of fixed-route accessible were about 6 percent of capital costs and about 1/10 of 1 percent of operating costs. The situation has improved significantly since then. A couple of other comments I was requested to refer to: Inter-city bussing is an issue that comes up in rural areas. I was not able to find it in my copy of the record so far, but the Department of Agriculture held a series of symposiums that have led to Congresswoman Virginia Smith's bill, and the issue of non-accessibility of common carrier intercity buses came up several times. As somebody else pointed out, Greyhound is running vans as well as large buses. In fact, many of them are, to use a brand name, the El Dorado Falcon. The exact same bus that is being run as a smallcity or rural local community public transit system is what Greyhound is running in some rural areas. They have gone to small buses because they are not using all the seats in some of these areas. Tracking down complaints regarding this is difficult because there is no central place to send complaints. If people have complaints, most of the time, they send them to Greyhound so they are not readily available. There is no central repository for concerns on intercity bus problems in rural areas. One anecdote I might bring in; in Southern California, I have been working with a system that is working to improve both-primarily, it is paratransit programs. The public transit system is 100 percent accessible, but it doesn't reach all areas of the county. The paratransit has a severely constrained capacity. There is an individual with developmental and physical disabilities who is going to a workshop that is twelve miles from his house. The coordinating agency for developmental disabilities is spending $150 a day to transport this individual because they can't get on to the paratransit program. Finally, in conclusion, in support of the ADA which does require both fixed-route accessible and paratransit as a supplement and complement to those services, the experiences that we have found throughout California and other parts of the country is that, indeed, both are needed. When they work together, you can provide a much higher level of service for all persons in the area. Thank you. I would be glad to answer any questions. Mr. MINETA. Thank you very much. There are going to be some things that we are going to have to consider. Let me ask you, what kind of criteria do you think we ought to look at in order to define comparable paratransit service? What kind of criteria should we be looking at to determine who in the disabled community is eligible to use paratransit services? Thirdly, what kind of criteria should we be looking at to determine what constitutes an undue financial burden to a public-transit entity? MS. PIRAS. I might try and cop out of that, somewhat, by saying I think that the legislation leaves a lot of that to a regulatory process. But that can be dangerous, too. Part of the problem we have had so far is, perhaps, leaving too much to a regulatory process. I believe the gentleman from Seattle made some very good points. Although one would have to be cautious, I guess, a truly committed public transit agency-Mr. Jenkins made the comment, the individual from Seattle made the comment-a transit property that is really working with its local community, rather than telling its local community what the community wants, can develop a process and a resulting level of service that is probably far more likely to meet needs than an imposed kind of approach. One of the interesting things, in the North Carolina study I mentioned, one of the other questions that was asked was, "What is your local handicapped population; what is your local wheel-chair user population? What percentage of those people are you serving?" Of the 200-some demand-responsive systems that reported, something like 70 percent of them, the answer was, "We don't know." Well, how can they be having a collaborative working relationship with the local community if they don't know who those people are? So, the public participation involvement of it is critical. I think, in terms of criteria, the so-called service criteria that were attempted to be used in the current DOT regulations provides some guidelines. Time of response, fare, service area are concerns that most users do seem to want to have some input into. I missed your second question, by now. Mr. MINETA. Who would be eligible for paratransportation? Ms. PIRAS. Again, a lot of that is familiarity with the transit system. It is hard to learn to use public transit. Most people, anywhere, don't use it. A transit mentality to understand that you might have to transfer, that you have to be at a bus stop before the bus gets there or you are probably not going to make it-it takes time to learn that. User training; with adequate user training, the number of people who really can use public transit would be higher. A lot of people can't use transit because they think they can't use transit. Medical certifications have been a mode of convenience in a number of areas because that, also, puts the burden on a doctor who says, "Okay, this person has qualified under some medical basis." Again, in many cases, the doctor just says, "I want this person out of my office. Let them ride transit and get them out of here. Let it be the transit system's problem." I think the disabled community, in many cases, is very able to police themselves and, again, working with a good collaborative process can impose some of those restrictions on themselves. In terms of undue financial burden, I believe the provision that is on the Senate side which allows for a credit, so to speak, for a paratransit program that is in existence that may be getting funding not only from the public transit side but from a variety of human services fundings can help to ease that burden. While it is not directly the subject of either this Committee's deliberations in general, or the ADA, specifically, the whole issue of coordination of funding for transportation purposes throughout Federal and state governments is one that is probably going to have to be addressed over the next few years as resources continue to tighten. Mr. MINETA. Thank you very much, Ms. Piras. I appreciate your testimony and your being here to help us deliberate on this issue. MS. PIRAS. Thank you. [Ms. Piras' prepared statement follows:] INITIAL TESTIMONY TO HOUSE COMMITTEE ON PUBLIC WORKS AND TRANSPORTATION REGARDING AMERICANS WITH DISABILITIES Submitted By: San Lorenzo. California September 20, 1989 AMERICANS WITH DISABILITIES ACT OF 1989 Testimony by Pat Piras These comments are submitted with a focus on transit systems in rural and small city areas. Additional written testimony will be forthcoming. Public transportation is a crucial service in rural areas, providing lifeline as well as socialization and community connections. For persons with disabilities, this may be doubly important. Public transit is provided through a variety of modes. and many systems utilize multiple service delivery methods. There are currently approximately 1,100 agencies which are recipients of UMTA Section 18 funding. The most recent information available, for FY 1984-85, indicates that 68.5% provide demand-responsive (paratransit) service. 54.5% provide fixed-route service, and 32.9% provide some variation of fixed-route service. Funding is often also provided from various human services and state and local sources. It should be recognized that, given a choice between fixed-route and demand-responsive service, virtually everyone would prefer the conveniences that the latter can provide. In a low-density area, demand-responsive is often the preferred service due to the spread-out distribution of the population. However, by comparison to fixed-route. paratransic is generally more labor-intensive and therefore can incur relatively higher costs. Further, the efficiency and productivity of the service is more depencent on human factors on the supply side. In particular, advance reservation paratransit services often do not experience the increased productivities that theory would suppose, due to the inflexibility that such scheduling incurs (e.g., an unexpected cancellation or "no-show" by a passenger often results in a now-empty vehicle deadheading along a predetermined route, rather than re-arranging planned stop assignments as would occur in an "on-call" or "immediate response" mode. In many rural areas and small cities, fixed-route transit is generally more efficient and cost-effective than specialized services. However, to be truly usable by persons with disabilities, considerations in addition to lift or ramp accessibility must be taken into the transit system's planning and funding -- including routing, scheduling, bus stop access, training, maintenance, and marketing/information services. If a transfer is required to complete a trip, and only one of two or three route segments is accessible, the trip is not likely to be taken at all. This is seldom taken into account in ridership projections or reports. page 2 In California, new bus purchases have been required to be accessible to wheelchair users uncer the provisions of Government Code Section 4500, enacted in 1971. Even with this long-standing commitment, only a relatively smail. number of systems have reached 100% access:bility. due to the long life-span of transit vehicles. As one example. Santa Rosa City Bus became fully accessible in FY 1983-34. That year, wheelchair ridership was 1.966 trips, or about .2% of total. By FY 1988-89, wheelchair ridership had grown. steadily to 10.930 trips. or .8% of total. Cver that time period, total transit ridership increased 34%, while lift usage increased by 456%. If accessibility were a standard feature on transit buses, manufacturers would be more able to predict market levels, and it is likely that unit costs could be lower. The "flip-flop" policy at the national level has negatively impacted the pricing, selection, and reliability of lift equipment. Frankly, many California transit properties are tired of the attitudes shown by other systems. Stucies in Seattle and Oakland have indicated that the attitude of management and policy Board members has a significant effect on how well accessible services are delivered and used. Over time, and given a fair chance, accessibility does work! The attached letter from the Fresno County Rural Transit Agency exemplifies this perspective. In contrast, the lack of a strong and consistent national mandate for accessibility has affected transit operators' choices on how service is delivered to persons with disabilities. A recent study from North Carolina A&T University surveyed transit properties submitting UMTA Section 15 reports for demand-responsive services. In the 1983 Section 15 Report, under USDOT's original (1979) "full accessibility" regulations, there were 112 systems reporting demand-responsive services; by the 1988 Section 15 Report, which (due to compilation and publication lags) covers operations under the more lenient "special efforts interim rules, the number had grown to 250 such systems. Cost reports which compare fixed-route and paratransit services for persons with disabilities are also often misleading. Most specialized services are available to "E&H" riders, and thus transport a significant number of elders, with eligibility based on age rather than difficulty or inability to use other public transit. This skews reported ridership levels and results in a lower cost per |