Show 04 __ DOT Proposed Changes
In this episode, Tajuana Arnold moderates a presentation by Marilyn Golden of the Disability Rights Education and Defense Fund on the topic of "DOT Proposed Changes to ADA Transportation Regulations". The full-length webcast originally aired on April 21, 2006 and can be found at:
DOT Proposes Changes to ADA Transportation Regulation Webcast
The Southwest ADA Center Podcast, Show Number 4.
(music)
Beth Case: Hello, I'm Beth Case and welcome to the Southwest ADA Center Podcast. In this podcast, we take highlights from the full length webcasts offered by the Southwest ADA Center. As always, if you like the information you hear in this podcast, you can listen to the full webcast by following the link that you can find on our website, www.ada-podcast.com.
Today's show is about the Department of Transportation's proposed changes to the ADA Transportation Regulation. It features Marilyn Golden from the Disability Rights Education and Defense Fund. And she is interviewed by Tajuana Dunning. This show first aired on April 21, 2006.
(music)
Marilyn Golden: The perhaps biggest issue in this proposed rule is that DOT is proposing to add to its regulation a provision requiring ADA transportation providers to make reasonable modifications to policies, practices, and procedures when necessary to avoid discrimination on the basis of disability. Unless the transit agency can show that the modifications would fundamentally alter the nature of the service or activity, or would result in undue financial or administrative burdens, or a direct threat to the health and safety of others.
Now, we already have one example of what it might mean because last fall DOT put out guidance on so-called origin to destination service.Yes, they put out a guidance called "origin to destination service" referring to paratransit. And it stated that an agency providing ADA paratransit under a, quote, curb to curb policy, that is under a basic policy that paratransit drivers will wait at the curb for passengers rather than going to the door to assist them, that policy -- that transit agency still may occasionally need to provide service beyond the curb if necessary to ensure that the individual can reach his or her destination. So for example, this would mean that if a physical barrier, like sidewalk construction or snow prevents a passenger from getting to the curb, the service provider must offer assistance beyond the curb, again, not necessarily to all passengers, but to this particular passenger for whom maintaining the curb to curb policy strictly would deny the ability for them to get to their destination. DOT has made it clear that adding this provision to their regulation would not mean, for example, providing any kind of personal assistance to riders, it would not mean going beyond the door to assist a passenger or take any actions that would present a direct threat to safety, like leaving vehicles unattended for lengthy periods of time. Of course other riders could be in those vehicles, or losing the ability to keep the vehicles under the driver's visual observation. So there are definitely limits on what -- how far this would go.
Moving on, another big topic in this proposed regulation is on commuter and inner city rail platform access.On the commuter innercity rail platform accessibility issue, DOT is requiring -- proposals to shift their requirements but still to require level entry boarding to the train from a fully accessible high platform. And then if necessary with a ramp or bridge plate over any gaps which will make it possible for everyone to board any or I should say every accessible train car. The proposal is trying to avoid the use of mini high platforms to provide disability access, allowing them only as an absolute last resort. They necessitate that the train has to move in small increments to allign its cars one by one with the mini high platform if people who need to board or disembark are on multiple cars, which they often are. This process is also called double stopping. It's very difficult. It's time-consuming and yet it has to be done permanently if mini high platforms are allowed.
At this point, I'd like to stop and take questions on the NPRM if anybody has anything, questions about what I've said or additions or concerns we haven't mentioned. Anything like that. Tajauna, are there any questions?
Tajuana: The first question is would paratransit have to help people down their ramps at the house?
Marilyn: Okay, well, this is a general question on the ADA, which is fine. Or actually the person may mean under the new rule. Not necessarily. They would have -- if the rule is adopted and DREDF would argue that transit agencies are already covered by the same requirement already because it's in the Department of Justice rule, and everywhere but the Fifth Circuit where this ruling was, the DOJ section would apply. So under the modification of policy requirement, the driver would have to help the individual if they -- if they needed it in order to get there. The concept is that paratransit is an origin to destination service and if you can't get to your destination from your origin without assistance beyond curb to curb, they would have to provide it, but that doesn't necessarily have to provide it to everyone. And DOT's guidance is clear that it doesn't mean they have to totally change the door to door policy. So it will depend on the individual.
Tajauna: These are two separate questions, but they are on the same topic of service animals. The first one says can the transit require crating of a service animal, and then the second one is more specific to service animals -- it sound like on air planes and it says could you please comment on the issue of the proposed NPRM Part 382, appendix A. concerning the transport of service animals by air. And she has in quotes, what if the service animal is too large to fit under the seat in front of the customer? Declared if no single seat in the cabin will accommodate the animal and passenger without causing an obstruction, you may offer the option of purchasing a second seat traveling on a later flight or having the service animal travel in a cargo hold. Those are your two service animal questions.
Marilyn: In terms of the transit agency requiring the crating of the service animal, and I'm presuming the first one was about a surface transportation, not air. It sounded like that. Do you think that's right?
Tajauna: That's what I get as well.
Marilyn: Transit agencies are required to allow just like every other covered entity under the ADA are required to allow service animals to accompany the individual unless there is a fundamental alteration of the service or a direct threat. There is very few circumstances that the ADA allows a covered entity not to let service animals join the person. So I can't imagine it being legal to require the crating of a service animal. I mean, there may be specifics that it could, but I doubt it. I can't imagine the situation. Usually if there is a legitimate exclusion, they -- you know, you just can't bring your service animal. It's true that DOT gives an example of say an animal barking during a movie. Sometimes the train has movies and perhaps that's an example where a service animal would need to be kept out of that train. A well trained service animal wouldn't do that any way. In terms of the Air Carrier Access Act, I'm not an expert on the NPRM under the Air Carrier Act, but I know that there was a lot of problems with that NPRM and including making someone in some cases buy another seat. DREDF would certainly oppose that. Service animals should be accommodated on the flight in our view should be accommodated on the flight that the individual is on.
Tajauna: Another question that we have is if this policy is passed, will transit drivers also be responsible for carrying items on board for the disabled passenger? For example, several bags of groceries, where will the assistance stop?
Marilyn: Well, for issues about what should be required on paratransit, we generally look to what is required on the bus because paratransit is supposed to be a complement to fixed route service. So we look to the comparable train situation and fixed route -- your bus system probably has a rule about how much groceries an individual can bring on the bus. You know, maybe as much as the bus passenger can carry. Whatever it is, we think it should be the same on paratransit. Sometimes transit agencies have made it more strict and that would, in DREDF's view, be a violation of the ADA. But on the other hand, you know, the limit should probably be equivalent because the service is supposed to be equivalent.
Tajauna: One thing we've seen a lot is people who are deaf and blind not being able to wait at the curb in inclement weather or in high crime areas after dark for paratransit. Because of their in a disability to see and hear they cannot wait at the door or the window and would be able on come out when the van arrives without special notification. Would this be a good example to give of a need for modifications to curb to curb policy?
Marilyn: I think that it would be a very good example. Yes, I think that's the kind of thing that DOT's guidance intends.
Tajauna: Hi, my question is more of when a regular bus system is closing at 8. The paratransit is also closing at 8. Now, in this case, low income people in the disability community and in the normal community is not having access to the city after 8. What can we as people do?
Marilyn: Again, you know, the ADA of course is a civil rights law and that's something we all know, but it's really in transportation that the nature of the ADA as a civil rights law, you know, in the way that that is good and in ways that may be limiting. The character that really comes into full force because paratransit under the ADA is really intended to be a complement to the fixed route service. It unfortunately does not provide people with disabilities everything that we need. So if there is a limitation in your fixed route service, it's legal under the ADA for paratransit to have the same limitation. It's not okay for paratransit to do less and so if your buses or trains all stop at 8:00 p.m, but except for one or two routes that go to 10:00 p.m, then it's not okay for paratransit to stop cold at 8:00 p.m. Paratransit would have to go the same places the fixed route goes until 10:00 p.m. I said ten when I meant eight. The point is, it should be the same. And if it's different on different routes, then paratransit should vary by the area of that route. But if you do have your fixed route service stopping at 8, there is no requirement under the ADA for paratransit to go any longer because it is really just a complement to the fixed route service. Disabled people do need more transportation than the ADA provides and our community needs to find a way to address it in some kind of other way. It's always a bit perhaps difficult or disappointing to be the bearer of bad news and when we do ADA training, sometimes we have to say that the ADA does not cover that. I would love it if it did, but I'm not here really to -- to say what we want the ADA to do or even to dissent, but to explain what it does and it does have that provision which in some people's eyes might be a limitation.
Tajauna: Our paratransit does not service a bedroom community five miles away, but runs an extra two hours on their fixed route service to do so. Are you saying it should service this area and open up for another four hours for paratransit?
Marilyn: No, I'm not. Paratransit service area, under the ADA, can be what it is and it doesn't have to be expanded. The ADA has an exception for paratransit which is sometimes interpreted too broadly, but it says that commuter service does not have to have complementary paratransit and that usually means routes that go out of the city or I should say into the city in the morning and out of the city in the afternoon, use multiride tickets and don't stop repeatedly but go a long distance. You know, something that runs all day isn't a commuter service and should have complementary paratransit. But things that really are commuter services or things that are already demand response do not have to have complementary paratransit.
Tajauna: The next one says what are the proposals for publicly and privately funded vehicles giving equal service for people with disabilities? I mean for example, is a cab company required to run their wheelchair van services the same hours that the regular cab service runs?
Marilyn: It's an interesting question because of course cab companies do not have to provide wheelchair accessible vehicles, but if they do provide them, do they have to run the same hours as everything else? I think some people would interpret this question in different ways. I think some would say no, and some would say yes. You can make an argument either way. I think I would say that they do, yes. If they are providing that service, it should be provided in the same hours and we have, you know, the ADA's equivalency provisions under privately funded transportation. The thing about ADA transportation is that it very much depends on the rules for a particular category and the rules for fixed route and paratransit and demand response do vary a little bit from each other. The rules for private and public vary a little bit. And so sometimes you have to really nail down what is the category before you know the rules. In this case, I would tentatively say that I think it would require.
Tajauna: is it permissible that an assistance dog may be allowed to go off lead and enter the bus ahead if the lift is not big enough for both the wheelchair and the dog?
Marilyn: That seems to me to be the kind of modification of policy the transit agencies really should be doing. Because requiring service animals to be accompanying people with disabilities is a modification of policy to begin with. It's a modification of the no pets policy to allow service animals to ride. And where they can't ride lifts for whatever reason, I think the service animal, particularly one that's behaving in the way that is the high standards set by most trained service animals, it should be fine if the animal moves on ahead briefly and waits for the individual. Again, any animal that will be disruptive probably shouldn't be taken on the vehicle anyway, but the ADA wouldn't proceed tech them this that case. It seems to me that the answer to that would be yes.
Tajauna: What does the ADA say about coordinating transportation services for human services programs for the disabled, elderly, low income and youth? If not addressed, what is the disability community doing to coordinate transportation with programs for other subpopulations? Is it working/feasible? Also does the ADA limit the ability for programs to coordinate?
Marilyn: Well the ADA certainly does not limit coordination. The ADA also does not require coordination of different kinds of programs. And so it's a non-ADA question, but a very good question. There is actually a lot of attention right now on coordination. FTA, along with some other federal agencies, has a national effort called united we ride. Which there is grants now for I think coordination sometimes that can be applied for. You know, it's working better in some areas than others. I think I'm saying this from memory, but I think it's in the Merimac Valley of New York and I'm really quick trying to open my notes on this to find it. You know, to address the question of is it working or not -- yes, Merimac Valley regional Transit Authority -- I said New York and I was wrong, it's Massachusetts -- which is a small system. It has a fixed route fleet of 40 or 50 vehicles. They have a nonfixed route totally integrated service. They have great coordination and it's ADA paratransit and it's also senior service and a fixed route deviation service which are completely coordinated. All systems use the same vehicles. Riders call the same place to arrange rides. All systems have the same dispatchers, the same phone number. They all use the same drivers. The service is really seamless, and they've had a cost savings because they don't have to have separate operating structures. So this is an example of kind of the best model of coordination. So it's working there and other transit agencies could do it.
I know that there is currently a project under the transit cooperative rehab -- TCRT the Transit Cooperative Research Program which is being conducted now. I think it's just getting going which is looking at best practices in the industry in coordination. And when they come to that research, they'll have a document that helps a transit agency know how to do this kind of coordination. It's clearly a great thing to do, not required by the ADA, certainly not prohibited by the ADA. One thing about it though is that when coordinated services is provided, it's important that transit agency still provide people who are due their ADA rights on the ADA service. You can't use coordination to change ADA service away from being what the ADA requires, but with that stipulation, coordination is a good thing. And there should be increasing amounts of assistance in the area of coordination. I think if people look at FTA and search for united we ride, there will be somebody resources they find on coordination and they may also want to check out the TCRT research project on that.
(music)
Beth: There's a lot more to this interview -- this one ran almost 2 hours long. So if you're interested in the Department of Transportation, be sure to visit our website at www.ada-podcast.com and you can get the link so you can listen to the whole webcast. There's also links there to some documents and other resources to help you if you're interested. So until next time, this is Beth Case with the Southwest ADA Center Podcast.
The Southwest ADA Center is a program of Independent Living Research Utilization at TIRR - Memorial Hermann in Houston, Texas, and is funded by the National Institute on Disability and Rehabilitation Research. If you have questions about disability law or would like to request materials or training, please call 1-800-949-4232. The Southwest ADA Center Podcast is protected by the Creative Commons Attribution Non-Commercial No-Derivative-Works 2.5 License. For more information and transcripts, visit www.ada-podcast.com.
(music)
Beth Case: Hello, I'm Beth Case and welcome to the Southwest ADA Center Podcast. In this podcast, we take highlights from the full length webcasts offered by the Southwest ADA Center. As always, if you like the information you hear in this podcast, you can listen to the full webcast by following the link that you can find on our website, www.ada-podcast.com.
Today's show is about the Department of Transportation's proposed changes to the ADA Transportation Regulation. It features Marilyn Golden from the Disability Rights Education and Defense Fund. And she is interviewed by Tajuana Dunning. This show first aired on April 21, 2006.
(music)
Marilyn Golden: The perhaps biggest issue in this proposed rule is that DOT is proposing to add to its regulation a provision requiring ADA transportation providers to make reasonable modifications to policies, practices, and procedures when necessary to avoid discrimination on the basis of disability. Unless the transit agency can show that the modifications would fundamentally alter the nature of the service or activity, or would result in undue financial or administrative burdens, or a direct threat to the health and safety of others.
Now, we already have one example of what it might mean because last fall DOT put out guidance on so-called origin to destination service.Yes, they put out a guidance called "origin to destination service" referring to paratransit. And it stated that an agency providing ADA paratransit under a, quote, curb to curb policy, that is under a basic policy that paratransit drivers will wait at the curb for passengers rather than going to the door to assist them, that policy -- that transit agency still may occasionally need to provide service beyond the curb if necessary to ensure that the individual can reach his or her destination. So for example, this would mean that if a physical barrier, like sidewalk construction or snow prevents a passenger from getting to the curb, the service provider must offer assistance beyond the curb, again, not necessarily to all passengers, but to this particular passenger for whom maintaining the curb to curb policy strictly would deny the ability for them to get to their destination. DOT has made it clear that adding this provision to their regulation would not mean, for example, providing any kind of personal assistance to riders, it would not mean going beyond the door to assist a passenger or take any actions that would present a direct threat to safety, like leaving vehicles unattended for lengthy periods of time. Of course other riders could be in those vehicles, or losing the ability to keep the vehicles under the driver's visual observation. So there are definitely limits on what -- how far this would go.
Moving on, another big topic in this proposed regulation is on commuter and inner city rail platform access.On the commuter innercity rail platform accessibility issue, DOT is requiring -- proposals to shift their requirements but still to require level entry boarding to the train from a fully accessible high platform. And then if necessary with a ramp or bridge plate over any gaps which will make it possible for everyone to board any or I should say every accessible train car. The proposal is trying to avoid the use of mini high platforms to provide disability access, allowing them only as an absolute last resort. They necessitate that the train has to move in small increments to allign its cars one by one with the mini high platform if people who need to board or disembark are on multiple cars, which they often are. This process is also called double stopping. It's very difficult. It's time-consuming and yet it has to be done permanently if mini high platforms are allowed.
At this point, I'd like to stop and take questions on the NPRM if anybody has anything, questions about what I've said or additions or concerns we haven't mentioned. Anything like that. Tajauna, are there any questions?
Tajuana: The first question is would paratransit have to help people down their ramps at the house?
Marilyn: Okay, well, this is a general question on the ADA, which is fine. Or actually the person may mean under the new rule. Not necessarily. They would have -- if the rule is adopted and DREDF would argue that transit agencies are already covered by the same requirement already because it's in the Department of Justice rule, and everywhere but the Fifth Circuit where this ruling was, the DOJ section would apply. So under the modification of policy requirement, the driver would have to help the individual if they -- if they needed it in order to get there. The concept is that paratransit is an origin to destination service and if you can't get to your destination from your origin without assistance beyond curb to curb, they would have to provide it, but that doesn't necessarily have to provide it to everyone. And DOT's guidance is clear that it doesn't mean they have to totally change the door to door policy. So it will depend on the individual.
Tajauna: These are two separate questions, but they are on the same topic of service animals. The first one says can the transit require crating of a service animal, and then the second one is more specific to service animals -- it sound like on air planes and it says could you please comment on the issue of the proposed NPRM Part 382, appendix A. concerning the transport of service animals by air. And she has in quotes, what if the service animal is too large to fit under the seat in front of the customer? Declared if no single seat in the cabin will accommodate the animal and passenger without causing an obstruction, you may offer the option of purchasing a second seat traveling on a later flight or having the service animal travel in a cargo hold. Those are your two service animal questions.
Marilyn: In terms of the transit agency requiring the crating of the service animal, and I'm presuming the first one was about a surface transportation, not air. It sounded like that. Do you think that's right?
Tajauna: That's what I get as well.
Marilyn: Transit agencies are required to allow just like every other covered entity under the ADA are required to allow service animals to accompany the individual unless there is a fundamental alteration of the service or a direct threat. There is very few circumstances that the ADA allows a covered entity not to let service animals join the person. So I can't imagine it being legal to require the crating of a service animal. I mean, there may be specifics that it could, but I doubt it. I can't imagine the situation. Usually if there is a legitimate exclusion, they -- you know, you just can't bring your service animal. It's true that DOT gives an example of say an animal barking during a movie. Sometimes the train has movies and perhaps that's an example where a service animal would need to be kept out of that train. A well trained service animal wouldn't do that any way. In terms of the Air Carrier Access Act, I'm not an expert on the NPRM under the Air Carrier Act, but I know that there was a lot of problems with that NPRM and including making someone in some cases buy another seat. DREDF would certainly oppose that. Service animals should be accommodated on the flight in our view should be accommodated on the flight that the individual is on.
Tajauna: Another question that we have is if this policy is passed, will transit drivers also be responsible for carrying items on board for the disabled passenger? For example, several bags of groceries, where will the assistance stop?
Marilyn: Well, for issues about what should be required on paratransit, we generally look to what is required on the bus because paratransit is supposed to be a complement to fixed route service. So we look to the comparable train situation and fixed route -- your bus system probably has a rule about how much groceries an individual can bring on the bus. You know, maybe as much as the bus passenger can carry. Whatever it is, we think it should be the same on paratransit. Sometimes transit agencies have made it more strict and that would, in DREDF's view, be a violation of the ADA. But on the other hand, you know, the limit should probably be equivalent because the service is supposed to be equivalent.
Tajauna: One thing we've seen a lot is people who are deaf and blind not being able to wait at the curb in inclement weather or in high crime areas after dark for paratransit. Because of their in a disability to see and hear they cannot wait at the door or the window and would be able on come out when the van arrives without special notification. Would this be a good example to give of a need for modifications to curb to curb policy?
Marilyn: I think that it would be a very good example. Yes, I think that's the kind of thing that DOT's guidance intends.
Tajauna: Hi, my question is more of when a regular bus system is closing at 8. The paratransit is also closing at 8. Now, in this case, low income people in the disability community and in the normal community is not having access to the city after 8. What can we as people do?
Marilyn: Again, you know, the ADA of course is a civil rights law and that's something we all know, but it's really in transportation that the nature of the ADA as a civil rights law, you know, in the way that that is good and in ways that may be limiting. The character that really comes into full force because paratransit under the ADA is really intended to be a complement to the fixed route service. It unfortunately does not provide people with disabilities everything that we need. So if there is a limitation in your fixed route service, it's legal under the ADA for paratransit to have the same limitation. It's not okay for paratransit to do less and so if your buses or trains all stop at 8:00 p.m, but except for one or two routes that go to 10:00 p.m, then it's not okay for paratransit to stop cold at 8:00 p.m. Paratransit would have to go the same places the fixed route goes until 10:00 p.m. I said ten when I meant eight. The point is, it should be the same. And if it's different on different routes, then paratransit should vary by the area of that route. But if you do have your fixed route service stopping at 8, there is no requirement under the ADA for paratransit to go any longer because it is really just a complement to the fixed route service. Disabled people do need more transportation than the ADA provides and our community needs to find a way to address it in some kind of other way. It's always a bit perhaps difficult or disappointing to be the bearer of bad news and when we do ADA training, sometimes we have to say that the ADA does not cover that. I would love it if it did, but I'm not here really to -- to say what we want the ADA to do or even to dissent, but to explain what it does and it does have that provision which in some people's eyes might be a limitation.
Tajauna: Our paratransit does not service a bedroom community five miles away, but runs an extra two hours on their fixed route service to do so. Are you saying it should service this area and open up for another four hours for paratransit?
Marilyn: No, I'm not. Paratransit service area, under the ADA, can be what it is and it doesn't have to be expanded. The ADA has an exception for paratransit which is sometimes interpreted too broadly, but it says that commuter service does not have to have complementary paratransit and that usually means routes that go out of the city or I should say into the city in the morning and out of the city in the afternoon, use multiride tickets and don't stop repeatedly but go a long distance. You know, something that runs all day isn't a commuter service and should have complementary paratransit. But things that really are commuter services or things that are already demand response do not have to have complementary paratransit.
Tajauna: The next one says what are the proposals for publicly and privately funded vehicles giving equal service for people with disabilities? I mean for example, is a cab company required to run their wheelchair van services the same hours that the regular cab service runs?
Marilyn: It's an interesting question because of course cab companies do not have to provide wheelchair accessible vehicles, but if they do provide them, do they have to run the same hours as everything else? I think some people would interpret this question in different ways. I think some would say no, and some would say yes. You can make an argument either way. I think I would say that they do, yes. If they are providing that service, it should be provided in the same hours and we have, you know, the ADA's equivalency provisions under privately funded transportation. The thing about ADA transportation is that it very much depends on the rules for a particular category and the rules for fixed route and paratransit and demand response do vary a little bit from each other. The rules for private and public vary a little bit. And so sometimes you have to really nail down what is the category before you know the rules. In this case, I would tentatively say that I think it would require.
Tajauna: is it permissible that an assistance dog may be allowed to go off lead and enter the bus ahead if the lift is not big enough for both the wheelchair and the dog?
Marilyn: That seems to me to be the kind of modification of policy the transit agencies really should be doing. Because requiring service animals to be accompanying people with disabilities is a modification of policy to begin with. It's a modification of the no pets policy to allow service animals to ride. And where they can't ride lifts for whatever reason, I think the service animal, particularly one that's behaving in the way that is the high standards set by most trained service animals, it should be fine if the animal moves on ahead briefly and waits for the individual. Again, any animal that will be disruptive probably shouldn't be taken on the vehicle anyway, but the ADA wouldn't proceed tech them this that case. It seems to me that the answer to that would be yes.
Tajauna: What does the ADA say about coordinating transportation services for human services programs for the disabled, elderly, low income and youth? If not addressed, what is the disability community doing to coordinate transportation with programs for other subpopulations? Is it working/feasible? Also does the ADA limit the ability for programs to coordinate?
Marilyn: Well the ADA certainly does not limit coordination. The ADA also does not require coordination of different kinds of programs. And so it's a non-ADA question, but a very good question. There is actually a lot of attention right now on coordination. FTA, along with some other federal agencies, has a national effort called united we ride. Which there is grants now for I think coordination sometimes that can be applied for. You know, it's working better in some areas than others. I think I'm saying this from memory, but I think it's in the Merimac Valley of New York and I'm really quick trying to open my notes on this to find it. You know, to address the question of is it working or not -- yes, Merimac Valley regional Transit Authority -- I said New York and I was wrong, it's Massachusetts -- which is a small system. It has a fixed route fleet of 40 or 50 vehicles. They have a nonfixed route totally integrated service. They have great coordination and it's ADA paratransit and it's also senior service and a fixed route deviation service which are completely coordinated. All systems use the same vehicles. Riders call the same place to arrange rides. All systems have the same dispatchers, the same phone number. They all use the same drivers. The service is really seamless, and they've had a cost savings because they don't have to have separate operating structures. So this is an example of kind of the best model of coordination. So it's working there and other transit agencies could do it.
I know that there is currently a project under the transit cooperative rehab -- TCRT the Transit Cooperative Research Program which is being conducted now. I think it's just getting going which is looking at best practices in the industry in coordination. And when they come to that research, they'll have a document that helps a transit agency know how to do this kind of coordination. It's clearly a great thing to do, not required by the ADA, certainly not prohibited by the ADA. One thing about it though is that when coordinated services is provided, it's important that transit agency still provide people who are due their ADA rights on the ADA service. You can't use coordination to change ADA service away from being what the ADA requires, but with that stipulation, coordination is a good thing. And there should be increasing amounts of assistance in the area of coordination. I think if people look at FTA and search for united we ride, there will be somebody resources they find on coordination and they may also want to check out the TCRT research project on that.
(music)
Beth: There's a lot more to this interview -- this one ran almost 2 hours long. So if you're interested in the Department of Transportation, be sure to visit our website at www.ada-podcast.com and you can get the link so you can listen to the whole webcast. There's also links there to some documents and other resources to help you if you're interested. So until next time, this is Beth Case with the Southwest ADA Center Podcast.
The Southwest ADA Center is a program of Independent Living Research Utilization at TIRR - Memorial Hermann in Houston, Texas, and is funded by the National Institute on Disability and Rehabilitation Research. If you have questions about disability law or would like to request materials or training, please call 1-800-949-4232. The Southwest ADA Center Podcast is protected by the Creative Commons Attribution Non-Commercial No-Derivative-Works 2.5 License. For more information and transcripts, visit www.ada-podcast.com.