On November 28^th, I and other community members attended a hearing at the Rochester-Genesee Regional Transportation Authority about updates to their plan for paratransit services (AKA RTS Access). I provided the following feedback to help promote equal access for people with disabilities as paratransit is an important part of our lives:

RTS policies should allow for longer service and less time waiting for a ride. This report indicates that callers can request rides with RTS Access staff (Schedulers or Dispatchers). It has been reported however that Dispatchers are transferring calls to Schedulers to request rides forcing the caller to wait on hold longer. CDR recommends that Dispatchers be allowed to schedule rides as is noted in the Paratransit Plan. Furthermore, the Scheduling office must expand its hours of operation beyond 5pm to meet the needs of passengers who work from 9am-5pm.  If RTS Access surveyed all riders, they would find this is a point of frustration, thus keeping the office open longer would reduce this frustration. Requiring riders to stay at their drop off destination for a minimum of one hour is unacceptable when riders may be performing chores that take less than 30 minutes to complete (example: dropping off a rent check or picking up milk from the store). Removing this requirement would increase ridership and also the independence of disabled people.

RGRTA must make rights and responsibilities of riders available to all passengers. In order to make the service fully inclusive, disabled people must be aware of their rights as far as ridership goes. Submitting written documents via USPS is not adequate because it is not accessible to all riders nor is it timely. CDR recommends that RGRTA submit these documents in a written AND alternate format (for example, large print Braille, audio CD, electronic format).

RTS must create and disseminate information an appeal process for service suspensions and “No-shows.” It is currently an issue for the riders of RTS Access that when a ride is missed, they are given warnings via USPS up to 10 missed rides within a six month period. Then the rider is subject to a 2-week service suspension. This does not take into account instances where the fault is not on the rider. It has been reported that warnings have been given to riders when the driver has arrived at the location early, waited the five-minute window and then left before the 20-minute window given to the rider has begun. When the notifications of a missed ride come, they are in a paper format that comes in the mail which may be inaccessible to some riders. CDR recommends that RTS send this information in an alternate format and create an opportunity for riders to appeal the suspensions. Also, CDR further recommends that the wait time for the drivers before they leave to be increased from 5 minutes to 10 minutes. This would equal half of the wait time window given to the riders.

Medical professionals should have more influence over the decision on approval of a rider using paratransit. As it stands, a medical professional is required to fill out a portion of the application for RTS Access however, this information is not widely considered during the application approval process. CDR recommends that if a rider is required to get their medical professional to fill out the application, the testimony of the medical professional should be more highly considered.

RTS must poll each person in their service for accurate data.  This report indicates RTS Access had an On Time Performance (OTP) Rate of 93.5% and intends to increase it to an OTP Rate of 95%.  These figures are questionable to an average rider of Paratransit Services because vehicles are at times outside the 20-minute window given to the passenger.  The data delivered to generate the On Time Performance rates has been skewed by the very computer system that generates the information.  It has been reported the GPS system used by the Busses computers indicates it is at a person’s driveway when in actuality they are at the corner of that street which is at least 3 driveways away. CDR recommends that when reporting on OTP, surveys are given to ALL riders who have taken the service in the last two years. This would show an accurate representation of true OTP and bring a better understanding of the people who decided to no longer take the service.

Riders should be alerted to the option of purchasing RTS passes online.  RTS riders are not being told that they are able to purchase RTS passes online. This makes getting passes difficult because either they must purchase on the bus with exact cash or find a way to get one from the RTS main office. Furthermore, CDR recommends that riders have the opportunity to purchase an unlimited 30 day pass for RTS Access similar to the one that fixed route riders can purchase.

RTS cannot request riders to provide advance notice of bringing a service animal into an RTS Access vehicle.  Per the Americans with Disabilities Act, riders are allowed to bring service animals any place that they are allowed to go. RTS cannot require riders to give advance notice of bringing their service animals on board.

RGRTA must make available accessible versions of all plan updates to fixed route and paratransit services. CDR recommends creating a fillable PDF for those using screen readers to gain the same information as those who do not. Graphs and images are not accessible to blind people so to create access, RGRTA must include image descriptions on ALL images.

The Paratransit Update Plan must accurately depict the way the fixed route is actually operated.  As currently reported, the Paratransit Update Plan states that RTS fixed route service runs from 4:41am to 2:04am which after some investigation has proven to be untrue. The majority of the time, the earliest a person can take a bus from Downtown Rochester is 5:50am. The Plan must accurately reflect the hours that fixed route service actually operates and CDR recommends that bus services run from 4:41am to 2:04am.

Bus operators MUST keep priority seating available for disabled and senior people. As it stands in policy, it is written that bus operators “may ask (but not require) other riders to offer these seats to senior and disabled people”. It is the experience of our community, that drivers often do not ask other riders to move away from these seats to make them available for those who need it. CDR recommends that instead of telling bus operators that they “may ask” riders to move, instead, bus operators MUST tell them to move for those who need to sit there.

Bus Operators MUST secure and unsecure all mobility devices aboard the fixed route buses.  In the plan, it is specified that Bus Operators are required to secure all mobility devices and that aides or other customers are not allowed to secure or unsecure mobility devices. This is not the experience of disabled riders in our community. It has been reported that often, Bus Operators do not want to get up and secure or unsecure mobility devices and ask that riders aide do so instead. CDR recommends that RGRTA perform random compliance checks with a member of the disability community who is a frequent rider of the fixed route. Furthermore, Bus Operators cannot require chair users to lock or turn off their chairs on the bus. The Federal Transit Administration policy states that the definition of a wheelchair does not include a requirement for brakes or any other equipment. Therefore, a wheelchair user is not required to deploy their brakes during service. Finally, Bus Operators and RTS drivers cannot require a wheelchair user to wear a seatbelt or shoulder harness if they decline. 

In closing, we ask that the Paratransit Plan Updates be improved to include accessibility for people with disabilities including the recommendations made above.