Text-Only Version Prepared by: TranSystems Corp. Medford, ma and: Planners Collaborative Boston, ma august 24, 2007 contents
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Proposed Additional Criteria, Standards, Monitoring and Reporting Finally, the Monitoring Plan notes that, while the MBTA is working hard on processes to keep the web site and the elevator information line up to date on elevator outages, there is a need for more monitoring of the accuracy of information. Except for internal audits such as those performed in 2005, there is not a continuing approach to monitoring the accuracy of the information provided to the public, nor the usefulness of the information. The Monitoring Plan recommends that the MBTA set a goal of improving the accuracy of its reporting from the current level of 87-88% accurate to 95% accurate in 2007. Elevator status information provided on the MBTA web site and elevator hot line should be audited periodically (annually) as done in 2005 to monitor and improve accuracy of public information. Other options to monitor announcements include hiring an external firm, such as the firm monitoring the stop announcements, to do a 100 percent check of elevators over selected days throughout the year. All public information that lends itself to digital format should be placed on the MBTA web site so that consistent information is available to all MBTA public information personnel as well as internet users. Section 2. Evaluation of THE RIDE Services This section describes the consultant team’s evaluation of the MBTA’s THE RIDE program. Sections 2.1 describes the organization and design of the service. Section 2.2 then presents a review of service policies and offers recommendations for strengthening these policies to ensure compliance with federal and state regulations. Rider and public input on THE RIDE services, including rider comments and complaints and input received through public meetings and focus groups is then summarized in Section 2.3. A summary of first-hand observations of the operations, made during the initial evaluation of the services by the TranSystems study team in the Spring and Summer of 2005 and then updated in the late 2006 and early 2007, is then presented in Section 2.4. The Monitoring Plan developed for THE RIDE is the summarized in Section 2.5. Finally, a review of service and performance statistics from July of 2004 through February 2007, including ridership, on-time performance, and rider complaints, are presented in Section 2.6. 2.1. Overview of THE RIDE Organization and Service Design In addition to fixed route bus and rail service, the MBTA also operates a service called THE RIDE. This door-to-door van and sedan service complements the fixed route services and is designed to meet the MBTA’s obligations to provide “complementary paratransit service” under the Americans with Disabilities Act of 1990 (ADA). THE RIDE service is managed by the MBTA’s Office of Transportation Access (OTA). The OTA is divided into two sections; one located at Ten Park Plaza that oversees THE RIDE services, and a Fixed Route Access section located at Back Bay Station that oversees fixed route bus and rail accessibility. Staff at the Ten Park Plaza office administer and manage all aspects of THE RIDE program. This office is responsible for setting service policies and standards, contracting and overseeing contracted service providers, rider eligibility certification, and customer service (handling and investigating rider complaints). The office also purchases and leases many of the vehicles used by contracted service providers. A detailed description of OTA staffing is provided in Section 2.6 of this report. The MBTA contracts with four regional service providers for the operation of THE RIDE services. The total service area is divided into four regions and each contractor serves a region. The regions overlap in the downtown “core” area and all contractors provide service to and within the core area. Figure 2.1 on the following page shows THE RIDE service regions. The four contractors and the areas they service are:
Figure 2.1. MBTA THE RIDE Service Area and Service Regions This page provides a map that shows the cities and towns served by THE RIDE. It also shows that the service is divided into four regions (a North region, Northwest region, Southwest region, and South region) and that Boston is a common area served as part of all fou regions. The communities that are part of the Boston core area as well as the communities included in each of the four regions are listed below. Boston includes: Allston, Back Bay, Brighton, Charlestown, Chinatown, Dorchester, Downtown Boston, East Boston, Fenway, Hyde Park, Jamaica Plain, Mattapan, North End, Roslindale, Roxbury, South Boston, South End and West Roxbury The North region includes: Beverly, Boston, Chelsea, Danvers, Everett, Lynn, Lynnfield, Malden, Marblehead, Melrose, Middleton, Nahant, Peabody, Reading, Revere, Salem, Saugus, Stoneham, Swampscott, Topsfield, Wakefield, Wenham and Winthrop The Northwest region includes: Arlington, Bedford, Belmont, Boston, Brookline, Burlington, Cambridge, Concord, Lexington, Lincoln, Medford, Newton, Somerville, Waltham, Watertown, Weston, Wilmington, Winchester, and Woburn The Southwest region includes: Boston, Canton, Dedham, Dover, Framingham, Medfield, Natick, Needham, Norwood, Sharon, Walpole, Wellesley and Westwood The South region includes: Boston, Braintree, Cohasset, Hingham, Holbrook, Hull, Milton, Quincy, Randolph, and Weymouth Each of the four contracted service providers performs all functions related to direct service operations. This includes trip reservations, trip scheduling, vehicle dispatching and vehicle operations. The service providers provide the facilities needed for operations, and own or lease the telephone systems, computer hardware and software and other technologies required for the operation, As noted above, the MBTA provides many of the vehicles used in the operation. Some vehicles used in the program are owned by the contractors. Table 2.1 below shows THE RIDE fleet by service provider as of March 2007. As shown, a total of 539 vehicles are used to provide the service. This includes 276 lift-equipped vans and minibuses, and 263 sedans. The MBTA provides 68% of the fleet, including 174 lift-vans and 193 sedans. Table 2.1. THE RIDE Fleet by Service Provider (Editor’s note: Data in the table is presented in the following order: Provider; Lift-Equipped Vans/Minibuses MBTA Owned; Lift-Equipped Vans/Minibuses Provider Owned; Sedans/Taxis MBTA Owned; Sedans/Taxis Provider Owned; Total Vehicles) GLSS; 41; 58; 34; 23; 156 VTS; 60; 18; 88; 47; 213 JV; 45; 0; 33;0; 78 Kiessling; 28; 26; 38; 0; 92 TOTALS; 174; 102; 193; 70;539
(Editor’s note: Data in the table shows ridership, revenue-hours, and revenue miles for each RIDE provider and then the total for all providers. Data is presented in the following order: Type of Statistic; GLSS; VTS; JV; Kiessling; TOTALS) Ridership; 415,105; 531,144; 227,576; 284,999; 1,458,824 Revenue Hours; 266,109; 383,270; 158,585; 160,850; 968,814 Revenue Miles; 3,420,621; 4,760,451; 2,695,060; 1,926,042; 12,802,174 Demand and need for THE RIDE service has grown steadily over the years. In the three years from Fiscal Year 2003 to Fiscal Year 2006, ridership grew from 1,178,119 one-way trips per year to 1,458,824 trips per year (a 24% increase or an average of 7% each year). It is important to note that the MBTA THE RIDE program underwent significant change in the Fall and Winter of 2004/2005, just prior to the beginning of this study. New contracts were executed with each of the four service contractors. These new contracts called for upgraded, state-of-the-art system software, as well as other technologies such as automatic vehicle locator (AVL) technology, mobile data computers (MDTs) and new telephone systems with call-back and call recording capabilities. While this new technology was vital for better management and monitoring of this growing service, there were inevitable transition issues. The switch to new reservations, scheduling and dispatching software resulted in some short-term loss in operating effectiveness. On-time performance dropped and rider complaints increased during this transition period. The effects of this transition period are reflected in this report. Rider comments in Section 2.3, which were solicited in the Fall of 2005, reflect the lingering service problems that were being experienced. The first-hand observations of THE RIDE contractor operations, which were conducted in the Spring of 2005, also reflect operating issues at that time. As noted in Section 2.6 of this report, though, service effectiveness and quality have since recovered from this transition period. In the first eight months of FY2007, on-time performance has improved to 91%, with 7.7% of trips being 15 to 30 minutes late and only 1.3% of all trips being more than 30 minutes late. 2.2. Evaluation of THE RIDE Service Policies One of the initial tasks in the evaluation involved a thorough review of THE RIDE service provider contracts and program materials to ensure that established service policies and contract requirements were in compliance with the ADA. The U.S. Department of Transportation (USDOT) regulations, which implement the transportation provisions of the ADA, require that public transit agencies that provide fixed route service also provide “complementary paratransit service” for individuals with disabilities who are unable to use the fixed route system. The level of service provided by the paratransit program must be “comparable” to that provided by the fixed route service. Comparability is defined by six service criteria, including:
The regulations also identify other operating policies and practices that must be followed in the provision of the paratransit service, including requirements related to:
Finally, the regulations require that public entities that provide complementary paratransit also have a process for determining who is “ADA Paratransit Eligible” and qualifies to use the paratransit service. A detailed review of THE RIDE’s public information, provider contracts and other formal and informal policies was undertaken as part of the study. A memorandum (Technical Memorandum #1) detailing the analysis, findings and recommendations was prepared and provided to the MBTA on August 2, 2005. Technical Memorandum #1 contains a thorough discussion of each regulatory requirement, an analysis of MBTA THE RIDE policies and standards, and findings and recommendations regarding compliance. Table 2.3 on the following page provides in summary of the findings and recommendations from Technical Memorandum #1. Note that the ADA requirements, current MBTA policies, and observations/recommendations are paraphrased. The reader is referred to Technical Memorandum #1 for a complete discussion of each item. Table 2.3. Summary of ADA Requirements, MBTA Policies, and Comments and Recommendations (Editor’s note: Data in the table is presented in the following order: ADA Requirement; Current MBTA Policy/Contract Requirement; Observations and Recommendations) Service Area - Provide paratransit service at least in three-quarter mile corridors around all non-commuter fixed routes/lines.; THE RIDE serves 62 communities. Includes all communities with non-commuter fixed route, plus a few that do not receive fixed route service.; Current policy exceeds ADA minimums. Service to full communities (rather than corridors) is more understandable and seen as positive. Response Time – “Next day” service; Negotiation of trip times +/- an hours permitted. ;Vendors make every effort to accommodate same-day service requests as well as required “next day” requests. Only negotiate trip times +/- 30 minutes.;Same day service is a significant rider benefit, but add-ons and changes to prescheduled trips can place an extra burden on dispatch function. 30-minute negotiation is reasonable given method of scheduling currently used. Fares – Paratransit fares can be up to twice the full, non-discounted fixed route fare for a similar trip.; A flat fare of $2.00 per trip was implemented in January of 2007. ; The new fare implemented in January 2007 meets regulatory requirements. ADA regulations allow paratransit fares to be twice the base fixed route fares for similar trips. The base, non-discounted bus fare is $1.50 and the base, non-discounted subway fare is $2.00. THE RIDE fares are therefore below the maximum allowed by the regulations. Days and Hours – Paratransit must be operated during the same days and hours as fixed route services.; THE RIDE contract hours are stated as 6:00 a.m. to 1:00 a.m. in most communities, with a few communities receiving service from 4:50 a.m. to 1:02 a.m. Operating practice is to accommodate earlier morning requests and to make pick-ups by 1:00 a.m. (with later drop-offs).; In most communities, THE RIDE operates longer hours than the fixed route. In a few communities, fixed routes hours are longer than formal THE RIDE contract hours. Actual operating practice appears in compliance, though. MBTA should adjust contract language and public information to reflect operating practice. Trip Purposes – All trip purposes to be served without restriction or priorities.; All trip purposes except K to 12 school transportation served.; All member communities are legally required to provide K to 12 transportation for students with disabilities. THE RIDE restriction probably does not result in a loss of service. Trip Caps. None permitted Current policies do not employ trip caps.; Policy appears consistent with regulatory requirements Waiting Lists – None permitted. ; Some riders given “stand-by” status as part of the internal scheduling process. This is “transparent to the rider,” though and all riders have the understanding that their trip requests have been scheduled. ;Policy appears consistent with regulatory requirements Trip Denials – Cannot have a pattern or practice of a substantial number of trip denials. FTA guidance indicates systems must plan to meet 100% of expressed demand.; Contracts require that vendors “comply with requirements of ADA regarding trip denials.” An understanding that all trip requests are to be served appears to exist. ; More specific language requiring all trip requests to be served is recommended. More specific language on tracking any trip denials that might occur is also recommended. Missed Trips – Cannot have a pattern or practice of a substantial number of missed trips. ; Vendor contracts define a missed trips as “a trip that is not completed due to the Contractor’s failure to transport a customer who had a scheduled trip (excluding cancels and no-shows).” Goal appears to be 0% missed trips and vendors are assessed a penalty for any and all missed trips.; A formal 0% goal is recommended. The missed trip definition also should consider situations where vehicle arrives beyond the on-time window and the rider then elects not to make the trip (i.e., this should be a missed trip rather than a no-show). This definition is applied in practice but should be formalized. On-Time Performance - Cannot have a pattern or practice of a substantial number of untimely pickups. Recent FTA guidance suggests arrivals should be on-time as well. ; Current standards appear to be: 85% of pickups within 20-minute window; 90% of pickups within 20-minute window for Fiscal Year 2006 to 2009; 100% of pickups within 30 minutes of scheduled time.; A standard for on-time arrivals should be established and on-time arrivals measured. Travel Times - Cannot have a pattern or practice of a substantial number of excessively long trips.; Standard is 60 minute maximum if direct travel time is 30 minutes or less. For trips with longer direct times, maximum is twice direct time. ; Current standard appears reasonable and seems consistent with regulatory requirements. Phone Service – Recent FTA reviews suggest that long hold times can be considered a kind of capacity constraint.; Contracts call for vendors to have adequate staff to provide all services required. No specific phone service performance standard has been established.; MBTA should develop a phone performance standard with rider and vendor input. ADA Paratransit Eligibility – Must determine eligibility based on regulatory criteria, provide interim service if decision takes more than 21 days after completed application is received, and have an appeals process which meets regulatory requirements.; MBTA determines eligibility using regulatory criteria, provides interim service as required, and has an appeals process which appears to meet all regulatory requirements.; While the process appears consistent with all regulatory requirements, it is recommended that the MBTA review the treatment of incomplete applications. Level of Assistance – Origin-to destination service is required. This can be either door-to-door or curb-to-curb.; Door-to-door service is provided for all THE RIDE trips; We strongly endorse the MBTA’s policy to provide door-to-door service. Door-to-door assistance is highly preferable in terms of customer service and may even be more efficient. Employee Training – Training in disability awareness and in the safe and proper use of accessibility equipment is required. Employees must be trained “to proficiency,” which implies testing.; MBTA contracts requirements call for “sensitivity training,” and “passenger assistance training.” Nationally recognized materials are used, and the sample training materials developed to assist vendors includes testing.; Training requirements appear to be consistent with regulatory requirements and training materials appear to be thorough. To strengthen the current contracts, a requirement to involve riders with disabilities in the training is recommended. Use of Securement Systems – All riders using “common wheelchairs” are to be accommodated. Transit systems can require that all mobility aids be secured. Passenger restraint is to be equal for all riders. Ambulatory riders to be permitted to use lifts as standees. Riders using scooters can be asked to transfer to seat but not required.; Contract requirements and training materials include most regulatory requirements.; Specific language on “common wheelchairs,” seat belt and shoulder harness use, standees, and scooter-users should be added to contract requirements. Service Animals and Life Support Equipment – Must be accommodated.; Contracts specify that service animals are to be accommodated.; Contract language regarding accommodation of life support systems is recommended. No-Show Policies – Transit systems can establish a process to suspend service for a reasonable period of time if riders have a pattern or practice of missing scheduled trips.; Vehicles required to wait at least 5 minutes after scheduled pickup time. No-shows must be documented using AVL information. MBTA tracks no-shows but has not established or implemented a suspension policy.; The MBTA’s decision to forgo the regulatory option to implement a no-show suspension policy until causes of missed trips can be more thoroughly documented appears appropriate. Any future policy should be “individualized,” focus on real abusers, and address causes and possible solutions. As shown, the current MBTA THE RIDE policies and contract requirements exceed the ADA regulatory minimums in several areas. The service area covers full communities and goes beyond the three-quarter mile corridors required as a regulatory minimum. Same-day service also is provided whenever possible and riders can make same-day changes to prescheduled trips. Door-to-door service is provided rather than curb-to-curb service. THE RIDE operating hours are longer than fixed route hours in many communities, and most fares paid on THE RIDE are less than the maximum allowed by the ADA. In several areas, THE RIDE policies and contractual requirements also appear to be consistent with regulatory requirements. Trip caps are not employed, there is an understanding that all trip requests are to be served, there is a 0% missed trip standard, on-time pickup standards and travel time standards appear appropriate, and all trip purposes, with the exception of K to 12 school transportation, are served (with school transportation legally required and provided by all member communities). ADA paratransit eligibility determination policies also appear consistent with regulatory requirements, and policies related to rider and mobility aid securement, accommodation of service animals and life support systems, employee training requirements, and no-show policies appear consistent with regulatory requirements. In a few areas, some minor adjustments to public information, provider contracts, or service policies, and some additional analysis are suggested. These include some additional analysis of fares, and some changes and clarifications to contracts and public information regarding days and hours of operation. Recommendations are also being made to strengthen the current contracts and to ensure compliance with the latest FTA guidance regarding regulatory requirements. The most significant of these are: more specificity in contracts on trip denial policies; a more detailed missed trip policy; consideration of on-time arrivals as well as on-time pickups; the establishment of a phone performance standard; and more specific language regarding securement requirements and accommodation of life support equipment. It is important to note that some of the ADA regulatory requirements are still in the process of being interpreted by the USDOT and/or the courts. How the regulations apply to each paratransit system’s unique design features also is something that must be determined on a case-by-case basis by the USDOT and the courts. Therefore, the information in this report should not be interpreted as an actual finding of compliance or non-compliance with the regulatory requirements. Instead, this memorandum includes the opinions of the consulting team on the apparent consistency of the current service policies and standards with regulatory requirements and recent USDOT and court interpretations. In some cases, there are still questions given the current level of guidance and interpretation that has been provided by the USDOT or the courts. In these cases, the “observations and comments” at the end of each section state that the issue is still a matter of interpretation. Following is a more detailed discussion of the key observations and recommendations for each THE RIDE policies. The U.S. Department of Transportation’s (USDOT’s) ADA regulatory requirements are first briefly summarized. The MBTA’s THE RIDE policies are then presented. Observations, comments and recommendations are then presented. Service Area The ADA regulations require that paratransit service be provided, at a minimum, to all areas that are within three-quarters of a mile of fixed bus routes. Small areas further than three-quarters of a mile from routes that are totally surrounded by routes must also must be served. THE RIDE service is provided in 62 cities and towns in Eastern Massachusetts. This includes all cities and towns that receive non-commuter fixed route MBTA service (except for Avon) as well as a few communities that do not receive non-commuter fixed route service. The map which shows each community is provided as Figure 2.1 above. The review of the current service area noted that the Town of Avon is served by fixed route 240 but is not in the THE RIDE service area. Avon is, however, a member community of the Brockton Area Transit Authority (BAT) and residents have access to that transit authority’s ADA paratransit service. The MBTA also has a cooperative agreement with BAT to provide THE RIDE service to and from the main transit terminal in Brockton which is used as both a fixed route and paratransit hub. This allows BAT area residents, including residents of Avon, to use the BAT paratransit service and then transfer to THE RIDE vehicles to travel to and from points in THE RIDE service area. The MBTA THE RIDE program exceeds the ADA requirement regarding service area. The MBTA has chosen to provide service throughout all areas of each community that is served rather than limiting service to areas in each community that are within ¾ of a mile of a fixed route. In our opinion, though, including full communities (rather than establishing corridors in each community) makes sense from a public information and understanding perspective. Communicating to residents the logic of ADA service corridors is difficult at best. The MBTA also provides service to some communities that do not receive non-commuter fixed route service. In many cases, these communities were served by THE RIDE prior to the passage of the ADA and service has been continued. Again, this appears to be a decision that makes sense. Other transit systems that propose to cut-back prior paratransit service areas to the ADA minimums have reported significant public opposition. Riders who have made life decisions (e.g., housing or employment decisions) tend to be significantly impacted by these proposed cut-backs. And, unlike other riders who may have other travel options, paratransit riders may be left without viable options if service areas are reduced. Response Time The ADA regulations require that paratransit services that are “prescheduled” (as THE RIDE is) be provided on a “next day” basis. Trip requests must be accepted up to the close of business on the day preceding the day of service. Same day service is not required. Trip requests must be taken during normal business hours (typically 8 to 4 or 9 to 5) on all days that precede a day of service (including Sundays and holidays if service is provided on the following day). A policy for allowing trip requests farther than one day in advance is to be developed. The exact number of days in advance that requests can be made is not specified in the regulations. Finally, to allow for the grouping of rides, the regulations permit systems to offer pick-up times that are up to one hour before or after the requested pick-up times. This is commonly referred to as the “scheduling window.” THE RIDE trip requests are taken 7 days a week, 365 days a year, up to 14 days in advance, and from 8:00 a.m. to 4:00 p.m. Vendors also are required to have toll-free numbers to allow riders to access both reservations and dispatch. The MBTA also has purchased and installed technology that allows riders to book trips via the Internet. Same day service is also provided. Page 19 of the Statement of Work (SOW) contained in the contracts between the MBTA and THE RIDE service providers states “requests will be accepted by the Dispatcher on the date the customer wishes to travel. Every effort will be made to accommodate these requests.” Page 19 of the SOW also says that vendors are to accept changes to confirmed trips and that “every attempt will be made to accommodate these changes as the schedule permits by utilizing the slots available in the schedule.” Contractors may adjust requested pick-up times to allow for the grouping of trips, but MBTA policy limits the “scheduling window” to only 30 minute adjustments rather than the one hour adjustments allowed by the regulations. The MBTA THE RIDE program exceeds the ADA requirement regarding service area. Same-day service, not required by the regulations, is allowed and accommodated when possible. This includes new same-day trip requests as well as requests to change the locations or times of trips scheduled in advance. Second, the MBTA uses a +/-30 minute “scheduling window rather than the +/- 60 minute window allowed by the regulations. Allowing same-day service is certainly a significant benefit to riders. It also can increase productivity by utilizing “slack time” in the schedules. It also, however, can place an extra burden on the dispatching process. Dispatchers must not only manage prescheduled runs and the inevitable changes that occur due to daily operating issues, but now must manage additions and changes to the schedule. Without diligent dispatch control, allowing same-day trips and same day changes can impact the on-time performance of prescheduled trips. Same day add-ons also could impact travel time. Since these add-ons are inserted into the schedule manually, they may not be “controlled” by the maximum ride time settings in the automated scheduling system. Again, dispatchers would need to pay close attention to the impacts that add-ons have on rides already on the schedule. A final consideration is that contractors are currently paid per trip and have an incentive to accept and provide additional trips. As noted later in the “On-Time Performance” section of this memorandum, there are detailed contract incentives and penalties in place that are intended to balance the tendency toward maximizing income in a per trip payment system with acceptable levels of service quality. Theoretically, contractors would not accept same-day add-ons to increase income if this would mean that late trip penalties might be triggered. It may, however, tend to create a situation where contractors can maximize their income by operating just above the minimum on-time performance standards established in their contracts. And it also would make the service monitoring process and careful implementation of service quality penalties a critical part of the management of the system. The use of a tighter “scheduling window” than allowed by the regulations makes sense given the trip reservation and scheduling process currently used by THE RIDE. Rather than negotiating actual pickup times with riders when they are on the phone placing trip requests (commonly called “real-time scheduling”), the current system has riders call in and leave their requested pickup times. The automated system (or schedulers) then create runs and develop actual scheduled times the evening before the day of service. Riders then receive a call-back with the final scheduled (or “promised”) pickup time. This type of a process is commonly referred to as “batch scheduling.” Since there is no “give and take” in the trip scheduling phase of this process (with riders able to say whether the times generated by the system do in fact work for them), using a tighter “scheduling window” minimizes the possibilities of offering times that do not work. It also is important to note that the use of batch scheduling with automated changes to requested pickup times may not meet the requirements of the regulations to “negotiate” alternative travel times with riders. Few systems in the country use “batch scheduling” as the primary method for scheduling trips. Many use batch scheduling within a real-time process (to develop subscription runs or to fine-tune the schedules within already given promised times), but few schedule all trip requests in this way. As a result, no systems that rely primarily on batch scheduling have yet been reviewed by the FTA and no guidance on this issue has been developed. On this issue, we noted that the MBTA’s scheduling policies include a number of protections to help ensure that pickup times offered meet rider needs. These include policies to record “earliest departure times” (to prevent the scheduling of trips before riders indicate they are able to leave), to record “earliest arrival times” (to prevent the scheduling of arrivals before buildings or programs open for business), and to schedule going trips based on appointment times (to help ensure that riders arrive on-time). These protections would certainly minimize the possibility that pickup times might be offered that truly don’t meet rider needs. With these protections, it is then possible that the current “batch scheduling” process might satisfy the trip negotiation requirements. Finally, we note that the MBTA has not changed the 14 day advance reservation policy which it set based on the original regulations in 1991. Unlike other transit systems, though, the current scheduling system does not encourage riders to place trip requests far in advance to ensure that service is received. In many other systems that use “real-time scheduling,” there is an advantage to being one of the first riders to request a trip. The likelihood of getting a ride closer to the time requested is increased if no other trips are on the schedule. In the MBTA’s batch scheduling system, on the other hand, there is no advantage or disadvantage to requesting a trip one day in advance versus 14 days in advance. All are treated equally in the final batch scheduling process. So, maintaining a 14 day in advance trip reservation policy may not increase trip cancellations and no-shows. A more detailed analysis of trip request patterns and cancellations and no-shows would be needed to determine if changing this policy would be beneficial. Fares The USDOT’s ADA regulations requires that the ADA paratransit fare can be no more than twice the “full fare” (non-discounted fare) for a comparable trip made by fixed route. Personal attendants traveling with eligible riders (from the same origin to the same destination) are to be accommodated on the paratransit service at no fare. Companions traveling with an eligible person can be charged the same fare as the eligible individual. At the time of the initial review in 2005, THE RIDE program utilized a zone-based fare system. Fares ranged from $1.50 to $4.50 per trip depending on the community of origin and the destination community. The zonal fares were developed to be consistent with rider fares under prior operating designs with different subarea configurations. A zonal system also was developed because of the complexity of fares throughout the MBTA system and the difficulties that would be encountered trying to exactly mirror fixed route fares on THE RIDE service. To determine if the current THE RIDE zonal fare structure was consistent with regulatory requirements, the community-to-community fares called for in the current THE RIDE fare matrix were compared to fares for similar trips on the fixed route system. The analysis looked for possible situations where the paratransit fare might potentially be more than twice the fixed route fare. The evaluation also considered a detailed study of THE RIDE fares actually paid in May of 2004. The analysis indicated that in most cases, the fares paid by THE RIDE riders were less than the regulatory maximum of twice the fixed route fare for a similar trip. The detailed analysis of actual THE RIDE fares showed that 80% of all trips had a fare of $1.50. And all but one trip of the remaining 20% had a $3.00 fare. Only one trip in May of 2005 had a $4.50 fare. As the fixed route fare structure was being examined, it was observed that one unique fixed route fare situation exists. It was noted that outbound trips made on the Green Line beyond Kenmore Square can be made fare free. This policy was established by the MBTA as a way to minimize fare collection delay on Green Line service. Instead of collecting base fares both ways on this segment of the Green Line, inbound fares were doubled and outbound fares were waived. The idea is that the total fare for people making round-trips in this corridor would be the same as if they paid the standard fare each way. A strict interpretation of the ADA regulations would then suggest that individuals only riding outbound in this corridor (not making a round-trip) would also ride free. If, however, you consider “round-trip” fares for people who are making trips both inbound and outbound on THE RIDE in this corridor, the total fare would be no more than twice the total fare paid by a Green Line rider also making a round-trip. The analysis did, however, identify a few potential situations where fares paid by THE RIDE riders could be more than twice the fixed route fare. These situations appeared to be very limited, though, and the number of actual trips (if any) where this situation exists is not known. In most cases, THE RIDE fares appeared to be below the maximum allowed by the ADA regulations. A recommendation was made in Technical memorandum #1 of the study that the MBTA more closely examine the fare structure for THE RIDE, identify origin-destination pairs where the fare might be more than twice the fixed route fare, and make adjustments in the fare matrices for THE RIDE accordingly. In January of 2007, the MBTA adopted a flat fare of $2.00 for THE RIDE service. This fare applies regardless of the distance traveled. Since the base, non-discounted fixed route bus fare is $1.50 and the base, non-discounted subway fare is $2.00, the new THE RIDE fare policy meets regulatory requirements. THE RIDE fares are less than the maximum allowed by the regulations. Days and Hours of Operation The USDOT’s ADA regulations states that “The complementary paratransit service shall be available throughout the same hours and days as the entity’s fixed route system.” The “Interpretation” section of the regulations (Appendix D) indicates that the hours in various parts of the paratransit service area can change based on the fixed route hours in that area. The RIDE Guide communicates the days and hours as “7 days a week, generally from 6 a.m. to 1 a.m., including holidays.” The Scope of Work in the vendor contracts is more detailed. It lists days and hours by community by zone. The exact hours of operation included in the contracts are shown on the following page. Most communities in each zone receive service 7 days a week, 6:00 a.m. to 1:00 a.m. A few have slightly different hours. Earlier than 6:00 a.m. hours are available in ten communities (Stoneham, Weston, Needham, Wellesley, Dedham, Medfield, Norwood, Sharon, Walpole, and Westwood) with the earliest start time being 4:50 a.m. in six of these communities. The latest operating time was 1:02 a.m. in six communities (Dedham, Medfield, Norwood, Sharon, Walpole, and Westwood). MBTA staff indicated that the hours of operation in the contracts are interpreted as pick-up times. That is, the last pick-ups of the day are to be made by 1:00 a.m. Given ride times of 30-60 minutes, vans therefore could be in operation until 1:30-2:00 a.m. Staff also indicated that contractors will accept pick-ups before the contract start times if fixed route service in the area is in operation earlier than these times. To determine if the days and hours of operation specified in the vendor contracts were consistent with regulatory requirements, the current fixed route schedules were examined and fixed route times in each community were compared to THE RIDE operating hours. This analysis used the fixed route schedules that were dated March 26, 2005. The analysis indicated that THE RIDE hours of operation exceed fixed route hours in many communities, but there are a few instances where fixed route hours exceed the formally advertised THE RIDE hours. In many communities outside of Boston and its immediate suburbs, fixed route service often ends well before 1:00 a.m. In these areas, THE RIDE service has significantly longer hours of operation. At the same time, though, several bus routes do make their first pickups on weekdays before 5:00 a.m., with many routes starting before 4:30 a.m. and the earliest route (#15) starting at 3:38 a.m. Several fixed routes also have last scheduled drop-off times on weekdays after 1:00 a.m., with the latest drop-off scheduled at 1:42 a.m. on weekdays (Route #73) and 1:36 a.m. on weekends (Route 1). As noted above, the stated operating practice (as opposed to the contract language) is to make last pick-ups by 1:00 a.m. Given typical ride times for THE RIDE, last drop-offs would therefore be generally consistent with the last drop-offs on the fixed route system. It also is possible that in actual practice, pick-ups are requested and accommodated earlier than the formal contract start times and are consistent with fixed route start times. Based on our analysis and discussions with MBTA staff, fixed route operating hours in some areas appear to exceed the operating hours formally stated in THE RIDE vendor contracts and indicated in THE RIDE public information. Actual THE RIDE operating practices appear to be largely consistent with ADA requirements, though. To ensure compliance, though, it is therefore recommended that the MBTA revise THE RIDE contracts and public information to reflect actual practice. This would include:
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