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Planning Decision Process 17 Discussion In relation to defining goals and objectives for commingling ADA and non-ADA riders, there was little evidence from this research that the transit agencies that commingle their ADA riders with non-ADA riders have established goals and objectives specifically addressing commingling. However, based on the case study research, there are several examples where defined goals and objectives for commingling would have been particularly useful for the transit agency. For example, in one case, the decision to commingle non-ADA riders with the transit agency's ADA paratransit service was made by the state legislature, which mandated that anyone receiving dialysis treatment would be automatically eligible for ADA paratransit service. Although this did not measurably impact the ADA program in the first few years, in more recent years the transit agency found that this group of riders had added significantly to the growing demand and costs for ADA paratransit service, a service that now consumes more than one-third of the transit agency's total operating budget. The decision by the state legislature to commingle riders receiving dialysis treatment, regardless of ADA status, came only with a modest initial grant, but without any continuing funding. By defining the purpose behind commingling and identifying program goals and objectives when the decision was first made, the transit agency may have been able to better define service parameters and more quickly identify the need to secure additional funding to sustain service. B. Identify Available Capacity and Funding The second set of planning decisions shown in Figure 1-1 involves an identification of whether there are sufficient resources--both in terms of capacity and funding--to add trips to existing ADA paratransit service. The capacity issue is really two-fold: (a) is there sufficient capacity already in place to meet the ADA paratransit regulatory requirements and (b) is there sufficient excess capacity to add service to accommodate non-ADA riders without affecting the transit agency's ability to meet its ADA obligations? If capacity is not available, then funding to support adding capacity becomes the next critical issue. Assess Existing Capacity: Are There Empty Seats on Existing ADA Paratransit Vehicles? One of the key considerations when planning for commingling riders is system capacity. Does the transit agency have "empty seats" (i.e., capacity) on its ADA paratransit service to accommodate non-ADA riders? Is there capacity during all parts of the service day or just during certain parts, for example, off-peak times? Or would the addition of non-ADA riders require adding capacity to continue to meet the demand for ADA paratransit service? Discussion Capacity can be assessed initially by analyzing existing ridership and trip patterns by time of day and comparing this information with available revenue hours of service. A simplified example of this assessment uses a fictitious transit agency that operates from 6 a.m. to 9 p.m. weekdays with 12 revenue service vehicles. The existing capacity of this agency is shown in Figure 1-2, with revenue hours shown by time of day. In this example, the assessment for one sample weekday is shown. In practice, however, the assessment should be done for a longer sample time period such as two weeks using different months that exhibit normal to high ridership (for example, during fall or spring, avoiding holidays), depending on the seasonal ridership patterns of the individual paratransit service. The assessment should be done separately for weekday and weekend days, since ridership patterns vary by day of the week. If ridership varies significantly by weekday, then

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18 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders Sample Day: Hours of Service Beginning at: Vehicles in Service 6am 7am 8am 9am 10am 11am 12pm 1pm 2pm 3pm 4pm 5pm 6pm 7pm 8pm Total Vehicle 1 oooo oooo oooo oooo oo oooo oooo oooo oo 8 Vehicle 2 oo oooo oooo oooo oooo oo oooo oooo oooo 8 Vehicle 3 oooo oooo oooo oo oooo oooo oooo oooo oo 8 Vehicle 4 oooo oooo oooo oooo oo oooo oooo oooo oo 8 Vehicle 5 oo oooo oooo oooo oooo oo oooo oooo oooo 8 Vehicle 6 oo oooo oooo oooo oo oooo oooo oooo oooo 8 Vehicle 7 oooo oooo oooo oooo oooo oooo oooo oooo oooo oooo 10 Vehicle 8 oooo oooo oooo oooo oooo oooo oooo oooo oooo oooo 10 Vehicle 9 oooo oooo oooo oooo oooo oooo oooo oooo oooo oooo 10 Vehicle 10 oooo oooo oooo oooo oooo oooo oooo oooo oooo oooo 10 Vehicle 11 oo oooo oooo oooo oooo oooo oooo oooo oooo oooo oo 10 Vehicle 12 oooo oooo oooo oooo oooo oooo oooo oooo oooo oooo 10 Revenue 1.5 2 5 10 10 11 11 11.5 11.5 10 9 6 6 2 1.5 108 Hours oooo 1 hour revenue service Note: oo hour revenue service Figure 1-2. Simple example of assessing capacity by time of day. the assessment should be done by day of the week, so that Mondays are assessed, Tuesdays are assessed, and so forth. Ridership patterns are then assessed, with an examination of scheduled trips and completed trips by time of day, and these patterns are then reviewed in light of available capacity. Figure 1-3 depicts this assessment, using the same fictitious transit agency, with capacity shown in terms of revenue vehicles deployed by hour of the day. The analysis shows the productivity (passenger 12 Scheduled Passenger Trips 11 Scheduled Passenger 10 Trips per Revenue 40 Hour 9 37 36 36 Completed Passenger 34 8 Trips per Revenue 32 32 Hour 7 Number of Revenue 28 Vehicles per 6 Hour 5 4 15 3.7 15 15 3.4 3.4 3.2 3.3 3.11 3.2 3.2 3 3.1 3.0 3.0 3.0 2.9 2.8 2.7 2.7 2.8 2.5 2.5 2.5 2.5 2.5 2.4 2.4 2.3 2 2.0 2.0 2.0 1.6 1 5 3.5 4 .67 3 a.m. a.m. a.m. a.m. . . oon p.m. p.m. p.m. p.m. p.m. p.m. p.m. p.m. 0 a.m 0 a.m 12 n 6:00 7:00 8:00 9:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 10:0 11:0 Hour of Day Figure 1-3. Example of scheduled versus completed passenger trips per revenue hour.

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Planning Decision Process 19 trips per revenue hour) throughout the service day, for both scheduled and completed passenger trips. For time periods during the service day that show a productivity below a certain threshold, for example below the system's average productivity or below a level that the system manager believes is achievable, there may be "empty seats" available. Of course, the transit agency would need to analyze those specific periods in more detail. How much service is actually provided during those time periods? Do those time periods have lower productivity because the passenger trips are long with limited opportunity for shared riding? Are there proportionately more riders in wheelchairs served during those time periods, which will tend to increase dwell times and impact productivity? Are there other legitimate factors that impact the lower productivity during those times? This more detailed analysis also may indicate that the paratransit system could accommodate additional passenger trips during those times. (It may also be possible to adjust revenue hours to add some capacity, depending on operator shifts and staffing arrangements.) In Figure 1-3, the data indicate that there are lower productivity periods during the early morning and early evening hours given the current vehicle and operator schedule. However, these are time periods with a limited number of revenue vehicles in service. The data indicate that the midday hour also shows some capacity, as there are just 32 passenger trips scheduled and all 12 vehicles are deployed. If the transit agency could serve as many passenger trips that hour as it does during the 2 p.m. hour (40 passenger trips served), then there is available capacity. This assessment of capacity can also be done with some computerized scheduling/dispatch systems, which can estimate slack time and also run "what if" test scenarios with various assump- tions about productivity, trip length, and distribution, among other factors. If potential available capacity is identified, the transit agency would then need to consider whether or not it would be adequate to support the trip demand and patterns of non-ADA riders that might be commingled. This is clearly a simplistic example for a very small transit agency. But the point is an agency that is considering adding non-ADA riders to its ADA paratransit service should formally assess its capacity and its ability to serve additional passenger trips and plan to make adjustments accordingly. Estimate Impacts of Adding Non-ADA Riders Once the transit agency has assessed its current capacity, it can then estimate the impacts of adding non-ADA riders: how will the additional riders impact service hours and miles? Is there enough capacity on the existing system to accommodate the additional trips? This will likely be a rough estimate, unless there are good data on the ridership numbers and patterns of the non-ADA riders that will be added. However, a rough estimate is adequate for planning purposes. Discussion Estimating demand for paratransit services is complicated by the fact that an individual's choice to use a particular paratransit service is partially related to service attributes and cost, which vary by individual paratransit service. Compared with fixed route transit, the service attributes that affect paratransit demand and ridership are more complex and include factors such as the advance notice required to book a trip and whether a trip can be scheduled at the desired time (Spielberg et al. 2004). The degree of driver assistance to riders is another attribute that may affect individuals' demand for and use of paratransit. To estimate the additional ridership that might be expected, data are needed on the following: The size of the non-ADA market group that will be served The number of estimated trips that this group might take on the paratransit service

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20 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders Depending on the non-ADA riders to be added, information on the estimated size of the group can be obtained through Census data or potentially through local sources. If clients from one or more human service agencies are to be added to the ADA paratransit program, informa- tion could be obtained from the relevant agencies. Assuming, as one example, the transit agency's governing body has proposed that non-ADA eligible seniors in the community should be served by the ADA paratransit service, information about that group is needed including the following: What is the definition of "senior" for purposes of eligibility for the service (e.g., 55 and older, 60 and older, 65 and older, 70 and older, 75 and older)? What is the estimated size of the senior group (using available Census data)? What is the overlap of that senior group with ADA eligible riders? With information on the estimated size of the non-ADA rider group to be added, the next step is to estimate their potential trip-making on the ADA service. Generally, this would require information on their trip rate; that is, how many trips they would be expected to take on the ADA paratransit service on an average week or month. There is some information available about trip demand for paratransit and specialized trans- portation services available from various sources that may be useful. Appendix C identifies a number of published sources that could be consulted. If trip rate data are not readily available for the non-ADA ridership group that is being added, the transit agency could develop an estimate based on its current ADA ridership. For example, the agency can identify the average number of trips per week or per month by an active rider, defined as those riders who actually use the service, as opposed to those who have become certified but are not active riders. The definition of an active rider may depend on the transit agency, but often it is defined as an eligible person who took at least one trip during a 12-month period. Depending on the similarity of the non-ADA rider group being added to the current ADA ridership, this average could serve to estimate expected trips from the non-ADA riders that are being commingled. It may be useful to use a high and low figure, based on the current ridership patterns, which would frame a range of estimated trips that might be expected per new rider. With the estimated size of the non-ADA rider group to be commingled and a trip rate, the number of new trips that might be expected can then be determined. This should be seen as a rough number but will provide useful information for planning purposes. However, unless there is primary data on the trip-making of the non-ADA riders to be added, the estimate will not indicate the time periods during the day when the new trips might be needed, although the estimate can serve to show the extent to which existing capacity can meet the increased demand. Developing such an estimate of the new demand for service that will be experienced with new, non-ADA riders added is less science than art, but it is a useful exercise to try to anticipate the ridership impacts of adding the non-ADA riders to the ADA paratransit service. Funding and Sustainability Once capacity is considered, the transit agency must assess its existing resources to determine whether there is adequate funding to support the addition of non-ADA riders for the foreseeable future. The project's case study research demonstrated that commingling is more successful and sustainable when funding is provided for the non-ADA riders that are added. This may seem an obvious point but it is one that the research team found deserves emphasis. When assessing funding, the "foreseeable future" is likely a short time horizon since transit funding can change year to year based on factors outside the control of the transit agency. Despite

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Planning Decision Process 21 this, the transit agency should take stock of its funding resources and the sustainability of that funding. Experience in the transit industry with ADA paratransit has shown that costs to operate ADA paratransit services have often grown significantly year to year with increases in demand, particularly in larger urban areas. The addition of new non-ADA riders on the ADA service will impact funding requirements into the future. Should the transit agency have capacity to add the non-ADA riders, then funding may not be a significant concern in the short term. In such cases, the transit agency can accommodate the non-ADA riders to the extent that there is space to serve the additional passenger trips without negatively impacting the ADA paratransit service. Nonetheless, an assessment of funding available to support the non-ADA service is recommended. Discussion As might be expected, the study's survey findings indicate that funding has played an important role in transit agencies' decisions regarding commingling. For those transit agency respondents that indicated that they commingle their ADA paratransit riders with non-ADA riders, funding was among the most frequently cited factors impacting the agencies' decision to commingle. (The most frequently mentioned factor was demand for service. Three funding-related factors combined to become the second most frequent factor, and passenger needs was the third most cited factor.) For those transit agency respondents that indicated they had commingled their ADA para- transit service with non-ADA riders in the past but no longer did so (16 agency respondents), funding was the second most frequent reason noted for the discontinuation of commingling, tied with transit management decision. (ADA capacity constraints were the most frequent reasons cited.) Transit agencies that do not commingle were also asked through the survey what factors, if any, would lead them to add non-ADA riders to their paratransit service in the future. According to the 23 agencies that responded to the question, funding from an agency or program sponsor, along with demand for service, were the top two factors. The case study research also underscored the importance of funding in relation to decisions about commingling and the sustainability of commingling. Most of the case study sites spoke to the importance of funding and maintaining funding resources; in several cases, funding was a key factor in decisions to maintain commingling. Funding Sources Used to Support Commingling. According to the study's case study research, transit agencies that commingle use a variety of funds to support commingling. Table 1-3 shows the sources of non-FTA funding, beyond passenger fares that were used to fund operations for those case study transit agencies that commingle ADA and non-ADA riders. Table 1-3. Sources of operating funds beyond FTA and fares supporting commingled services. No. of Transit Agencies Other Operating Funds N=14 Medicaid 6 Older Americans Act funds (Title III) 4 Other federal human service agency funds 9 State funds, dedicated to transit 8 State funds, discretionary 2 Local funds, dedicated to transit 3 Local funds, discretionary 1

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22 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders Although human service transportation funds from programs such as Medicaid and Area Agencies on Aging are important for supporting the practice of commingling, there are numerous transit agencies that commingle non-ADA riders without human service program funding. According to the study's survey, transit agencies that commingle ADA and non-ADA riders using the same vehicles (53% of survey respondents) indicated that "non-sponsored older adults" are the most frequent of the "other paratransit" passengers that they served; funding for these non-sponsored riders comes from state and local sources, typically state funding dedicated to transit. When funding for the commingled service becomes insufficient or is no longer available, a transit agency may have to reconsider its decision to commingle. Of the case study sites included in this project, two completely ended commingling due to funding cutbacks, and another two "un-mingled" (i.e., separated) a previously commingled non-ADA rider group because of funding issues. Both of these latter sites involved Medicaid transportation, and this experience raises important considerations for commingling with Medicaid. Several points to consider follow. ADA Paratransit Level of Service Requirements. As described in the introduction, when providing ADA paratransit service, a transit agency must meet the U.S. DOT's ADA regulatory requirements. For example, in addition to the ADA paratransit eligibility standards described in 49 CFR 37.123, these regulations include service criteria, which must be met by ADA comple- mentary paratransit service programs as outlined in 49 CFR 37.131. These criteria are shown in Table 1-4. Some of these ADA requirements function essentially as performance standards, establishing a level of service that is often higher than required by other specialized transportation services (Kittelson et al. 2003). What this means in practice is that the service, in terms of attributes such as trip reservations and on-time performance, is often better--for all riders including non-ADA riders--than other specialized transportation services in the community. Commingling ADA and Medicaid riders. The case study research revealed significant findings for commingling ADA paratransit service with Medicaid transportation; in particular, when the level of transportation service required (e.g., on-time performance, on-board travel time) is less rigorous for Medicaid customers than that required by ADA paratransit (this issue may Table 1-4. Key ADA paratransit service criteria. Same Service Area Operate in the same service area as the fixed route system, which generally includes a -mile corridor on either side of a fixed route as described in 49 CFR 131(a). Comparable Response Have a comparable response time, where response time is defined Time 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). Comparable Fares 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). No Trip Priorities Meet requests for any trip purpose (i.e., no trip purpose restrictions) as described in 49 CFR 131(d). Same Day/Hours of Operate during the same days and hours as the fixed route service as Service described in 49 CFR 131(e). No Capacity Constraints 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) as set out in 49 CFR 131(f).

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Planning Decision Process 23 also apply to other agency-funded transportation). The higher level of service provided by ADA paratransit service compared with various other paratransit services has cost impacts, resulting in costs for ADA paratransit service and specifically costs per trip that are typically higher than other specialized transportation services. When the cost for transportation service exceeds what Medicaid or other program sponsors of specialized transportation are willing to fund, commingling ADA paratransit with the non-ADA riders becomes problematic. The Medicaid Non-Emergency Medical Transportation Program (NEMT) does not have specific level of service requirements set at the federal level; however, there may be requirements established at the state level because Medicaid is administered at the state level as a joint federal-state program. Experience with Medicaid transportation across the country, however, indicates that typically Medicaid NEMT does not have the range of requirements that govern ADA paratransit, which then subsequently raises the level of service to riders. Impact on operating costs. Applying a higher level of service as required by ADA to other riders will likely impact operating costs for the transit agency. As operating costs increase, sponsors of non-ADA riders in commingled ADA paratransit services may question whether they want to fund the trips at the higher cost. This has been a particular issue with Medicaid transportation, as Medicaid agencies in many states have increasingly moved to new models and structures to contain costs, including capitated rates. These agencies may offer payment schemes that provide reimbursement at levels considerably less than the actual cost of the trips. Where a transit agency commingles Medicaid trips, it may determine at some point that it cannot continue to serve the Medicaid trips at the maximum reimbursement levels offered. In some Florida communities with an extensive history of coordinated and commingled transportation, the transit agency has determined that it can no longer commingle ADA and Medicaid riders because payment levels from the Medicaid sponsor did not cover operating costs. Furthermore, this project found that, at one transit agency, some of the Medicaid riders who are also ADA eligible have continued to ride the transit agency's ADA paratransit service rather than move to the new Medicaid transportation provider, presumably preferring the higher level of service provided by ADA paratransit, even though Medicaid transportation is free, whereas ADA paratransit requires a fare. This situation leaves the transit agency with the responsibility for providing those Medicaid trips, but without any funds from the Medicaid agency. On the other end of the spectrum is the coordinated and commingled paratransit service in Pittsburgh, known as ACCESS. This program, which began in the late 1970s as a federal demonstration program testing the brokerage concept for specialized transportation in a large metropolitan region, recognizes that the addition of ADA paratransit into the coordination mix in the 1990s generally increased the overall level of service because of ADA's high service standards. This higher level of service improves paratransit service for all riders, including those who are not ADA eligible. That the other agencies involved with ACCESS have continued to participate and to fund trips that are now somewhat more expensive given the higher level of service resulting from ADA's requirements is a testament to ACCESS's success and, significantly, the availability of funding from sponsors of non-ADA riders. If Funding Is Available to Support "Other" Riders Available funding to support the non-ADA riders is a preferred scenario for a transit agency that pursues commingled service. The use levels of the non-ADA riders that are commingled should be tracked and monitored against the funding that is provided to ensure that all sponsor- ing agencies are paying their fair share of the operating costs. This will allow the transit agency to monitor whether the funding is sufficient to support the non-ADA riders' trip-making and to negotiate changes over time.

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24 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders If Funding Is Not Available to Support "Other" Riders Should the transit agency find that there is not sufficient additional funding for commingled service or that the funding appears to be very short term, it has three basic options: To commingle only to the extent that capacity allows (if the capacity estimate suggests excess capacity), To seek additional funding to support the non-ADA service, or Not to commingle its ADA paratransit service with non-ADA riders. These options, discussed below, assume that the transit agency is responsible for decision- making on commingling, which is not always the case. Commingle to the Extent Capacity Allows. This is a straightforward option. Should the determination of capacity find that there is existing capacity on the existing ADA paratransit service, the transit agency may decide to add other non-ADA service to the extent that new trips can be accommodated, keeping in mind the need to provide unconstrained ADA paratransit service. This decision and the fact that commingling is being implemented without new funding or with limited short-term funds should be documented. Ridership by the non-ADA riders should also be tracked and monitored. If demand grows later and operating funds become limited, the decision framework for commingling may need to be re-visited. Seek Additional Funding. Alternatively, the transit agency can try to find other funding to support the non-ADA service. Depending on the non-ADA rider group to be commingled, there may be funding sources available locally, such as human service agencies. A case in point: One of this project's case study sites was able to secure local human service agency funding when it lost state transit funding. When the state announced transit funding reductions, the transit agency promptly approached the key human service agencies in its community whose clients used the transit agency's paratransit service and requested funding. With very few transportation options in the rural area, the human service agencies agreed to the request and provided lump sum payments to the transit agency, ranging from $5,000 up to $65,000, with several of the agencies continuing to provide the payments each year. Even though these annual subsidy amounts are not guaranteed, and not all agencies provide an annual subsidy each year, these local contributions are a significant source of the agency's operating budget. In a year with generous contributions, the annual subsidy funds from the human service agencies constitute as much as one-third of the transit agency's total operating funds. Decide Not to Commingle. If the transit agency is responsible for the decision concerning whether or not to commingle, it may decide not to commingle riders because of the lack of funding to support the added transportation service. This is not necessarily a negative outcome, as there are other ways that the transit agency can support specialized transportation in the community. Consider Other Options to Support Transportation for Non-ADA Riders Even if a transit agency decides not to commingle ADA and other riders, it can still support and participate in coordinated transportation efforts to improve specialized transportation locally. In fact, FTA now requires a local coordinated planning effort. Additionally, there are various ways that a transit agency might coordinate, short of commingling non-ADA service with its ADA paratransit program, including the following options.

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Planning Decision Process 25 Provide Retired Paratransit Vehicles to Other Community-Based Paratransit Providers The transit agency could consider a program where retired paratransit vehicles, still in operable condition, are provided to non-profit organizations in the community that operate specialized transportation. A number of larger transit agencies have such programs; one of the agencies has a well-organized process that includes an application form for non-profits to express their interest in obtaining a donated vehicle. This transit agency also informs the non-profits about the costs for maintaining the vehicles, based on its own experience, so they have a better understanding of ongoing operating costs. In addition, the transit agency provides information for obtaining vehicle insurance. In some cases, transit agencies also support the provision of service by providing maintenance, insurance, driver training, and other in-kind services. Coordinate Vehicle Operator Training Program with Other Community-Based Providers With this option, the transit agency could consider expanding its vehicle operator training program to include other transportation organizations. Such a coordinated vehicle operator training program could be managed and conducted by a transit system itself, or the coordinated training could be organized through a third-party such as the state's RTAP program (Rural Transit Assistance Program). Share Maintenance Capabilities Where a transit agency has capacity in its maintenance function, it may be possible to offer maintenance services to small agencies in the community that have transportation programs but lack in-house maintenance. One example of such an arrangement was planned and spearheaded by the Illinois Department of Transportation (IDOT), which partnered with the Springfield Mass Transit District (SMTD) to offer maintenance services to smaller community-based agencies operating in the rural areas around Springfield. This arrangement resulted in the Regional Maintenance Center, provided through SMTD's maintenance department. This center serves non-profit agencies within a 60-mile radius of Springfield, providing non-routine maintenance and repair services for paratransit vehicles on a pre-scheduled basis (KFH Group et al. 2001). Develop Partnerships with Community-Based Human Service Agencies The development of partnerships with local human service agencies is a form of transportation coordination, with an objective of improving specialized transportation effectiveness and efficiency. Coordination can take various forms, and recent research found a number of public transit agencies that have developed partnerships with local human service agencies, allowing these agencies to transport their own clients in a more cost-effective manner than possible for the public transit system (KFH Group et al. 2008). The specific parameters of the partnerships vary: some have the transit agencies providing vehicles and additional support such as driver training and vehicle maintenance to the human service agencies; others involve provision of operating funds to support the agencies' own transportation service and the agencies become contractors to the public transportation system, serving riders who otherwise might be passengers of the public transit system's paratransit service. The human service agencies also benefit in that they have more control over their transportation service, with the ability to schedule trips and outings for their clients as they see fit, without having to conform to the public transit agency's hours and other operating policies and procedures. Support Mobility Management Initiatives Local communities are increasingly implementing mobility management as a strategy to improve the use of transportation resources and link those needing transportation with