Accessibility Documents for Comment

Comments Due on July 15

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Comment

Document(s) to be Balloted

Title

Modified Date

Size (Kb)

Posted Comments

Patrisha Piras — 7/15/2009 11:01:03 PM
Section	Hold times
Original text	4.2 Measuring by Hourly Average of Reservation Hold Times This should be done only if a transit agency cannot measure by Maximum Hold Time, due to technological limitations.
Proposed text	Why? Please explain reasons. And if the sentence is retained, the comma before "due to" is incorrect.
Patrisha Piras — 7/15/2009 10:59:42 PM
Section	Hold times, pages aren't numbered!
Original text	Measuring by maximum hold time is the best method for measuring ADA paratransit reservation telephone hold times.
Proposed text	What is the basis for this statement? What research or evidence documents the statement? Other parts of Section 4 are far too absolute -- the section is labeled "Standards" and states that "And if a transit agency does not have ACD technology, it MUST monitor hold times in other ways" -- too extreme.
Patrisha Piras — 7/15/2009 10:55:03 PM
Section	Call Out Stops, p 14
Original text	4.2 Other passenger information technology available
Proposed text	This should recognize that much of this part is likely to change before the next review of this standard, five years from now.
Patrisha Piras — 7/15/2009 10:53:30 PM
Section	Call Out Stops, p 11
Original text	Disciplinary measures should be on par with those for other safety violations.
Proposed text	ADA is a civil rights statute, not safety as Mr Ashby so often tells us. And "safety" is too broad a range -- is this on a par with driers not wearing seat belt, or like texting which is now an instantly terminable offense at some systems?
Patrisha Piras — 7/15/2009 10:50:40 PM
Section	Call Out Stops, p4
Original text	2. Training: Create a training program for all agency personnel regarding the requirements of the stop announcement and route identification program.
Proposed text	2. Training: Create a training program for all RELEVANT or DESIGNATED agency personnel regarding the requirements of the stop announcement and route identification program.
Patrisha Piras — 7/15/2009 10:49:40 PM
Section	Call Out Stops, p3
Original text	2.1.13 orientation announcements: Announcements made at intervals along a route sufficient to permit passengers to be oriented to their location. Examples include stops after routes turn from one street to another and at a time or distance appropriate for the characteristics or geography of the route segment between announcements.
Proposed text	2.1.13 orientation announcements: Announcements made at intervals along a route sufficient to permit passengers to be oriented to their location. Examples include stops after routes turn from one street to another and at a time or distance appropriate for the characteristics or geography of the route segment between OTHER announcements. (or end sentence at route segment)
Patrisha Piras — 7/15/2009 10:47:45 PM
Section	Call Out Stops
Original text	Page 2 talks about going beyond ADA regs, but with the exception of incentives, almost everything in this document is "mere" compliance. There's some good stuff here, but it does not go beyond ADA.
Proposed text	Also, "public involvement" should include people with cognitive as well as vision disabilities.
Patrisha Piras — 7/15/2009 10:43:00 PM
Section	Where's My Ride, page 2, Definitions
Original text	Definition of paratransit: 3.1.3 paratransit: An alternative mode of flexible passenger transportation that does not follow fixed routes or schedules
Proposed text	This absolutely has to be changed, due to disputes with IRS over federal fuel excise tax. Language about "does not follow fixed routes or schedules" is fatal. Use definition in ADA regs, or simply "demand-responsive transportation"
— 7/15/2009 10:32:34 PM
Section	all 3 documents, "participants"
Original text	Call Out Stops has affiliations, other two do not
Proposed text	With affiliations is more informative and preferable
— 7/15/2009 10:30:38 PM
Section	all 3 documents, "Introduction"
Original text	states that "This is not a part" of the document -- so, what's it's purpose and/or relevance?
Proposed text	In "Hold Time", statement that customers "need to go through a call center" does not make sense and has no legal relevance. This may be a practice but is not "required, " and lots of places do not refer to this function as a "call center" (which is never defined in the document). What are "organizations that influence complementary paratransit services"? P&P Committee is mis-named in Hold Times document. In Call Out Stops, reference to "transportation provisions enacted as part of the ADA -- just call them regulations!
— 7/15/2009 10:18:41 PM
Section	hold times, cover page
Original text	Document is labeled "Recommended Practice," but abstract describes it as "minimum requirements."
Proposed text	Change "requirements" to something like practices, procedures, or protocols. These are not "requirements." Also, move phrase about that should be implemented by Transit Agencies" after the new word for "requirement." Agencies are asked to implement the activities rather than the Call Centers.
— 7/15/2009 10:10:21 PM
Section	all 3 documents, cover page
Original text	significant inconsistency in "approved" or "authorized" and by whom. Hold time documents references "technical oversight review" which has been eliminated
Proposed text	needs editing, consistency, and accuracy
Gretchen Weber — 7/15/2009 9:41:58 PM
Section	# 3- R P for a FRSA/RI Program-3.5-Equipment Maintenance- (Page 12)
Original text	Larger systems should designate and train mechanics specifically to handle communications components, rather than relying on outside maintenance contractors.
Proposed text	Systems should ensure that mechanics are trained and qualified to handle communications components whether the work is performed by employees or outside maintenance contractors. (Comment on text)- Again, the standards should not dictate the process, but rather the outcome which in this case is competently maintaining and promptly repairing the communications equipment. Once we know the performance standard, Community Transit can figure it out. Large systems do habitually contract out maintenance work and are responsible for ensuring standards are met.
Gretchen Weber — 7/15/2009 9:38:56 PM
Section	# 3- R P for a FRSA/RI Program-3.4.2- Discipline- (Page 11)
Original text	Disciplinary measures should be on par with those for other safety violations.
Proposed text	(Comment on text)- In states that are not “Right to Work”, discipline must be bargained upon in good faith with the union. It may not be possible to enforce discipline at this level.
Gretchen Weber — 7/15/2009 9:37:52 PM
Section	# 3- R P for a FRSA/RI Program-3.4-Incentives and Discipline- (Page 11)
Original text	The importance of compliance should be considered on par with maintaining passenger and driver safety and, where appropriate, retraining or additional monitoring should be provided and proper disciplinary action be taken.
Proposed text	Retraining or additional monitoring should also be provided and/or proper disciplinary action should be taken as warranted.
Gretchen Weber — 7/15/2009 9:36:40 PM
Section	# 3- R P for a FRSA/RI Program- 3.4-Incentives and Discipline- (Page 10)
Original text	Management has a responsibility to promptly alert operators and other personnel directly or indirectly involved with the program when there has been a failure to comply with the agency’s fixed route stop announcement and route identification program.
Proposed text	Management has a responsibility to alert operators and other personnel directly or indirectly involved with the program when there has been a failure to comply with the agency’s fixed route stop announcement and route identification program as soon as reasonably possible.
Gretchen Weber — 7/15/2009 9:35:13 PM
Section	# 3- R P for a FRSA/RI Program- 3.2- Training- (Page 7)
Original text	It is recommended that all staff, including senior management and local union leadership, attend training to include an explanation of required ADA service elements, including stop announcements and route identification.
Proposed text	It is recommended that appropriate staff, including senior management and local union leadership, attend training to include an explanation of required ADA service elements, including stop announcements and route identification.
Gretchen Weber — 7/15/2009 9:33:06 PM
Section	# 3- R P for a FRSA/RI Program- 3.2- Training- (Page 7)
Original text	Transit agencies should note the importance of community involvement and compensate the individuals similar to other outside consultants and expert whenever possible.
Proposed text	(Comment on text)- Community involvement is very different from hiring professional consultants. These two concepts should not be linked. Community Transit does not pay community members for participating in our public input processes. With regard to hiring consultants, Community Transit follows a competitive procurement process which is based on professional knowledge and experience. This process would not be based on an individual's personal disability status. This is another example of where the FRSA/RI standards should be about outcomes, not methodology of who we accomplish them.
Gretchen Weber — 7/15/2009 9:29:10 PM
Section	# 3- R P for a FRSA/RI Program- 3.1.1- Stop Announcements (Page 5)
Original text	Determine how destinations landmarks and other information are to be announced (e.g., “Main at Third” or “Main at Third, City Hall”) in consultation with drivers and members of the disability community to ensure that the announcements provide effective audible cues to the people who are blind or who have low vision as well as cognitive and other disabilities.
Proposed text	(Comment on text)- We support this as long as the term "consultation" is intended to mean receiving and considering input.
Gretchen Weber — 7/15/2009 9:27:12 PM
Section	# 3- R P for a FRSA/RI Program- 3.1-Program Development- (Page 5)
Original text	Procedures should provide for an opportunity for, and consideration of, public participation and community input in the development of stop announcement and route identification program elements.
Proposed text	Procedures should provide for an opportunity for, and consideration of, public input in the development of stop announcement and route identification program elements.
Gretchen Weber — 7/15/2009 9:25:33 PM
Section	# 3- R P for a FRSA/RI Program- 3.1-Program Development- (Page 5)
Original text	Transit agencies should adopt formal agency policies and procedures to guide the development and implementation of the stop announcement and route identification program.
Proposed text	Transit agencies should adopt agency policies and procedures to guide the development and implementation of the stop announcement and route identification program.
Gretchen Weber — 7/15/2009 9:24:12 PM
Section	# 3- R P for a FRSA/RI Program- 3.-Program Elements- (Page 4)
Original text	Training: Create a training program for all agency personnel regarding the requirements of the stop announcement and route identification program.
Proposed text	Training: Create a training program for appropriate agency personnel regarding the requirements of the stop announcement and route identification program.
Gretchen Weber — 7/15/2009 9:22:57 PM
Section	# 3- R P for a FRSA/RI Program- 3.-Program Elements- (Page 4)
Original text	Program development: Adopt formal agency policies, procedure and information to guide the development and implementation of the program.
Proposed text	Program development: Adopt agency policies, procedures and information to guide the development and implementation of the program.
Gretchen Weber — 7/15/2009 9:21:19 PM
Section	# 3- R P for a FRSA/RI Program- 1.2- Purpose (page 2)
Original text	Public involvement should include consultation with drivers and members of the community to ensure that the announcements provide effective audible cues to people who are blind or who have low vision.
Proposed text	(Comment on text)- We support this as long as the term "consultation" is intended to mean receiving and considering input.
Gretchen Weber — 7/15/2009 9:19:20 PM
Section	# 3- R P for a FRSA/RI Program- 1.2-Purpose (page 2)
Original text	The development of the agency’s stop announcement and route identification program should include an extensive public involvement process… The implementation and operation of the program also should include extensive public outreach and awareness elements, as well as a travel training program that includes instruction on how the stop announcement and route identification program functions.
Proposed text	The development of the agency’s stop announcement and route identification program should include an appropriate public involvement process… The implementation and operation of the program also should include appropriate public outreach and awareness elements, as well as a travel training program that includes instruction on how the stop announcement and route identification program functions.
Gretchen Weber — 7/15/2009 9:18:04 PM
Section	# 3- R P for a FRSA/RI Program- 1.2- Purpose (Page 2)
Original text	In cooperation with local residents and community groups, With input from the community, each transit agency should develop written policies identifying what elements they are adopting above the ADA minimum to be the locally accepted stop announcement and route identification program.
Proposed text	With input from the community, each transit agency should develop written policies identifying what elements they are adopting to be the locally accepted stop announcement and route identification program.
Gretchen Weber — 7/15/2009 9:16:54 PM
Section	# 3- R P for a FRSA/RI Program
Original text	N/A
Proposed text	(Comment on entire document)-If a transit company is in compliance with the varied elements of a major program, this should qualify as meeting the intent of a formal written policy and thus be enough to meet standards. If all future Recommended Practices from APTA specified a written company-wide program policy, this would create a huge bureaucratic expectation that is not required to accomplish the goals.
Gretchen Weber — 7/15/2009 9:15:59 PM
Section	# 3- R P for a FRSA/RI Program
Original text	N/A
Proposed text	(Comment on entire document)-Community Transit would like for the standards to be based on outcomes, not about methodology used to get there.
— 7/15/2009 8:29:09 PM
Section	3.3.1 RFP 3 FTA OCR
Original text	– Specific criteria for monitoring the performance of equipment with respect to equipment failure and equipment maintenance (including public address systems, voice annunciation systems and signage).
Proposed text	FTA OCR Comment on this text Could some specific criteria be provided (or referenced)?
— 7/15/2009 8:23:15 PM
Section	3.3.1 RFP #3 p. 12 Monitoring program overview
Original text	Each transit agency should develop written policies and procedures for an ongoing program to monitor operators’ adherence to both stop announcement and route identification requirements established by the ADA regulations, as well as any specific local requirements. The monitoring program should be developed in cooperation with the local union(s) and incorporated into the rulebook(s) and/or other documents as applicable. It is imperative that operators, monitors and supervisors use the same list of required on-board stop announcements and external route identification lists.
Proposed text	Each transit agency should develop written policies and procedures for an ongoing program to monitor operators’ adherence to both stop announcement and route identification requirements established by the ADA regulations, as well as any specific local requirements. The monitoring program should be developed in cooperation with the local community, people with disabilities, disability organizations and the local union(s) and incorporated into the rulebook(s) and/or other documents as applicable. It is imperative that operators, monitors and supervisors use the same list of required on-board stop announcements and external route identification lists.
— 7/15/2009 8:17:20 PM
Section	5.3 Emerging passenger information technology RFP #3
Original text	While readily available in rail applications, technology to provide audio announcements at bus stops, shelters and stations/terminals is currently in development and testing. The equipment will provide audible announcements of bus arrivals and departures (the same information being displayed on variable message signs).
Proposed text	FTA OCR note on this text: FTA has noted the promising practice, used by Denver RTD and other transit providers, of posting notices in all buses stating the requirement to announce stops / routes and providing a contact information for reporting operators that fail to make the announcements. Has the committee considered endorsing this low-cost and apparently effective practice? [2] Has the committee taken a position on the practice of announcing multiple stops simultaneously (“now approaching A St., followed by B St.”). [3] Has the committee considered saying that there is a point where too many stops are being announced, or is the consensus that more is always better. [4] Has the committee considered suggesting that operators be required to (and able to) deactivate automated announcement systems that are malfunctioning (announcing the wrong stops or routes)?
— 7/15/2009 8:12:41 PM
Section	p.17 RFP 3 FTA OCR
Original text	Route identification announcements are to be made by the vehicle operator if the automated system malfunctions, is inoperable, or is not present on a particular vehicle.
Proposed text	Route identification announcements are to be made by the vehicle operator if the automated system malfunctions, is inoperable, or is not present on a particular vehicle. The operator should announce the route and the destination; so that the customer with a disability can determine weather he is on the correct side of the street.
— 7/15/2009 8:10:49 PM
Section	4.1 RFP # 3 FTA OCR
Original text	A semiautomatic stop announcement system requires that an operator activate the announcements by pressing a button as the vehicle approaches a stop.
Proposed text	FTA OCR comment on this text: We have never seen this type of system. Are there examples of transit providers that actually perform announcements with this kind of system? S
— 7/15/2009 8:08:46 PM
Section	4.1 Automated stop announcement systems RFP #3 FTA OCR
Original text	An internal sign that displays coordinating text for the next stop and other audio announcements can be added to the automated stop announcement system. The sign should be a light-emitting type that does not depend on ambient lighting, current technology as of the publication of this recommended practice warrants a minimum of 16 characters per line with bright yellow against a black or dark gray background. Light-emitting diode (LED) signs are the most common type used on board vehicles; however, liquid crystal display (LCD) signs and monitors also can be used to display the text.
Proposed text	An internal sign that displays coordinating text for the next stop and other audio announcements can be added to the automated stop announcement system. The sign should be a light-emitting type that does not depend on ambient lighting, current technology as of the publication of this recommended practice warrants a minimum of 16 characters per line no smaller than 27 in. × 2⅛ in. × 4⅛ in. (single line) or 6⅛ in. (double line). with bright yellow against a black or dark gray background..Light-emitting diode (LED) signs are the most common type used on board vehicles; however, liquid crystal display (LCD) signs and monitors also can be used to display the text.
— 7/15/2009 8:06:28 PM
Section	4.1 page 15 FTA OCR 4.1
Original text	4.1 Automated stop announcement systems
Proposed text	4.1 Automated stop and route announcement systems
— 7/15/2009 8:04:43 PM
Section	3.5 Equipment maintenance RFP #3 page 15 FTA OCR
Original text	Vehicle operators depend on having equipment that is in good condition and in proper working order so that they may make audible and clear announcements, whether using a public address or automated system. Maintaining and promptly repairing this communications equipment is an important element of any successful announcement program. Specifically, DOT ADA regulation 49 CFR § 37.161 requires that:
Proposed text	Vehicle operators depend on having equipment that is in good condition and in proper working order so that they may make audible and clear announcements, whether using a public address or automated system. Maintaining, regularly inspecting, and promptly repairing this communications equipment is an important element of any successful announcement program. Specifically, DOT ADA regulation 49 CFR § 37.161 requires that:
— 7/15/2009 8:02:26 PM
Section	3.4.2 Discipline RFP #3 FTA OCR
Original text	3.4.2 Discipline If an employee does not comply with the stop announcement and route identification program requirements, then the agency’s disciplinary process should be used. Disciplinary measures should be on par with those for other safety violations. Willful disregard for company policies — such as tampering with equipment or deliberately calling out the wrong information — should be elevated to the highest level of discipline.
Proposed text	If an employee does not comply with the stop announcement and route identification program requirements, then the agency’s disciplinary process should be used. Disciplinary measures should be on par with those for other safety violations. Willful disregard for company policies — such as tampering with equipment or deliberately calling out the wrong information or intentionally disabling automated announcement or PA system equipment (except in cases of malfunction) — should be elevated to the highest level of discipline.
— 7/15/2009 7:59:48 PM
Section	p.15 RFP # 3 FTA OCR
Original text	Investigation, discipline and grievance protocols should be applied consistently and equitably, The importance of compliance should be considered on par with maintaining passenger and driver safety
Proposed text	FTA OCR notes on these comments. Safeguards against overly frequent monitoring are problematic because they give rise to situations where operators who are known to be performing announcements poorly escape discipline / training because they argue that they are being subjected to too much scrutiny. Although equitable treatment of operators is a legitimate concern, in general, here there is a conflict between the concern for equity and ensuring full rights of riders with disabilities. Since the focus of this effort is best practices in compliance, rather than in workforce management, we would suggest deleting the reference to equitable treatment of operators. In addition, it is important to engage in dialogue with the union. Unions need to understand that if the drivers are protected unilaterally in cases of non-compliance, then ultimately the transit system will be held responsible.
— 7/15/2009 7:52:02 PM
Section	page 14 RFP #3
Original text	– Factors to include: - clarity - sound level - visibility (for signage) - conformance with required information to be announced - responsiveness to passenger requests for stop/route identification - operator familiarity with equipment use - working condition of equipment (e.g., PA, annunciators, signage, speakers) – Reporting: - standard operating procedures for monitoring and documentation - analysis of trends to trigger possible corrective actions - comparison of rates of compliance when the annunciator is used vs. when operator announcements are made using the PA system
Proposed text	– Factors to include: - clarity - sound level - visibility (for signage) - conformance with required information to be announced FTA note about required information:Does this mean the information required by DOT or the information required by the transit provider? In any case, references to discussion of DOT and transit provider required information would be helpful here - responsiveness to passenger requests for stop/route identification - operator familiarity with equipment use - working condition of equipment (e.g., PA, annunciators, signage, speakers) – Reporting: - standard operating procedures for monitoring and documentation - analysis of trends to trigger possible corrective actions - comparison of rates of compliance when the annunciator is used vs. when operator announcements are made using the PA system with special attention to rates of voice announcement performance on vehicles where the automated announcement or PA systems have failed.
— 7/15/2009 7:48:16 PM
Section	Methods of monitoring page 13 RFP #3 FTA OCR:
Original text	- transit agency observation (e.g., supervisory ride checks, management/ administrative staff ride reports)
Proposed text	- transit agency observation (e.g., supervisory ride checks, management/ administrative staff ride reports, staff during their morning and evening commutes)
— 7/15/2009 7:45:24 PM
Section	3.3.2 Monitoring program elements RFP #3 FTA OCR page 13
Original text	- coverage of all routes and operators on a periodic basis
Proposed text	FTA OCR note: This is the type of information that should not be made public because it risks alerting operators of when they are less likely to be monitored
— 7/15/2009 7:43:09 PM
Section	3.3.1 RFP #3 OCR Monitoring program overview
Original text	Each transit agency should develop written policies and procedures for an ongoing program to monitor operators’ adherence to both stop announcement and route identification requirements established by the ADA regulations, as well as any specific local requirements. The monitoring program should be developed in cooperation with the local union(s) and incorporated into the rulebook(s) and/or other documents as applicable. It is imperative that operators, monitors and supervisors use the same list of required on-board stop announcements and external route identification lists. At a minimum, the monitoring program should include the following: – A clear definition of the goals of the monitoring program. – A description of the frequency, sample size, type and method of selecting observations. – A description of how the monitoring will be done.
Proposed text	Each transit agency should develop written policies and procedures for an ongoing program to monitor operators’ adherence to both stop announcement and route identification requirements established by the ADA regulations, as well as any specific local requirements. The monitoring program should be developed in cooperation with thethe local community, people with disabilities and the local union(s) and incorporated into the rulebook(s) and/or other documents as applicable. It is imperative that operators, monitors and supervisors use the same list of required on-board stop announcements and external route identification lists. At a minimum, the monitoring program should include the following: – A clear definition of the goals of the monitoring program. – A description of the frequency, sample size, type and method of selecting observations. – A description of how the monitoring could be done.
— 7/15/2009 7:39:51 PM
Section	RFP #3 p. 11 3 2.2 Operator training FTA OCR
Original text	– Use of a current manual stop list consistent with any automated list of stop announcements. – Parameters of the monitoring program. – Incentive programs and disciplinary actions for noncompliance.
Proposed text	– Use of a current operator stop list consistent with any automated list of stop announcements. – Parameters of the monitoring program. FTA OCR note: – I’t’s not clear what parameters means.. It may not be beneficial for operators to know when and how they will be evaluated – if an operator know that they will be assessed once per year, they could infer that they are unlikely to be monitored after a certain point in time. It is preferable for the operators to know that they COULD be monitored (ie they could be told “you may be monitored by secret shoppers, management, riders, video, etc. at any point in time”), but not necessarily the specifics for how they will actually be monitored or the frequency of the monitoring. – Incentive programs and disciplinary actions for noncompliance.(verbal warning, written warning, retraining, suspension, termination)
— 7/15/2009 7:34:09 PM
Section	3.2.2 RFP 3 3.2.1 Agency wide training
Original text	– An understanding as to why stop announcements and route identification are important.
Proposed text	An understanding as to why stop announcements and route identification are important. – An understanding as to why stop announcements and route identification are important. Failure to make stop and route announcements leads to increased reliance on paratransit which impacts the system’s overall costs. Compliance with the ADA is required as a condition of eligibility for receipt of Federal funding that supports the system. People with disabilities who are discriminated against may file lawsuits over failure to comply.
— 7/15/2009 7:30:49 PM
Section	3.1.3 RFP 3 FTA OCR
Original text	– Provide for upgrading and maintaining of stop announcement and route identification efforts as needed (moving from manual to automated systems, improving public address equipment and signage, etc.).
Proposed text	– Provide for upgrading and maintaining of stop announcement and route identification efforts as needed (moving from operator to automated systems, improving public address equipment and signage, etc.).
— 7/15/2009 7:29:18 PM
Section	3.1.2 Route identification
Original text	– If used, determine policies and procedures for optional route identification assistive devices or technologies (wayside announcements, bus hailing kit, etc.). Wayside announcements would be required if a bus is making a stop at a transit center served by multiple routes.
Proposed text	- If used, determine policies and procedures for optional route identification assistive devices or technologies (wayside announcements, bus hailing kit, etc.). Wayside announcements would be required if a bus is making a stop at a transit center served by multiple routes. In flag stop systems or other systems for patrons at stops / stations to identify their desired routes to operators, vehicles should be stopped at every stop / station where people are waiting. Operators should come to a complete stop at the curb, open the door, and make a route announcement.
— 7/15/2009 7:25:46 PM
Section	RFP #3 p.10 FTA OCR
Original text	– Establish protocols for avoiding unnecessary or unrelated announcement information (e.g., “Welcome aboard” or “Have a nice day”).
Proposed text	– Establish protocols for minimizing unnecessary or unrelated announcement information (e.g., “Welcome aboard” or “Have a nice day”). If possible, a more specific description of the type of other announcements to be avoided would be preferable. Many transit providers will justifiably consider some of their “unrelated” announcements to be very important and balk at the suggestion that they should be minimized, particularly security announcements. FTA also considers some unrelated announcements, such as announcements of elevator outages, to be vital and required. Also, no admonishment to reduce unnecessary announcements should discourage translations into alternate languages, which in many cases are required under Title VI. –
— 7/15/2009 7:24:02 PM
Section	RFP3 3.1.1.1 - Stop announcements
Original text	- making manual announcements when the automated system fails Establish policies/procedures for optional descriptive information,
Proposed text	- making operator announcements when the automated system fails. – Establish policies/procedures for optional descriptive information, such as: - transferring route numbers and As described on page 4 announcing transferring route numbers is a critical component of announcing transfer points and is required by the ADA
— 7/15/2009 7:21:11 PM
Section	RFP #3 3.1.1 Stop annoucements
Original text	- other stops for orientation, such as after turns or at intervals of a predetermined distance or time.
Proposed text	where no other criteria for making announcement exists, for effective orientation, announcements should be made every one to two minutes. Stop announcements should be made more frequently on a circuitous route for effective orientation. In addition, in settings where there are long segments of the route where no other stop announcement criteria exists, (including where closed door service exists, or service runs along a limited access road, announcements should be made prior to the beginning and end of those stretches.
— 7/15/2009 7:17:24 PM
Section	3.1.1.1 stop annpuncements
Original text	- lead time/distance for making announcements following stop lists;
Proposed text	announcement should be initiated at least six seconds before reaching the stop.
— 7/15/2009 7:06:32 PM
Section	3.1.1 page 9 RFP 3
Original text	Announcements for a particular stop should always be consistent. – Ensure that manual and automated stop lists are coordinated. – Establish operating/rulebook procedures for performing manual announcements,
Proposed text	Announcements for a particular stop should always be consistent, whether made by the automated system or the vehicle operator. – Ensure that operator and automated stop lists are coordinated. – Establish operating/rulebook procedures for performing operator announcements
— 7/15/2009 7:03:16 PM
Section	3.1.1 Stop announcements page 9 FRP#3 FTA OCR
Original text	- other stops for orientation, such as after turns or at intervals of a predetermined distance or time.
Proposed text	Based on our experience with compliance revies, FTA has found in In general, announcements made at intervals of two minutes or less, at lower speeds, should be sufficient to orient passengers to where they are on their route. Announcements made at intervals of five minutes or more are likely to be insufficient. Assuming that a bus travels a mile in six minutes, if stops are announced only six minutes and a passenger's stop is missed, the passenger will have to walk back a mile, which is unreasonable. If multiple turns are made within a block of each other, stops immediately following the last of the multiple turns. In addition, stops at intervals of more than a half mile from the previously announced stop.
— 7/15/2009 6:51:46 PM
Section	3.1 3.1 Program development RFP #3 p.8
Original text	Transit agencies should adopt formal agency policies and procedures to guide the development and implementation of the stop announcement and route identification program. The program should include parameters for what information to include in stop and route identification announcements. Exact program parameters will depend on the method(s) used by transit agencies, whether automated or manual. If manual announcements are made, a good quality public address system that allows for clear, audible announcements to be heard throughout the vehicle is critical to the success of the program and compliance with the ADA regulatory requirements.
Proposed text	Transit agencies should adopt formal agency policies and procedures to guide the development and implementation of the stop announcement and route identification program. The program should include parameters for what information to include in stop and route identification announcements. Exact program parameters will depend on the method(s) used by transit agencies, whether automated or made by the operator Regardless of the general announcement method used, an agency needs to have a good PA system because the automated systems might fail A good quality public address system that allows for clear, audible announcements to be heard throughout the vehicle is critical to the success of the program and compliance with the ADA regulatory requirements.
— 7/15/2009 6:48:49 PM
Section	2.1.11 RFP#3 page 7 FTA OCR
Original text	2.1.11 manual announcement: A voice announcement made by an operator, whether or not it is amplified, using a PA system.
Proposed text	2.1.11 operator announcement: A voice announcement made by an operator, whether or not it is amplified, using a PA system.
— 7/15/2009 6:46:04 PM
Section	RFP #3 Overview p.5 FTA OCR
Original text	– To ensure consistency between information provided by manual and automated announcements, when both are employed by the transit agency’s stop announcement and route identification program.
Proposed text	– To ensure consistency between information provided by operator and automated announcements, as both are part of the transit agency’s stop announcement and route identification program. –
— 7/15/2009 6:46:00 PM
Section	RFP #3 Overview p.5 FTA OCR
Original text	– To ensure consistency between information provided by manual and automated announcements, when both are employed by the transit agency’s stop announcement and route identification program.
Proposed text	– To ensure consistency between information provided by operator and automated announcements, as both are part of the transit agency’s stop announcement and route identification program. –
— 7/15/2009 6:44:12 PM
Section	Where's My Ride - General
Original text	(Additional proposed text)
Proposed text	We recommend adding a “best practice” that call agents be able to respond to verbal abuse from passengers or other callers using a simple three step process. If the caller is verbally abusive or using offensive language, the agent should warn the caller to stop. If the caller persists, the agent should state that s/he is ending the call and should hang up. If a caller consistently uses abusive or offensive language, a supervisor should contact the caller and counsel him/her not to do so. Further action may be taken consistent with the agency’s policies on inappropriate behavior.
— 7/15/2009 6:43:39 PM
Section	RFP #3 Abstract
Original text	minimum criteria
Proposed text	policies and practices
— 7/15/2009 6:43:11 PM
Section	Where's My Ride -Section 6.1
Original text	– Offer a variety of methods for “Where’s my ride?” inquiries:
Proposed text	– Offer the method or methods for “Where’s my ride?” inquiries that work best for the customers and the transit agency. Possible methods include:
— 7/15/2009 6:42:07 PM
Section	Where's My Ride-Section 5
Original text	Rapid resolution of “Where’s my ride?” calls is a priority. Speed of resolution is measured by total call time, since the calls often involve either the use of personal cell phone minutes or tying up a business phone in a reception area.
Proposed text	Rapid resolution of “Where’s my ride?” calls is a priority. Speed of resolution is measured by total call time.
— 7/15/2009 6:15:42 PM
Section	Page 13 Section 8 RFP #1
Original text	8. Performance Monitoring The transportation provisions of the Americans with Disabilities Act indicate that paratransit capacity constraints are not permitted. A capacity constraint is defined as operational pattern or practice that significantly limits the availability of service to ADA paratransit eligible persons. Therefore, the inability of a customer to access the phone system would be viewed as a capacity constraint. It is recommended to use the following practices for performance monitoring.
Proposed text	The transportation provisions of the Americans with Disabilities Act prohibit capacity constraints for ADA paratransit. A capacity constraint is defined as operational pattern or practice that significantly limits the availability of service to ADA paratransit eligible persons. Therefore, the inability of a customer to access the phone system would be viewed as a capacity constraint. It is recommended to use the following practices for performance monitoring.
— 7/15/2009 6:10:14 PM
Section	Page 13 Section 7 Training
Original text	The agency should include in its rider orientation materials, in-person orientation sessions, and/or on-hold messages information on reservation-making protocols.
Proposed text	The agency should include in its rider orientation materials, in-person orientation sessions, and/or on-hold messages information on reservation-making protocols. The agency should develop multi-lingual scripts to assist agents in delivering accurate, courteous and consistent responses.
— 7/15/2009 5:59:02 PM
Section	4.5 Transit Systems Without ACD Technology RFP #1 FTA
Original text	Agents should periodically inform callers that they have not been forgotten.
Proposed text	Agents should periodically inform callers that they have not been forgotten (at least every 2 minutes) For consistency with Section %
— 7/15/2009 5:58:05 PM
Section	RP Where's My Ride Calls
Original text	NDRN’s Second Comment on “Where’s My Ride?” Calls addresses Recommeded Practice as a whole.
Proposed text	NDRN is again impressed with the ideas and values incorporated into the “Recommended Practices for Handling ADA Complementary Paratransit “Where’s My Ride” Calls. NDRN was particularly impressed with the thoroughness and tone of Recommended Practice, Item 5 “Customer service for “Where’s my ride” calls. Our comment to the Recommended Practices for Handling “Where’s My Ride” calls is related to our comments to Recommended Practice for Reservation Hold Times. While the Recommended Practices for Handling “Where’s My Ride” calls recognizes that these calls are time-sensitive, the Recommended Practices do not include any provision for measuring Hold Times. We understand that the issue is complicated because while some larger volume call centers can use dedicated “Where’s my ride” agents, while dedicated agents will not make sense in smaller call centers. However, the Recommended Practices need to include a system for measuring Hold Times for “Where’s my ride” calls and such hold times need to be kept to an absolute minimum because of the very nature of those calls. Particularly when “Where’s my ride” calls are being made by individuals away from their homes or workplaces, they may be using payphones, the telephones of the offices or businesses they have just visited or using limited cell phone minutes. They also may be waiting in less than ideal locations, in office lobbies or outside in bad weather. Thus prompt response is even more important in these situations and of course complete and accurate responses in these situations is critical.
— 7/15/2009 5:57:30 PM
Section	RP Where's My Ride Calls
Original text	NDRN’s Second Comment on “Where’s My Ride?” Calls addresses Recommeded Practice as a whole.
Proposed text	NDRN is again impressed with the ideas and values incorporated into the “Recommended Practices for Handling ADA Complementary Paratransit “Where’s My Ride” Calls. NDRN was particularly impressed with the thoroughness and tone of Recommended Practice, Item 5 “Customer service for “Where’s my ride” calls. Our comment to the Recommended Practices for Handling “Where’s My Ride” calls is related to our comments to Recommended Practice for Reservation Hold Times. While the Recommended Practices for Handling “Where’s My Ride” calls recognizes that these calls are time-sensitive, the Recommended Practices do not include any provision for measuring Hold Times. We understand that the issue is complicated because while some larger volume call centers can use dedicated “Where’s my ride” agents, while dedicated agents will not make sense in smaller call centers. However, the Recommended Practices need to include a system for measuring Hold Times for “Where’s my ride” calls and such hold times need to be kept to an absolute minimum because of the very nature of those calls. Particularly when “Where’s my ride” calls are being made by individuals away from their homes or workplaces, they may be using payphones, the telephones of the offices or businesses they have just visited or using limited cell phone minutes. They also may be waiting in less than ideal locations, in office lobbies or outside in bad weather. Thus prompt response is even more important in these situations and of course complete and accurate responses in these situations is critical.
— 7/15/2009 5:55:32 PM
Section	4.5 4.5 Transit Systems Without ACD Technology RFP #1 FTA
Original text	Agents should periodically inform callers that they have not been forgotten.
Proposed text	Agents should periodically inform callers that they have not been forgotten (at least every 2 minutes)
— 7/15/2009 5:52:26 PM
Section	RFP #1 4.1.1 4.1.1 Example for Measuring by Maximum Hold Time
Original text	seconds, 60 seconds, 90 seconds, 120 seconds, etc., until 300 seconds [5 minutes] or more). If there were 10,000 calls last month, how many were answered within 3 minutes? It should be at least 91%. How many were answered within 5 minutes? It should be at least 97%. In addition, if it takes more than 5 minutes to answer any call, the agency would want to increase those increments to measure the hold time customers are actually experiencing, so that staff can be adjusted accordingly. Monitoring/reporting should not stop at the 5 minute mark.
Proposed text	30 seconds, 60 seconds, 90 seconds, 120 seconds, etc., until 300 seconds [5 minutes] or more). If there were 10,000 calls last month, how many were answered within 3 minutes? It should be at least 95%. How many were answered within 5 minutes? It should be at least 99%. In addition, if it takes more than 5 minutes to answer any call, the agency would want to increase those increments to measure the hold time customers are actually experiencing, so that staff can be adjusted accordingly. Monitoring/reporting should not stop at the 5 minute mark. In fact, monitoring efforts should increase at the 5 minute mark to determine why any calls are being answered at the 5 minute mark.
— 7/15/2009 5:51:07 PM
Section	RFP #1 Section 4.1 page 6
Original text	Measuring by maximum hold time is the best method for measuring ADA paratransit reservation telephone hold times. 91% of calls should be a11swered within 3 minutes, 97% of all calls should be answered within 5 minutes. NOTE: 1: Calls are measured on an hourly basis during the times the call center is taking reservations. NOTE 2: Each call group should be analyzed separately. For example, the call group could be a reservation call group, a general information call group, or a “where’s my ride” call group. Some transit agencies defer calls to Reservations and/or Dispatch. NOTE 3: For transit agencies that do not measure by Maximum Hold Time; averaging is described below. (See Measuring by Averages below. If averaging, hold time must be measured hourly.)
Proposed text	The following comments are being submitted by National Disability Rights Network, www.ndrn.org: We believe that the actual Recommended Practice for Reservation Hold Times for ADA Complementary Paratransit Call Centers” Reservation Hold Time Standards set too low a bar. Our understanding is that a “Recommended Standard” as opposed to a minimum standard or requirement, is in essence like a “best practice.” It is a standard that the consensus of the drafting group felt that the best-managed and fully-staffed call centers would be able achieve regularly under normal circumstances. NDRN recognizes that different paratransit call centers in different parts of the country in large and small communities have tremendous differences in demands, funding, technology and staffing. However, we believe that to set a Standard that only 91% of calls will be answered within 3 minutes is far too long. Similarly the Standard that 97% of call should be answered within 5 minutes is likewise too long. We urge that a higher percent of calls be answered within shorter time limits for both Standards in 4.1 Measuring by Maximum Hold Time. NDRN also has a related comment on a subset of these calls, the “Where’s my ride? Calls which are addressed in our other comment.
— 7/15/2009 5:48:51 PM
Section	4.1 Page 7 RFP #1
Original text	NOTE: 1: Calls are measured on a n hourly basis during the times the call center is taking reservations.
Proposed text	FTA OCR note on note 1. Many of the phone systems that FTA sees in compliance reviews (with an ACD) have the ability to measure calls in 1/2 hour increments.
— 7/15/2009 5:43:41 PM
Section	RFP #1 Section 4.1 page 6
Original text	4.1 Measuring by Maximum Hold Time Measuring by maximum hold time is the best method for measuring ADA paratransit reservation telephone hold times. 91% of calls should be answered within 3 minutes, 97% of all calls should be answered within 5 minutes.
Proposed text	A best practice, using the maximum allowable hold time method, would be a standard that 95% of calls should be answered within 3 minutes, and 99% of all calls should be answered within 5 minutes. Here is an example of how a transit agency might apply this standard, measuring by maximum allowable hold times. Phone reports typically list how many calls were received each day, each week, and each month, as well as what percent of the calls were answered within specified time increments (e.g. 30 seconds, 60 seconds, 90 seconds, 120 seconds, and so forth. If there were 10,000 calls last month, how many were answered within 3 minutes? It should be at least 95%. How many were answered within 5 minutes? It should be at least 99%. If a system answers 97% of all calls within 3, that leaves one hour or two 30 minute increments spread over the day where hold times may be long. This could lead to a capacity constraint if these blocks happen at times when riders are calling to reserve trips. In our experience with compliance reviews, many systems have internal performance standards in the 95 and 99% range, so 91% is too low for the bottom of the range.
— 7/15/2009 5:30:47 PM
Section	Section 3.1.3 RFP #1 page 5 FTA OCR
Original text	3.1.3 Hold Time The time period between the receipt of a call by a call center and the engagement of the caller. This period does not include the time in which the caller is in the initial process of making selections within the receiving phone system. Once a caller has entered the system, their hold time does not actually end until such time as the ride reservation process actually begins. Secondary holds must not be used to manipulate the overall length of time a caller is considered to be on hold.
Proposed text	The time period between the receipt of a call by a call center and the engagement of the caller. This period does not include the time in which the caller is in the initial process of making selections within the receiving phone system. Once a caller has entered the system, their hold time does not actually end until such time as the ride reservation process actually begins. Secondary holds Secondary holds must be minimized and must not be used to manipulate the overall length of time a caller is considered to be on hold.
Gail Bauhs — 7/15/2009 5:29:50 PM
Section	Page 6, Section 4.1 Measuring by Maximum Hold Time
Original text	91% of calls should be answered within 3 minutes, 97% of calls should be answered within 5 minutes.
Proposed text	Delete sentence. Whether it is the stated intention or not, these standards will likely become the future criteria against which all ADA Complimentary Paratransit Call Centers will be judged. Therefore, adoption of any numerical standards should be based on sound research methodologies. In addition, these standards should vary by system and factor in specific local conditions, such as available equipment, funding, staffing, type and size of call center, if the call center handles more than just ADA calls, and so on. Each of these factors has an effect on appropriate and attainable answer time standards. Rather than establishing numerical standards, it is preferable to suggest a methodology that can be followed by each organization to help them balance these factors and allow them to determine what is optimal for their circumstances and riders.
Tina Dubost — 7/15/2009 5:25:31 PM
Section	Where's My Ride Section 5
Original text	(See previous comment)
Proposed text	If answering the passenger’s question will take more than a few minutes, the agent should give the passenger an estimate of the time to address the issue. It may be appropriate for the agent to obtain a contact number. If a delay will require rescheduling or conditions are uncertain, the agent should tell the passenger how much time will be required to resolve the problem and give him or her the option to call back at a specified time, to wait on hold, or to be called back. Agents should ensure that follow-up calls are made. If the waiting-on-hold option is chosen, the agent should provide updates to the caller at regular intervals and offer to call back. When appropriate agents should apologize for the inconvenience. If applicable and consistent with agency policies, an agent should reassure a caller that he or she will not be penalized with a “no-show” and update the passenger’s record. Note: I don't think agents should have the authority to distribute free ride coupons. There is potential for excessive coupons to be distributed, for coupons to be distributed to “favored” customers, and for coupons to be distributed to discourage customers from filing a complaint about a legitimate problem. We believe that this practice is inadvisable and should be removed from the report.
Tina Dubost — 7/15/2009 5:24:17 PM
Section	Where's My Ride Section 5
Original text	Passengers who call the “Where’s my ride?” line deserve professional, courteous and honest information provided in a patient manner. Accurate details of a vehicle’s estimated time of arrival provided with empathy set the tone for a good customer service experience. Passengers want their calls answered quickly. Upon answering, an agent should give his or her name and department and ask, “How can I be of assistance?” An apology should be readily offered when appropriate. Callers want to know the most recent known location of the vehicle, the number of other stops before the caller will be picked up, the estimated time of arrival, the vehicle number, and any other identifying information, such as vehicle type and any identifying name on the vehicle. They do not want to be placated with a stock answer such as, “It will be 10 minutes” or “Your driver is around the corner.” It is preferable to give an updated estimated time of arrival and to confirm the exact location where the passenger will be waiting. Agents should then ensure that the information is received by the driver. The agent should obtain a contact number, if available. If a delay will require rescheduling or conditions are uncertain, the agent should tell the passenger how much time will be required to resolve the problem and give him or her the option to call back at a specified time, to wait on hold, or to be called back. Agents should ensure that follow-up calls are made. If the waiting-on-hold option is chosen, the agent should provide updates to the caller at least every three minutes and offer to call back. Agents should apologize for the inconvenience and, when appropriate, offer a free ride coupon for the inconvenience. If applicable, an agent should reassure a caller that he or she will not be penalized with a “no-show” and update the passenger’s record.
Proposed text	Passengers who call the “Where’s my ride?” line deserve professional, courteous and honest information provided in a patient manner. Accurate details of a vehicle’s estimated time of arrival provided with empathy set the tone for a good customer service experience. Passengers want their calls answered quickly. Upon answering, an agent should give his or her name and department and ask how s/he can help the customer. Callers may want to know information such as the most recent known location of the vehicle, the number of other stops before the caller will be picked up, the estimated time of arrival, the vehicle number, and any other identifying information, such as vehicle type and any identifying name on the vehicle. They do not want to be placated with a stock answer such as, “It will be 10 minutes” or “Your driver is around the corner.” Callers should be given the best available information on the estimated time of arrival. It may be appropriate to confirm the exact location where the passenger will be waiting. Agents should ensure that necessary information is received by the driver.
— 7/15/2009 5:23:21 PM
Section	RFP#1 page 5 purpose and References
Original text	1.2 Purpose The purpose of this document is to suggest recommended targets for response times in processing calls requesting paratransit service. 2. References USDOT ADA Regulation Part 37
Proposed text	1.2 Purpose The purpose of this document is to provide technical assistance for response times in processing calls requesting paratransit service. 2. References USDOT ADA Regulation 49 CFR Part 37
Tina Dubost — 7/15/2009 5:21:23 PM
Section	Where's My Ride - Section 4.4
Original text	4.4 Web-based systems For riders with Internet access, it is possible to provide personal accounts that may be used to log on to a website for information. A rider’s personal login can be used to locate trips scheduled for that day. For a selected trip, the current location of the vehicle on which the user’s trip is scheduled can then be displayed on a map, along with vehicle number, driver name and estimated time to arrive at the requested pickup.
Proposed text	4.4 Web-based systems For riders with Internet access, it is possible to provide personal accounts that may be used to log on to a website for information. A rider’s personal login can be used to locate trips scheduled for that day. The passenger can review his/her trips and can obtain information on the estimated arrival time.
— 7/15/2009 5:20:51 PM
Section	RFP #1 FTA OCR
Original text	Organizations that provide complementary paratransit services and consumer information, - Organizations that contract with others for complementary paratransit service and/or call-center operations, and - Organizations that influence complementary paratransit services. This document is concerned particularly with call centers serving ADA complementary paratransit services. As such, it takes into consideration the existence of guidance from the Federal Transit Administration (FTA) concerning response times and other key performance indicators for handling telephone reservations of ADA complementary paratransit services. Operators of call centers
Proposed text	Organizations that provide ADA complementary paratransit services and consumer information, - Organizations that contract with others for ADA complementary paratransit service and/or call-center operations, and - Organizations that influence ADA complementary paratransit services. This document is concerned particularly with call centers serving ADA complementary paratransit services. As such, it takes into consideration the existence of information and technical assistance from the Federal Transit Administration (FTA) concerning response times and other key performance indicators for handling telephone reservations of ADA complementary paratransit services. Operators of call centers
Tina Dubost — 7/15/2009 5:20:24 PM
Section	Where's My Ride - Section 4.3
Original text	A third approach is to use an interactive voice response (IVR) system in combination with an automated vehicle location (AVL) system to supplement the staffed “Where’s my ride?” lines. Such a system has the potential to off-load some calls from the “Where’s my ride?” staff. Some IVR systems can be configured to perform callouts (e.g., when promised times are jeopardized, or to notify riders of vehicle arrival). IVR is easily operated on a 24/7 basis. For this approach to work successfully, it is critical that the technology include routine position updates from vehicles and that these be used to constantly recompute estimated time of arrival for passengers. This can add considerably to the expense. An IVR system will not be successful if it is not as knowledgeable as a dispatcher would be in understanding when a vehicle is falling behind. Also, it will not be a complete substitute for staff, since it cannot be used for passengers with analog phones, those who lack fluency in a major language or those who have a disability that hinders interaction with an IVR script. IVR systems also cannot answer questions about why a delay is occurring, which some passengers may feel is needed to inform their decisions about contingencies.
Proposed text	4.3 IVR/AVL systems A third approach is to use an interactive voice response (IVR) system in combination with an automated vehicle location (AVL) system to supplement the staffed “Where’s my ride?” lines. Such a system has the potential to off-load some calls from the “Where’s my ride?” staff. Some IVR systems can be configured to perform callouts (e.g., when promised times are jeopardized, or to notify riders of vehicle arrival). IVR may be operated on a 24/7 basis. For this approach to work successfully, it is critical that the technology include routine position updates from vehicles and that these be used to constantly re-compute estimated time of arrival for passengers. This can add considerably to the expense. An IVR system needs to have up-to-date information to be effective. Also, it will not be a complete substitute for staff, since it cannot be used for passengers with analog phones, those who lack fluency in a major language or those who have a disability that hinders interaction with an IVR script. IVR systems also cannot answer questions about why a delay is occurring, which some passengers may feel is needed to inform their decisions about contingencies.
Tina Dubost — 7/15/2009 5:18:54 PM
Section	Where's My Ride Section 4
Original text	There is no one recommended practice for handling all “Where’s my ride?” calls. However, because such calls are time-sensitive, systems should be designed to prioritize their processing without constraining access to ADA complementary paratransit. The approach that will work best at any given site depends upon its available resources, both human and technological. The goal of any operational solution is to provide the customer service objectives of quick and accurate responses to the passenger’s questions. Broadly speaking, common approaches for handling “Where my ride?” calls include the following: – Dedicated “Where’s my ride?” agents – Multiple-role agents – IVR/AVL systems – Web-based systems – Text messaging systems These approaches are discussed in the following sections.
Proposed text	There is no one recommended practice for handling all “Where’s my ride?” calls. However, because such calls are time-sensitive, systems should be designed to respond efficiently and accurately. The approach that will work best at any given site depends upon its available resources, both human and technological. The goal of any operational solution is to provide the customer service objectives of quick and accurate responses to the passenger’s questions. Broadly speaking, common approaches for handling “Where my ride?” calls include the following: – Dedicated “Where’s my ride?” agents – Multiple-role agents – IVR/AVL systems – Web-based systems – Text messaging systems These approaches (which may be used in combination) are discussed in the following sections.
— 7/15/2009 5:18:15 PM
Section	RFP #1 FTA OCR
Original text	Abstract: This recommended practice establishes minimum requirements for reservation hold times when contacting a Paratransit Call Center that should be implemented by Transit Agencies.
Proposed text	This recommended practice establishes policies and practices for measuring and monitoring reservation hold times of a Paratransit Call Center that should be implemented by Transit Agencies.
Tina Dubost — 7/15/2009 5:14:54 PM
Section	Telephone hold time Section 4.6
Original text	4.6 Queue Positioning It is a best practice to include this feature to let callers know where they are in the queue.
Proposed text	Queue Positioning We applaud the working group for recommending this feature as a best practice (Section 4.6).
— 7/15/2009 5:14:39 PM
Section	Page 6, Section 4.1 Measuring by Maximum Hold Time
Original text	91% of calls should be answered within 3 minutes, 97% of calls should be answered within 5 minutes.”
Proposed text	Delete sentence. Whether it is the stated intention or not, these standards will likely become the future criteria against which all ADA Complimentary Paratransit Call Centers will be judged. Therefore, adoption of any numerical standards should be based on sound research methodologies. In addition, these standards should vary by system and factor in specific local conditions, such as available equipment, funding, staffing, type and size of call center, if the call center handles more than just ADA calls, and so on. Each of these factors has an effect on appropriate and attainable answer time standards. Rather than establishing numerical standards, it is preferable to suggest a methodology that can be followed by each organization to help them balance these factors and allow them to determine what is optimal for their circumstances and riders.
Tina Dubost — 7/15/2009 5:14:07 PM
Section	Telephone Hold Time Section 4.1
Original text	4.1 Measuring by Maximum Hold Time Measuring by maximum hold time is the best method for measuring ADA paratransit reservation telephone hold times. 91% of calls should be answered within 3 minutes, 97% of all calls should be answered within 5 minutes.
Proposed text	Continued from previous comment Alternatively, we propose averaging hold times by day instead of hour. Averaging by day avoids the problem of high call volumes during the first and last hours of the day – a problem experienced by most ADA paratransit call centers. We understand that peak hours are exactly the times that the hourly average measurement is aimed at controlling. However, setting the daily average low enough – say 1.5 minutes like the SamTrans standard – would help ensure that peak-hour hold times are not exorbitant, and would allow some variation during the day. In fact, the SamTrans daily standard of an average maximum hold time of 1.5 minutes ensures that even at peak hours, the hold time will generally not exceed three (3) minutes. We understand that setting an industry standard for call hold times is a challenge. We believe that customer and community acceptance should play a part in determining what level of performance is acceptable. SamTrans is proud of the fact that both customers and advocates review call-hold time data every month and have remained supportive of our standard and our ability to meet it over the years. Customer complaints about being put on hold during a reservation call or “Where’s my ride?” call are extremely rare. We take this to mean that our level of performance is satisfactory to stakeholders.
Tina Dubost — 7/15/2009 5:13:18 PM
Section	Telephone Hold Times Section 4.1
Original text	4.1 Measuring by Maximum Hold Time Measuring by maximum hold time is the best method for measuring ADA paratransit reservation telephone hold times. 91% of calls should be answered within 3 minutes, 97% of all calls should be answered within 5 minutes.
Proposed text	SamTrans does not presently meet either of the hold time standards proposed. Measuring by maximum hold time is problematic for two reasons. First, we are unable to track hold times with our current phone reports, and the capability to do so would require purchasing an additional report from our phone provider. Second, our hold time performance is significantly lower than the proposed standard. In April 2009, a typical month, approximately 92% of calls were in queue less than 5 minutes. APTA’s standard is 97%. Approximately 82% of calls were in queue less than 3 minutes. APTA’s standard is 91%. We prefer the alternate measurement method – average hold times by hour – which is compatible with SamTrans phone reports and measurement methods. However, we believe the proposed standard is too strict. We recommend that the standard be relaxed from one (1) minute to three (3) minutes, as we have indicated in our mark-up of the draft report.
Tina Dubost — 7/15/2009 5:10:36 PM
Section	Telephone Hold time section 7
Original text	A training program for paratransit call agents should include the following topics to ensure a qualified and professional workforce who is committed to reducing reservation hold times while providing a high level of public service. 1) Equipment/software familiarization and operation 2) Policy and procedure knowledge 3) Trip booking/scheduling techniques and operation 4) Trouble shooting difficult situations 5) Documentation requirements 6) Interpersonal communication requirements (e.g., active listening skills) 7) General ADA knowledge 8) Performance standards and expectations 9) Usage of TDD/TTY and relay devices 10) Complaint processing or referrals 11) Call wrap up, review, and closure techniques 12) Advanced phone technology enhancement usage 13) Performance tools and criteria 14) End-of-day shut down procedure 15) Communication and continuous improvement efforts with supervisor and team members 16) Customer behavior (code of conduct) understanding 17) General employee work rules and code of conduct 18) Understanding of how phone data is stored and retrieved 19) Knowledge of paratransit eligibility levels and codes 20) Confidentiality and privacy law issues 21) Knowledge of local area 22) Periodic retraining and professional development The agency should include in its rider orientation materials, in-person orientation sessions, and/or on-hold messages information on reservation-making protocols.
Proposed text	A training program for paratransit call agents should include the following topics to ensure a qualified and professional workforce who is committed to providing a high level of public service. 1) Equipment/software familiarization and operation 2) Policy and procedure knowledge 3) Trip booking/scheduling techniques and operation 4) Trouble shooting difficult situations 5) Documentation requirements 6) Interpersonal communication requirements (e.g., active listening skills) 7) General ADA knowledge 8) Performance standards and expectations 9) Usage of TDD/TTY and relay devices 10) Complaint processing or referrals 11) Call wrap up, review, and closure techniques 12) Advanced phone technology enhancement usage, if applicable 13) Performance tools and criteria 14) End-of-day shut down procedure 15) Communication and continuous improvement efforts with supervisor and team members 16) Customer behavior (code of conduct) understanding 17) General employee work rules and code of conduct 18) Knowledge of paratransit eligibility levels and codes 19) Confidentiality and privacy law issues 20) Knowledge of local area 21) Periodic retraining and professional development The agency should include in its rider orientation materials, in-person orientation sessions, and/or on-hold messages information on reservation-making protocols.
Tina Dubost — 7/15/2009 5:10:02 PM
Section	Telephone Hold Time Section 6
Original text	This comment refers to all of section 6.
Proposed text	We believe that this section is not necessary. Technology changes so rapidly that this section will soon be outdated. Transit agencies that are planning to purchase or upgrade their telephone systems should discuss alternatives with their telephone vendors.
Tina Dubost — 7/15/2009 5:06:22 PM
Section	Hold Time Section 5
Original text	This section provides recommended secondary hold-time practices. Secondary holds occur when an agent answers a call and then places the call on hold. Secondary holds can happen when a telephone system is set up to allow an agent to handle more than one call at a time. Secondary holds can also happen when a call is placed on hold to resolve an issue requiring extended time. The best practice is to handle initial calls without placing anyone on hold. If a secondary hold is necessary, the agent should inform the caller of the reason for placing him or her on hold and should check back with the caller at least every two minutes. The agent should not pick up another call until the first call is successfully resolved or transferred outside the reservation queue. All secondary hold times should be kept to the very minimum. As stated in section 5, paragraph 4 of the APTA document Recommended Practices for Handling ADA Complementary Paratransit “Where’s My Ride?” Calls (and this applies to all calls handled by the call center), “Rapid resolution of “Where’s my ride?” calls is a priority. Speed of resolution is measured by total call time, since the calls often involve either the use of personal cell phone minutes or tying up a business phone in a reception area.” Secondary holds should not be used to distort initial hold time. Secondary holds should not be calculated in, but measured separately.
Proposed text	5. Secondary Holds This section provides recommended secondary hold-time practices. Secondary holds occur when an agent answers a call and then places the call on hold. Secondary holds can happen when a telephone system is set up to allow an agent to handle more than one call at a time. Secondary holds can also happen when a call is placed on hold to resolve an issue requiring extended time. The best practice is to handle minimize secondary holds. If a secondary hold is necessary, the agent should inform the caller of the reason for placing him or her on hold and should check back with the caller at regular intervals. The agent should not pick up another call until the first call is successfully resolved or transferred outside the reservation queue. All secondary hold times should be kept to the minimum. Calls should be handled in a prompt and courteous manner. Secondary holds should not be used to distort initial hold time. Secondary holds should not be calculated in to the initial reservation hold time, but measured separately.
Tina Dubost — 7/15/2009 5:05:20 PM
Section	Hold Time 4.8
Original text	4.8 Free Calls Calls made within the service area to the call center should be toll free.
Proposed text	4.8 Free Calls Calls made within the service area to the call center should not require the caller to pay long distance toll charges. Explanatory note: Section 4.8 states that calls should be toll-free. Free calls usually require an 800-number to be available, which can be expensive. We believe an acceptable alternative is to ensure that all calls local numbers so that people can call without paying long distance toll charges.
Tina Dubost — 7/15/2009 5:02:35 PM
Section	Hold Time/ section 4.7
Original text	4.7 Busy Signals There should be no busy signals.
Proposed text	4.7 Busy Signals Busy signals should be minimized.
Tina Dubost — 7/15/2009 5:01:38 PM
Section	4.5
Original text	There could be numerous ways to conduct sampling. One would be to have a "secret caller" program where the system would ask certain riders to keep track of the times they called and were on hold. The second would be to observe the call-takers for a certain number of hours each month (on different days and at different times that are randomly selected) and keep detailed notes on the times when calls are placed on hold. When there’s no ACD system, the phones frequently have multiple extensions, and receptionists will have callers on hold that will be indicated by blinking extension buttons. An outside individual could sit with reservationists, note any time someone is placed on hold on an extension, and then time how long each extension is on hold. This method has advantages over an ACD tracking system, because such manual tracking would also capture information on secondary holds.
Proposed text	There could be numerous ways to conduct sampling. One would be to have a "secret caller" program where the system would ask certain riders to keep track of the times they called and were on hold. The second would be to observe the call-takers for a certain number of hours each month (on different days and at different times that are randomly selected) and keep detailed notes on the times when calls are placed on hold. When there is no ACD system, the phones frequently have multiple extensions, and receptionists will have callers on hold that will be indicated by blinking extension buttons. An outside individual could sit with reservationists, note any time someone is placed on hold on an extension, and then time how long each extension is on hold. This method would also capture information on secondary holds.
Tina Dubost — 7/15/2009 4:58:23 PM
Section	4.21.
Original text	4.2.1 Example for Measuring By Hourly Average Hold Time An average hold time should be calculated for each hour the Call Center is open. Each hourly average should be one minute or less.
Proposed text	4.2.1 Example for Measuring By Hourly Average Hold Time An average hold time should be calculated for the time that the Call Center is open. The average should be two minutes or less.
— 7/15/2009 4:57:17 PM
Section	RFP #1 General comment from FTA OCR
Original text	general comment on page ii
Proposed text	The standards process is not an attempt to adopt a practice that everyone can then say they already do. Rather, this is a chance to adopt a target or goal, whether or not all of the participants currently meet it. Since the goal of this process document is to put the customer first (page ii), we think it is important to step back and remind ourselves that this is not an exercise in self-validation. As a recommendation practice, we would hope that the result is not the least common denominator.
Tina Dubost — 7/15/2009 4:56:49 PM
Section	4.2
Original text	4.2 Measuring by Hourly Average of Reservation Hold Times This should be done only if a transit agency cannot measure by Maximum Hold Time, due to technological limitations. Average hold time should be calculated for each hour of the day when calls are taken. The average hold time should be no more than 1 minute. It is recommended that periodic reviews be conducted to identify any patterns of excessive reservation hold times. NOTE 5: Each call group should be analyzed separately. For example, the call group could be a reservation call group, a general information call group, or a “where’s my ride” call group.
Proposed text	4.2 Measuring by Hourly Average of Reservation Hold Times Measuring by monthly average is an acceptable alternative. Average hold time should be calculated as an overall average or for each hour of the day when calls are taken. The average hold time should be no more than three minutes. It is recommended that periodic reviews be conducted to identify any patterns of excessive reservation hold times. NOTE 5: Each call group should be analyzed separately. For example, the call group could be a reservation call group, a general information call group, or a “where’s my ride” call group.
Tina Dubost — 7/15/2009 4:55:00 PM
Section	4 and 4.1
Original text	4. Recommended Hold Time Standards and Methods for Measuring Them This section provides recommended hold-time standards and methods for measuring them. The best method is to measure by maximum hold time (see 4.1). Only if a transit agency cannot measure by maximum hold time due to technological limitations, should it measure by hourly average instead (see 4.2). And if a transit agency does not have ACD technology, it must monitor hold times in other ways (see 4.5). 4.1 Measuring by Maximum Hold Time Measuring by maximum hold time is the best method for measuring ADA paratransit reservation telephone hold times. 91% of calls should be answered within 3 minutes, 97% of all calls should be answered within 5 minutes. NOTE: 1: Calls are measured on an hourly basis during the times the call center is taking reservations. NOTE 2: Each call group should be analyzed separately. For example, the call group could be a reservation call group, a general information call group, or a “where’s my ride” call group. Some transit agencies defer calls to Reservations and/or Dispatch. NOTE 3: For transit agencies that do not measure by Maximum Hold Time; averaging is described below. (See Measuring by Averages below. If averaging, hold time must be measured hourly.)
Proposed text	This section provides recommended hold-time standards and methods for measuring them. The recommended method is to measure by maximum hold time (see 4.1). An overall average is an alternative (see 4.2). And if a transit agency does not have ACD technology, it must monitor hold times in other ways (see 4.5). 4.1 Measuring by Maximum Hold Time Measuring by maximum hold time is the recommended method for measuring ADA paratransit reservation telephone hold times. 91% of calls should be answered within 3 minutes, 97% of all calls should be answered within 5 minutes. NOTE: 1: Calls are measured on an hourly basis during the times the call center is taking reservations. NOTE 2: Each call group should be analyzed separately. For example, the call group could be a reservation call group, a general information call group, or a “where’s my ride” call group. Some transit agencies defer calls to Reservations and/or Dispatch. NOTE 3: For transit agencies that do not measure by Maximum Hold Time; averaging is described below. (See Measuring by Averages below.)
David Chia — 7/15/2009 4:54:56 PM
Section	"Recommended Practice for Reservation Hold Times for ADA Complementary Paratransit Call Centers," pp. 6-7, Section 4.1
Original text	91% of calls should be answered within 3 minutes, 97% of all calls should be answered within 5 minutes. ... Phone reports typically list how many calls were received each day, each week, and each month, as well as what percent of the calls were answered within specified time increments (e.g., 30 seconds, 60 seconds, 90 seconds, 120 seconds, etc., until 300 seconds [5 minutes] or more). If there were 10,000 calls last month, how many were answered within 3 minutes? It should be at least 91%. How many were answered within 5 minutes? It should be at least 97%.
Proposed text	91% of calls in each hour should be answered within 3 minutes, 100% of all calls should be answered within 5 minutes. ... Phone reports typically list how many calls were received each day, each week, and each month, as well as what percent of the calls were answered within specified time increments (e.g., 30 seconds, 60 seconds, 90 seconds, 120 seconds, etc., until 300 seconds [5 minutes] or more). If there were 10,000 calls last month, how many were answered within 3 minutes? It should be at least 91%. How many were answered within 5 minutes? It should be 100%. [Note 1 and Note 4 allude to measuring on an hourly basis, but the standard should say so explicitly]
Tina Dubost — 7/15/2009 4:51:29 PM
Section	3.1.3
Original text	Once a caller has entered the system, their hold time does not actually end until such time as the ride reservation process actually begins.
Proposed text	Once a caller has entered the system, their hold time does not actually end until such time as s/he is connected to an agent.
— 7/15/2009 2:22:49 PM
Section	#2, pg. 5, Section 5 - Customer Service for "Where's my ride" calls
Original text	Rapid resolution of "Where's my ride?" calls is a priority. Speed of resolution is measured by total call time, since the calls often involve either the use of personal cell phone minutes or tying up a business phone in a reception area.
Proposed text	The Disability Rights Network of Pennsylvania believes that the "Where's my ride?" calls be subjected to the same standards for hold times as in the Recommended Practices for Reservation Call Hold Times. It is even more imperative in a situation where a passenger has uncertainty about the whereabouts of a ride to have their call dealt with quickly and not be placed on indefinite hold. Again, we have heard from many people with disabilities who ride paratransit who have faced difficulties with transit authorities on this issue. The recommened practice should also add a monitoring requirement for transit authorities to monitor how effectively these calls are handled by customer service agents.
— 7/15/2009 2:10:47 PM
Section	#2, pg. 4, Section 4.5 Text Messaging Systems
Original text	For passengers with cell phones, PDAs or laptops, it may be possible to send text messages containing ride information updates.
Proposed text	The Disability Rights Network of Pennsylvania believes that this recommendation should be strengthened to advise transit authorities to strongly consider developing systems to provide passengers with cell phones, PDAs, laptops, or other devices with immediate, updated information on the whereabouts of a person's ride. The inability to get quick and accurate information about the whereabouts of a ride is a recurring problem for people with disabilities who ride paratransit and one that causes extreme frustration, consternation, and anxiety. Developing systems that can provide immediate and up-to-date information to riders through such devices or using other technologies are the best way to eliminate uncertainty and ensure that riders are kept fully informed.
Shirley Hsiao — 7/14/2009 7:47:46 PM
Section	#3, Section 3.3.1 Monitoring Program Overview
Original text	"Each transit agency should develop written policies and procedures for an ongoing program to monitor operators’ adherence to both stop announcement and route identification requirements established by ADA regulations, as well as any specific local requirements."
Proposed text	[ Each transit agency should follow a core guidebook, developed by the American Public Transportation Association, which presents minimal standards and a cost-effective program to monitor operators’ adherence to stop announcement and route identification requirements established by the ADA. ] Long Beach Transit believes a uniform approach, presented by APTA, is the best approach to the proposed Recommended Practice. Without common methodology shown in a guidebook, each transit agency’s individual policies and procedures could vary greatly, resulting in gaps of program quality. A cost-effective model for monitoring operators should also be presented, as additional resources would be needed to accommodate efficient and meaningful sampling of operators’ behaviors. After such guidelines are developed, it would be helpful for APTA to sponsor workshops to help each agency learn the techniques and apply them to their operating procedures.
— 7/14/2009 7:35:42 PM
Section	FTA OCR general comment
Original text	everything done by FTA OCR 7/14 from 7:03- 7:23 is for Where's My Ride
Proposed text	everything done by FTA OCR 7/14 from 7:03- 7:23 is for Where's My Ride
— 7/14/2009 7:24:54 PM
Section	9-10 6.2 For “Where’s my ride?”agents FTA -OCR
Original text	– Verify information to ensure that you accurately identify the passenger and his or her location and pickup information. – Ask for phone contact information. – Ensure that information provided to the caller is as accurate as possible, based on technologies available and the most updated information available. – Handle the call as expeditiously as possible. – Minimize the length of secondary holds. – Convey sensitivity to the passenger: - Look at things from the passenger’s perspective. - Consider the passenger’s needs. - Consider any environmental factors (e.g., weather, security and shelter). - Ask the caller before placing him or her on hold. - Give the caller the option to be placed on hold or called back. - Update the passenger at regular intervals.
Proposed text	Develop a script to assist “Where’s my ride?” agents in delivering accurate, courteous and consistent responses – Verify information to ensure that you accurately identify the passenger and his or her location and pickup information. – Ask for phone contact information. – Ensure that information provided to the caller is as accurate as possible, based on technologies available and the most updated information available. – Handle the call as expeditiously as possible. – Monitor and minimize the length of secondary holds. – Convey sensitivity to the passenger: - Look at things from the passenger’s perspective. - Consider the passenger’s needs. - Consider any environmental factors (e.g., weather, security and shelter). - Ask the caller before placing him or her on hold. - Give the caller the option to be placed on hold or called back. - Update the passenger at least every one to two minutes.
— 7/14/2009 7:20:56 PM
Section	Page 9/ 6.1 For transit agencies FTAOCR
Original text	– Respond to different language requirements - Contract with an outside service to provide other language offerings. Examples include the following: - http://www.optimalphoneinterpreters.com/index.shtml - http://www.certifiedlanguages.com/ - http://www.languageline.com/ - http://www.spectracorp.com/language_translation_services.asp - Offer multilingual IVR scripts.
Proposed text	– Respond to different language requirements in keeping with your LEP plan - Contract with an outside service to provide other language offerings. Examples include the following: - http://www.optimalphoneinterpreters.com/index.shtml - http://www.certifiedlanguages.com/ - http://www.languageline.com/ - http://www.spectracorp.com/language_translation_services.asp - Offer multilingual IVR scripts. – Ensure that passengers can be informed about significant events that have impacted service for many riders. - Provide an automated message explaining the significant event before the caller gets into the queue. - Provide the staff flexibility to increase or decrease the number of “Where’s my ride?” agents based on operating conditions. - Automate call-out through IVR. Monitor and track performance
— 7/14/2009 7:17:48 PM
Section	6/ 5. Customer service for “Where’s my ride?” calls -FTA OCR
Original text	Rapid resolution of “Where’s my ride?” calls is a priority. Speed of resolution is measured by total call time, since the calls often involve either the use of personal cell phone minutes or tying up a business phone in a reception area.
Proposed text	Rapid resolution of “Where’s my ride?” calls is a priority. Speed of resolution is measured by total call time, since the calls often involve either the use of personal cell phone minutes; finding a public phone or tying up a business phone in a reception area. It is important that recommended practice for “Where’s my Ride?” calls be at least as good as those for paratransit reservation calls, considering that vehicle wait time windows are often between five and six minutes
— 7/14/2009 7:15:56 PM
Section	Page 8 5. Customer service for “Where’s my ride?” calls
Original text	The agent should obtain a contact number, if available. If a delay will require rescheduling or conditions are uncertain, the agent should tell the passenger how much time will be required to resolve the problem and give him or her the option to call back at a specified time, to wait on hold, or to be called back. Agents should ensure that follow-up calls are made. If the waiting-on-hold option is chosen, the agent should provide updates to the caller at least every three minutes and offer to call back. Agents should apologize for the inconvenience and, when appropriate, offer a free ride coupon for the inconvenience. If applicable, an agent should reassure a caller that he or she will not be penalized with a “no-show” and update the passenger’s record.
Proposed text	The agent should obtain a contact number, if available. If a delay will require rescheduling or conditions are uncertain, the agent should tell the passenger how much time will be required to resolve the problem and give him or her the option to call back at a specified time, to wait on hold, or to be called back. Agents should ensure that follow-up calls are made. If the waiting-on-hold option is chosen, the agent should provide updates to the caller at least every one to two minutes and offer to call back. Agents should apologize for the inconvenience and, when appropriate, offer a free ride coupon for the inconvenience. If applicable, an agent should reassure a caller that he or she will not be penalized with a “no-show” and update the passenger’s record.
— 7/14/2009 7:13:32 PM
Section	Page 8/4.5 4.5 Text messaging systems FTA OCR
Original text	For passengers with cell phones, PDAs or laptops, it may be possible to send text messages containing ride information updates.
Proposed text	For passengers with cell phones, PDAs or laptops, it may be possible for an agency to send text messages containing ride information updates.
— 7/14/2009 7:11:44 PM
Section	Page 8 4.3 IVR/AVL systems FTA OCR
Original text	if it is not as knowledgeable as a dispatcher would be in understanding when a vehicle is falling behind. Also, it will not be a complete substitute for staff, since it cannot be used for passengers with analog phones, those who lack fluency in a major language or those who have a disability that hinders interaction with an IVR script. IVR systems also cannot answer questions about why a delay is occurring, which some passengers may feel is needed to inform their decisions about contingencies.
Proposed text	if it is not as anticipatory or knowledgeable as a dispatcher would be in understanding when a vehicle is falling behind. Also, it will not be a complete substitute for staff, since it cannot be used for passengers with analog phones, those who lack fluency in a major language or those who have a disability that hinders interaction with an IVR script. IVR systems also cannot answer questions about why a delay is occurring, which some passengers feel is needed to inform their decisions about contingencies.
— 7/14/2009 7:09:51 PM
Section	page 7 /4.2 FTA OCR
Original text	Regardless of how “Where’s my ride?” responsibilities are shared with other responsibilities, it is generally true that the fewer staff members who need to be pulled in to solve an issue, the faster and more accurate the response to the passenger is likely to be.
Proposed text	Regardless of how “Where’s my ride?” responsibilities are shared, , it is generally true that the fewer staff members who need to be pulled in to solve an issue, the faster and more accurate the response to the passenger is likely to be.
— 7/14/2009 7:07:47 PM
Section	Page 5 1.2
Original text	This Recommended Practice is intended to assist transit agencies in delivering accurate and courteous responses to “Where’s my ride?” calls, based on the best available information at the time of the call.
Proposed text	This Recommended Practice document is intended to assist transit agencies in delivering accurate and courteous responses to “Where’s my ride?” calls, based on the best available information at the time of the call.
— 7/14/2009 7:06:20 PM
Section	FTA OCR introduction
Original text	Customers using complementary ADA paratransit services need to go through a call center in order to request transportation. There is a wide range of customer responsiveness which customers may experience when they call, resulting from a range of operational procedures and infrastructure investment among call centers. As a result, some customers may have a relatively positive experience while other customers may experience long delays and other frustrations in placing their transport requests.
Proposed text	Customers using ADA complementary paratransit services need to go through a call center in order to request transportation. There is a wide range of customer responsiveness which customers may experience when they call, resulting from a range of operational procedures and infrastructure investment among call centers. As a result, some customers may have a relatively positive experience while other customers may experience long delays and other frustrations in placing their transport requests.
— 7/14/2009 7:04:52 PM
Section	FTA OCR
Original text	This document is concerned particularly with call centers serving ADA complementary paratransit services. As such, it takes into consideration the existence of guidance from the Federal Transit Administration (FTA) concerning response times and other key performance indicators for handling telephone reservations of ADA complementary paratransit services. Operators of call centers that serve other forms of paratransit—for example, public dial-a-ride or non-emergency medical transportation (NEMT)—may benefit from this document but may find that differing service characteristics justify different guidelines.
Proposed text	This document is concerned particularly with call centers serving ADA complementary paratransit services. As such, it takes into consideration the existence of guidance from the Federal Transit Administration (FTA) concerning response times and other key performance indicators for handling telephone reservations of ADA complementary paratransit services. Operators of call centers that serve other forms of demand-responsive service —for example, public dial-a-ride or non-emergency medical transportation (NEMT)—may benefit from this document but may find that differing service characteristics justify different guidelines.
— 7/14/2009 7:03:38 PM
Section	FTA OCR- Introduction page 2
Original text	This recommended practice is intended to assist transit agencies to provide quality service to all customers accessing complementary paratransit service information via automated or non-automated call centers. It describes recommended policies, procedures, and practices to incorporate in customer service plans related to reservation hold times that enable consumers to quickly complete the purpose of their calls with a high degree of satisfaction. It provides a rationale for and establishes recommended methods to measure reservation hold times, and it addresses technology considerations and implementation strategies to monitor and report performance results and educate and train management, staff, and customers. APTA recommends the use of this recommended practice by:
Proposed text	This recommended practice document is intended to assist transit agencies to provide quality service to all customers accessing complementary paratransit service information via automated or non-automated call centers. It describes recommended policies, procedures, and practices to incorporate in customer service plans related to “where’s my ride?” that enable consumers to quickly complete the purpose of their calls with a high degree of satisfaction. It provides a rationale for and establishes recommended methods to measure “where’s my ride?”, and it addresses technology considerations and implementation strategies to monitor and report performance results and educate and train management, staff, and customers. APTA recommends the use of this recommended practice by:
Chester Patton — 7/6/2009 6:48:14 PM
Section	p. 13, Section 41.
Original text	Route identification announcements are to be made by the vehicle operator if the automated system malfunctions, is inoperable, or is not present on a particular vehicle.
Proposed text	Route identification announcements are to be made by the vehicle operator if the automated system malfunctions, is inoperable, or is not present on a particular vehicle. Some automated systems may allow for yard departure announcements for routine pre-revenue system testing and programmed safety messages.
Chester Patton — 7/6/2009 6:45:07 PM
Section	p.5, Section 3.1.1
Original text	Announcements for a particular stop should always be consistent.
Proposed text	Announcements for a particular stop should always be consistent. Using the nomenclature "Approaching" instead of "Next Stop" prior to a bus stop location announcement may avoid creating customer expectations that the bus will stop without a passenger request.
Chester Patton — 7/6/2009 6:41:53 PM
Section	p.13, Section 4.1
Original text	External announcements are played to passengers waiting curbside or on platforms announcing route name and number, destination and transfer point information. The message plays in a loop mode as long as the door is open, in order for individuals to be able to identify the correct vehicle. The external announcement is triggered by the door-open signal.
Proposed text	External announcements are played to passengers waiting curbside or on platforms announcing route name and number, destination and transfer point information. The message plays in a loop mode as long as the door is open, in order for individuals to be able to identify the correct vehicle. The external announcement is triggered by the door-open signal. External announcements should match the route destination sign.
Chester Patton — 7/6/2009 6:36:33 PM
Section	p.5, Section 3.1.1
Original text	3.1.1 Stop announcements – Select stop locations to announce, including: - transfer points for other routes; - major intersections, including arterial streets, major thoroughfares as shown on maps and commercial centers; - destination points, including ends of lines, major shopping centers, hospitals, city halls or other facilities used or generally recognized by the riding public; and - other stops for orientation, such as after turns or at intervals of a predetermined distance or time.
Proposed text	3.1.1 Stop announcements – Select stop locations to announce, including: - transfer points for other routes; - major intersections, including arterial streets, major thoroughfares as shown on maps and commercial centers; - destination points, including ends of lines, major shopping centers, hospitals, city halls or other facilities used or generally recognized by the riding public; - cities and towns, by stating the city name with the first stop announcement after crossing municipal boundaries; and - other stops for orientation, such as after turns or at intervals of a predetermined distance or time.
— 7/2/2009 5:37:31 PM
Section	Pg. 8 - Sec. 3.2.2 Fixed route vehicle operator training
Original text	Employees should sign an acknowledgment of receipt of training and agree to follow the established stop announcement and route identification program protocols.
Proposed text	King County Metro's position is that this sentence is unnecessary and a contribution to bureaucratic excess. Agencies just need to include this responsibility in contract, policy or procedure language and then take corrective action if an employee does not comply.
Pamela Schurgot — 6/22/2009 5:09:09 PM
Section	#3 Fixed Route Stop Announcement & Route ID Program
Original text	None
Proposed text	SEPTA strongly supported the Access Committee’s initiative to examine best practices in stop announcement and route identification programs. We actively participated in the development of these recommendations, during a site visit contributing information, reports and documentation. This study is a well-organized, comprehensive, and thoughtful summary of practices nationwide. Although we recognize that staffing, financial constraints, or collective bargaining agreements may hamper some agencies in implementing some of the practices RP#3 suggests, we strongly support their use in planning if not as operational requirements. SEPTA continues to place a high priority on consistent compliance with all ADA regulations; consistent monitoring, training, and re-training; and aggressive attention and followup on all accessibility-related complaints. These practices maintain and strengthen the accessibility and usability of our system for all our riders.
Pamela Schurgot — 6/22/2009 5:08:11 PM
Section	#2 Handling ADA Complementary Paratransit "Where's my Ride"
Original text	None
Proposed text	SEPTA strongly supported the Access Committee’s development of white papers to examine best practices in paratransit service provision. RP#2 provides a thoughtful and comprehensive discussion of issues impacting each approach to handling WMR calls. It is good to see the recommendations to minimize secondary holds and use of perfunctory answers such as “10 minutes”. In itself, this document could serve as the basis for a very effective staff training program. Although, as the study notes, staffing and financial constraints may hamper smaller agencies in implementing all the practices recommended here, we support their use as checklists that will facilitate providing good customer service
Pamela Schurgot — 6/22/2009 5:07:17 PM
Section	#1 Reservation for Hold Times
Original text	None
Proposed text	SEPTA strongly supported the Access Committee’s initiative to examine best practices in paratransit service provision, and then actively participated in the development of these standards, contributing information, reports and documentation and conferring with working group representatives. SEPTA’s standards exceed those proposed. Although we recognize that staffing and financial constraints may hamper some agencies in fully implementing the standards RP#1 suggests, we support their use as a planning objective. The phrase “hold time” occurs in the title and throughout the document. For clarity, we strongly urge that this phrase be expanded in Section 3.1.3’s definition and elsewhere in the text to Hold Time (Wait Time, Time in Queue). What is described here as “hold time” is known in the communications industry, and by SEPTA, as “time in queue” or “wait time” before being connected with personnel in the unit. (“Hold time” is, literally, time spent on hold, when a caller is placed on hold by a staff member during a call and after connecting with personnel in the unit.) SEPTA has for many years collected both average and maximum time in queue, on an hourly basis and per unit, for all telephone service to ADA paratransit callers.
— 6/18/2009 3:46:31 AM
Section	rDZKgqLTqiL
Original text	tF1zwU bkwPpwvo03NXzw47jvGa
Proposed text	tF1zwU bkwPpwvo03NXzw47jvGa
— 6/5/2009 5:11:38 PM
Section	Page # 13 / 4.1 Automated stop announcement system
Original text	The OCU has a display and keypad that are specifically adapted for transit operations and installed in the operator’s area within arm’s reach.
Proposed text	The OCU has a display and keypad that are specifically adapted for transit operations and installed in the operator’s area within arm’s reach. This system must not in any way obscure the vision of or in any way create a deficiency of the viewing area that is necesssary for safe operation.
— 6/5/2009 5:02:24 PM
Section	Page # 10 / 3.3.2 Monitoring Program Elements
Original text	- visibility (for signage)
Proposed text	- visibility (for signage) a- Destination Sign Clean and easely read. b- Destination sign set with the proper destination.
— 6/5/2009 4:54:43 PM
Section	Page # 2/ 1.2 Purpose / Fixed Route
Original text	(2) The entity shall announce any stop on request of an individual with a disability.
Proposed text	(2) The entity shall announce any stop upon request. (not just for individuals with disablities but for all whom request it).
— 6/5/2009 4:42:35 PM
Section	Pg # 2 / 1.2 Purpose / Fixed Route
Original text	(2) The entity shall announce any stop on request of an individual with a disability.
Proposed text	(2) The entity shall announce any stop upon request. (not for just individuals with disablities but for all who request it).
— 5/27/2009 3:21:10 PM
Section	Iran, New York
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Proposed text	easy order processing and no prescription needed! <a href= http://forums.pligg.com/members/oxycodone.html >buy oxycodone</a> <a href= http://forums.pligg.com/members/ritalin.html >buy ritalin</a> <a href= http://forge.mysql.com/people/person.php?id=5138 >viagra sale</a> <a href= http://www.ocf.berkeley.edu/~ncbcl/forum/viewtopic.php?t=20 >buy coumadin</a> <a href= http://www.ocf.berkeley.edu/~ncbcl/forum/viewtopic.php?t=21 >buy proscar</a>
— 5/23/2009 9:15:29 PM
Section	4 - 4.5 Text messaging systems on Handling Wheres My Ride Calls
Original text	For passengers with cell phones, PDAs or laptops, it may be possible to send text messages containing ride information updates.
Proposed text	For passengers with cell phones, PDAs or laptops, it may be possible to send text messages containing ride information updates. Moreover, passengers with speech impediments may benefit from automating a speed dial to the Where's My Ride number and including a standard macro that inputs the passenger's system ID# and name. That should speed the resolution process.
— 5/23/2009 8:57:27 PM
Section	Page 10 of #3 (Fixed Route Stop Announcement) - Factors to Include:
Original text	"Sound Level"
Proposed text	at what decibels? What is the acceptable decibel range? I've hard announcements at a whisper level and others at a level that would make Garrett Morris cover his ears.
— 5/20/2009 5:57:27 PM
Section	general comment.
Original text	RP #3 fixed route stop announcement will not open. #1 & #2 open correctly but no way to view #3 hard to comment when can't read it.
Proposed text	fix the link
— 5/19/2009 2:17:25 PM
Section	#1 RP Reservation Hold Times Section 7. Education & Training
Original text	7) General ADA Knowledge
Proposed text	7)Service criteria for ADA complementary paratransit.
Dottie Watkins — 5/19/2009 9:32:20 AM
Section	Pg. 10 / #3 RP for a Fixed Route Stop Announcement and Route Identification Program
Original text	Management and union leadership should negotiate a labor rule related to stop announcement and route identification requirements that is consistent with other agency disciplinary and incentive programs.
Proposed text	Management should create a labor rule related to stop announcement and route identification requirements that is consistent with other agency disciplinary and incentive programs. Union leadership should be engaged to support the program.
— 5/15/2009 4:25:38 PM
Section	This is a test comment from MG for Heidi.
Original text	This is a test - commenting on Document 1.
Proposed text	This is a test.
— 5/15/2009 2:43:15 PM
Section	13
Original text	test
Proposed text	test

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