SUMMARY
Provision of Alternative Services by Transit Agencies: The Intersection of Regulation and Program
Transit agencies are increasingly offering alternative service for ADA paratransit riders. In the transit industry lexicon, an alternative service is an on-demand or same-day transportation option subsidized by a transit agency and offered to its ADA paratransit-eligible riders. This option is an alternative to the next-day service of ADA paratransit.
Why Offer an Alternative Service?
According to the literature, echoed by the research conducted for this project, transit agencies provide alternative services for two primary reasons:
- To provide an additional mobility option that exceeds the minimum requirements of ADA paratransit
- To reduce the overall cost of providing ADA paratransit service
The on-demand/same-day nature of the alternative service—exceeding ADA paratransit’s requirement for next-day service—is popular with many ADA paratransit riders, and transit agencies understand this.
But transit agencies may be challenged to report the extent to which—or even if—the alternative service reduces overall costs for providing ADA paratransit. Understanding if the alternative service reduces costs requires two types of trip data: (1) “mode-shift” trips diverted from ADA paratransit to the alternative service and (2) newly “induced” trips riders take beyond the trips they would have taken on ADA paratransit, given the convenience and appeal of the on-demand alternative service.
Alternative Service Providers: From Taxis to TNCs
In addition to taxis, transit agencies are looking to ridesourcing companies, also known as transportation network companies or TNCs, to provide their alternative service. Compared to taxi companies—the providers for a small number of long-standing alternative service programs—the use of TNCs, either instead of or in addition to taxis, raises questions given TNCs use sedans and trip booking that requires a smartphone and credit or debit card. How does a rider who uses a wheelchair and needs accessible service get a trip? What if the rider does not have a smartphone? Or a credit or debit card? And is drug and alcohol testing required for drivers?
These are some of the issues underlying this study, which was structured around understanding how taxis, ridesourcing services, and other nondedicated service providers are being used for alternative services for individuals with disabilities.
The research was structured to answer three core questions:
- To what extent do alternative services for ADA paratransit riders reduce overall paratransit costs?
- To what extent do the alternative services, particularly those that use the new ridesourcing providers, meet the travel needs of ADA paratransit riders, especially those who use wheelchairs?
- What are the legal and regulatory issues that frame the planning, implementation, and operation of an alternative service? What should transit agencies address to ensure their alternative service complies with applicable regulation?
The Research Process
Research efforts involved:
- Identifying and explaining the regulation for alternative services. This includes federal laws and regulations from the ADA to Title VI to the FTA’s drug and alcohol testing requirements to National Transit Database (NTD) reporting, among others. The guide does not provide legal advice or formal instruction but explains what transit agencies need to consider and address to ensure compliance with applicable regulations and FTA guidance.
- A survey of 18 transit agencies’ alternative services to learn how the service was planned and implemented, the providers used, cost and use data, and the lessons learned for sharing with other transit agencies planning an alternative service.
- In-depth case studies of five of those alternative services.
- Interviews with providers of alternative services—three TNCs, a broker, and a large taxi company.
- Assessing the models and types of subsidies used for providing alternative services and the policies structuring the service, along with advantages and disadvantages.
- Collecting materials from the surveyed transit agencies, including contracts and RFPs for an alternative service, which may be helpful to other transit agencies planning an alternative service.
- Developing an Excel-based tool designed for two purposes:
- Helping to estimate costs and potential savings as part of planning for an alternative service.
- Calculating net savings from an existing alternative service by estimating savings from the mode-shift trips that would otherwise have been via ADA paratransit and comparing that figure with the subsidies paid out for the induced trips the alternative service “generates.”
What Did the Research Find?
Goals and Goal Achievement
- According to the survey, reducing costs for transporting ADA paratransit customers and providing a same-day or on-demand option for paratransit riders are primary goals, with safety the third primary goal.
- All but two surveyed transit agencies indicated they met their goals, with the remaining two reporting partial achievement.
Subsidy Method, Service Models, and Policies
- The most common service model is a provider-side subsidy with multiple providers.
- In this model, the rider typically pays a base fare, the transit agency subsidizes the remaining portion of the fare up to a certain amount, and the rider pays any overage beyond that (for longer trips).
- Reported advantages of a user-side subsidy model (the survey found two) included less administrative effort for the transit agency and greater transportation flexibility and choices for riders.
- In this model, the transit agency matches funds the rider puts on their fare payment card up to a certain amount per month.
- Subsidy amounts are typically capped. The more common subsidies for provider-side models range from $9 to $18 of the trip cost, with $15 the most common. Two agencies provide a much higher subsidy per trip: $27 and $38. Matching policies on the two user-side subsidy models in the survey were a 1-to-1 match and a 4-to-1 match.
- Alternative services typically begin as pilots, particularly if using TNCs.
- Service policies vary considerably, though there are several common approaches, including:
- Decentralized reservations: riders call providers directly
- Service area extends beyond ADA’s required ¾-mile corridors
- Trip limits are imposed for provider-side subsidy models
Wheelchair-Accessible Service
- Wheelchair-accessible service is necessary to ensure compliance with the ADA. To meet the ADA’s service equivalency requirements, service response times for riders needing a wheelchair-accessible vehicle (WAV) must be equivalent to those for riders using a sedan.
- Wheelchair-accessible service is provided in different ways:
- By the primary provider(s)
- If not by the primary provider(s):
- Transit agency requires primary provider(s) to provide accessible service through a third party
- Transit agency contracts directly with a WAV provider, e.g., a nonemergency medical transportation (NEMT) company
- Based on data or estimates reported by seven transit agencies, trips using WAVs were 3.6–8.2% of the total reported alternative service trips, with one exception: one transit agency reported WAV trips at 24.1% of its alternative service trips.
Safety and Insurance
- Driver training requirements
- Some transit agencies included driver training requirements in contracts with providers.
- Others reported no special training other than what is required by the providers or their regulatory authority.
- Drug and alcohol testing
- Half of the transit agencies reported that alternative service drivers meet federal drug and alcohol testing requirements. All but two of these use taxis. The remaining two use UZURV.
- Insurance requirements
- The transit agencies commonly set insurance requirements above those set by the state or local regulatory entity and also require to be named as an additional insured.
Data and Data Sharing
- Data sharing remains an issue. While more than half the transit agencies reported receiving requested data, the rest reported they did not.
- The interviewed providers reported they provide all requested data.
- Some of the transit agencies reported including data on their alternative services with annual NTD reports, however such data is to be reported only if the service meets the federal definition of public transportation and is shared-ride.
Regulatory Environment
- Transit agencies reported that providing equivalent service for riders who need accessible service as required by the ADA, particularly equivalent response times, was a challenge when planning and implementing their alternative service.
- There is uncertainty about the FTA’s taxicab exception and NTD reporting.
Service Equivalency
- The alternative services include wheelchair-accessible service but not all transit agencies seem to report data for WAV trips. On-time performance (OTP) for WAV trips is needed to measure service equivalency for response time.
- One case study agency reported it periodically gets response time data for WAV trips, with response times averaging 10 to 15 minutes compared to the anecdotal average of 5 minutes for non-WAV trips.
Evaluation of Alternative Services
- Evaluation is focused on overall costs for providing transportation for ADA paratransit riders, with data collected on:
- Costs of the alternative service
- Passenger trips provided by the alternative service
- Data relevant to evaluating service equivalency for response time is not commonly collected.
Method to Estimate Cost Savings for ADA Paratransit
- Half the surveyed transit agencies reported having a method to estimate cost savings, but did not provide details.
- Based on the case studies, the method to estimate cost savings is typically a straightforward comparison between cost per trip on the alternative service versus cost for those same trips on the ADA paratransit service. This only accounts for mode-shift trips and not for costs associated with new induced trips on the alternative service. That is, these transit agencies’ cost comparison methods assume all trips on the alternative service are mode-shift trips.
- One of the case study agencies, however, has a documented method to estimate savings by comparing the reduction in cost from mode-shift trips to the additional cost of subsidizing induced trips.
Input from Riders
Rider input was very limited, though offers some insight:
- Riders who use the alternative service:
- Are a mix—some have switched all trips to the alternative service and some still use ADA paratransit for some trips
- Often use the alternative service rather than ADA paratransit for their return trips, especially after medical appointments
- Like the service attributes, including the direct, no-shared-ride trips; service reliability; and same-day trip booking
- Riders who do not use the alternative service:
- Do not know about the alternative service
- Do not want to pay a higher fare for the alternative service
Were the Three Research Questions Answered?
To what extent do alternative services for ADA paratransit riders reduce overall paratransit costs?
The research suggests alternative services provide at least some cost savings based on cost per subsidized trip versus cost per ADA paratransit trip. In the case of the one transit agency with a more complete method, it calculated a 3% overall savings while total ridership (on ADA paratransit plus the alternative service) increased by over 50%.
Capping the subsidy for alternative service trips that is significantly less than the cost for ADA paratransit trips and limiting the number of trips a rider can take helps protect a transit agency from potential “new” costs associated with induced trips on the alternative service. However, to fully estimate if the alternative service reduces overall ADA paratransit costs, the method needs to differentiate between mode-shift trips and induced trips. Costs for induced trips, depending on the subsidy level and possible trip limits, may be more than any savings associated with mode-shift trips.
To what extent do the alternative services, particularly those that use the new ridesourcing providers, meet the travel needs of ADA paratransit riders, especially those who use wheelchairs?
Alternative services meet more spontaneous travel needs of ADA paratransit riders than next-day ADA paratransit. For three of the case study agencies, the alternative service responds to specific requests by the disability community for a same-day service.
While very limited, rider input gathered through the research found riders like the direct, no-shared-ride trips, the ability to schedule same-day trips, and service reliability.
For riders who use wheelchairs, the alternative services include an accessible component. However, the research findings estimate WAV trips are a smaller proportion of total alternative service trips than ADA paratransit: 3.6–8.2% (with one exception of 24.1%) of the total reported alternative service trips versus the 15–25% typical for ADA paratransit. The research team lacks adequate data on service equivalency for riders who use wheelchairs and robust rider feedback (and recognizes the small data set for the research project), so this study does not provide answers as to whether riders needing a WAV use the alternative service at lower rates than ADA paratransit because of personal preferences or because the WAV service is less timely or available, so service quality is deterring use.
What are the legal and regulatory issues around planning, implementing, and operating an alternative service? What should transit agencies address to ensure their alternative service complies with applicable regulation?
The research project has identified and documented legal and regulatory issues transit agencies should address for their alternative services. The research found certain issues matter more than others and deserve more attention. These include the taxicab exception, service equivalency for riders who use wheelchairs, and NTD reporting.
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