CHAPTER 6
Access

SUM services have elevated the focus on service availability for transportation-disadvantaged groups, such as older adults, low-income individuals, individuals with disabilities, or individuals who live in rural areas. There are both success stories and lessons learned among the multiple ongoing and recent pilot deployments of SUM services in rural regions nationwide. The following access topics are covered in this guide:

• Accessibility and equivalent service.
• Technology and digital access.
• Service provisions for all groups.
• Compliance with federal regulations.
• Partnerships and coordination.

By focusing on these five key areas, rural transportation providers can implement SUM services that are accessible for all community members and provide reliable and convenient access to transportation.

Why This Is Important

Implementing SUM services in rural areas can help ensure that all community members have mobility options, providing access to jobs, educational opportunities, and healthcare facilities. SUM services can help reduce barriers to access for unbanked individuals. For example, some services require users to have a smartphone and a credit or debit card, which can limit access for people with disabilities, low income, or who are younger, older, or less educated. SUM services can also promote economic development by providing access to transportation services for all user groups.

Agency Examples

City of Battle Creek, BCGo Microtransit

Battle Creek Transitʼs BCGo service, which is an on-demand microtransit service available throughout Calhoun County, Michigan, facilitates access to and from the rural areas of the county via an app-scheduled system. The access lessons learned are as follows:

• The BCGo service was designed and implemented to be fully ADA accessible, and was focused on areas without current services.
• To support access to service for cash payers, the system allows riders to request to pay cash (to be collected by drivers) at the time of the reservation or use pre-paid debit cards to either pay for a single trip or add stored funds in their BCGo account. However, discounted

• fares for people with low incomes, older adults, people with disabilities, and youth have not been implemented.
• BCGo is working to set up a system that would allow social service organizations or employers to pay fares on behalf of their clients via an invoice.
• For people who do not primarily speak English, the Liftango app is compatible with built-in smartphone language translation systems, which is one of the reasons the agency encourages users to request trips via the app. The BCGo customer service phone line can also provide translation support if needed.
• When BCGo launched, approximately 80 percent of riders requested trips via phone calls, but through direct education about the app and its benefits, the agency reduced this to 30 percent. This change helps maintain high-quality service for those who need the phone option while providing others with the additional flexibility and accessibility inherent to smartphone apps.

Missouri HealthTran

Missouri HealthTran helps people in 42 Missouri counties make healthcare-related trips using all the available area transportation services. The on-demand service relies on volunteer drivers who use their personal vehicles to provide rides and are then reimbursed for mileage. The accessibility lessons learned are as follows:

• One key component of the service that addresses accessibility is that the service is free to riders, with the fare paid for by the medical care provider. All billing is conducted by Community Asset Builders.
• Working with Medicaid can be a challenge.

City of Wilson, North Carolina, RIDE

One of the cities participating in the North Carolina Department of Transportation (NCDOT) Mobility for Everyone Everywhere in North Carolina (MEE NC) program provides the following lessons learned with respect to accessibility:

• The City of Wilson made slight adjustments regarding accessibility. One such adjustment was providing, by default, a wheelchair accessible vehicle (WAV) for any person with a disability who requested a RIDE trip. There have been instances where a visually impaired individual has requested a RIDE trip, could use a vehicle that was not wheelchair accessible, and did not want to take an ADA-accessible WAV away from someone that might need it more. In these instances, the visually impaired rider utilized a vehicle that was not wheelchair accessible.
• Some people with disabilities need door-to-door service but do not require a WAV vehicle and do not want to tie them up. The solution was for these riders to call the customer service line and let them know they do not need a WAV but still need door-to-door service.

Shift Bike, Eagle County, Colorado

Shift Bike, an electric bikeshare program in Eagle County, Colorado, provides the following lessons learned for accessibility:

• Shift Bike has a membership level available to riders who demonstrate a need for financial assistance. Proof of financial assistance need is submitted through the Shift Bike app.
• The focus on locating stations near deed-restricted affordable housing and workforce housing is also driven by goals to provide accessibility to all groups. Increased utilization of these stations and memberships through better marketing efforts is a soft goal of the partners.

• Currently, there are no accessible/adaptive e-bikes in the Shift Ride fleet. Partners have been in conversation with the vendor about adding some of these vehicles into the fleet; an additional step is figuring out where key station locations for users in need of these vehicles should be.
• The vendor for Shift Bike makes informational materials available in Spanish and offers memberships (at $25) for access to the entire system.
• Shift Bikes do not come with helmets; the town has worked with a local public health organization to organize helmet giveaways at events or give them out at businesses near stations.

Winnebago and Waupaca Counties, Wisconsin, Catch-a-Ride (Lutheran Social Services)

The Catch-a-Ride programs in Wisconsinʼs Winnebago and Waupaca Counties provide affordable transportation options for workers with low incomes in those areas as well as the general public in Waupaca County. Their lessons learned are as follows:

• The fare structure for the Winnebago Catch-a-Ride system has proven to be challenging for people with very low incomes, especially as the rates increase over the time that eligible riders participate in the program. Despite these challenges, the agency cannot reduce the service costs without risking the programʼs overall sustainability.
• To enhance the affordability of the Waupaca Catch-a-Ride service, a voucher program is planned. To be eligible for trip vouchers, riders must show proof of household income that is at or below 250 percent of the federal poverty level. These riders will receive trip vouchers that reduce the cost of each trip from $3 to $2 for a period of 90 days.
• Waupaca County has a large Hispanic population. In an effort to ensure these members of the community knew about the Catch-a-Ride program and could access it if desired, Make the Ride Happen (MTRH) staff worked with Hispanic leaders to conduct outreach. Connections were made via chamber of commerce members, a local church, and the staffʼs personal contacts. Despite the outreach, it appears that this community is still hesitant to participate in the program. Anecdotally, MTRH thinks that the requirement to share some personal information (name, destination address, digital payment details, employment information if applying for vouchers) may be intimidating for the Hispanic community.
• Regarding language access, the Feonix Mobility Rising app initially had difficulty with Spanish language translation, but that was fixed in the early stages of service deployment. The call center also has access to translation services if needed. Language needs in the area for people who do not speak English regularly include Spanish and Hmong, but other languages are expected to become more prevalent as people immigrate from other countries (e.g., Myanmar, Afghanistan, and Iran).

Wood County, Wisconsin, Bike Share Programs

Wood County Health Department in Wood County, Wisconsin, manages River Riders Bike Share and Marshfield Community Bike Share. The access lessons learned include the following:

• The county has goals to make the program accessible for residents by keeping the price down for rides; this has been made possible through local grant funding from colleges and non-profits. The program currently uses a pay-as-you-go model for fees (at $1 per hour), which has proven to be more popular with riders than the previous iteration, which had memberships. However, this has complicated access for people who are unbanked; a workaround solution from the technology vendor is for these riders to download a separate smartphone application, go into the library, and ask for assistance from a staff member to also download the application and

• help check out the bike. This workaround structure has a high learning curve for both riders and employees alike, as training is needed on how to check out bicycles in this manner.
• The pay-as-you-go model has proven to be more popular for the program than previous versions with memberships, so there is not likely to be a change from it. The county has considered how to work in promotion codes or credits based on volunteer hours to help encourage utilization. There are currently no other payment levels available for low-income users, but they are being explored. Ideally, the program could help cover the cost of rides for low-income users in the long term.
• The county is looking to increase customer education campaign efforts through bike events in order to encourage further usage of the systems. The program has had some events in the past offering free rides from community events and promotional giveaways for attendees; some community events have been in conjunction with the local police departments.
• The county has a few accessible bikes in the system; two are tricycles and one is a tandem side-by-side bike (the latter is popular and has had issues with vandalism).

Federal Regulations

Service operators and technology companies can assess their understanding of the ADA and Title VI requirements, as well as their historical ability to meet these requirements, through a structured and comprehensive approach. First, ADA and Title VI compliance policies and procedures, and documentation on accessibility and non-discrimination practices, should be documented. Second, past performance reports and compliance audits, along with metrics such as the number of ADA-compliant vehicles and response times for service requests, should be reviewed. Third, interviews with both key staff and customers can be conducted to determine how accessibility is being addressed. Of particular importance is determining compliance, assessing mechanisms for collecting and addressing feedback from customers, and reviewing the process for handling customer complaints and resolutions. Fourth, staff training and training materials should be reviewed to ensure that access is an element of training programs. Fifth, the accessibility of technology platforms should be evaluated. Sixth, establishing an advisory committee to provide ongoing guidance on accessibility and engaging with advocacy groups should be considered. Finally, an action plan to continuously monitor and improve accessibility should be developed.

ADA Requirements

Confirm ADA requirements for the specific service types (e.g., response time, fares, hours and days of service, restrictions or priorities based on trip purpose, availability of information and reservations capability). Further, data on response times should be collected and analyzed, and periodic audits should be conducted to verify compliance.

With the availability of information and reservations capability, you should ensure that information about services is accessible in formats such as large print, Braille, and audio. Also, websites and digital platforms should be verified to show that they comply with accessibility guidelines. Further, reservation systems that accept bookings during normal business hours and up to 14 days in advance should be ensured, and the process should be tested for accessibility.

There are several additional steps that can be used to confirm compliance with the ADA service criteria, as follows:

• Perform a comprehensive self-assessment using ADA checklists and guidelines.
• Consult with disability advocacy groups and hold public meetings for feedback.
• Regularly review and update policies to reflect current ADA requirements.

• Provide ongoing training for staff on ADA requirements and best practices.
• Establish a system for continuous monitoring and generate regular compliance reports.
• Schedule internal and external audits to verify compliance and make necessary improvements.
• Maintain detailed records of compliance efforts, including policies, training materials, and audit reports.

Create standardized processes and practices to regularly assess any constraints on capacity or service availability. A process for collecting and managing data should be developed. The implementation of automated systems (e.g., GPS tracking, automated dispatch) to collect real-time data on vehicle locations, trip requests, and service performance can be very helpful. This can be supplemented with manual data collection methods, such as driver logs and customer feedback forms. Also, data from various sources should be integrated into a centralized database to facilitate comprehensive analysis.

Daily monitoring processes should be created to track real-time data and identify immediate issues. Regular reports (e.g., daily, weekly, monthly) should be generated to monitor key metrics, identify trends, and compare against benchmarks. Also, if possible, you can use data visualization tools to create dashboards and visual reports.

In terms of capacity and service availability, regular assessments (e.g., quarterly, biannually) should be conducted to evaluate capacity and service availability. Also, data should be analyzed to identify peak demand periods and areas with high service requests, and service coverage should be assessed to ensure all areas within the service zone are adequately served.

Regular customer surveys should be conducted to gather feedback on service availability and overall satisfaction. Also, feedback from drivers should be collected on operational challenges and service availability issues. Engagement with community organizations and stakeholders to gather input on service needs could be helpful.

If issues arise, the root cause analysis should be conducted to determine the underlying factors of identified constraints. Further, the impact of issues on service performance and rider satisfaction should be assessed. If constraints are identified, action plans should be developed to address these constraints, including specific steps, timelines, and responsible parties. Further, solutions should be implemented and progress monitored, adjusting action plans as needed.

As mentioned in other guidance, continuous improvement and adaptation are critical. Feedback loops should be created to use lessons learned for future service planning and operations. Regular training for staff on data collection, analysis, and problem-solving techniques should be conducted, and standardized processes should be periodically reviewed and updated to ensure they remain effective and relevant.

Finally, documentation and standard operating procedures (SOPs) are critical, including the development and documentation of SOPs for data collection, reporting, analysis, and capacity assessments. Also, the implementation of training programs for staff to ensure familiarity with SOPs should be considered along with regularly reviewing and updating SOPs to reflect changes in technology and service requirements.

Title VI Requirements

Assess the planned service to ensure Title VI requirements are met, starting by understanding those requirements. A Title VI analysis should be conducted including the identification of service area demographics using U.S. Census data and other tools to understand the racial, ethnic, and income composition; engagement with community members through public meetings, surveys,

and focus groups; and comparison of planned service levels (e.g., frequency, coverage, hours of operation) in minority and low-income areas to those in non-minority and higher-income areas to ensure no disproportionate burden.

Developing a Title VI plan is another step in the assessment. The plan should include a policy statement affirming the commitment to non-discrimination; establish procedures for filing Title VI complaints and ensure public accessibility; inform the public of their rights under Title VI and how to file a complaint; and develop a language assistance plan for individuals with limited English proficiency. Service monitoring and reporting is needed as well, along with training and awareness, documentation and record-keeping, and the potential use of technology and tools to map service areas and demographic data, assess service performance, and identify issues.

Develop mitigations for any Title VI requirement not met via initial service plans and re-evaluate until all requirements are met. The following provides a step-by-step approach. First, by conducting a thorough review of the Title VI analysis to identify specific areas where requirements are not met, and using demographic data, service performance metrics, and community feedback to pinpoint disparities, non-compliance issues can be identified. Second, stakeholder engagement is critical, consisting of meetings with affected communities and advocacy groups to gather input on the issues and ensuring that the engagement process is inclusive, providing language assistance and accessible meeting formats as needed. Third, the development of mitigation strategies can include the following:

• Modifying routes, schedules, and service frequencies to ensure access for minority and low-income populations
• Implementing fare structures that do not disproportionately impact low-income riders, such as discounted fares or fare capping
• Enhancing language assistance services for individuals with limited English proficiency, including translated materials and bilingual staff
• Increasing outreach efforts to inform affected communities about available services and their rights under Title VI
• Investing in infrastructure improvements in underserved areas, such as better bus stops, shelters, and accessibility features.

The implementation of mitigation measures should consist of developing a detailed action plan with specific steps, timelines, and responsible parties for each mitigation strategy. Further, the necessary resources must be identified, including funding and personnel, to implement the mitigation measures. The impact of the implemented mitigation measures must be continuously monitored using performance metrics and community feedback. Also, regular evaluations should be conducted to assess whether the mitigations are effectively addressing the identified disparities.

If the initial mitigations do not fully address the issues, the service plan should be re-evaluated and, if necessary, additional or alternative strategies should be developed. Also, stakeholders should be engaged again to gather feedback on the effectiveness of the mitigations and any remaining concerns.

Detailed records of all mitigation efforts should be maintained, including community engagement activities, implemented measures, and evaluation results. If necessary, reports to relevant authorities, such as the FTA, detailing compliance efforts and outcomes, should be prepared and delivered. A continuous improvement process should put in place by establishing a process for ongoing assessment and improvement to ensure that Title VI compliance is maintained over time, and by regularly updating the Title VI plan and related policies to reflect changes in service, demographics, and regulatory requirements.

Accessible Vehicles

Further evidence is needed beyond simple vehicle provision to demonstrate that WAVs are being provided consistently and at comparable service times to non-WAVs for requested trips. To demonstrate this, consider the following evidence and strategies:

• Performance metrics: Collect and analyze data on average wait times and travel times for both WAV and non-WAV trips, ensuring minimal discrepancies. Track the percentage of on-time pickups and drop-offs for WAV trips compared to non-WAV trips.
• Service availability: Map the geographic coverage of WAVs to ensure they are available across the same service areas as non-WAVs. Monitor the availability of WAVs during peak service times to ensure they are as accessible as non-WAVs.
• Customer feedback: Conduct regular surveys with riders who use WAVs to gather feedback on their experiences, including wait times and service quality. Track and resolve complaints related to WAV service times and availability promptly.
• Third-party audits: Engage independent auditors to periodically review and report on the performance of WAV services compared to non-WAV services. Implement mystery rider programs where individuals with disabilities request WAV services to assess the consistency and quality of service.
• Service agreements: In contracts with transportation network companies (TNCs), include specific service level agreements (SLAs) that mandate comparable service times for WAV and non-WAV trips, and monitor these SLAs. Include penalties for non-compliance and incentives for meeting or exceeding SLA targets.
• Technology integration: Use real-time tracking and reporting tools to monitor the availability and performance of WAVs, ensuring dispatch systems prioritize WAV requests appropriately. Provide transparent access to performance data for stakeholders, including advocacy groups for people with disabilities.
• Training and support: Ensure that drivers of WAVs receive specialized training to handle the needs of riders with disabilities efficiently and respectfully. Offer dedicated customer support lines for riders with disabilities to address any issues promptly.
• Community engagement: Form advisory committees with representatives from the disability community to provide ongoing input and oversight on WAV service performance. Hold public forums to discuss WAV service performance and gather direct feedback from users.

Through subsidizing rides and utilizing existing fleets with WAVs in for-hire ride service platforms, SUM services inclusive of TNC can help improve accessibility for riders with disabilities. Partnerships with TNCs to offer subsidized rides for riders with disabilities can be facilitated through government funding, grants, or public-private partnerships. Also, voucher or discount programs can be implemented specifically for riders with disabilities to reduce the cost of rides. Further, financial incentives can be provided to TNC drivers who operate WAVs to increase the availability of accessible vehicles. Finally, agencies can work with TNCs to integrate existing WAV fleets from paratransit or other accessible transportation services into their platforms, ensuring a larger pool of accessible vehicles.

Commingling of ADA paratransit and general public customers in microtransit can be a solution, but concerns about wait time and travel time equivalency between different riders may need to be addressed. If this strategy is employed, ensure ADA paratransit trips are given priority in scheduling to meet mandated service requirements and minimize wait times. Agencies should also designate specific time windows or service areas for ADA paratransit riders to ensure timely service and allow flexible scheduling options to accommodate the varying needs of different rider types. Clearly communicate service policies and expectations to all drivers, staff, and riders, and engage with ADA riders and advocacy groups to understand their needs and concerns.

Service Provision

If a new service is replacing a previous service, plan for mitigations that minimize or eliminate barriers to access for riders and incorporate specific user needs/context. Actions that can be taken include the following:

• Identify areas where the previous service was lacking or had barriers to access. This includes understanding the specific needs and contexts of the riders who were using the previous service.
• Communicate with current riders, community groups, and other stakeholders to gather feedback on the previous service and understand their needs and concerns. This can be done through surveys, focus groups, and public meetings.
• Create a detailed plan that outlines how the new service will address the identified gaps and barriers. This plan should include specific actions to ensure a smooth transition for riders, such as providing clear information about the new service, training for staff, and ensuring that all necessary resources are in place.
• Make sure the new service is accessible to all riders, including those with disabilities. This may involve ensuring that vehicles are wheelchair accessible, providing information in alternative formats, and offering assistance for those who need it.
• Implement a pilot phase for the new service to test its effectiveness and gather feedback. Use this feedback to make necessary adjustments before fully rolling out the service.
• Clearly communicate the changes to all riders, including how the new service will work, any new features or improvements, and how it will benefit them. Use multiple channels to reach all riders, including digital platforms, printed materials, and in-person events.
• Continuously monitor the new service to ensure it is meeting the needs of riders and addressing the barriers identified. Use performance metrics and rider feedback to make ongoing improvements.

Develop and initiate stakeholder planning process, which can consist of identifying key stakeholders, such as local government officials, transit agencies, community organizations, and representatives from key population groups (e.g., older adults, persons with disabilities); establishing advisory groups, focus groups, and public forums to gather diverse perspectives; using surveys to collect input from a broad range of community members; and organizing and holding public meetings to discuss plans and obtain feedback.

In terms of engaging internal stakeholders on zone planning, it is critical to ensure coordination among different departments within the agency. Training should be provided for staff on the importance of inclusive planning and the specific needs of different community groups. Internal stakeholders should be kept informed with regular updates and be involved in decision-making processes.

Look at the equivalence between SUM service and others with respect to the fare structure, availability of accessible vehicles, and the provision of service to all areas of a zone. In terms of the fare structure, dynamic pricing models based on demand, distance, and time of day, as well as subscription models, discounts, and pay-as-you-go options can be used. Also, flat rates, monthly or annual passes, and discounted fares for older adults, students, and persons with disabilities can be considered.

In terms of the availability of accessible vehicles, this availability can vary since service can be provided by third-party mobility service providers. Offering on-demand accessibility features that comply with the ADA can be an issue. However, more traditional transit services (e.g., paratransit) tend to provide more consistent availability of accessible vehicles due to compliance with the ADA.

In terms of service coverage, SUM services should offer flexible coverage areas and dynamic routing but may have service gaps in less profitable or low-demand areas, especially in rural areas.

More traditional transit services operate on fixed routes and schedules, which aim to provide coverage within designated service areas, including underserved areas.

Helping Riders

Agencies implementing a new SUM service need to train staff on travel training, including customer-facing smartphone apps with the service, and scheduling/reservations/call center staff on technology and messaging with customers. These actions can be accomplished by considering several steps.

Developing customer training programs that include hands-on practice sessions and real-world scenarios will assist with the use of technology. Conducting regular workshops and refresher courses to keep staff updated on new technologies and best practices will help to reinforce their skills and knowledge. User-friendly training materials, such as step-by-step guides, video tutorials, and FAQs, can be created to assist staff in learning and troubleshooting. Role-playing and simulation exercises can be used to help staff practice customer interactions and problem-solving in a controlled environment.

Feedback mechanisms by which staff can share their experiences and challenges can be used to continuously improve training programs. Ensuring that all staff members (including those in scheduling, reservations, and call centers) are cross-trained on the technology and customer service protocols helps ensure a consistent and seamless experience for customers. In addition, establishing a system of ongoing support and mentorship where experienced staff can assist newer employees in mastering the technology and customer service skills should be considered.

Consider special staff members (e.g., “mobility navigators”) to help assist riders uncomfortable with technology. These navigators can provide personalized support and help bridge the gap for those who struggle with using apps or other tech-based services. Finally, providing accessible alternatives for riders who cannot use technology, such as a simple phone number for booking rides, should be considered. Staff should be trained on how to handle these alternative methods.

Agencies can look at SUM as an opportunity to improve accessibility for persons with disabilities and provide options for spontaneous trip requests. Microtransit services can offer flexible and on-demand transportation options, which are beneficial for individuals with disabilities who may require more adaptable transit solutions. For micromobility, distribute adaptive vehicles, such as adult tricycles at needed locations (such as centers for adults with intellectual disabilities).

Implement accessible complaint processes, subsidize services for people with disabilities, and create call centers that can act as information hubs as well as support trip booking needs. Both online and call-in systems are necessary for on-demand service scheduling to be accessible. Smartphone apps need to be accessible for people with visual disabilities and accommodating for people with cognitive disabilities.

Establishing a fare structure that accommodates the diverse budgetary needs of riders and is sustainable is crucial to SUM. These can include distance-based fare structures that help balance affordability with operational costs. Income-based discounts (e.g., household income) can be considered; for example, riders with household incomes below 150 percent of the federal poverty level could receive a 50 percent discount. Voucher programs for low-income riders could be introduced, with eligible riders receiving vouchers that reduce the cost of each trip

for a specified period. Finally, partnering with local businesses and community organizations to subsidize fares for specific groups, such as older adults or individuals with disabilities, can be considered.

Replicability and Scalability

The replicability and scalability of accessible SUM services can be determined from the various pilot programs and initiatives that have taken place across multiple rural regions. The following factors should be considered:

• Ensuring services are ADA-compliant and accessible to all, including those with disabilities, is crucial. This includes providing accessible vehicles, alternative payment methods, and language support.
• Programs like Battle Creek Transitʼs BCGo and Missouri HealthTran show that targeting underserved populations and offering free or subsidized rides can significantly improve access.
• Utilizing apps and digital platforms to schedule rides and provide information can enhance service efficiency. However, it is essential to offer alternatives for those without access to smartphones or the internet.
• Implementing fare structures that consider the financial capabilities of low-income individuals and offering discounts or vouchers can promote accessibility for all user groups.
• Adhering to ADA and Title VI requirements ensures non-discrimination and accessibility, which are vital for replicability.
• Collaborating with local organizations, businesses, and government agencies can provide the necessary support and resources for scaling services.

By focusing on these areas, rural transportation providers can replicate and scale SUM services to ensure all rural community members have reliable and convenient access to transportation. The success stories and lessons learned from various programs highlight the potential for broader implementation and adaptation to different contexts.

Key Takeaways

• SUM services aim to provide accessible transportation for all individuals, including older adults, low-income individuals, people with disabilities, and those in rural areas.
• Ensuring access to transportation services can reduce barriers for all individuals and promote economic development.
• Agencies must ensure compliance with ADA and Title VI requirements, including providing accessible vehicles, comparable service levels, and non-discriminatory practices.
• Agencies should continuously monitor and improve access through regular assessments, stakeholder engagement, and feedback mechanisms.
• Staff training on technology and customer service is essential, along with providing support for riders uncomfortable with technology.
• Establishing sustainable fare structures, including income-based discounts and voucher programs, is crucial to making SUM services accessible to all.

Additional Resources

The agreement templates described in Appendix B, including RFIs, RFPs, Service Agreements, and the Intergovernmental Agreement, contain elements that ensure the accessibility of SUM services. The RFI and RFP templates help agencies ensure access for transportation-disadvantaged populations; technology platformsʼ accessibility and capabilities to support multiple languages;

user-facing activities which can help users who may need additional support; compliance with the ADA, Title VI and Civil Rights Act; and access to people without access to or familiarity with smartphones. The Service Agreement and Intergovernmental Agreement templates provide language that ensures that customers with disabilities have access to the service; ensures that individuals who may not have access to modern technology can still use the service; requires that accessible/adaptable vehicles are available; and ensures that those with special needs have access to transportation.

The Implementation Checklist described in Appendix C covers steps such as regulatory readiness, which includes compliance with the ADA and Title VI, rider needs, and community and stakeholder engagement.