Implementing the U.S. DOT Reasonable Modification Rule (2019) / Chapter Skim
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44 Case Examples Introduction This chapter presents case examples of transit systems' experiences implementing the reasonable modification final rule. Six case examples were developed for this synthesis: 1.
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Case Examples 45 Figure 4-1. Locations of case examples.
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46 Implementing the U.S. DOT Reasonable Modification Rule ACCESS brokers approximately 1.5 million trips per year, through six service providers operating from seven locations.
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Case Examples 47 case-by-case basis as long as they are reasonable and do not create a direct threat to others or a fundamental change to basic ACCESS service." ACCESS does not require customers to use the words "reasonable modification" when making a request. They encourage customers to include as many details as possible, including reasons why the request is necessary.
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48 Implementing the U.S. DOT Reasonable Modification Rule Figure 4-2.
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Case Examples 49 that would be occurring once a month. ACCESS provided the needed assistance and then found a work-around for the customer.
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50 Implementing the U.S. DOT Reasonable Modification Rule How Appeals Are Handled Customers who are unsatisfied with a denied request can file a complaint with the ACCESS administrative office by telephone or in writing.
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Case Examples 51 agencies may receive. In the 2017 calendar year, ACCESS received fewer than 100 advance requests, of which 80%–90% were approved, and fewer than 50 ad hoc requests, about 50% of which were approved.
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52 Implementing the U.S. DOT Reasonable Modification Rule Chicago Transit Authority Introduction and Context The Chicago Transit Authority (CTA)
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Case Examples 53 Particularly with ad hoc requests, operators and other personnel take reasonable modification requests in stride as part of providing day-to-day customer service. CTA's general policies are such that some policies would not need to be modified to accommodate people with disabilities.
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54 Implementing the U.S. DOT Reasonable Modification Rule what some people may view as a reasonable modification or accommodation request is not necessary since the accommodation may already exist as a general means of practice.
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Case Examples 55 If an operator is uncertain how to respond to any customer request, they are instructed to contact the Operation's Control Center. Control Center personnel may make the decision or request assistance from a supervisor or the Manager of ADA Compliance Programs depending on the situation.
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56 Implementing the U.S. DOT Reasonable Modification Rule Concluding Thoughts CTA's overall commitment to accessibility, safety, and excellent customer service may have preempted the need for many types of requests for reasonable modifications.
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Case Examples 57 General Approach to Reasonable Modifications KATS provides an essential lifeline for many passengers, and providing assistance tailored to each passenger's needs is part of how the organization provides regular service to everyone. KATS had a reasonable modification policy prior to the 2015 U.S.
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58 Implementing the U.S. DOT Reasonable Modification Rule Evaluation of Requests and Decision Making Decisions on advanced requests can be made by the operations manager, operations supervisor, or trip scheduler.
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Case Examples 59 rule. This has not caused a significant change for KATS operators, because it is standard policy for KATS to provide assistance to meet customer needs.
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60 Implementing the U.S. DOT Reasonable Modification Rule All of rabbittransit's fixed-route services and most of its demand response services are operated in-house with a portion of the demand response services contracted out.
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Case Examples 61 Planning or via email; rabbittransit provides their telephone number and email address on the website as part of the posted reasonable modification procedure. Instructions for submitting complaints and a link to rabbittransit's Discrimination Complaint Form are also provided.
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62 Implementing the U.S. DOT Reasonable Modification Rule when it comes to riders with disabilities.
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Case Examples 63 Impacts on Operations Rabbittransit has received very few requests for reasonable modifications -- an estimated two per month on average -- in large part because rabbittransit already proactively makes it easy to ride. One common request is for different passenger pick-up/drop-off locations due to weather or construction.
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64 Implementing the U.S. DOT Reasonable Modification Rule Headquartered in San Carlos, SamTrans provides fixed-route bus services throughout most of the populated areas of the county with service into downtown San Francisco and to Palo Alto in Santa Clara County.
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Case Examples 65 the context of general system accessibility as well as for specific services. The websites of both SamTrans and Caltrain include information on reasonable modification, and reasonable modification is discussed as part of travel training.
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66 Implementing the U.S. DOT Reasonable Modification Rule Figure 4-6.
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Case Examples 67 customer reduced the size of some of the attachments so that the device did not block the aisle or otherwise create a safety hazard. An example of a request on paratransit that was not straightforward for determining an immediate response involved a pick-up request in a private parking lot that was not safe for certain buses in the fleet to maneuver.
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68 Implementing the U.S. DOT Reasonable Modification Rule has not received complaints to suggest that ad hoc reasonable modification requests are being denied.
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Case Examples 69 locations to avoid access barriers. The District has not experienced a high volume of modification requests in advance, but for those few it does receive, many are already consistent with regular service policies.
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70 Implementing the U.S. DOT Reasonable Modification Rule modification requests, but not a formal procedure for handling requests.
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Case Examples 71 process in situations where they may have operational control or situational expertise that would be better suited to making an informed decision. Sometimes, road supervisors are called upon to evaluate potential safety issues.
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72 Implementing the U.S. DOT Reasonable Modification Rule this modification in situations where a passenger with dementia (or other types of cognitive or emotional disabilities)
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Case Examples 73 they will proactively consider this an advanced request and add a note in the Proline record of how to handle the approved or denied request in the future. This allows SARTA to reduce the decision-making burden on operators, dispatchers and transit supervisors.
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74 Implementing the U.S. DOT Reasonable Modification Rule Summary This chapter presents the experiences of six transit agencies operating a wide variety of services in a wide variety of operating environments and organizational structures -- from a two-bus general public demand response system in a small town in a very rural area, to the fixed-route bus and rail system serving Chicago.
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