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14 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders C. "Evaluate Service Compatibility" is shown in orange. D. "Consider Primary Service Parameters" is shown in green. As with most projects of this nature, there are no "right" or "wrong" answers; however, commingling ADA and non-ADA riders without considering how the service will be organized and operated can lead to significant issues down the road. Even if the decision to commingle has already been made, careful planning will help to ensure successful implementation and ongoing success. A. Define Purpose and Objectives for Commingling Define Purpose What is the purpose of commingling ADA and non-ADA paratransit riders? The variation in answers may be surprising. For some communities, considering whether to expand the ADA paratransit service to include non-ADA paratransit riders may be out of necessity: there may simply be no other service available and people who do not qualify for ADA paratransit need transportation. In other communities, there may be a desire to eliminate what is perceived as duplication or fragmentation of existing services by combining resources so that service quality and availability may be improved. For other communities, the purpose may be to take advantage of available funding or a political requirement to provide service. With the advent of the FTA's coordinated planning requirements, there also may be a desire to explore options that include expanding ADA paratransit. Finally, as environmental concerns grow, there also may be an interest in commingling trips from different services in an effort to reduce the number of vehicles needed and to take advantage of the associated reductions in vehicle miles traveled (VMT) and carbon emissions. Regardless of whether the decision is made by the transit agency and its partners or in response to forces outside the agency, it is important to understand and document the purpose of commingling trips. This effort will help the transit agency in developing an approach to providing the service that meets the needs of the target ridership and will also be important for subsequent evaluation of the commingled service. Because this Resource Guide is intended specifically to aid transit agencies that are considering commingling their ADA paratransit riders with non-ADA paratransit riders using the same vehicle fleet, it is important for transit agencies to ensure that the quality of their ADA paratransit service continues to meet the requirements of the ADA, even if that affects non-ADA riders. Discussion Seventy-four (60%) of the 121 transit agencies that replied to the survey conducted for this research reported that they provided trips to ADA and non-ADA paratransit riders. Of those, 64 transit agencies reported that they commingled riders; 10 reported that they provided service using different vehicles. As shown in Table 1-1, respondents to the survey question on factors influencing the decision to commingle indicated that the most common reason for initiating commingling on their paratransit service was the "demand for service" (78%). Where there is demand for specialized service from population groups in the community, such as older adults and others not eligible for ADA paratransit, it may be possible to open up the ADA paratransit service to serve other population groups. The second most common reason cited in the survey for the decision to commingle was "passenger needs" (57%), which can be seen as another version of "demand for service." Both of

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Planning Decision Process 15 Table 1-1. Factors influencing the decision to provide "other" paratransit service. ADA + "Other" ADA + "Other" on Different on Same Vehicles Vehicles Factor (N=58) (N=9) Demand for service 78% 67% Passenger needs 57% 67% Transit management decision 54% 33% Transit board decision 45% 44% Funding change from public sources 29% 44% Funding change from program sources 24% 0% Other external factors 24% 44% Coordination requirements 21% 11% Cost allocation 16% 0% Funding program requirements 16% 11% Scheduling/dispatching 16% 11% Other Internal factors 14% 11% Availability of technology 12% 11% Funding program reporting requirements 7% 11% ADA capacity constraints 4% 11% Insurance 4% 0% these reasons can also be seen as underlying a local political decision to commingle. These were also the top two reasons for providing service to ADA and non-ADA riders on different vehicles. Responses from nine agencies are shown in the second column of data in Table 1-1 (67% each). The other two most frequent reasons given for deciding to commingle riders, according to the study's survey, included a "transit management decision" (54%) and a "transit board decision" (45%). In a slight contrast, the agencies that chose to provide service to both rider groups using different vehicles cited "transit board decision," "funding changes from public sources," and "other external factors" as their third most common reasons for providing service to both rider groups (44% each). Interestingly, few survey respondents cited coordination requirements (21% of agencies commingling on the same vehicles and 11% of those using separate vehicles) as a reason behind their decision to commingle. It is possible that the decision-making reasons may change now that the FTA requirements for coordinated planning have been implemented as part of the United We Ride program. Another key interest for the study was identification of the non-ADA rider types that are being served by other paratransit services, particularly where ADA and non-ADA service is commingled on the same vehicles. A related issue was whether the other passenger groups that are served differ based on the practice of serving the varying passenger types on the same or different vehicles. Table 1-2 summarizes survey responses to the question: what types of "other" paratransit passengers are served? The responses are categorized by transit systems that commingle different passenger types on the same vehicles versus those that provide ADA and other paratransit services using different vehicles. The table shows that providing paratransit service for non-sponsored older adults continues to be part of many transit agency programs whether the riders are commingled on the same vehicles (60% of respondents commingling on the same vehicles) or served with different vehicles (44% of respondents commingling using separate vehicles). For commingling agencies using the same vehicles, providing trips for non-sponsored riders with disabilities (57%), other agency funded (57%) and/or general public riders (54%) were almost equally represented. In contrast, 67% of systems that provided service using different vehicles served general public riders,

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16 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders Table 1-2. Composition of "other" paratransit passengers. ADA + ADA + "Other" "Other" on Different on Same Vehicles Vehicles "Other" Paratransit Passengers N=63 N=9 Non-Sponsored Older Adults 60% 44% Non-Sponsored Persons with Disabilities 57% 33% Other Agency Funded 57% 22% General Public 54% 67% Medicaid 46% 11% Title III 44% 0% Non-Sponsored Low Income Persons 33% 22% Head Start 10% 0% 33% serve non-sponsored riders with disabilities, and only 22% serve other agency funded trips (again, representing only 9 respondents). The case study research allowed for more in-depth assessment of the reasons underlying the decision to commingle ADA and non-ADA riders. According to this research, presented in Appendix B, common reasons for commingling included the following: State coordination legislation: for several transit agencies, state legislation or even executive orders require the provision or coordination of transportation services for people who are transportation disadvantaged, for example, Florida and Pennsylvania. External factors: at several transit agencies, a separate specialized transportation program and the ADA paratransit service were commingled after a merger between two organizations. A local political decision made by the transit agency governing board: this decision was typically made at a city or county level, and was often articulated as "it just makes sense" to serve the additional non-ADA riders along with ADA paratransit riders. A financial decision made by the transit agency governing board: in one case, the governing board determined that it would be more cost-effective to provide the specialized transportation service along with the ADA paratransit service, and in another case, the decision to add non-ADA riders was made after dedicated transit funding provided to the transit agency was reduced and the agency wanted to capture the transportation funds of the community's human service agencies. Define Goals and Objectives Once the purpose of commingling is defined and documented, the transit agency should identify specific goals and objectives to support the decision. Although this step is sometimes neglected, it is important that all of the partners involved with commingling make this effort together. Articulating specific goals and objectives provides the transit agency and its partners with the foundation upon which to develop rider eligibility, service policies and operating procedures, and a framework for monitoring and evaluating the service over time. The specific goals and objectives will depend upon the purpose of commingling; the objectives should be measurable. For instance, a transit agency may decide it wants to expand paratransit service to provide trips for low-income individuals using funds from the Job Access and Reverse Commute (JARC) program. Goals should be set to target the specific types of trips to be served. For example, the goal may be to provide demand response service for job interviews and short-term training programs to help non-working individuals gain employment. An objective may be to provide 20 trips per week, based on program eligibility. This information can be used later to set eligibility and op- erating parameters for the service so that it may be dovetailed into the existing ADA paratransit service, without compromising the quality of ADA service provided.