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
ACT OF 1989

Submitted By:
PAT PIRAS

San Lorenzo, California

September 20, 1989

26-421 0 90 - 11

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, paratransit is generally more labor-intensive and therefore can incur relatively higher costs. Further, the efficiency and productivity of the service is more dependent 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

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Piras testimony

segments is accessible, the trip is not likely to be taken at all. This is seldom taken into account 717 ridership projections or reports.

page 2

In California, new bus purchases have been required to be accessible to wheelchair users under 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% accessibility. 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. Over 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. Studies 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

trip than if only disabled riders were calculated. A 1982 study by staff of the Metropolitan Transportation Commission (San Francisco Bay Area) concentrated only on trips made by wheelchair users and concluded that "the total cost of accessibility is relatively modest compared to the total cost of all transit and paratransit services." Based on this methodology, it was estimated that the incremental cost of fixed-route accessibility was no more than 6% of capital costs and .1% of operating costs.

In order to effectively implement the intent of the Americans With Disabilities Act of 1989, two additional concerns are raised for the Committee's consideration:

a) In many communities, particularly in rural areas, existing paratransit services receive a significant level of funding support from human services, and, categorical programs. In order to sustain the levels of available transportation services, these non-UMTA funding sources should be required to be maintained, and coordinated with the public transit services.

b) The wide variety of wheelchairs and powered "scooter"-type mobility aids has created a legitimate safety concern for many transit operators. Although critical for individual mobility, research shows that most "scooter"-type wheelchairs are not designed, and are often unsuitable, for use on a moving transit vehicle. However, the purchaser is seldom informed of this usage constraint. USDOT coordination with the Department of Health and Human Services, which often funds such equipment purchases, is urged.

In conclusion, the denial to persons with disabilities of opportunities for full availability of transit services cannot be allowed to continue. Experience has shown that the combination of fixed-route accessibility, with supplemental paratransit, can meet the widest variety of personal needs and local conditions. Both types of service are needed. The enactment of the Americans With Disabilities Act of 1989, coupled with the appropriation of adequate mass transit funding, can ensure the delivery of these services.