1.0   Overview

1.1   Executive Summary

2.0   Customer Service Executive Summary

2.1   Customer Service Recommendations

3.0   Paratransit Operations Executive Summary

3.1   Paratransit Operations Recommendations

4.0   ADA Structure Within Pace Executive Summary

PACE BLUE RIBBON COMMITTEE

PARATRANSIT RIDER MINORITY

REPORT

1.0

OVERVIEW

We would like to take this time to thank the Pace Board of Directors for giving us the opportunity to submit the minority report on behalf of the Blue Ribbon Committee (BRC) paratransit riders.  The conclusions expressed in this minority report are based upon the consensus of its authors and community stakeholders such as customer input through on-going Pace ADA Advisory Committee, BRC public hearing testimony and feedback submitted by grassroots paratransit and disability rights organizations, supplemented by careful review of published professional literature.

It is our opinion that the following areas of concern require immediate serious consideration for the improvement of paratransit service:  A restructuring of the current zoning system in the city of Chicago; the reestablishment of the communication with the current Pace ADA Advisory committee and access to a wider array of Pace staff and management resources; disability awareness training of carriers, Pace staff and administration, drivers, customer service on every level;  a customer friendly complaint process; independent monitoring of Pace’s service with customer involvement; as well as allowing for flexibility in the paratransit system that better meets the needs of the paratransit riders.

Unlike the BRC recommendations, these recommendations have been reached completely independent of the influence of Pace and has the best interest of the riders in mind.  Furthermore, there will be no claims of “No pattern and practice of ADA violations” made in this report because as agreed upon by the committee as a whole, that claim goes beyond the scope of the BRC’s expertise and is left for the Federal Transit Administration to determine. We are in agreement with this position held by the committee.  In addition, unlike the BRC major report, this report has been presented in its entirety for evaluation to its members authoring it.

Section 1.1

EXECUTIVE SUMMARY

In compliance with 775 ILCS 30/2 Sec. 2, which states:  It is the policy of this State to encourage and enable the blind, the visually handicapped and the otherwise physically disabled to participate fully in the social and economic life of the State and to engage in remunerative employment, which demonstrates a right given by the state to expect top quality paratransit service in the state of Illinois, it is to achieve this end that this report is written.  For the past 20 plus years Chicago paratransit riders have worked to improve the quality of transportation to allow them to participate fully in the activities of life. It is the goal of the authors of this report to improve paratransit service and obtain top quality paratransit service befitting the paratransit riders.

The members compiling this report have collectively over 40 years of paratransit rider experience and have been in an advisory capacity on behalf of paratransit riders for a minimum of 24 years collectively.  This experience of first hand knowledge demonstrates the expertise held by these Blue Ribbon Committee members in the area of advisory capacity.

            If there was any one event that contributed most significantly to the progress of the BRC, it was the development of the public hearings. We want to express our appreciation to the chair for being instrumental in arranging time for that public feedback process. This hearing held on September 17, 2008, was the only public feedback hearing held since the zoning transition.   

            In the area of customer service, we are in agreement with a large number of the recommendations submitted by the Customer Service subcommittee.  Through the graciousness of the Chair of this subcommittee in allowing us to give input in his meetings, the Customer Service subcommittee was able to get a better understanding of the paratransit rider issues with our help.  In fact, a most number of these recommendations were previously made by the Pace ADA Advisory Committee and were rejected by Pace staff.

Like the Customer Service subcommittee, the Operations subcommittee was disadvantaged by a steep learning curve regarding knowledge of current paratransit service policies and issues.  The BRC public hearing held on September 17 marked a turning point for this subcommittee. Armed with a better understanding of the problems experienced by Chicago paratransit riders, this subcommittee was able to move forward.  We are in basic agreement with the 5 recommendations developed by this subcommittee.   However, due to time constraints, this subcommittee was not able to complete their work to its conclusion. We therefore respectfully submit additional necessary recommendations to enhance the excellent work begun by the Operations subcommittee. We fully believe that we would have reached a consensus on most, if not all, of the additional recommendations, in whole or in part, had the BRC schedule allowed.

While we can agree with the work of the afore-mentioned subcommittees and thus submit additional or revised recommendations in order to complement their work, we must author a minority report dissenting from the work of the ADA Structure subcommittee, whose work was done in such a way that the integrity of their conclusions are entirely questionable.

2.0

CUSTOMER SERVICE EXECUTIVE SUMMARY

This subcommittee met 9 times for a total of 15 hours. No members of the Pace ADA Advisory committee and no Chicago paratransit riders were assigned to this subcommittee. There was a quorum at every meeting. Each meeting was attended by “observers” which included 4 members of the Pace ADA Advisory committee, 3 of whom are BRC members. These meetings were held in both in person and via conference calls.

The Customer Service subcommittee members were not provided with or otherwise familiar with Pace Paratransit Service Policy Guidelines or the provisions of carrier contracts. As a result, considerable time was spent by subcommittee members in developing recommendations that were later determined to be unnecessary as the corresponding policies or procedures were already in place at Pace. Because the input of the authors of the minority report and Pace ADA Advisory members was often relegated to the end of the meetings and as time allowed, we were unable to alert subcommittee members to all of these instances.

2.1

CUSTOMER SERVICE RECOMMENDATIONS

Recommendation 1:  PRIVATE INFORMATION STAYS PRIVATE.  We strongly recommend that Pace have in place stiff punishment, up to and including contract revocation for any carrier who knowingly gives paratransit riders' private information other than their address to drivers.  For example, dispatchers MUST NOT give customers' phone numbers out to drivers so they can call the customer when they arrive at their pickup address.  Keeping customer information private also means drivers should not be discussing the customer's disability or trip purpose over public air waves or among each other.  In addition, consistent with suburban paratransit policies, home addresses and customer names should not be disclosed over the radio.

Recommendation 2: We recommend that each of Pace's paratransit carriers put in place a separate telephone number or menu option to handle ride cancellations, with the handling of a cancellation by a live operator.  This will prevent those needing to cancel a trip from having to call into the regular number used to schedule rides and wait on hold, or run out of cell phone battery power or minutes. However, if a rider does call into the regular number to cancel a ride, the cancellation should be taken and logged in by the call taker.  The cancellation shall be taken and logged, no questions asked about the reasons for canceling.  In addition, each call that comes in for a cancellation should be assigned a tracking number and given to the customer for future reference. 

Recommendation 3: We strongly recommend that in the event a rider reports a problem regarding driver or vehicle safety during travel, that Pace instructs carriers to take riders seriously and take steps to investigate the problem ASAP to ensure the safety of the passenger.  In addition where necessary, Pace staff should be sent to the scene to further investigate and resolve the problem.

Recommendation 4:  We recommend that Pace re-institute policies allowing for same-day changes and will-call reservations on paratransit and that these policies be implemented system wide.  These policies recognize that people with disabilities can run into situations where their plans change for various reasons.

Recommendation 5:  We strongly recommend that the entire Pace complaint process be analyzed by an independent third party such as the ADA Advisory Committee with recommendations for improvement being made to provide confidence to paratransit customers that the process is credible and transparent. We specifically recommend that Pace develop a complaint system with the following components:

• Respond to paratransit customer complaints within 10 business days of their being filed.  We further recommend that Pace inform the customer if a response cannot be delivered within 10 business days of the reason why the response will be delayed.  Such information should be provided to the customer within 10 business days of the complaint being filed, 
• Multiple means of filing complaints (in-person, telephone (voice, relay, TTY), written letter, e-mail, large print, Braille, audio recording) must be advertised and available to customers, 
• All written responses from Pace must be provided in the customer's preferred format.  We further recommend that responses to complaints include a re-statement of the complaint in plain language and specific actions which have been taken to address it,
• An appeal process that includes review by an independent reviewer,
• Protection of the complainant from disclosure of their identity beyond the complaint process and protection from retaliation,
• Improve accountability for complaints by assigned each call that comes in a tracking number, which follows each Customer Assistance Report (CAR) and is given to the customer for future reference.
• A centralized data base designed to provide the public with the number of complaints filed against each service provider, nature of complaints by type, the number of complaints found valid, the number found invalid, the number of days required to respond to customer, and the number of complaint responses appealed.
• Complaint response letters written in a format which demonstrate true customer concern and appreciation for customer efforts to report and resolve service issues. Complaint responses should not be intimidating or be written in such a way as to discourage riders from making complaints.
• Recording and monitoring of customer service lines. Any customer service representative found to engage in unprofessional or intimidating conduct, or to willfully misrepresent ADA requirements, should be subjected to disciplinary procedures as well as retraining.

Recommendation 6:  We recommend that Pace record and monitor the emergency “800” telephone number, ensure that all calls are answered, reduce excessive hold times, and sufficiently train operators so they know how to properly and promptly assist customers with emergencies.

Recommendation 7: We recommend that Pace work closely with its ADA Advisory Committee and others in the disability community to develop a curriculum for provision of disability awareness and cross cultural training to drivers, dispatchers, schedulers, customer service personnel, management (both within Pace and at each carrier) and other Pace staff who are involved in the provision of paratransit service.  We further recommend that individuals with disabilities and disability organizations be engaged to deliver this curriculum once it is developed.  Names and contact information for those who can provide training must be furnished to the paratransit carriers.  The curriculum must be shared at public meetings with paratransit riders before being adopted by Pace and there must be opportunities to provide comment.  Once adopted, we recommend that this be the standard curriculum paratransit carriers use to deliver disability awareness and cross cultural training and retraining, and that it be written into paratransit contracts that this curriculum is delivered to new and veteran paratransit drivers consistent with regular training and retraining.  Going forward, we recommend that any changes to this standard training curriculum be approved by Pace after consultation with its ADA Advisory Committee and opportunities for public comment.

Recommendation 8: We recommend in all instances where Pace communicates with its customers, Pace at a minimum comply with Title II of the ADA.  This means that customer communications be provided in accessible formats including but not limited to: large print, Braille, audio and electronic.  We recommend that materials delivered in electronic format be prepared in compliance with the Illinois Information Technology Accessibility Act (IITAA) and its implementing standards and guidelines.  We further recommend that Pace undertake an analysis of its website to ensure that it is in compliance with IITAA. 

We further recommend that Communications be prepared in simple, plain language and that they be made available at a minimum in English and Spanish.  We recommend that a clearly defined process be put in place for individuals to request that communications be delivered in other formats, as well as for requesting materials in the formats already listed. The recording space on each carrier's phone line is one means of delivering information to Pace customers.  Other means include but are not limited to: presentations to organizations serving people with disabilities, press releases in local mainstream and disability-related media, and information displayed and handed out on Pace vehicles with drivers being required to read such information to those who cannot read it themselves and who request this accommodation.  We also recommend that Pace maintain as part of its customer files the preferred format in which to communicate with each paratransit rider.

Recommendation 9:  In the event of a customer hearing, Pace should provide the rider with a clear explanation of the hearing process. Riders should be given the right to have someone of their choice to speak on their behalf such as a lawyer etc. This option should be made known to them at least 7 days in advance of the hearing. In the event that they do not bring anyone with them, a panel made up of member of the Pace ADA Advisory Committee should be allowed to evaluate the rider’s deeds in addition to Pace staff.

Recommendation 10: We strongly recommend that Pace make no changes in paratransit policy without first consulting with the ADA Advisory Committee regarding each change, and second, presenting these changes to riders in compliance with 49 CFR Part 37.137, "Public Participation." If, through the public participation process there is significant opposition to any policy change, we recommend that Pace not implement it as proposed.

Recommendation 11: We recommend that Pace and its carriers require and enforce, per existing policy,  that schedulers ask if there are any special instructions the rider needs to have given to the driver at the time a trip is scheduled with pickup at a location other than a rider's routine origins.  In addition, Pace should modify the trip intake form so that it correlates with existing policy. In other words, include “Boarding, debarking and vehicle accommodations” that are clear to the dispatchers/DRIVERS for sending proper vehicles that meet the needs of the riders.  We further recommend that special instructions be included in the customer's file for trips originating at routine places such as a home and work address.  This will facilitate the easy provision of these instructions to the driver via the manifest or Mobile Data Terminal.  That way, drivers have no excuse for leaving riders simply because they did not know that pick-up and boarding accommodations were needed and expected.

Recommendation 12:  We recommend that Pace subcontract with an independent organization to conduct customer satisfaction surveys of paratransit riders on a semi-annual basis in order to help improve service.  Such independent surveys are valuable as they will provide Pace and the paratransit riding public with confidence that an unbiased evaluation of paratransit through customer feedback is routinely taking place.  To that end, the survey results should be shared semi-annually with the ADA Advisory Committee and at least annually with paratransit riders through a variety of means including but not limited to public meetings, presentations to organizations serving people with disabilities and dissemination in disability-related media.

Recommendation 13:  We recommend that Pace work with its ADA Advisory Committee to develop an incentive program to reduce no-shows and late cancellations by paratransit riders.  As the 2005 National Council on Disability Report on transportation shows, such programs have been shown to reduce no-show and late cancellation rates in paratransit systems where implemented.

Recommendation 14: We recommend that Pace develop and make available paratransit service policy guidelines for suburban paratransit riders, consistent with the guidelines for Chicago paratransit service policies. Such published policies and guidelines should be readily available to riders and staff. The lack of such information has led to many disputes and misunderstandings between all levels. Carriers should never be the primary source for communicating service policy changes. Publishing this information and making it available in a wide range of alternate formats will increase satisfaction and productivity for all.

3.0

PARATRANSIT OPERATIONS EXECUTIVE SUMMARY

This subcommittee met 7 times for a total of 19 hours. Four members were users of Chicago paratransit services. The authors of the Minority report and current members of the Pace ADA Advisory committee covered each Operations subcommittee meeting as members or “observers.”

Only one Chicago paratransit user was able to attend the first two meetings of this subcommittee. The testimony and perspective of this member was challenged by the majority throughout the first two meetings. Considerable skepticism as to whether there were any post-transition problems or issues at all with Chicago paratransit service was expressed. The BRC public hearing held September 17 marked a turning point for this subcommittee, although progress remained hampered by continuing unawareness of many members as to existing paratransit policies as well as the provisions of carrier contracts.

3.1

PARATRANSIT OPERATIONS RECOMMENDATIONS

Recommendation 1: We support the reevaluation of the Chicago zoning model and the reconstruction of the Chicago paratransit service model. We believe it is likely that the reevaluation and reconstruction of the Chicago paratransit zoning service model is in the planning stages or already taking place.  Therefore, we urge Pace to immediately include paratransit riders and the Pace ADA Advisory committee in all decisions and deliberations regarding paratransit service changes.

Recommendation 2: Pace should work with its customers and the ADA Advisory committee to establish a system to evaluate its paratransit vehicles region wide to assess issues of vehicle configuration and features. Vehicle configurations and features include but are not limited to issues of safety, ease of use, accessibility for a wide range of mobility devices of various sizes, ambulatory users, space constraints, suspension systems, securement/seatbelts, seat height, clear floor space, customer comfort, color, markings, identification of carriers, fuel efficiency, and compliance with all applicable laws.

Recommendation 3: RTA in close collaboration with the Pace ADA Advisory committee should develop an independent, on-going monitoring system that relies on paratransit rider participation and involvement in all phases of monitoring.

Recommendation 4: Pace should implement a region wide centralized scheduling system that would allow customers to call one toll-free number region wide to arrange all trips. Note that the recommendation to implement a region wide centralized scheduling system was made by RTA consultants several years ago.

Recommendation 5: Pace should have a conflict mediator available through a toll-free number during all hours of operation to immediately address conflicts as they occur between paratransit personnel and passengers/riders with a goal of increasing safety and preventing escalation of conflict.

Recommendation 6: To prevent excessive travel times and avoid potential capacity constraints, Pace should:

• Reinstate 90 minute cap on trip lengths,
• Advise riders of the maximum travel time for their trips when rides are scheduled,
• Provide riders with the RTA Travel Information number as well as the URL for the RTA Trip planner so that riders can confirm the accuracy of their travel times prior to their trip,
• Advise riders of “same-day” appeal process for trips they believe to be in excess of comparable fixed route travel times so that an appropriate resolution can be reached prior to travel,
• All trips exceeding 90 minutes should be reviewed by Pace and efforts should be made to shorten these trip lengths or otherwise provide appropriate accommodations for those riders who require such accommodation.

Recommendation 7:  Pace should reduce the amount of time required to schedule trips, including hold times, in order to avoid capacity constraints.

Recommendation 8:  Pace should offer more than one trip time to riders when it is necessary to negotiate travel times, in order to avoid capacity constraints.

Recommendation 9:  Pace, in close collaboration with the Pace ADA Advisory committee, should evaluate the effectiveness of the current Trapeze system in order to make the changes necessary to eliminate circuitous, doubling-backing, or otherwise inefficient routing. It is economically practical to create routes that reduce travel times and make seats quickly available for additional customers while also preventing the inefficient use of fuel. Efficient routing will serve to avoid capacity constraints and contribute to public efforts to improve air quality across the region.  

Recommendation 10: Pace should reinstate the “wait and return” policy for Chicago paratransit riders purchasing Pace passes in person at the one site where such can currently be purchased within the City of Chicago. 

Recommendation 11:  Pace should officially and publicly retract the faulty policy offensively termed as the “line of sight” policy as the default for paratransit pick-ups and drop-offs.

Recommendation 12: We recommend that Pace strengthen accountability by refining and auditing paratransit data collection and reporting to accurately measure on-time performance and prevent data distortion resulting from carriers retroactively changing pick-up times, and recording as late cancels or no-shows riders who must seek another means of transport due to late pick-ups.

Recommendation 13:  Pace should eliminate service disparities and ensure that paratransit service quality is comparable across all service areas as well as otherwise fulfill their Title VI requirements. We recommend that monitoring of service comparability across service areas and carriers are included as a responsibility of any independent monitoring system.

Recommendation 14: Pace should reduce dwell time costs by building into carrier contracts policies and practices that discourage excessive time expended by carriers in securing riders, collecting fares, completing paperwork and engaging in radio communications.

Recommendation 15: Pace should promote service policies and procedures that enhance and prioritize customer safety in all aspects of the provision and utilization of paratransit service.

Recommendation 16: Pace should demonstrate a commitment to improving the regional coordination of paratransit services, including the establishment of equitable fares to City and suburban riders.

4.0

ADA STRUCTURE WITHIN PACE EXECUTIVE SUMMARY

This subcommittee was only able to meet 7 times for a total of 9 hours. Three members were Chicago paratransit riders, although the attendance of 2 was limited due to the serious injury and extended recovery of one member while out-of-country travel as well as insufficient notice of meetings prevented the other from fully participating. Unlike the other subcommittees, all meetings were conducted via conference calls. The process was plagued by inadequate communications, including insufficient notice of meetings, while consensus was claimed for decisions arrived at in meetings in which a quorum was not achieved.  Member participation was sporadic and in general significantly less than that of the other subcommittees. An attempt to further divide the subcommittee into 3 smaller subgroups did not succeed. Furthermore, the Chair’s publicly stated agenda, “a separate ADA Advisory committee for Chicago paratransit riders only” notably drove the work of this subcommittee, while personal conflicts resulted in recommendations that were not sufficiently vetted and were of a personal nature.

Initially, “observers” were denied access to meeting notices and agendas and a marked reluctance to share subcommittee planning and information was prominent throughout this subcommittee process. Process and communications were perceived as exclusive and appeared to be conducted outside of the public forum, while consensus was claimed at meetings in which a quorum was not achieved. “Observers” and minority report authors did not feel welcome to contribute to this subcommittee’s work, and were only recognized to speak when there were not enough subcommittee members present to maintain a dialogue, or at the meeting end when all voting matters had been concluded.  Offers to assist the Chair and subcommittee in achieving its mission were not accepted.  Consequently, this subcommittee did not complete its work and numerous irregularities significantly compromise the validity of the work that was started.

4.1

ADA STRUCTURE WITHIN PACE RECOMMENDATIONS

Recommendation 1:  There should be a regional committee governed by paratransit riders such as the existing Pace ADA Advisory Committee in place in order to meet the needs of paratransit riders and serve as a sounding board to Pace for the benefit of the riders.

Recommendation 2:  We recommend that Pace provide and participate in independent conflict mediation with the Pace ADA Advisory committee in instances where Pace staff or management disagree with the position of the Advisory committee or exhibit emotional reactions harmful to the ADA Advisory committee process.

Recommendation 3:  The availability of Pace staff and resources should be expanded to allow paratransit riders and the Pace ADA Advisory Committee the benefit of the full range of Pace staff and management resources.

Recommendation 4: Pace should provide the Pace ADA Advisory committee with the same level of support as is provided to the Pace Citizens Advisory Board.  

Recommendation 5: In the event that the recommendations are agreed upon by Pace as submitted by the ADA structure within Pace subcommittee, we recommend that no leadership from any existing RTA or service board ADA Advisory committee be allowed to serve in a leadership capacity for two years. This will prevent any discrimination of individuals who have served in leadership roles on ADA Advisory committees.

Recommendation 6: Pace should not retaliate or otherwise engage in unprofessional behaviors towards the Pace ADA Advisory committee as a whole, ADA Advisory committee members, or paratransit riders who pursue resolution of service complaints or oppose Pace positions regarding paratransit services.

Recommendation 7: Pace should provide all necessary accessibility accommodations to the Pace ADA Advisory committee and paratransit riders Pace personnel is in communications with.

With the goal of achieving high quality paratransit service and improving

the quality of life for the disabled community, this report is written and

respectfully submitted,

___________________    _____________________    __________________

Horacio Esparza                Sharon Lamp                         Alva Rodriguez

___________________

Darlene Hale