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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.