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Planning Decision Process 27
the range of disabilities that may be encountered when providing service. This includes not
only physical disabilities but cognitive disabilities as well, which riders may exhibit in un-
expected ways. Operator training should expose the operators to the range of both physical
and cognitive disabilities that riders may have and help them understand how best to assist
these differing needs.
Compatibility of Different Types of Transportation Services
Closely related to compatibility of types of riders is the compatibility of different types of
transportation service. In this context, transportation service refers predominately to the
assistance provided to riders in using the service but also includes, among other service attri-
butes, fare payment procedures for the riders. The transit agency must consider whether the
service it provides through its ADA paratransit program is appropriate for the rider group(s)
to be commingled.
If, for example, the transit agency's ADA paratransit service is primarily a curb-to-curb model
with door-to-door service provided only for those riders who require such assistance, then it may
not be appropriate to commingle a rider group when all the riders in that group need door-to-door
or door-through-door service to effectively travel. On the other hand, if the to-be commingled
service is primarily subscription service, the transit agency may determine that it can commingle
the rider group on its paratransit service if the sponsoring agency provides or funds an aide
on the vehicle to assist with the riders' needs in boarding and alighting. Or there may be other
arrangements that could be designed such that the non-ADA rider group could be successfully
added onto the agency's ADA service.
Sometimes questions arise when different geographic areas are served to accommodate different
sponsoring agencies. For example, one transit agency that was not part of this study received
complaints from its ADA customers when service was provided to JARC beneficiaries to loca-
tions outside of the ADA service area. The bottom line is that transit agencies should review any
differences in service requirements for the rider group(s) that may be commingled and determine
their effect on daily operations. If there are differences, they will need to be clearly communicated
to customers to minimize confusion and misunderstanding.
In the final analysis, it may be determined that it is not possible to commingle all riders. In that
case, the transit agency may either elect to serve some customers using separate vehicles or not
to serve them at all. This decision will likely be based on a combined analysis of resources and
compatibility and may require backtracking to reexamine funding and/or capacity factors.
If at this point it is decided that any differences can be accommodated, it is time to move into
the final planning phase, which considers practical matters such as defining service area, days
and hours of service, and so on.
D. Consider Primary Service Parameters
Finally, assuming the plan is to move forward to commingle ADA and other riders, the transit
agency needs to consider the primary service parameters and how they should be structured to
accommodate the needs of riders and funding providers. Service or operating parameters refer to
the key characteristics of the paratransit service that define and structure the paratransit operation,
including the service area, service span (days and hours of service), reservation time period,
and fare structure. These parameters are governed initially by ADA regulations, which means
that a transit agency contemplating--or implementing--commingled ADA and non-ADA
paratransit services must consider the extent to which the ADA paratransit service parameters
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28 Resource Guide for Commingling ADA and Non-ADA Paratransit Riders
(i.e., ADA paratransit service criteria) would also apply to or conflict with the other non-ADA
service.
If external factors require that a transit agency commingle its ADA service with non-ADA
service, rather than making that decision as part of a formal planning process, there may be little
choice as to the new parameters that must be incorporated. For example, if the transit agency's
governing board determines that Medicaid NEMT service will also be provided beyond the
ADA paratransit service area, then the service policies and procedures governing that service will
need to be incorporated and implemented, regardless of whether the service mix is a "good fit."
The transit agency will then need to operationalize those new parameters and, to the extent they
are different from the ADA service parameters, the transit agency will need to ensure that riders
understand the differences in practice.
On the other hand, a transit agency may have some discretion on setting the service parameters
for the non-ADA service. In this instance, the transit agency may decide to blend certain of the
parameters so that they are the same for both ADA and non-ADA riders. The transit agency
could decide to use the ADA fare structure for the non-ADA riders (assuming there are no fare
structure restrictions that apply to the non-ADA service). Or, the transit agency may set up
different parameters for the non-ADA riders from the ones that structure service for the ADA
eligible riders. But again, where the service parameters are different, it is critical that the riders
and vehicle operators understand the differences in those parameters and know which ones apply
for any given rider.
Discussion
From a transit agency as well as a rider perspective, key parameters to be considered for
commingled service include those related to the ADA paratransit requirements (listed in Table 1-4)
including, for example, the geographic service area where riders may travel, the days and hours
that paratransit service is offered, advance reservation policies, and fare structure, including policies
for attendants traveling with the passenger and companions. During the planning stage, it is
recommended that these operating parameters be considered at a policy level, that is, to what
extent the transit agency can adopt the same parameters for the commingled paratransit service,
or whether there must be differences to meet programmatic requirements of the commingled
services. From both a policy and an operational perspective, implementation of commingled
service will likely be more feasible if operating parameters are uniform across the entire service.
This may not be possible, though, due to requirements of the commingled services. It is during
the planning process when the transit agency should consider these issues and their impact on
commingled operations. Section 2 of this Resource Guide addresses the operationalizing of
operating parameters into service policies.
There is no "right" or "wrong" way to address this aspect of commingling, as long as the ADA
requirements are met. What is important is ensuring that the service parameters can be imple-
mented by the transit agency and, once operationalized as service policies, are clearly defined and
continually articulated to the riders. Operations staff must be thoroughly familiar with the service
policies and procedures as well and rider and caregiver education must be conducted, which is
particularly critical when the operating parameters are different.
One of the project's case study transit agencies was required to add service for seniors to its
ADA paratransit program, resulting in a commingled service. The funding program sponsor
for the senior service required that each of its riders sign the trip manifest, attesting to the fact
that the trip was taken. This was not a difficult practice to implement, but the transit agency
determined that it would also apply the policy to its ADA riders. While the ADA has no require-
ment for riders to sign manifests, the transit agency decided it would be better to have a standard
policy that applies to all riders rather than differentiate among riders regarding this service
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Planning Decision Process 29
requirement. Establishing a standard policy also eliminates the need to educate the different rider
groups on different policies and makes vehicle operator training somewhat easier, as there is no
need to differentiate the practice by type of rider.
The survey data and the case study research findings show that transit agencies that commingle
do not necessarily use the same parameters for their paratransit service. If there are differences,
they tend to be with the service area and fare structure. Differences in service area seem to cause
problems for several of the transit agencies interviewed, and this could be because the difference is
so readily apparent to riders. Differences in reservation hours or fares are less visible to riders, but
if some riders can access certain valued destinations and others cannot, this will be more difficult
for riders and the community to accept.
