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10 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders Have a comparable response time, where response time is defined as the elapsed time between a request for service and the provision of service. Comparability is defined as accommodating trip requests for ADA paratransit eligible individuals at any requested time on a particular day in response to a request for service made during normal business hours on the previous day as described in 49 CFR 131(b). Have comparable fares. Comparability is defined as fares that are no more than twice the base, non-discounted adult fare for fixed route services as described in 49 CFR 131(c). Meet requests for any trip purpose (i.e., no trip purpose restrictions) as described in 49 CFR 131(d). Operate during the same days and hours as the fixed route service as described in 49 CFR 131(e). Operate without capacity constraints for ADA trips requested by ADA eligible passengers (e.g., no waiting lists, trip caps, or patterns and practices of a substantial number of trip denials, untimely pick-ups or excessively long trips). 49 CFR 131(f). Finally, 49 CFR 131(g) allows for public entities to provide ADA complementary paratran- sit service to ADA paratransit eligible individuals that exceeds the minimum criteria included in this section. If transit agencies commingle ADA and non-ADA riders, they must preserve the integrity of the ADA paratransit service (i.e., ADA service criteria must be met for all ADA eligible trips), even it means curtailing other non-ADA-required services. Before passage of the ADA, many fixed route transit agencies provided or supported some level of specialized transportation for people with disabilities and older adults. These services were sometimes supported by human service agency funds, such as from Title III of the Older Americans Act or through limited locally generated (i.e., non-sponsored) funds. After the ADA was passed and the requirement to provide ADA complementary paratransit for all eligible per- sons with disabilities came into effect, many transit agencies had to make a decision about whether and how to provide non-ADA specialized transportation. Models for Commingling ADA and Non-ADA Paratransit Riders During the course of this project, four models for commingling ADA and non-ADA paratran- sit riders were identified, representing the spectrum of commingled approaches. The first three models were the most commonly observed in the project survey; the fourth model does not truly fit the definition of commingled service used for this project but was identified as a commingling strategy by several transit agencies. The four models include the following: Model #1: Human Service Transportation + ADA Paratransit Pre-ADA human service transportation providers that added ADA paratransit services after passage of the ADA. This model includes programs with roots in human service trans- portation that have been expanded to include ADA paratransit service. In practice, this model includes two subtypes: non-profit agencies that have become the ADA paratransit service provider for the local transit agency and transit agencies that have incorporated former non- profit transportation programs into their paratransit service structure. That latter practice was more common when ADA paratransit was first introduced and systems were merged. It is less likely to occur now. Model #2: ADA + Human Service Transportation ADA paratransit service providers that added human service transportation service after their ADA paratransit service. This model is the focus of this research project and of the