel great
    distances even when using a manual wheelchair.

-   In a second case, the applicant indicated he used a manual
    wheelchair and cited the lack of sidewalks, curb cuts, or distances
    greater than two blocks as an issue. The professional also confirmed
    a maximum reasonable travel distance of two blocks. The
    determination granted conditional eligibility when there was
    "extreme weather." The determination also granted "feeder" service.
    Feeder service was not defined or described, however. Discussions
    with MVRTA staff indicated that it would have been more appropriate
    to include additional path-of-travel conditions and maximum distance
    conditions in the determination. Feeder service might then be
    considered operationally for trips where this option was
    appropriate, rather than as a "condition" of eligibility.

-   In a third case, the applicant indicated he used a manual wheelchair
    and noted he had the ability to travel up to eight blocks. He was
    granted conditional eligibility for "extreme weather" and also when
    there were no curb cuts. Again, other path-of-travel issues (beyond
    just a lack of curb cuts) that might prevent use of fixed route
    probably should have been included in the conditions of eligibility.

-   In a fourth case, the applicant indicated she used a power scooter.
    She was granted conditional eligibility when there is "ice, snow,
    heavy rain, or temperatures below 32 degrees." Again, MVRTA should
    have considered path-of-travel barriers.

-   The fifth case involved an applicant who used a manual wheelchair
    some of the time and a walker at other times, and the professional
    indicated a maximum travel distance of two blocks. The determination
    provided for conditional eligibility only when there was "extreme
    weather." Again, both path-of-travel and maximum distance issues
    should have been included in the determination.

-   Finally, in a sixth case, the applicant reported that she
    experienced severe fatigue due to dialysis treatments that prevented
    her from using the bus. The determination provided conditional
    eligibility only for dialysis trips. Rather than limiting service by
    trip purpose, it would have been more appropriate to grant
    eligibility when severe fatigue prevents use of the fixed route bus.
    It would also have been appropriate to follow up to determine if the
    severity of the health condition affects travel only on days when
    the applicant receives dialysis treatment or at other times as well,
    and if there might be a maximum distance the applicant can be
    expected to walk (she and the professional had indicated a maximum
    walking distance of two blocks).

Overall, this detailed review of specific determinations indicated a
need for MVRTA to be more thorough in setting conditions of eligibility.
A common error seems to be overlooking the path of travel and the
maximum distance that applicants could travel to/from bus stops. As
discussed earlier in this section, there also is a need to better define
for applicants the exact "extreme weather" conditions that have been
determined to affect their travel. MVRTA could also consider feeder
service to fixed route an operational option for serving riders (when
appropriate) rather than as a condition of eligibility. In addition,
eligibility conditions should reflect functional limitations rather than
trip purpose.

The review of these individual files and completed application forms,
along with discussions with MVRTA staff during the review also confirmed
that the wording of some of the questions in the current application
form could be improved. Some of the more "personal" questions about
types of trips taken and living situations also seemed to have little
bearing on the actual determinations being made. As noted above, MVRTA
was developing a new application form and had requested input from FTA
on proposed changes to the current form.

**No-Show Suspension Policy**

Section 37.125(h) of the DOT ADA regulations states that transit
agencies "may establish an administrative process to suspend, for a
reasonable period of time, the provision of complementary paratransit
service to ADA eligible individuals who establish a pattern or practice
of missing scheduled trips." The team reviewed MVRTA's policies and
practices regarding no-show suspensions.

MVRTA has developed a policy that provides for suspensions of service
for "service disruptions." The MVRTA's ADA Customer Manual describes
"service disruptions" to include:

-   No-shows

-   Late cancellations (cancellations less than one hour before the
    scheduled pickup time)

-   Incorrect address information (which can include providing incorrect
    address information during the trip reservation process, or failing
    to notify MVRTA of a change in address)

-   Non-payment of fare

The "service disruption" policy detailed in the ADA Customer Manual then
calls for the following notice and suspension policy:

-   Written notification is to be provided to riders after the first
    service disruption within a six-month period. This first letter
    provides specific information about the service disruption recorded
    by MVRTA, notes that this is the first disruption within the past 60
    days, and reminds the rider of the policy and potential suspension.
    Riders are also encouraged to call the Office of Special Services if
    they feel the service disruption was due to factors beyond their
    control.

-   If there is a second service disruption within the same six-month
    period, a second written notification is provided. This second
    notification again details the specific service disruption recorded,
    notes this is the second disruption recorded in the past 60 days,
    and again encourages riders to call if the disruption was beyond
    their control or recorded in error. It also warns the rider that one
    more disruption may result in a suspension of service.

-   A third service disruption in a six-month period triggers a
    suspension of service for 30 days. Riders are sent a letter
    detailing the third disruption and are again encouraged to contact
    MVRTA if the disruption was beyond their control. The letter notes
    that a 30-day suspension of service will go into effect two weeks
    from the date of the letter, and informs riders that they can appeal
    the proposed suspension.

-   Each additional service disruption, after the third incident, within
    the same 60-day period triggers another 30-day suspension. A similar
    suspension letter is sent and riders are informed of their right to
    appeal.

If MVRTA proposes a suspension, a rider must appeal the suspension
within 14 days of the date of the suspension letter. If the rider
appeals the suspension, service is continued until the appeal is heard.

Currently, warning letters and suspension letters are signed by the
Director of Paratransit Operations. The MVRTA Appeal Officer (an outside
professional on retainer) then hears and decides on the appeal.

At the time of the team's visit, MVRTA was actively implementing this
no-show policy. A database has been created to track service disruptions
and the notifications given. A review of this database indicated that
between January 1, 2004 and January 31, 2005, MVRTA issued 570 warning
letters. In many cases, MVRTA "waived" the disruptions from a rider's
record after the rider called to explain the no-shows, late
cancellations, or other disruptions. Staff also noted that they attempt
to work with riders to address any difficulties they may be having with
the service that are causing no-shows or late cancellations. If they can
work with a rider to develop a course of action to address the
difficulties, MVRTA often waives the suspension. Records showed that
during this 13-month period, MVRTA suspended a total of 16 riders.

**Findings**

1.  Most individuals who apply to MVRTA for ADA complementary
    paratransit service receive unconditional eligibility. For 185
    determinations made during the first six months of FY 2005, 162 of
    185 applicants (87.6 percent) received unconditional eligibility.
    Only four applicants (2.2 percent) were determined not eligible.

2.  A review of recent denials indicated that in some cases the reasons
    used to deny eligibility were not appropriate. Two applicants were
    denied eligibility because they lived outside the ADA complementary
    paratransit service area. Also, it appears that staff may be
    inappropriately considering vehicle ownership and the ability to
    drive as factors in ADA complementary paratransit eligibility
    determinations. Two applicants were incorrectly sent denial
    letters---rather than requests for more information---because they
    had submitted incomplete applications.

3.  MVRTA appears to be encouraging use of its accessible fixed route
    services and is granting conditional eligibility to applicants who
    are able to use fixed route bus services some of the time. In the
    first six months of FY 2005, 10.3 percent of applicants were granted
    "ADA conditional" or "ADA conditional and Non-ADA" eligibility. For
    several individuals, MVRTA granted conditional eligibility only for
    "extreme weather," while other barriers such as travel distances
    to/from bus stops and path-of-travel barriers (i.e., accessible and
    safe paths of travel) were not fully considered. One applicant
    received conditional eligibility for a specific trip purpose (trips
    to dialysis) rather than on the more appropriate functional issue
    (when severe fatigue prevents use of the fixed route service).

4.  As of the time of the review team's site visit, MVRTA was not
    enforcing conditional eligibility and was providing trips to riders
    with conditional eligibility as if they had full ADA complementary
    paratransit service eligibility.

5.  MVRTA's application form for paratransit service appears to be
    potentially confusing to applicants. MVRTA has been working to
    revise the current EZ Trans application form in response to concerns
    raised by local riders and a local disability agency. A proposed new
    application form was developed and forwarded to FTA in July 2004.
    This proposed new application form does appear to address several of
    the concerns raised. However, some information included in the
    application packet still appears to be potentially confusing to
    applicants. Certain questions in the proposed application are too
    narrow, while other questions do not address issues related to an
    applicant's functional abilities.

6.  A review of 144 randomly selected applications found that MVRTA made
    all eligibility determinations within 21 days of the receipt of
    completed applications. Most decisions (89 percent) were made in 14
    days or less.

7.  MVRTA's current "Service Disruptions" policy does not appear to
    comply with Section 37.125(h) of the DOT ADA regulations. This
    section allows for a suspension of service, for a reasonable period
    of time, for a "pattern or practice of missing scheduled trips." The
    practice of suspending riders for no-showing or late canceling only
    three trips in 60 days may not always constitute a true "pattern or
    practice." For a rider who travels only a few times each month,
    missing three trips in 60 days might be a pattern or practice. For
    riders who travel on a daily basis, however, three trips in 60 days
    would be less than 4 percent of their total scheduled trips.

8.  The types of "service disruptions" included in MVRTA's policy also
    do not all appear to be consistent with Section 37.125(h) of the
    regulations. This section of the regulations allows suspensions of
    service for a pattern or practice of "missing scheduled trips." A
    passenger's providing a wrong address or failing to inform MVRTA of
    an address change does not necessarily lead to a trip being missed.
    If it did, this disruption would be covered as a no-show. Also,
    while MVRTA has a right to refuse to provide a trip to a rider who
    refuses to pay the fare, the regulations do not provide for a
    suspension of future service for failure to pay a fare.

**Recommendations**

1.  MVRTA should discontinue considering residential location and auto
    ownership in making determinations of "not eligible." MVRTA should
    also review the regulations for ADA complementary paratransit
    service eligibility to ensure that determinations of "not eligible"
    are made for appropriate reasons.

2.  MVRTA should consider all potential barriers to fixed route travel
    when making "ADA conditional" determinations. This should include
    path-of-travel barriers---such as inaccessible sidewalks---walking
    distances to/from bus stops, as well as weather conditions or other
    factors. MVRTA should also more specifically define eligibility
    conditions related to weather than just "extreme weather." For some
    applicants, the barrier to travel might be snow or ice. For others,
    the barrier might be extreme heat or cold.

3.  When setting conditions of eligibility, MVRTA should use limitations
    related to specific functional abilities rather than trip purposes
    or types of service. For example, eligibility "when severe fatigue
    prevents you from using the fixed route bus" would be more
    appropriate than eligibility for "dialysis trips only." And, while
    "feeder" service may be an appropriate service option for some
    trips, it is not an appropriate option for many trips and therefore
    should not be the only type of service granted to applicants.

4.  MVRTA should consider incorporating the following changes as it
    revises its application form and materials:

-   The current "Frequently Asked Questions" are overly complex in their
    discussion of ADA complementary paratransit eligibility. The
    discussion of industry trends toward in-person assessments, in
    particular, seems obtuse given that this is not part of the MVRTA
    process. More "customer-friendly" information tailored to
    prospective applicants should be considered.

-   The optional form, which requests open-ended responses to the two
    eligibility "Categories," appears to be duplicative. This page has
    useful information, but is not always returned with the application
    form since it is optional. Instead, MVRTA might consider an
    open-ended question at the end of Part B that asks applicants to
    describe in their own words any other reasons, not addressed above,
    why they feel they cannot get to or from bus stops, or board and
    ride the fixed route system.

-   The first page of the application form should indicate that service
    will be provided if it takes longer than 21 days to process the
    application.

-   "Sometimes" and/or "Not Sure" check-box options should be added to
    several of the questions. Applicants may be able to perform certain
    functional tasks only some of the time. And if applicants have no
    experience using fixed route service, they may not be sure of
    certain fixed route travel abilities.

-   Question 4 in Part B of the proposed new application should be
    reworded. Instead of the maximum time applicants can "wait for
    transportation," the question might ask if the applicant can wait a
    specified amount of time (say 15 minutes) for an MVRTA fixed route
    bus if there is no place to sit.

-   The layout of Question 5 in Part B of the proposed new application
    should be changed. Many applicants appear to circle one of the
    distances in the first column rather than the "Never," "Sometimes,"
    or "Always" options next to each distance.

-   Question 8 in Part B of the proposed new application form should not
    reference "your destination," but should be worded more broadly to
    ask if applicants are able to get to "destinations." A "sometimes"
    option would also be appropriate for this type of question. The
    answers also suggest that information about a single, particular
    trip is being requested, rather than about getting to various
    destinations.

-   Given that MVRTA's fixed route service operates as a "flag stop"
    system, a question asking if the applicant is able to identify and
    signal for a fixed route bus to stop for them should be included in
    the application.

-   Also, to address another major issue that affects applicants with
    vision and cognitive disabilities, abilities to safely cross streets
    should be included in the application. It also would be useful to
    identify if applicants are able to travel to familiar locations on
    the fixed route bus, but are not able to travel to unfamiliar
    locations.

-   Question 16 in Part B of the proposed new application, which was
    developed to broaden the question about weather, is now much too
    general. A better question about the impacts of weather on the
    applicants travel, along with an open-ended "any other issues" type
    question, should be considered.

-   The instructions to professionals at the beginning of Part D are
    sometimes duplicative. Also, MVRTA should consider changing the
    sentence "EZ Trans service does not include persons who find it
    uncomfortable or difficult to get to and from fixed route buses" to
    "To be considered eligible for EZ Trans service, riders must be
    unable, due to their disability or health condition, to get to or
    from fixed route buses. Getting to or from buses must pose an
    unreasonable level of effort or risk, rather than simply being more
    difficult or less convenient than receiving curb-to-curb van
    service."

-   The professional's opinion on maximum travel distance, rather than
    just the ability to travel two blocks (as now requested) would be
    helpful.

-   Question 9 in Part D of the proposed new application, which mirrors
    Question 8 in Part B, is again much too general.

-   Question 10 of Part D of the proposed new application, regarding
    PCAs, does not seem to be worded appropriately. It seems aimed more
    at whether a PCA should be required, rather than at whether the
    applicant sometimes or always needs to travel with a PCA.

-   The optional question in Part E of the proposed new application
    would seem to have limited applicability to determining an
    applicant's functional ability to use fixed route service. At best,
    it would allow one to draw very broad conclusions about an
    applicant's activities. At worst, it may be misleading in terms of
    functional abilities.

5.  MVRTA should remove "Incorrect Address" and "Non-Payment of Fare" as
    types of disruptions that count toward a suspension of service. If
    incorrect information is provided in the reservations process, this
    will result in a no-show---which already is covered in the policy.
    And, while MVRTA can refuse to provide service if the fare is not
    paid, this should not also result in suspension of future service
    opportunities.

6.  MVRTA should consider the frequency of use of the EZ Trans service,
    along with the number of no-shows and/or late cancellations, to
    determine if a particular rider has demonstrated a "pattern or
    practice" of missing scheduled rides.

# 7. Observations Regarding Telephone Capacity and Trip Reservations

The team reviewed the telephone system and trip reservation process to
determine whether riders who use EZ Trans service can effectively reach
call-takers and schedule their trips. Information reviewed and
observations made on telephone service and capacity and trip
reservations included:

-   Consumer interviews and review of complaints filed with MVRTA

-   MVRTA's policies and procedures for taking trip reservations for ADA
    complementary paratransit service

-   Call-taking practices of MVRTA staff

**Consumer Comments**

Conversations with EZ Trans ADA consumers prior to the on-site visit did
not cite any difficulties with long hold times, busy signals, or other
issues related to telephone access. No complaint received and recorded
directly by MVRTA related to telephone access or long telephone hold
times.

**Telephone Service Standards**

MVRTA does not have any formal telephone system performance standards.
The number of calls handled by each call-taker is tallied by hour daily,
but no other procedures for monitoring phone system performance are in
place.

To evaluate phone system performance, the review team relied primarily
on observations of reservations and dispatching and a consideration of
call volumes, staffing levels, and phone system design. These
observations are presented in the following paragraphs.

**Telephone and Reservations Policies and Procedures**

MVRTA advertises one central information phone number (978-469-6878). A
recorded message presents callers with a list of options; the Office of
Special Services is reached by selecting "option 3." After selecting
option 3, callers are connected with a call-taker. Toll-free service is
available by calling 877-308-7267.

The Office of Special Services utilizes four dedicated phone lines. No
automated call distribution equipment is used. If all lines are busy,
the next incoming call is directed to voicemail. If a call is placed on
hold, a light on each phone blinks. If the call is kept on hold for more
than 90 seconds, one of the phones emits a beep until the call is
answered.

Typically, one call-taker covers the phones from 7 a.m. until 8 a.m.,
three call-takers are on duty from 8 a.m. until 3 or 4 a.m., and one to
two call-takers take calls between 4 and 5 p.m. Call-takers work on
weekdays only (excluding holidays). On Sundays and holidays, MVRTA has a
voicemail system that callers can use to leave trip requests for
next-day service. The morning dispatcher has responsibility for checking
the messages when she arrives (scheduled for 5 a.m.). However, all
public information (printed and website) states that reservations are
accepted only on weekdays. The ADA Customer Manual states, "Trips may be
reserved 2 weeks in advance but no later than 1 weekday in advance
(excluding holidays)." In addition, one of the call-takers believed that
riders could call only on weekdays.

Riders may request trips up to 14 days in advance. Trips for ADA
complementary paratransit service may be requested up to one day in
advance. Non-ADA EZ Trans trips must be requested no later than two
weekdays in advance.

**Assist Medical Transportation**

Assist Medical Transportation utilizes one dedicated phone line for EZ
Trans reservations. When the first line is busy, calls roll over to
another main phone line and a third auxiliary line. Assist Medical
managers indicated that because most EZ Trans riders are longstanding
Assist Medical customers, they are aware of all three phone numbers and
utilize the second and third lines if the EZ Trans line is busy. An
answering machine is used to record calls received when a dispatcher is
not on duty (before 5:30 a.m. and after 7 or 8 p.m. on weekdays).

**Observations of Paratransit Reservations Practices**

The review team observed reservations at the MVRTA office for
approximately six hours on Tuesday, Wednesday, and Thursday, March 15,
16, and 17, 2005: from 2 to 5 p.m. on March 15, from 9 to 11 a.m. on
March 16, and again on the morning of March 17. These observations
covered some of the peak call times for EZ Trans service, which MVRTA
staff identified as between 7 and 9 a.m. and between 2 and 4 p.m. During
those hours of observation, only one call was placed on hold, and that
call was answered promptly.

Call-takers manually record the number of calls they handle during each
hour of the day on phone log sheets. A compilation of log sheets for the
week of February 14 to 18, 2005, showed call volumes that ranged from 28
to 128 per day, with an average of 87 calls per day. On the day with the
highest call volume (Friday, February 18), call-takers averaged 43 calls
each, or about five calls per working hour. While there are no phone
management system reports to document telephone system performance, busy
signals and hold times are not likely to be a problem at those call
volumes and staffing levels.

Call-takers enter trip requests into the ADEPT software. The software
generates the pickup window based on the time requested by the caller.
The pickup window, as based on MVRTA policy, is -15/+15 minutes relative
to the negotiated time. However, some requests, even some made several
days ahead, may not get pickup windows. These are called "standby
requests." MVRTA guarantees the trip at the time of the call. The rider
must call back to get the pickup window. The rider can call after 4:30
p.m. on the weekday before the trip. For trip requests after 8 a.m., the
rider can call the morning of the trip to get the pickup window.

If an EZ Trans rider wants to travel into the area served by LRTA's ADA
complementary paratransit service (Road Runner), the call-taker can
either arrange a direct trip to the Lowell Transit Center or to a
designated transfer point on the Methuen/Dracut line. The rider is then
responsible for booking the second stage of the trip with Road Runner.
As mentioned in Section 5 ("Service Parameters"), MVRTA stated it has
tried to assist with coordination of transfers, but has been hindered by
communication difficulties that LRTA has had with its paratransit fleet.

The three call-takers each have second responsibilities that they tend
to between calls. One call-taker reviews the applications for EZ Trans
before passing them to the Director of Paratransit Operations. The
second call-taker enters data from the driver manifests into the ADEPT
software. The third call-taker conducts background research for riders
who may be subject to no-show suspensions.

Other observations of the review team are summarized as follows:

-   Call-takers are generally polite and knowledgeable about all MVRTA
    special services.

-   Call-takers take trips requests for all special services: ADA and
    non-ADA EZ Trans and the Ring and Ride services.

-   As mentioned in Section 5, call-takers did not prioritize trip
    requests by trip purpose.

-   Many of the calls handled by call-takers are for issues other than
    trip requests and cancellations, such as time checks for future
    trips, eligibility and recertification questions, and fixed route
    service information.

-   MVRTA has a "reservationist's script" that includes both questions
    to ask the caller and steps to follow in using the ADEPT software.
    The call-takers tend not to follow the set of questions included in
    the script. They seem familiar with many of the riders who call.
    Perhaps because of this familiarity, they tend not to confirm
    addresses, telephone numbers, use of mobility devices, companions,
    or need for a PCA.

-   Riders can request a trip by either pickup time or drop-off
    (appointment) time. Call-takers were consistent in providing a
    30-minute pickup window, rather than a precise time.

-   When call-takers receive a "Where's my ride?" call, they can often
    respond without transferring the call to dispatch. There is a
    workstation in the call-takers' office connected to the global
    positioning system (GPS) that allows them to check the location of
    all STS vehicles in service.

-   None of the call-takers speak Spanish. If the call-takers need a
    Spanish speaker, they transfer the call to the morning dispatcher.

**Assist Medical Transportation**

Team members observed Assist Medical staff handle reservations and
dispatch functions from 10 a.m. until noon on March 16. During that
time, one call-taker/dispatcher and a backup were on duty; the owner of
the company was on hand as well. Assist Medical received about 15 calls
during that period, and all were answered promptly. No call was placed
on hold.

Calls typically begin around 8 a.m., although the dispatcher is on duty
at 5:30 a.m. Most riders call between one and three days in advance of
their desired trip date. Service is available on weekdays only, from 5
a.m. until 7:30 p.m., although peak periods of demand are generally in
the early to mid-morning and early afternoon hours. Customers wishing to
travel on Saturday are referred to STS.

Trip requests are recorded on a paper driver manifest form and later
transferred into an Excel spreadsheet. According to Assist Medical
managers, about 80 percent of the trips are standing orders, and are
more or less permanently recorded in the spreadsheet. Pickup times are
set based on an allowance of 30 minutes prior to the appointment time,
if there is one; 45 minutes are allowed for longer trips.

All return trips are booked; "will call" returns are not accepted.
However, if a rider is ready to return early or is not ready until after
the scheduled return pickup time, he or she can call Assist Medical and
the first available vehicle is sent to serve the trip (riders are never
left stranded). Assist Medical staff noted that negotiation of trip
times is rarely necessary.

Assist Medical has a map showing the 3/4-mile corridor for EZ Trans ADA
service, but typically does not check it. Most riders and their
origins/destinations are well-known to Assist Medical staff, and most
trips are within the 3/4-mile area.

**Findings**

1.  Both MVRTA and Assist Medical schedule an adequate number of
    call-takers to handle the volume of calls received promptly. Review
    team members observed virtually no calls that were placed on hold.
    There does not appear to be a pattern of excessively long hold times
    that would discourage riders from attempting to use the EZ Trans
    service.

2.  MVRTA does not have a standard for telephone performance.

3.  MVRTA accepts trip requests via voicemail on weekends and holidays
    before service. However, its public information states that trip
    requests are accepted only on weekdays. One of the call-takers
    stated that reservations can be made only on weekdays.

4.  Some riders did not get a confirmed pickup window at the time of
    their call. MVRTA asks them to call back to get the pickup window.
    However, MVRTA does guarantee the requested trips to all riders.

5.  Call-takers were consistent in confirming the scheduled pickup time
    in terms of a 30-minute window, rather than a precise time.

6.  Call-takers were not consistent in confirming other components of
    the trip request, such as addresses, telephone numbers, use of
    mobility devices, and need for a PCA.

7.  MVRTA riders who want to travel to the Lowell Transit Center
    sometimes need to transfer to LRTA's Road Runner ADA complementary
    paratransit service. When they need to make this transfer, the rider
    is responsible for booking the second stage of the trip.

**Recommendations**

1.  Although all calls appear to be answered promptly, MVRTA may wish to
    consider developing a standard for monitoring future telephone
    performance. This standard should set maximum hold times for
    incoming calls for a given hour of day.

2.  MVRTA should update its public information material to inform its
    customers that they can make trip requests the day before service,
    including voicemail requests on Sundays and holidays.

3.  MVRTA should consider having the call-takers confirm trip
    information such as the pickup and drop-off addresses, telephone
    numbers, use of mobility devices, and need for a PCA to ensure clear
    customer communications.

4.  For ADA eligible riders who are traveling to the Lowell Transit
    Center by transferring from EZ Trans to LRTA's Road Runner service,
    MVRTA should consider assisting riders with the reservation of the
    Road Runner portion of the trip. MVRTA should also continue attempts
    to work with LRTA to coordinate the vehicle transfers.

# 8. Observations Regarding Scheduling of Trip Requests

The team reviewed scheduling of EZ Trans trip requests. Information
reviewed and observations on scheduling included:

-   Consumer interviews

-   MVRTA policies and procedures

-   Scheduling software

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

**Consumer Comments**

None of the consumers interviewed cited any concerns with the scheduling
practices of MVRTA. None of the complaints received by MVRTA dealt with
scheduling. The complaint filed with FTA does not include any scheduling
issues.

**Policies and Procedures**

At the time of the assessment, MVRTA's Office of Special Services was
scheduling about 200 passenger trips per weekday, and 30 to 50 passenger
trips per Saturday. These trips include:

-   EZ Trans ADA trips

-   EZ Trans non-ADA trips

-   Ring and Ride and other Special Services trips

As mentioned earlier, these services are integrated into a single
operation. Since riders for all special services are carried by a single
fleet, schedulers (along with dispatchers and drivers) make no
distinction among the riders for the different special services.

Among the trips handled by MVRTA's schedulers are trips ultimately
provided by Andover Livery. Andover Livery averages about 25 trips per
day, with a daily range of 0 to 40 trips. Andover Livery carries only
ambulatory passengers; nearly all of its trips are within the town of
Andover or adjacent towns in the MVRTA service area.

The trips cited above *do not include* trips handled directly by Assist
Medical. Assist Medical schedules about 50 passenger trips per weekday
(none on Saturday), all of which are either EZ Trans (ADA or non-ADA).
Nearly all Assist Medical trips have their origins and/or destinations
in the town of Methuen.

In practice, most of the initial trip scheduling takes place when the
call-takers take trip requests and provide the pickup windows to the
caller. During this process, the call-takers are using the ADEPT
software to place trips onto vehicle runs. On weekdays, Special Services
operates 11 runs or routes during the peak service period. On Saturdays,
Special Services operates four runs.

The individual with primary responsibility for completing the Special
Services schedules is also the p.m. dispatcher. She puts together the
schedules for Tuesday to Saturday service, as well as service on
alternating Mondays. The Director of Paratransit Operations completes
the schedule for the other Mondays.

The lead scheduler has several years' experience in this task. She knows
the skills and experience of the drivers and also knows many of the
regular riders. Generally, she starts to work on the schedule two
working days ahead. By that time, a majority of the trips have been
requested---a combination of subscription and demand trips. The value
that she provides to the schedules created by ADEPT is looking at the
runs constructed so far by ADEPT and making adjustments that, in her
opinion, match geographic areas of runs to drivers. She also takes into
consideration matching individual passengers to drivers. For a given
day, she may move 10 to 20 percent of the passenger trips to different
runs from the runs that ADEPT had previously assigned the trips to.

While ADEPT generally generates realistic pickup and drop-off times,
sometimes it will create runs with trips that have on-board travel times
greater than 60 minutes. The scheduler will re-arrange trips to
eliminate these policy violations. Also, the scheduler feels confident
in occasionally creating scheduling violations in ADEPT if she believes
that, in practice, the run will be performed without violations. These
include keeping a rider on a vehicle for longer than 60 minutes and
scheduling a pickup or drop-off outside of the on-time window. She has
the authority to manually override the parameters set in ADEPT.

The call-takers stop taking trip requests at 4:30 p.m. After that time,
the scheduler finalizes the schedule for the following day. In addition
to trips placed onto vehicle runs, there is generally a subset of trips
that have not been placed on runs. Some of these trips are assigned to
Andover Livery, based on their geographic location. Other requested
trips not assigned to MVRTA vehicle runs fall into three categories.
These categories include:

-   **Standby**: trips for which a rider received a confirmed pickup
    window that was within the negotiation window allowed by the ADA,
    but the rider requested a different window.

-   **Wait Listed**: trips that the call-taker confirmed with the rider,
    but that the scheduler subsequently removed from the schedule.

-   **Will Call**: trips for which the call-taker did not provide a
    pickup window to the rider and that the scheduler still did not
    place onto a run (called "standby" by call-takers).

Note that MVRTA has not had denials since FY 2003 and guarantees service
for all acceptable EZ Trans trip requests. The phrases cited above are
internal MVRTA terms. Typically, the total number of trips that are
either "standby," "wait listed," or "will call" is 20 to 25 per weekday.

The scheduler usually completes the schedule for the following day by 7
p.m. She tries to minimize the trips not assigned to runs. She may
assign additional trips to Andover Livery. She sends Andover Livery the
list of its assigned trips in the evening. She leaves the list of
unassigned trips for the morning dispatcher to fit onto runs as
cancellations (both overnight and same-day) and no-shows occur.

Based on a review of recent records, about half of Special Services
trips are subscription service, i.e., trips with a regular weekly
schedule with the same origins and destinations that riders receive
without the need to call in. MVRTA schedulers pre-set very few of these
subscription trips onto the same run on a given day: about 10 one-way
trips. This lack of "anchoring" is unusual for subscription trips.
However, with the relatively small volume of trips to schedule, the lead
scheduler believes that letting subscription trips "float" to different
runs provides her with greater flexibility.

**Assist Medical Transportation**

Assist Medical Transportation provides EZ Trans service for riders
traveling within Methuen and from Methuen to Andover, North Andover, and
Lawrence.

Assist Medical takes reservations for the trips that it provides, and
prepares its own vehicle schedules. Trip requests are recorded on a
paper driver manifest form and later transferred into an Excel
spreadsheet. As noted earlier in this report, Assist Medical managers
estimate that about 80 percent of the trips are standing orders. Pickup
times are set based on an allowance of 30 minutes prior to the
appointment time, if there is one; 45 minutes are allowed for longer
trips. All return trips are booked; "will-call" returns are not
accepted.

At the end of the day, trip requests are sorted by time and given to the
senior driver for manual scheduling onto vehicle runs, one for each of
the vehicles that is dedicated to EZ Trans service. Trips that do not
fit easily onto a run are added to a "miscellaneous sheet" and same-day
dispatched to the driver who is best able to complete the trip.

Assist Medical generally does not have a problem accommodating the trip
requests it receives. In some months (e.g., May, September, and
October), the trip cap of 1,150 trips per month set by MVRTA is not
sufficient to cover demand. When the cap is reached, Assist Medical asks
customers to call MVRTA for their trips.

**Findings**

1.  Scheduling of trip requests does not appear to contribute to missed,
    late, or long trips.

2.  At the time of the review, Special Services was scheduling about 200
    passenger trips per weekday, and 30 to 50 passenger trips per
    Saturday. About half of Special Services trips are subscription
    service.

3.  MVRTA schedulers assign 0 to 40 trips per day to Andover Livery, all
    ambulatory passengers. Andover Livery creates schedules for these
    trips.

4.  Assist Medical takes reservations for the trips that it provides,
    and prepares its own vehicle schedules. About 80 percent of its
    trips are subscription. It is able to create its schedules with the
    help of an Excel spreadsheet.

**Recommendations**

None.

# 9. Observations Regarding Operations

The team reviewed the transportation operations of MVRTA's EZ Trans
service to determine whether requested trips are being served in a
timely fashion and are not excessively long, and if any operational
procedures or practices appear to cause or contribute to service
limitations. Activities regarding operations and service delivery
included:

-   Consumer interviews and review of complaints filed with MVRTA

-   Review of EZ Trans service policies and procedures

-   Site visit to Assist Medical Transportation

-   Observations of dispatch

-   Interviews with eight drivers

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

-   Analysis of EZ Trans trip durations

# 

**Consumer Comments**

# 

The team reviewed consumer comments regarding operations to help to
identify potential operational problems. In the interviews conducted by
the review team prior to the site visit, one individual brought up
on-time pickups. MVRTA had on file five complaints from 2002 and 2003.
In these complaints, individuals cited unjustified no-shows and rude
drivers.

The single complaint filed with FTA concerning EZ Trans service did not
refer to any operational issues.

**Service Standards and Policies**

MVRTA has established service standards for on-time performance, trip
denials, travel time, and no-shows. The service standards are described
below.

-   **On-time Performance.** The pickup window is -15/+15 minutes from
    the negotiated pickup time. Assist Medical and Andover Livery each
    have performance targets that at least 90 percent of trips each
    month be within the pickup window. MVRTA does not have a target for
    trips that it provides in-house through MVATC. There is no standard
    for on-time drop-offs.

-   **Trip Denials.** MVRTA states that it has had no denials for ADA
    trips since FY 2003.

-   **On-board Travel Time.** MVRTA has a standard that the maximum
    travel time for an EZ Trans passenger trip is 60 minutes.

-   **No-Shows and Late Cancellations.** MVRTA defines a passenger
    no-show as "when the MVRTA vehicle arrives at the specified location
    within the 30-minute window and the customer is not ready or does
    not take the scheduled trip." A late cancellation is a trip
    cancelled by the rider less than one hour before the scheduled
    pickup.

**Observations on Dispatch**

Review team members observed Special Services dispatchers, who work at
the MVRTA facility in Haverhill. Team members also observed the Assist
Medical dispatcher (discussion of Assist Medical's EZ Trans operations
is presented later in this section of the report).

Special Services has two dispatchers who cover all service hours, Monday
to Saturday. The junior dispatcher works from 4:30 a.m. to 12:30 p.m. on
Monday through Thursday; 12:15 p.m. to 8:15 p.m. (or until the last
vehicle returns) on Friday; and 7:45 a.m. to 6:15 p.m. (or until the
last vehicle returns) on alternate Saturdays. The senior dispatcher
works 12:15 p.m. to 8:15 p.m. on Monday through Thursday; 4:30 a.m. to
12:30 p.m. on Friday; and 7:45 a.m. to 6:15 p.m. on alternate Saturdays.
As mentioned in Section 8 of the report, the senior dispatcher is also
the primary scheduler. The Director of Special Services is the backup
dispatcher. The Special Services operation is small enough that one
dispatcher can comfortably handle all vehicles on the road.

At the time of the review team's site visit, MVRTA had 13 full-time
drivers, with 12 work shifts on weekdays and five work shifts on
Saturday. The scheduled number of peak runs is 10, generally on weekdays
from 7:30 to 9:30 a.m. and 2:45 to 4:45 p.m. The first two vehicles
leave the garage at 5 a.m. At the end of the day, there is one vehicle
available until 8:15 p.m. On Saturday, two vehicles leave the garage at
8 a.m. and three vehicles are available until 6:15 p.m.

The morning dispatcher is responsible for checking phone messages for
overnight cancellations and trip requests. The morning dispatcher also
checks in drivers. The drivers pick up their manifests and keys, and
then do a pre-trip inspection of their assigned vehicle. All vehicles
are garaged and maintained at MVRTA's facility in Haverhill.

All Special Services vehicles are equipped with mobile data terminals
(MDTs). In addition, Special Services has an automated vehicle location
(AVL) system that uses a global positioning system (GPS) to track the
location of all vehicles on a continuous basis. Much of the routine
communication between the dispatcher and drivers is done via the MDTs.
Drivers are instructed to enter ("perform") all pickups and drop-off
times into the MDT. They are also supposed to enter the times when they
leave the vehicle, and the beginning and end times of their breaks.

The dispatcher can send text messages via the MDT. This is the primary
means for canceling or adding trips to a driver's run. The driver cannot
send text to the dispatcher, so he or she must radio for non-routine
messages. If a rider fails to appear after the driver waits at least
five minutes within the 30-minute pickup window, the EZ Trans procedure
is for the driver to contact the dispatcher---either via radio or the
"no-show" message on the MDT. The dispatcher is supposed to try to
contact the rider, using the phone numbers in the rider file.

A limitation of the technology used by Special Services is the lack of
connection between the MDTs and the ADEPT software used by the
dispatcher. Drivers transmit their pickup and drop-off times to the
dispatcher. But then the dispatcher must separately enter the times into
the ADEPT dispatch module to update estimated run times. Similarly, when
the dispatcher adds or removes trips from vehicle runs, she must
separately enter the information into the MDT module to send to the
driver and enter it into ADEPT. The general manager cited the cost of
software and hardware as the barrier to installing the interface between
the MDTs and ADEPT.

If a driver falls behind schedule, he or she is supposed to radio the
dispatcher. The dispatcher, with information from the MDTs and AVL, is
usually aware of drivers that are running late. The dispatcher may
choose to move trips from one run to another. If a driver has a road
call for a mechanical problem with the vehicle, an MVRTA mechanic brings
a spare vehicle out to the driver; MVRTA does not have backup drivers
waiting at the garage.

If drivers want to re-arrange the order of pickups and drop-offs, they
are supposed to ask the dispatcher before leaving the garage or radio
the dispatcher to make the request. The dispatcher may then approve (or
not) the change. Some drivers, however, said that they make changes
without prior approval from the dispatcher.

Most "Where's my ride?" calls are handled by the call-takers, who are in
a different part of the MVRTA office. They have access to the AVL, which
lets them see the location of the vehicles. This enables the call-takers
to respond to many of these calls without contacting the driver. If the
call-takers need further information, they can transfer the call to the
dispatcher.

**Andover Livery**

Andover Livery provides a limited number of trips for EZ Trans,
averaging about 25 per day. Special Services sends a daily list of trips
with rider name, origin and destination addresses, and times to Andover
Livery. It uses sedans and carries only ambulatory riders. Most of these
trips are within Andover, or are between Andover and an adjacent town.

If the MVRTA dispatcher wants to provide a same-day add-on to Andover
Livery's trips, she sends a one-page fax to Andover Livery with the trip
information.

If Special Services gets a "Where's my ride?" call for a trip provided
by Andover Livery, the call-taker calls Andover Livery's dispatcher to
learn the status of the trip.

**Assist Medical Transportation**

Team members visited the office of Assist Medical Transportation on
Wednesday, March 16. During this visit, team members observed
call-taking, scheduling and dispatching; interviewed managers, drivers,
and other staff; and collected data about staffing and other resources
and sample operations data.

**Staffing**

In addition to the company owner, Assist Medical's staff includes a lead
dispatcher/call-taker, a backup dispatcher/driver who works several days
per week, and 15 drivers. (Eight bus monitors are also on staff to work
on the Andover school department contract.) Two of the drivers are
dedicated to EZ Trans service, but a total of eight individuals are
certified to drive for MVRTA. Assist Medical's driver force is stable
and experienced. MVRTA provides training in defensive driving and
passenger assistance.

**Reservations, Scheduling and Dispatching**

Assist Medical provides EZ Trans service for riders traveling from
Methuen to Andover, North Andover, and Lawrence (these four towns
comprise "Zone 1" for non-ADA EZ Trans service). Many customers are
former users of MVRTA's Weebus service for seniors. Assist Medical
operates on weekdays only, from 5 a.m. until 7:30 p.m., although peak
periods of demand are generally in the early to mid-morning and early
afternoon hours. Customers wishing to travel on Saturday are referred to
EZ Trans in Haverhill.

Assist Medical's operations are independent of MVRTA's in-house
operations. It takes reservations for the trips it provides, and
prepares its own vehicle schedules. The telephone system used by the
company, described in Section 7 of this report, includes a dedicated EZ
Trans line and several others.

As noted in Section 8 of this report, Assist Medical does not accept
"will-call" returns. However, if a rider is ready to return early or is
not ready until after the scheduled return pickup time, he or she can
call Assist Medical and the first available vehicle is sent to provide
the trip (riders are never left stranded). Assist Medical staff noted
that negotiation of trip times is rarely necessary.

**Service Policies**

Assist Medical provides curb-to-curb EZ Trans service; however, drivers
provide door-to-door assistance when necessary.

In the event of a passenger no-show, Assist Medical drivers wait at
least five minutes and then radio dispatch for instructions. The
dispatcher tries to call the passenger, and if he cannot make contact,
the driver is allowed to leave the location.

The ADA fare for a one-way trip is \$2.00. In Zone 1, the non-ADA fare
for a one-way trip is \$3.00, a significant increase from the \$1.00
fare that was in place until June 2002. As a result of a program
established by the mayor of Methuen, Methuen seniors are able to
purchase subsidized tickets at the senior center that effectively reduce
the fare to \$2.00 per one-way ride, and most riders take advantage of
these tickets.

**Driver Interviews**

The review team interviewed six MVRTA drivers, as well as the two
dedicated EZ Trans drivers for Assist Medical. Interview topics included
individual driving/employment history, training, vehicle condition and
maintenance, schedule, and operating procedures. Drivers also had the
opportunity to offer additional comments.

**Training**

Most MVRTA drivers viewed the training they were given at the start of
employment as positive and helpful. Initial training appears to be
targeted in both length and content to the needs of the individual
employee. One driver reported going through a six-week training period
before being allowed to drive on his own. Another reported an initial
training period of only two weeks, with most falling in the range of
three to four weeks. Training includes both classroom instruction in
safety, driving in inclement weather, use of vehicle technology, map
reading, and dealing with people with both physical and mental
disabilities. The most senior driver commented that he believed that the
training is inadequate for some of the newer drivers and should be more
focused on mentoring from a veteran driver and should mandate a minimum
of one week on-the-road observation of actual runs. Following initial
training, all drivers are required to participate in refresher training
several times per year.

Assist Medical drivers received less formal training, although since
their initial dates of hire were on average almost 10 years ago,
recollections of the details of their initial trainings were not as
fresh. Drivers did note that they received regular sensitivity and CPR
training, although no other types of refresher training were identified.

**Vehicles**

All MVRTA drivers had positive comments about the condition of the
vehicles and the responsiveness of the maintenance staff. While
particular praise was directed to the new, 2005 vehicles, the older
vehicles were also identified as being in excellent condition. Those who
had experience driving for different carriers noted that the vehicle
quality was uncharacteristic in the industry. The only negative comment
regarding vehicles concerned the height of the first step in the 2005
vehicles, which two drivers reported had caused some ambulatory
passengers to use the lift, and the slipperiness of the front and back
flap on the lift. All drivers were impressed with the quality of the
maintenance work performed on the vehicles and noted that on the rare
occasions they experienced in-service failures, maintenance was
dispatched to the scene immediately and the problem was
resolved---either by fixing the problem or providing a replacement
vehicle. Most reported failures were for operation of the mechanical
lift, although there were also reports of minor electrical, heat, and
other routine issues.

Assist Medical drivers were equally complimentary of the condition and
maintenance of vehicles, although the equipment used by Assist Medical
is older than the MVRTA vehicles.

**Schedule**

MVRTA drivers' attitude toward the schedule varied markedly based on
driver experience. For the most part, newer drivers felt that the
schedule was too tight, made it difficult to stay on time, and was
unreasonably indirect, requiring considerable back-and-forth travel.
More senior drivers, however, reported that the schedule was
well-prepared and reasonable and that staying on time was not a problem.
One driver noted that the schedule has gotten better recently with
recent hires, as more vehicles are now used to cover trips. When a
driver calls in sick, other drivers' schedules are overburdened. More
senior drivers also noted that routing has become more direct and
reasonable during the last year. Some of the differences between the
perceptions of the more junior and senior drivers can be attributed to
their relative understandings of the pickup window. More junior drivers
were less inclined to understand that even if they cannot make their
estimate time of arrival (ETA), they may still be within the window and
on time. All drivers felt they had the opportunity to modify their
schedule with dispatch approval, although junior drivers were less
comfortable with making modifications than senior drivers were.

Assist Medical drivers indicated no problems with the schedule or logic
of the routings, which should be expected given the compactness of their
service area. Note that one of the drivers also creates the schedule, so
would be less inclined to have concerns with the schedule.

**Operating Procedures**

As noted above, MVRTA drivers' understanding of the pickup window
appeared to be related to tenure. Some drivers reported that when they
started driving, they were not aware that there was a pickup window and
that it was only explained to them after they expressed anxiety about
meeting their ETAs. Many of the drivers noted that they either do not
pay attention to the pickup window or that that information is
unavailable to them. Some expressed mild irritation that everybody
(dispatch and consumers) was aware of the window, but they were not.
Most drivers felt that passengers were aware of their pickup window, but
still got angry with them if the driver arrived after ETA, even if it
was within the window. None of the drivers seemed to understand that if
they arrived at a pickup prior to the ETA, they might still be within
the window. All reported that if they arrived early they did not contact
dispatch until the ETA, although some, based on knowledge of the
individual passenger, might offer an early ride. Some reported "driving
around" until the ETA.

All drivers were consistent in their handling of no-shows. If a
passenger fails to show, they wait five minutes before contacting
dispatch and await further instruction. Senior drivers were more likely
to knock on a customer's door or otherwise attempt to get a customer's
attention prior to contacting dispatch, while junior drivers were
adamant that they are not allowed to leave the vehicle under any
circumstance. All drivers reported that if they are running
significantly late (generally more than 15 minutes), they contact
dispatch. They reported that dispatch sometimes, but certainly not
always, removes trips from their manifest. Several drivers reported that
dispatch is watching their speed and that if they go over the speed
limit, they will hear about it.

Assist Medical drivers did understand the pickup window well and felt
that consumers were aware as well. In general, Assist Medical drivers
have more autonomy than MVRTA drivers and so are more inclined to use
the window to self-monitor schedule adherence while on the road. Assist
Medical drivers reported that they will wait until the start of the
window when they arrive early and in the case of no-shows, will contact
dispatch and then wait five minutes before being given clearance to
leave.

## 9.1 Analysis of On-Time Performance

**On-Time Performance Standards**

MVRTA asks riders to be ready for pickups from 15 minutes before to 15
minutes after the agreed upon (negotiated) pickup time. Pickups are then
considered to be on time if performed within this pickup window. Pickups
before the 30-minute pickup window are also considered on-time where
riders are ready to leave early.

The contracts with the two subcontractors---Assist Medical and Andover
Livery---establish a minimum performance standard of making at least 90
percent of pickups on time. If performance falls below 90 percent in any
month of service, a penalty of \$500 per percentage point below this
standard can be assessed. No minimum level of performance is included in
the contract with MVATC for its own Special Services operation.

MVRTA has not established a standard for on-time arrivals. However, as
noted in the description of the reservation, scheduling, and dispatch
processes earlier in this report, appointment times are captured in the
reservations process. For "going" trips that have an appointment time,
trips are booked based on the desired arrival (appointment) time.
Appointment times are then shown on driver manifests, as well as on
dispatch screens. They are used in operations to ensure that riders
arrive at their appointments on time.

**Reported On-Time Performance**

Table 9.1 shows on-time performance for pickups reported by MVRTA for
recent months for each of the three service providers. An on-time
performance percentage was included in most of the monthly service
reports provided by MVRTA. For a few of the months, however, this
information was not included.

**Table 9.1 -- Paratransit Service On-Time Pickup Performance Reported
by MVRTA,**

**March to December 2004**

  -------------------- ---------------- ----------------- -----------------
  **Month**            **Percent of                       
                       On-Time                            
                       Pickups**                          

                       **MVATC**        **Assist          **Andover
                                        Medical**         Livery**

  March                99.4             99.2              99.8

  April                99.4             98.6              99.8

  May                  NA               NA                NA

  June                 98.8             99.3              99.6

  July                 99.2             100               99.6

  August               NA               NA                NA

  September            99.1             99.6              99.6

  October              98.8             99.5              100

  November             97.2             98.8              99.8

  December             96.3             99.1              99.4
  -------------------- ---------------- ----------------- -----------------

As shown, on-time performance as reported by MVRTA is very good. For all
three providers, it ranged on a monthly basis from 96.3 percent to 100
percent. In most months, on-time performance was reported to be better
than 98 percent.

**Calculated On-Time Performance for Sample Days**

In order to develop an independent measure of on-time performance, the
review team collected and analyzed pickup and drop-off times recorded on
driver manifests and compared these with scheduled pickups and
appointment times for trips performed during the week of February 14 to
18, 2005. This analysis was performed for each of the three operations:
MVATC (in-house), Assist Medical, and Andover Livery. Following are the
results of this analysis for each service provider.

**MVATC Service**

Trips performed by MVATC on Wednesday, February 16, 2005, were analyzed.
The actual pickup and drop-off times were first taken from the completed
driver manifests. Appointment times, also indicated on the run
manifests, were also recorded. The agreed upon pickup times (i.e., the
pickup times negotiated with and given to riders) and the 30-minute
pickup windows for each trip were then looked up in the original trip
record. Pickup times were then compared with pickup times negotiated
with customers, and actual drop-off times were compared with customer
appointment times.

Table 9.2 shows MVATC on-time pickup performance. The review team
analyzed 144 trips from completed driver manifests for the sample day (a
number of trips did not have specified pickup times, such as "will call"
trips). As shown, 70.8 percent of these pickups were made within the
30-minute pickup window. Another 25 percent of pickups were made early.
A total of 95.8 percent of pickups were therefore made early or on time.

**Table 9.2 -- On-Time Performance for MVATC Pickups,**

February 16, 2005

  -------- --------------------- -------------------- --------------------
                                 **Number**           **%**

  Total                          144                  100
  Sample                                              

  \% in                          102                  70.8
  Window                                              

  \% in                          138                  95.8
  Window                                              
  or Early                                            

  All                            36                   25.0
  Early                                               
  Trips                                               

           1--15 mins            27                   18.8

           16--30 mins           6                    4.2

           \> 30 mins            3                    2.1

  All Late                       6                    4.2
  Trips                                               

           1--5 mins             2                    1.4

           6--10 mins            2                    1.4

           11--20 mins           2                    1.4
  -------- --------------------- -------------------- --------------------

Only six of the 144 pickups were late. Two were made within five minutes
of the pickup window, two were made within 10 minutes of the pickup
window, and two were made within 15 minutes of the pickup window. No
pickup was more than 15 minutes late.

The nine pickups that were more than 15 minutes before the start of the
pickup window were analyzed further to see if there were any issues
related to very early pickups. All nine of these very early pickups were
for return trips where it is likely that riders called and indicated
that they were ready to return early.

Table 9.3 shows on-time arrival information. Of the 144 trips on
February 16, 2005, that were analyzed, 56 had listed appointment times.
As shown, 91.1 percent of the drop-offs for these 56 trips occurred on
or before the indicated appointment times. Of the five trips for which
drop-offs were late, four were less than 15 minutes late, and one was 19
minutes late. No drop-off was more than 19 minutes after the appointment
time.

**Table 9.3 -- On-Time Performance for MVATC Drop-Offs,**

February 16, 2005

  ------------- -------- --------------------- ---------------- -------------------
                                               **Number**       **%**

  Total Sample                                 56               100

  All Late                                     5                8.9
  Trips                                                         

                         1--15 mins            4                7.1

                         15--30 mins           1                1.8

  All On-Time                                  51               91.1
  Trips                                                         

                0--30                          37               66.1
                mins                                            
                early                                           

                31--45                         11               19.6
                mins                                            
                early                                           

                46--60                         3                5.4
                mins                                            
                early                                           
  ------------- -------- --------------------- ---------------- -------------------

The majority of drop-offs (66.1 percent) were made from zero to 30
minutes before the appointment. Another 11 were made up to 45 minutes
early. Only three drop-offs were between 45 and 60 minutes early, and no
drop-off was more than 60 minutes before the appointment time.

**Assist Medical Transportation**

The review team analyzed a total of 130 trips performed by Assist
Medical on February 15 to17, 2005. All of these were trips scheduled on
one of the two regular MVRTA runs. Other trips that did not fit onto the
schedules for these two vans and were "same-day dispatched" during the
day were not part of the sample. These trips could not be analyzed
because the drivers on these other runs do not record actual pickup or
drop-off times. The review team did, however, examine sample schedules
for these other non-dedicated runs to see if the scheduling appeared
reasonable. Adequate time appeared to be available on these other runs
to allow these same-day dispatched trips to be performed on time. In
most cases, it appeared that these same-day dispatched trips were not
shared-ride and were performed directly by the drivers. On-time
performance for these trips was therefore probably not a problem.

Table 9.4 shows on-time pickup performance for the 130 Assist Medical
pickups that were analyzed. As shown, 80 percent of these pickups were
made within the 30-minute pickup window. Another 17.7 percent of pickups
were made early. A total of 97.7 percent of pickups were therefore made
early or on time.

Only three of the 130 pickups that were analyzed were late. One was made
within five minutes of the pickup window, and two were made between six
and 10 minutes of the pickup window. No pickup was more than 10 minutes
late.

**Table 9.4 -- On-Time Performance for Assist Medical Pickups,**

**February 15--**17, 2005

  -------- --------------------- -------------------- --------------------
                                 **Number**           **%**

  Total                          130                  100
  Sample                                              

  \% in                          104                  80.0
  Window                                              

  \% in                          127                  97.7
  Window                                              
  or Early                                            

  All                            23                   17.7
  Early                                               
  Trips                                               

           1--15 mins            22                   16.9

           16--30 mins           1                    0.8

           \> 30 mins            0                    0.0

  All Late                       3                    2.3
  Trips                                               

           1--5 mins             1                    0.8

           6--10 mins            2                    1.5

           11--20 mins           0                    0.0
  -------- --------------------- -------------------- --------------------

The 23 early pickups were analyzed further to see if there were any
issues related to very early pickups. Nineteen of these early pickups,
including the one that was more than 30 minutes early, were for return
trips where it is likely that riders had called and indicated that they
were ready to return early.

In order to analyze on-time arrivals for Assist Medical, the review team
had to estimate appointment times. Assist Medical does not record
appointment times as part of the reservations and scheduling process. It
does, however, consistently schedule pickup times to be 30 minutes
before the arrival time requested by the rider. To estimate likely
on-time arrivals, the review team assigned likely appointment times that
were 30 minutes after the scheduled pickup times. Table 9.5 shows the
results of the analysis of on-time arrivals.

**Table 9.5 -- On-Time Performance for Assist Medical Drop-Offs,**

**February 15--**17, 2005

  ------------- ------- --------------------- ---------------- -------------------
                                              **Number**       **%**

  Total Sample                                95               100

  All Late                                    1                1.0
  Trips                                                        

                        1--15 mins            1                1.0

                        15--30 mins           0                0.0

  All On-Time                                 94               99.0
  Trips                                                        

                0--30                         94               100
                mins                                           
                early                                          
  ------------- ------- --------------------- ---------------- -------------------

A total of 95 trips were analyzed. For some of these trips, the recorded
drop-off time was earlier than the originally requested pickup time.
These were likely return trips where riders had completed their business
early and had called to schedule earlier pickups. These trips were not
included in the sample.

Of the 95 that were analyzed, 94 had drop-offs that were on or before
the estimated appointment time. Only one trip might have been late,
assuming that the appointment time was 30 minutes after the scheduled
pickup time. For this one trip, the drop-off was 35 minutes after the
scheduled pickup time, which means the drop-off may have been five
minutes late.

**Andover Livery**

The review team analyzed overflow trips referred to and performed by
Andover Livery on February 16, 2005. The analysis could only consider
on-time arrivals. Drivers at Andover Livery record only drop-off times
on their run manifests. They do not record pickup times.

A total of 14 of the 34 trips referred to Andover Livery on February 16,
2005, had appointment times listed in the original trip record. Table
9.6 shows the on-time arrival performance for these trips. As shown, all
14 of the drop-offs occurred on or before the recorded appointment
times.

**Table 9.6 -- On-Time Performance for Andover Livery Drop-Offs,**

February 16, 2005

  ------------- --------------------- ---------------- -------------------
                                      **Number**       **%**

  Total Sample                        14               100

  All Late                            0                0
  Trips                                                

  All On-Time                         14               100
  Trips                                                

                0--30 mins early      11               78.6

                31--45 mins early     2                14.3

                46+ mins early        1                7.1
  ------------- --------------------- ---------------- -------------------

The majority of drop-offs (78.6 percent) were made from zero to 30
minutes before the appointment time. Two drop-offs were made from 30 to
45 minutes early and one was made more than 45 minutes early. Further
analysis of these very early drop-offs indicated that the riders had
called and requested earlier pickups.

Since nearly all trips provided by Andover Livery are within Andover or
between Andover and an adjoining town, travel times are relatively
short. Even though actual pickup times are not recorded by Andover
Livery, the review team examined the 34 trips assigned to this service
provider on February 16, 2005, using the drop-off times to estimate
whether the pickups probably would have been made within or before the
pickup window. This analysis indicated that all pickups likely were made
within the 30-minute pickup window.

**Overall On-Time Performance**

Tables 9.7 and 9.8 summarize the on-time performance for all three
service providers. Table 9.7 shows combined on-time pickup information
for the total sample of 308 pickups. Table 9.8 shows combined on-time
arrival information for the total sample of 165 drop-offs.

As shown, pickups were on-time or early 97.1 percent of the time for the
sample trips. Less than 1 percent of pickups were late by more than 10
minutes. Arrivals were on time 96.4 percent of the time and less than 1
percent were more than 15 minutes late.

**Table 9.7 -- Estimated On-Time Pickup Performance for All Service
Providers,**

**Based on Analysis of 308 Trips, February 15--17, 2005**

  -------- --------------------- -------------------- --------------------
                                 **Number**           **%**

  Total                          308                  100
  Sample                                              

  \% in                          240                  77.9
  Window                                              

  \% in                          299                  97.1
  Window                                              
  or Early                                            

  All                            59                   19.2
  Early                                               
  Trips                                               

           1--15 mins            49                   15.9

           16--30 mins           7                    2.3

           \> 30 mins            3                    1.0

  All Late                       9                    2.9
  Trips                                               

           1--5 mins             3                    1.0

           6--10 mins            4                    1.3

           11--20 mins           2                    0.6
  -------- --------------------- -------------------- --------------------

**Table 9.8 -- Estimated On-Time Arrival Performance for All Service
Providers,**

**Based on Analysis of 165 Trips, February 15--**17, 2005

  ------------- -------- --------------------- ---------------- -------------------
                                               **Number**       **%**

  Total Sample                                 165              100

  All Late                                     6                3.6
  Trips                                                         

                         1--15 mins            5                3.0

                         15--30 mins           1                0.6

  All On-Time                                  159              96.4
  Trips                                                         

                0--30                          142              86.1
                mins                                            
                early                                           

                31--45                         13               7.9
                mins                                            
                early                                           

                46--60                         4                2.4
                mins                                            
                early                                           
  ------------- -------- --------------------- ---------------- -------------------

## 9.2 Analysis of Trip Length

To assess on-board travel times for ADA-eligible EZ Trans riders, the
review team analyzed a sample of driver manifests from MVRTA and Assist
Medical Transportation, contrasted ADA complementary paratransit service
travel times to those of comparable fixed route trips, and examined a
report generated by ADEPT that identified trips with travel times that
are longer than a specified maximum.

**Policies and Procedures**

MVRTA's travel time standard is that all EZ Trans trips be performed in
60 minutes or less. The ADEPT software can generate a report that
identifies trips with long travel times. However, MVRTA does not appear
to be using that function to track long trips.

**Consumer Comments**

No consumer complaints or comments concerned long ride times on EZ Trans
ADA complementary paratransit service.

**Review of Trip Length**

**MVATC**

MVRTA provided a report that identified all EZ Trans trips provided by
MVATC between July 1, 2004 and December 31, 2004, that had travel times
that exceeded 60 minutes. Both ADA and non-ADA trips are included in the
report. Table 9.9 summarizes travel time performance for that period by
month.

**Table 9.9 -- MVATC's EZ Trans Trips with Travel Times \> 60 Minutes,**

**July 1 to December 31, 2004**

+---------------+----------------+----------------+-------------------+
| **Month**     | **Number of    | **Percent of** | **Average Length  |
|               | Trips \> 60    |                | (minutes) of      |
|               | Minutes**      | **All Trips**  | these Trips**     |
+---------------+----------------+----------------+-------------------+
| July          | 57             | 1.7%           | 72                |
+---------------+----------------+----------------+-------------------+
| August        | 55             | 1.5%           | 71                |
+---------------+----------------+----------------+-------------------+
| September     | 60             | 1.7%           | 72                |
+---------------+----------------+----------------+-------------------+
| October       | 77             | 2.2%           | 73                |
+---------------+----------------+----------------+-------------------+
| November      | 65             | 2.1%           | 70                |
+---------------+----------------+----------------+-------------------+
| December      | 90             | 2.7%           | 73                |
+---------------+----------------+----------------+-------------------+
| Total         | 404            | 2.0%           | 72                |
+---------------+----------------+----------------+-------------------+

As Table 9.9 shows, between 1.5 percent and 2.7 percent of the EZ Trans
trips provided by MVATC in each of the first six months of FY 2005
exceeded MVRTA's maximum travel time standard of 60 minutes. On a daily
basis, the number of long trips ranged from one to nine; on most days,
three to four trips exceeded the 60-minute standard. The average travel
time for these long trips ranged from 70 to 73 minutes each month. A
review of the origins and destinations of these trips revealed that many
are long-distance trips that are made regularly, often involving small
groups of riders traveling to the same destination. The long trips
selected from among the trips served on February 16, 2005, included a
number of the same individuals traveling between the same locations.

Next, the review team conducted an analysis of all 168 EZ Trans ADA and
non-ADA paratransit trips served by MVATC on February 16, 2005. Table
9.10 shows the distribution of trip duration for these trips.

As shown in Table 9.10, the average trip duration was 20 minutes
(individual travel times ranged from one minute to 64 minutes). The
majority of trips (79 percent) were completed in 30 minutes or less.
Virtually all trips were completed in 60 minutes or less, the MVRTA
standard for maximum travel time. Only one trip took longer than 60
minutes, but at 64 minutes, not significantly so.

**Table 9.10 --** Average Trip Length for February 16, 2005

  ---------------------------------------- ------- -----------------------
  **Number of Trips**                              168

  **Average Travel Time**                          20 mins

  **15 minutes or less**                           50.6%

  **16--30 minutes**                               28.6%

  **31--45 minutes**                               12.5%

  **46--60 minutes**                               7.7%

  **Over 60 minutes**                              0.6%
  ---------------------------------------- ------- -----------------------

Of all the EZ Trans trips served by MVATC on February 16, 2005, the
review team further analyzed all trips with travel times of 45 minutes
or longer. Travel times for these trips were compared with fixed route
travel times to determine whether the paratransit trip lengths are
significantly longer than comparable trips taken on fixed route service.

The review team worked with an MVATC dispatcher to develop trip
itineraries to estimate the comparable fixed route travel times. Each
estimate of fixed route travel time included the following components:

-   Travel time on each bus

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

-   Walking time at each end of the trip

    -   5 minutes for less than 1 block

    -   10 minutes for 1--3 blocks

    -   15 minutes for 4--6 blocks

    -   20 minutes for more than 6 blocks

For each EZ Trans paratransit trip, Table 9.11 shows the time of day at
which the trip was made, the origin and destination, and the actual EZ
Trans travel time, as determined from the actual pickup and drop-off
times recorded on the driver manifests. Table 9.11 then shows the fixed
routes that would be used to connect the same origin and destination,
the number of transfers involved, a calculation of travel time on board
the buses, an estimate of walking time to and from the fixed route(s),
and a calculation of total fixed route travel time. Since MVRTA operates
on a flag stop policy, the estimates for walking time consider the
nearest point along a route that a rider would board or alight a bus on
that particular route, rather than specific stops.

The final column of Table 9.11 compares the ADA complementary
paratransit services with MVRTA fixed route travel times. The values in
"Travel Time Difference" column represent the difference in travel times
between the two modes. A minus sign (-) indicates that the ADA
complementary paratransit service travel time would have been *less*
than the estimate fixed route travel time.

As shown in Table 9.11, the average travel time for this sample of the
longest EZ Trans paratransit trips operated by STS was 53 minutes. The
average travel time for the comparable fixed route trips (for the nine
trips for which fixed route service is available at the time of day and
between the specific origins and destinations of the paratransit trips)
was 106 minutes, which includes both ride time on the bus and walking
time to and from the bus route. One of the fixed route trips could have
been completed on one bus route; two would have required one transfer,
and six would have required two transfers.

The table also shows that, on average, EZ Trans trips were 52 minutes
shorter than comparable trips would have been if made using the fixed
route system. All but one of the paratransit trips would have taken
significantly longer using MVRTA bus routes---travel time differentials
between paratransit and comparable fixed route trips ranged from 39 to
103 minutes. One trip, however, with an origin and destination in North
Andover, took nearly twice as long on EZ Trans as it would have on the
fixed route system. As mentioned above, all but one of these EZ Trans
paratransit trips meet the MVRTA standard of a maximum travel time of 60
minutes.

**Assist Medical Transportation**

The review team also calculated paratransit travel times for EZ Trans
trips served by Assist Medical Transportation.

Table 9.12 shows a summary for travel times for all 126 EZ Trans trips
provided by Assist Medical on February 15, 16, and 17, 2005, based on
the pickup and drop-off times recorded on driver manifests. As the table
shows, the average travel time for the trips provided on each of those
days ranged from eight minutes to 15 minutes. The overall average travel
time for all 126 trips was 11 minutes. Assist Medical's longest trip for
these three days was 33 minutes.

**Table 9.11 -- Comparison of Travel Times on EZ Trans vs. Fixed Route
for Selected Trips: February 16, 2005**

![](media/image1.wmf)

Notes: Addresses are rounded to the nearest 100 block.

Walking time at each end of the trip:

> 5 minutes: less than 1 block 15 minutes: 4--6 blocks
>
> 10 minutes: 1--3 blocks 20 minutes: more than 6 blocks

**Table 9.12 -- Summary of Travel Time Analysis for Trips Provided by
Assist Medical,**

**February 15--17, 2005**

  --------------- ----------------- ----------------- --------------------
  **Date**        **Number of       **Average Travel  **Maximum Travel
                  Trips**           Time (mins)**     Time (mins)**

  February 15     46                13                31

  February 16     41                15                33

  February 17     39                8                 28

  **Total**       **126**           **11**            **33**
  --------------- ----------------- ----------------- --------------------

**Andover Livery**

Andover Livery's EZ Trans driver manifests for February 16, 2005, were
reviewed, but travel times could not be calculated because its drivers
record actual drop-off times but not pickup times.

**Findings**

1.  MVRTA has EZ Trans service standards for trip denials, on-board
    travel time, missed trips, and passenger no-shows.

2.  MVRTA has a standard for on-time pickups for Assist Medical and
    Andover Livery, but not for trips provided in-house. There is no
    standard for on-time drop-offs.

3.  The review team did not observe any practice by EZ Trans dispatchers
    that limited or denied service to its riders. One limitation in the
    existing design of the technology, however, was the lack of
    connection between the mobile data terminals (MDTs) and the ADEPT
    software used by the dispatcher. Dispatchers must manually transfer
    information from one system to the other.

4.  MVRTA uses Andover Livery as a subcontractor for EZ Trans service.
    Andover Livery provides about 25 ambulatory trips per day.

5.  MVRTA also uses Assist Medical as a subcontractor for EZ Trans
    service. Assist Medical's operations are independent of MVRTA's
    in-house operations. Assist Medical provides 40 to 50 trips per
    weekday.

On-Time Performance

1.  MVRTA does not appear to have any substantially late pickups or
    drop-offs.

2.  On-time performance for MVRTA's paratransit services is very good.
    Based on an analysis of selected trips performed during the week of
    February 14 to 18, 2005, pickups were on time or early 97.1 percent
    of the time. Drop-offs also were on time or early 96.4 percent of
    the time. Less than 1 percent of pickups were more than 10 minutes
    late and less than 1 percent of drop-offs were more than 15 minutes
    late. Very early pickups and drop-offs also did not appear to be an
    issue. In almost all cases, it appears that early pickups and
    drop-offs were the result of riders completing their business early
    and calling to arrange for pickups earlier than originally
    scheduled.

3.  While on-time performance appears to be very good, data collection
    and performance monitoring among the three service providers vary.
    Assist Medical does not record actual pickup and drop-off
    information for trips assigned to non-MVRTA vehicles. Andover Livery
    records only drop-off times and not pickup times. Also, Assist
    Medical does not record appointment times.

4.  While on-time arrival performance appears very good, MVRTA does not
    regularly monitor drop-off times for trips that have appointment
    times.

Trip Length

1.  EZ Trans does not appear to operate any significantly long ADA
    complementary paratransit service trips.

2.  An analysis of the 168 trips provided by MVATC on February 16, 2005,
    indicated an average trip length of 20 minutes. Most trips (79
    percent) were completed in 30 minutes or less. Virtually all trips
    were completed in 60 minutes or less. Only one trip in the sample
    took longer than 60 minutes.

3.  Analysis of the 126 EZ Trans trips provided by Assist Medical on
    February 15, 16, and 17, 2005, showed an average trip length of 11
    minutes. The maximum trip length during these three days was 33
    minutes.

4.  When the actual travel times of 11 long EZ Trans trips (45 minutes
    or longer) served by MVATC on February 16, 2005, were compared with
    the estimated travel times for comparable fixed route trips, EZ
    Trans travel times were shorter in all cases but one. The average
    travel time for the sample of EZ Trans trips was 53 minutes, while
    the average fixed route travel time was 80 minutes. Fixed route
    trips involved an average of 1.6 transfers, and 24 minutes of
    walking time to and from bus routes.

5.  Only one of the 11 trips in the review team's sample exceeded the
    MVRTA standard of 60 minutes.

6.  Trip duration for Andover Livery could not be analyzed because the
    carrier does not record pickup times.

**Recommendations**

1.  MVRTA should establish the same standard for on-time pickups for its
    in-house service as it has for Assist Medical and Andover Livery.

2.  MVRTA should establish a standard for on-time drop-offs.

On-Time Performance

1.  MVRTA should work with Assist Medical and Andover Livery to develop
    more complete trip time reporting. This should include recording
    actual pickup and drop-off times for all trips. For Assist Medical,
    it also should include recording appointment times indicated by
    riders. More complete data collection would make ongoing monitoring
    of on-time performance easier and more consistent.

2.  MVRTA should regularly monitor on-time arrivals as well as on-time
    pickups.

Trip Length

1.  To ensure that EZ Trans travel times remain reasonable, MVRTA should
    review travel time performance periodically. This review should be
    based on the ADEPT "Travel Time Threshold" report for trips provided
    in-house by MVATC, and actual trip data recorded on driver manifests
    used by Assist Medical and Andover Livery.

2.  To allow for periodic review of travel time performance MVRTA should
    require Andover Livery to record both actual pickup and drop-off
    times on driver manifests.

# 10. Resources

The team reviewed the resources provided by MVRTA for ADA complementary
paratransit services. The purpose of this portion of the review is to
assess the adequacy of resources, such as funds, labor, equipment and
facilities, to support effective service. The review team met with
MVRTA's administrator and general manager to review the budget process
for MVRTA's EZ Trans service. Following are the results of those
interviews, along with an analysis of information provided by MVRTA.

**Policies and Procedures**

The MVRTA administrator is responsible for developing the budget for all
MVRTA services, including EZ Trans and other special services. For EZ
Trans service, the administrator works with the MVATC general manager to
develop ridership, cost, and fare revenue projections for future years.
The general manager submits estimates based on expenses, revenue, and
ridership of current and recent years. If there are no proposed service
changes, the projected costs for the next fiscal year (which runs from
July 1 to June 30) are generally based on increases in wages and other
expected changes. For example, for FY 2006, which begins on July 1,
2005, the general manager's recommendations for the EZ Trans budget are
listed in Table 10.1.

**Table 10.1 -- MVRTA Budget Projection for FY 2006**

+-----------------------+----------------------------------------------+
| **Budget Category**   | **Changes, FY05 to FY06**                    |
+-----------------------+----------------------------------------------+
| Fare Revenue          | Increase (\$106,000 to \$121,000)            |
+-----------------------+----------------------------------------------+
| Labor                 | Increase for operators and call-takers       |
|                       |                                              |
|                       | Decrease for dispatchers                     |
|                       |                                              |
|                       | Increase for sick, vacation, and holiday     |
+-----------------------+----------------------------------------------+
| Fringes               | Increase for FICA, unemployment, health      |
|                       | insurance                                    |
|                       |                                              |
|                       | Increase for uniforms                        |
|                       |                                              |
|                       | Decrease for 401(k)                          |
+-----------------------+----------------------------------------------+
| Services              | No change for drug testing                   |
|                       |                                              |
|                       | No change for computer software and repairs  |
|                       |                                              |
|                       | Increase for radios                          |
+-----------------------+----------------------------------------------+
| Vendor Services       | Increase for childcare and other services    |
+-----------------------+----------------------------------------------+

In projecting the required resources and developing the budget, MVRTA
looks at EZ Trans ADA and non-ADA service as a single operation. MVRTA
estimates the costs of its ADA complementary paratransit service by
prorating the total EZ Trans costs by the proportion of ADA ridership;
for example, if 70 percent of EZ Trans trips are for ADA EZ Trans, MVRTA
estimates that the cost for ADA complementary paratransit service is 70
percent of the total EZ Trans costs.

**Budget**

Table 10.2 presents the ridership and costs for EZ Trans for FY 2002 to
FY 2006. The figures for FY 2005 and FY 2006 are projections.

**Table 10**.2 -- EZ Trans Ridership and Costs

+--------------------+-------+-------+-------+-------+-------+-------+
|                    | **F   | **F   | **F   | **F   | **F   | **F   |
|                    | Y02** | Y03** | Y04** | Y05** | Y05** | Y06** |
+--------------------+-------+-------+-------+-------+-------+-------+
|                    | **act | **act | **act | **7   | *     | *     |
|                    | ual** | ual** | ual** | mos** | proje | proje |
|                    |       |       |       |       | cted* | cted* |
+--------------------+-------+-------+-------+-------+-------+-------+
| All Operating      | 79    | 87    | 82    | 48    | *953  | *941  |
| Costs (\$)         | 7,236 | 9,134 | 7,108 | 0,310 | ,750* | ,670* |
+--------------------+-------+-------+-------+-------+-------+-------+
| Fare Revenue (\$)  | 8     | 13    | 10    | 8     | *107  | *105  |
|                    | 7,139 | 1,037 | 9,556 | 8,269 | ,775* | ,795* |
+--------------------+-------+-------+-------+-------+-------+-------+
|                    |       |       |       |       |       |       |
+--------------------+-------+-------+-------+-------+-------+-------+
| All EZ Trans Trips | 7     | 5     | 5     | 2     | *54   | *57   |
|                    | 2,917 | 8,097 | 3,030 | 9,438 | ,916* | ,312* |
+--------------------+-------+-------+-------+-------+-------+-------+
| ADA Trips          | 5     | 4     | 3     | 2     | *38   | *40   |
|                    | 2,417 | 0,857 | 8,161 | 0,646 | ,747* | ,176* |
+--------------------+-------+-------+-------+-------+-------+-------+
| Non-ADA Trips      | 2     | 1     | 1     | 8,792 | *16   | *17   |
|                    | 0,500 | 7,240 | 4,869 |       | ,169* | ,136* |
+--------------------+-------+-------+-------+-------+-------+-------+
| \% change, ADA     |       | -     | -     |       | *     | *     |
| trips              |       | 22.1% | 13.8% |       | 8.7%* | 6.0%* |
+--------------------+-------+-------+-------+-------+-------+-------+
|                    |       |       |       |       |       |       |
+--------------------+-------+-------+-------+-------+-------+-------+
| ADA Operating      | 57    | 61    | 59    | 33    | *672  | *660  |
| Costs (\$)         | 3,100 | 8,255 | 5,196 | 6,860 | ,936* | ,115* |
+--------------------+-------+-------+-------+-------+-------+-------+
| \% change,         |       | 7.9%  | -3.7% |       | *1    | *-    |
|                    |       |       |       |       | 3.1%* | 1.9%* |
| ADA Operating      |       |       |       |       |       |       |
| Costs              |       |       |       |       |       |       |
+--------------------+-------+-------+-------+-------+-------+-------+

EZ Trans ridership, both ADA and total, decreased from FY 2002 to FY
2003. This was due in part to the change in the structure and scope of
MVRTA's Special Services. Until FY 2002, MVRTA used a larger set of
private contractors to provide ADA and non-ADA paratransit. Starting in
FY 2003, MVRTA brought most of the service in-house (through MVATC).
MVRTA also raised the fares for both ADA and non-ADA trips.

**Funding**

Funds for EZ Trans service come from four sources:

-   EZ Trans passenger fares

-   FTA Section 5307 Transit Capital funds that can be allocated to ADA
    complementary paratransit service, along with other federal funds

-   State operating assistance

-   Local assessments: funds provided by the cities and towns receiving
    EZ Trans service

Table 10.3 presents the proportion of funds from each of these sources
for FY 2003 to FY 2006.

As evidenced in the lack of service denials, high on-time performance
(where measured), and availability of backup service, MVRTA has been
able to fund all demand for ADA complementary paratransit service. In
addition, because MVRTA currently provides both ADA and non-ADA
paratransit, it has the option of reducing non-ADA service in order to
continue to meet the demand for ADA trips.

**Table 10.3 -- EZ Trans Funding Source**s

  ------------------------ ------------ ------------ ------------- -------------
                           **FY03**     **FY04**     **FY05**      **FY06**

                           **actual**   **actual**   *projected*   *projected*

  Passenger Fares          \$131,037    \$109,556    *\$100,895*   *\$105,795*

  Federal Grants           163,438      167,965      *414,693*     *470,965*

  State Assistance         417,834      374,952      *162,915*     *185,020*

  Local Assessments        166,825      174,635      *162,916*     *185,020*

                           100%         100%         100%          100%

  **TOTAL**                \$879,134    \$827,108    *\$841,419*   *\$946,800*
  ------------------------ ------------ ------------ ------------- -------------

**Operating Resources**

The review team gathered information on operating resources for EZ Trans
service to determine whether MVRTA was allocating resources to ensure
that it was serving the demand for ADA complementary paratransit
service. Team members looked at the number and distribution of EZ Trans
staff, equipment, and subcontractor resources.

**Staff**

Table 10.4 lists the number of full-time EZ Trans staff at the time of
the on-site visit.

**Table 10.4 -- EZ Trans Staff**

  --------------------------------------- -------------------------------
  **Position**                            **Full-time Positions**

  Operator                                13

  Call-taker                              3

  Dispatcher/scheduler                    2

  Assistant General Manager               1
  --------------------------------------- -------------------------------

Other MVRTA staff who contribute to EZ Trans operations include:

-   Administrator

-   General manager

-   Operator trainer/safety officer

-   Vehicle mechanics

There appears to be sufficient office staff to perform all necessary
activities. The Assistant General Manager for Special Services also
handles eligibility determinations and is the backup scheduler and
dispatcher. She is also the most knowledgeable about the ADEPT software.
The call volume is light enough so that all three call-takers have other
administrative tasks.

EZ Trans has a peak service of 11 runs. On Saturdays, it has four runs.
The procedure to cover runs for sick drivers is:

-   Call in drivers not scheduled for work

-   Same-day dispatch trips of an uncovered run within existing runs

-   Same-day dispatch trips of an uncovered run by extending driver
    shifts

**Vehicles**

At the time of the on-site review, MVRTA had a fleet of three Dodge vans
(model year 2000) and 11 small buses for all Special Services. The 11
small buses were model year 2005 El Dorado Aerolites that went into
service in early 2005. MVRTA was anticipating delivery of seven
additional model year 2005 El Dorado Aerolite small buses in June 2005.
At that time, MVRTA would retire the three vans. Assist Medical would
receive two of the new vehicles for EZ Trans service.

Assist Medical's fleet for EZ Trans service includes three Trans Dodge
vans (model year 2000) provided by MVRTA. Two are in regular operation,
and the third is used as a backup vehicle. Assist Medical also has 11
other vehicles available for EZ Trans. MVRTA planned to provide two new
vehicles to Assist Medical in June 2005 to replace two of the vans. All
vehicles are garaged at 455 Market Street, Lawrence. Assist Medical uses
local garages to provide vehicle maintenance.

Andover Livery uses its own sedans to provide EZ Trans service.

**Other Equipment**

There are three call-taker workstations. In addition, the assistant
general manager sits in the adjacent office and can take incoming calls,
if necessary. MVRTA has no call management software, but the assistant
general manager's phone can alert her if there are calls on hold. The
review team did not observe any long hold times.

Special Services uses ADEPT software for its customer database,
reservations, scheduling, and dispatching. Both the dispatchers and
call-takers have access to the AVL system. All vehicles used by MVRTA
for Special Services are equipped with MDTs. Much of the communication
between the dispatchers and drivers takes place via the MDTs. As
mentioned earlier, there is no link between the MDT system and the ADEPT
dispatch module, so the dispatcher must manually transfer data between
the two systems. The general manager believed that the benefit in making
that link would not justify the cost.

**Subcontractors**

The availability of Assist Medical and Andover Livery provides MVRTA
with the flexible capacity to handle the existing demand for EZ Trans
service. Since neither subcontractor is guaranteed any volume of
business, MVRTA is free to use them for any level of service. Given the
anticipated fleet expansion, MVRTA would likely have the capacity to
provide the service currently provided by Assist Medical, with the
hiring of additional drivers.

**Findings**

1.  MVRTA provides sufficient financial resources to serve all demand
    for ADA complementary paratransit service.

2.  In projecting the required resources and developing the budget,
    MVRTA looks at EZ Trans ADA and non-ADA service as a single
    operation. MVRTA estimates the costs of its ADA complementary
    paratransit service by prorating the total EZ Trans costs by the
    proportion of ADA ridership.

3.  MVRTA has sufficient staff and equipment to meet all demand for EZ
    Trans service.

4.  The availability of Assist Medical and Andover Livery provides MVRTA
    with the flexible capacity to handle the existing demand for EZ
    Trans service.

**Recommendations**

None.

**Attachment A**

**Response from**

**Merrimack Valley Regional Transit Authority**

**Attachment B**

**On-Site Review Schedule**

**ADA Complementary Paratransit Service Review**

**Merrimack Valley Regional Transit Authority (MVRTA)**

**Haverhill, Massachusetts**

**March 15--18, 2005**

**Schedule**

+--------+----------------------------------+------------+------------+
| **     | **Activity**                     | **Who**    | **Where**  |
| Time** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| **Tu   |                                  |            |            |
| esday, |                                  |            |            |
| March  |                                  |            |            |
| 15,    |                                  |            |            |
| 2005** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 10:00  | -   Opening Conference           | All        | 85         |
| a.m.   |                                  |            | Railroad   |
|        |                                  |            | Ave.,      |
|        |                                  |            | Haverhill  |
+--------+----------------------------------+------------+------------+
| 10:30  | -   Review information requested | All        | 85         |
| a.m.   |     & policies & procedures with |            | Railroad   |
|        |     MVRTA managers               |            | Ave.       |
+--------+----------------------------------+------------+------------+
| 11:30  | -   Tour facility                | All        | 85         |
| a.m.   |                                  |            | Railroad   |
|        |                                  |            | Ave.       |
+--------+----------------------------------+------------+------------+
| 1:30   | -   Review budget and resources  | C          | 85         |
| p.m.   |                                  | hia/Berger | Railroad   |
|        | -   Review eligibility process   |            | Ave.       |
|        |                                  | Thatch     |            |
|        | -   Review complaints            | er/Griffin |            |
|        |                                  |            |            |
|        |                                  | Monahan    |            |
+--------+----------------------------------+------------+------------+
| 3:00   | -   Observe call-takers; record  | Chia       | 85         |
| p.m.   |     trip request information     | /Thatcher/ | Railroad   |
|        |                                  | Berger     | Ave.       |
|        | -   Continue review of           |            |            |
|        |     complaints                   | Monah      |            |
|        |                                  | an/Griffin |            |
+--------+----------------------------------+------------+------------+
| **Wedn |                                  |            |            |
| esday, |                                  |            |            |
| March  |                                  |            |            |
| 16,    |                                  |            |            |
| 2005** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 8:00   | -   Interview carrier drivers    | C          | 85         |
| a.m.   |     and staff                    | hia/Berger | Railroad   |
|        |                                  |            | Ave. (STS) |
|        | ```{=html}                       | Thatcher/  |            |
|        | <!-- -->                         | Monahan    | 455 Market |
|        | ```                              |            | St.        |
|        | -   Observe trip scheduling and  |            | (Assist    |
|        |     dispatch                     |            | Medical)   |
|        |                                  |            |            |
|        | -   Observe call-takers; record  |            |            |
|        |     trip request information     |            |            |
+--------+----------------------------------+------------+------------+
| 10:00  | -   Continue review of budget    | C          | STS        |
| a.m.   |     and resources                | hia/Berger |            |
|        |                                  |            | Assist     |
|        | -   Observe trip scheduling and  | Thatcher   | Medical    |
|        |     dispatch                     |            |            |
|        |                                  | Monahan    | Assist     |
|        | -   Observe call-takers; review  |            | Medical    |
|        |     telephone system             |            |            |
+--------+----------------------------------+------------+------------+
| 1:00   | -   Review trip scheduling       | Chia       | STS        |
| p.m.   |                                  |            |            |
|        | -   Review on-time performance   | Thatcher   |            |
|        |                                  |            |            |
|        | -   Review telephone system and  | Monahan    |            |
|        |     performance                  |            |            |
|        |                                  | Berger     |            |
|        | -   Compile driver interviews    |            |            |
+--------+----------------------------------+------------+------------+
| 3:00   | -   Observe dispatch             | Chia       | STS        |
| p.m.   |                                  |            |            |
|        | -   Review service area, days &  | Monahan    |            |
|        |     hours                        |            |            |
|        |                                  | Berger     |            |
|        | ```{=html}                       |            |            |
|        | <!-- -->                         |            |            |
|        | ```                              |            |            |
|        | -   Observe call takers; record  |            |            |
|        |     trip request information     |            |            |
+--------+----------------------------------+------------+------------+
| **Thu  |                                  |            |            |
| rsday, |                                  |            |            |
| March  |                                  |            |            |
| 17,    |                                  |            |            |
| 2005** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 8:00   | -   Observe call-takers; record  | C          | STS        |
| a.m.   |     trip request information     | hia/Berger |            |
|        |                                  |            |            |
|        | -   Review trip duration         | Monahan    |            |
|        |                                  |            |            |
|        | -   Continue review of           | Thatch     |            |
|        |     eligibility process          | er/Griffin |            |
+--------+----------------------------------+------------+------------+
| 11:00  | -   Meet with EZ Trans manager   | All        | STS        |
| a.m.   |                                  |            |            |
+--------+----------------------------------+------------+------------+
| 1:30   | -   Continue review of trip      | Monahan    | STS        |
| p.m.   |     duration                     |            |            |
|        |                                  | All        |            |
|        | -   Continue data analysis       |            |            |
+--------+----------------------------------+------------+------------+
| **F    |                                  |            |            |
| riday, |                                  |            |            |
| March  |                                  |            |            |
| 18,    |                                  |            |            |
| 2005** |                                  |            |            |
+--------+----------------------------------+------------+------------+
| M      | -   Complete preliminary data    | All        | STS        |
| orning |     analysis & remaining detail  |            |            |
|        |     work                         |            |            |
|        |                                  |            |            |
|        | ```{=html}                       |            |            |
|        | <!-- -->                         |            |            |
|        | ```                              |            |            |
|        | -   Prepare materials for        |            |            |
|        |     debriefing session           |            |            |
+--------+----------------------------------+------------+------------+
| 1:00   | -   Exit Conference              | All        | STS        |
| p.m.   |                                  |            |            |
+--------+----------------------------------+------------+------------+

**Attachment C**

**Application Material for MVRTA**

**EZ Trans Eligibility**

**Attachment D**

**New Form for EZ Trans Eligibility (Proposed)**

**Attachment E**

***More Information Documentation* Form**

**Attachment F**

***EZ Trans Reviewer's Determination Page***

**Attachment G**

**Sample Letter Templates for Categories of**

**EZ Trans Eligibility**

1.  **Full ADA**

2.  **ADA Conditional**

3.  **Non-ADA**

4.  **ADA Conditional and Non-ADA**

5.  **Not Eligible**

**Attachment H**

***ADA Customer Manual***

***Non-ADA Customer Manual***

**Attachment I**

**Appeal Process**