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Demystifying ADA complementary paratransit

Yesterday, I shared why access to public transportation is important to me as a person with a disability who cannot drive and who relies on the fixed route service.

Photo by Transportation for America.

In addition, I explored why access to public transportation is equally important to people with disabilities who rely on ADA complementary paratransit service (MetroAccess). I expressed concern about cutting MetroAccess service back to the minimum required service area without having adequate, affordable, and accessible alternative transportation options in place.

A number of commenters asked questions or gave opinions about ADA complementary paratransit, which for WMATA is MetroAccess. Easter Seals Project ACTION has an excellent Q&A section on this topic. Here are excepts from their site which are relevant to our discussion, reprinted with permission:

What is ADA complementary paratransit?

The Americans with Disabilities Act (ADA) requires public transit agencies that provide fixed-route service to provide "complementary paratransit" services to people with disabilities who cannot use the fixed-route bus or rail service because of a disability. The ADA regulations specifically define a population of customers who are entitled to this service as a civil right. The regulations also define minimum service characteristics that must be met for this service to be considered equivalent to the fixed-route service it is intended to complement.

Service characteristics: In general, ADA complementary paratransit service must be provided within ¾ of a mile of a bus route or rail station, at the same hours and days, for no more than twice the regular fixed route fare.

What are the three categories of eligibility for ADA complementary paratransit?

Category 1: People who can't navigate travel on the bus or train, even if it's accessible, because of a disability

This category includes people who are unable, due to a mental or physical impairment (including a vision impairment), to board, ride, or disembark from an accessible bus or train without assistance. For example:

  • People with cognitive disabilities, if they do not know where to get off the bus or how to go to their destination from the bus stop
  • People who are blind or who have low vision, if they don't have the travel skills needed to navigate the route to their destination.
  • A person with a visual impairment that allows him/her to see well enough to travel independently during the daytime but not at night.
Category 2: People who need an accessible bus or train.

This category includes people who use wheelchairs and other people with disabilities who can use an accessible vehicle but who want to travel on a route that is still inaccessible (not served by accessible buses or accessible trains and key rail stations).

Category 3: People who have a specific disability-related condition

This category includes people who have a specific disability-related condition that prevents them from traveling to a boarding location or from a disembarking location. Environmental barriers (distance, terrain, weather) or architectural barriers not under control of the transit agency (such as lack of curb ramps) that prevent an individual from traveling to or from the boarding or disembarking locations may form the basis for eligibility. For example:

  • A person who uses a wheelchair may be able to negotiate a trip to the bus stop up a moderately sloped hill on a summer day, but not in the winter after a heavy snowfall.
  • A person may be eligible if architectural barriers present safety hazards on the only route to the train station or bus stop.
  • A person who walks with a cane and would need to travel 3/4 mile to the bus route, but she cannot walk that great a distance.
  • People with disabilities that affect them very differently over time, such as multiple sclerosis. During some periods, they are able to go to the bus stop or train station. During other periods, they are not able to do so.
All three categories include people who may be able to ride fixed-route transit for some, but not all of their trips.

What is conditional eligibility?

In terms of ADA complementary paratransit, conditional eligibility (also known as trip-by-trip eligibility) refers to paratransit eligibility for some trips, but not all, as the customer's ability to use fixed-route service is likely to change with differing circumstances. Conditional eligibility may be appropriate for individuals who can reasonably be expected to use fixed route service for some trips (when barriers that prevent travel are not present), but who cannot be expected to use fixed route service under other conditions. A few examples of barriers and conditions that may prevent an individual's use of fixed route service include:

  • Weather conditions may prevent use of fixed route service by someone with a temperature sensitivity.
  • A person who is able to navigate the fixed route system for some trips. (See note below on travel training.)
  • A person with a variable condition (for example, multiple sclerosis, HIV disease, or the need for kidney dialysis) may be unable to ride fixed route service depending upon their condition at the time of the trip.
  • Barriers in the environment (such as lack of a sidewalk or curb cuts) that prevent a person from getting to or from a bus stop, or from using the bus stop (if a lift cannot be deployed at the bus stop because it lacks a 5' by 8' landing area, for example) would prevent use of fixed-route service for that trip.
Travel Training: Many people who cannot negotiate the entire fixed route system can be travel trained for certain trips. Typically, training is provided for trips that the person makes frequently, such as to work or school. These individuals would only be ADA paratransit eligible for trips they have not been trained to make on fixed route. As part of the application and determination process, it should be determined if such training has been provided. Individuals cannot, however, be required to participate in travel training. The public entity may choose to offer training and may encourage individuals to take advantage of this service. Until the individual takes advantage of this service and is adequately trained, paratransit service must be provided.

Can a person with a disability who lives outside of the designated ADA complementary paratransit service area apply for ADA paratransit eligibility?

Yes. Individuals who live outside of the ADA complementary paratransit service area, or even outside of the transit agency's jurisdiction, can still apply for ADA paratransit eligibility. Their applications should be accepted and considered. This includes persons visiting from other transit districts as well as persons who live just beyond the borders of the transit agency or in other areas where no public transit service is provided. These persons may be able to get to the ADA paratransit service area on their own and would then be able to ask for paratransit service.

Penny Everline has served on transportation advisory groups at the local, regional, and national levels including the WMATA Riders' Advisory Council, the Fairfax Area Disability Services Board Transportation Committee, the Transportation Planning Board's Access for All Advisory Committee, and the Pedestrian and Bicycle Information Center (PBIC) National Work Group. She recently left her job with Easter Seals Project ACTION, a national training and technical assistance center funded through the Federal Transit Administration, to focus on advocacy work at the local/regional level. She holds an MSW degree and teaches at George Mason University. 


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How hard would it be to add more bus service to go into neighborhoods instead of just main roads especially in MD & VA.

Visual Impaired:

there is no cheap way around that; This could be solved if the system had money.

The system could be built so that all bus stops have electronic signs which tell info verbally and visually

Have everything done verbally and visually this could be easy on trains and station

Turn on the systems in buses: I have been in many many buses where the signs inside are not turned on or are either on for the sign but they verbally part is off.

If they can tell everybody about service changes 3 months after they occurred they can turn the signs on so that they can tell you what stop your at.

Barriers Environment:

Slopes, hills, f**ked up sidewalks etc should be at the fault of the city/county/state and they should be made to fix them.

Get rid of the giant trees whose roots are breaking up the sidewalk

Bulldoze the hills like they do in many areas and on most highways.

Make surfaces completely flat or almost no grade change before building a street/sidewalk. Do like they do with railways but build it for wheelchairs.

Temperature Sensitivity:

That can be also anyone regardless of other condition's that could be an otherwise healthy person.

There are probably many people with this that don't know they can use MetroAccess.

If jurisdictions can pay for this they need to pay for Code Red days.


The sidewalks could be raised to the level of the newer buses so there is no need for a ramp; and so they could board like they do on the train.

Retire all the older buses which have steps.

Redesign the sidewalks in the jurisdictions so that all stops are well chair accessible.

Build cities/counties that are accessible to wheelchairs from the get go.

Common sense:

Make the head of whatever department that is designing roads/sidewalks, transit system to try using what they built with a wheelchair.

Extended more bus routes to go into neighborhoods

Use the raised platforms for wheelchairs like are used on many streetcar and lightrail lines around the world.

by kk on Mar 31, 2010 5:45 pm • linkreport

I'm curious: who pays for this? I'm not asking in a Teabagger way, I'm just wondering. Are there federal funds to cover this? Or does it just come out of general funds?

by oboe on Mar 31, 2010 5:57 pm • linkreport

If you try to accommodate every type of disability, then you end up bankrupting the system and serving no one. Instead, you go with established unirversal design guidelines, and admit that some people will simply lose out, but you will reach the majority of those in need.

Just like every bus doesn't drive down every street, or even serve every neighborhood, a paratransit system will never be able to serve every person with a disability.

by urbaner on Mar 31, 2010 6:38 pm • linkreport

@oboe: This is an unfunded mandate. The transit agency is responsible for providing this service. There is no federal money that I know of except perhaps specific grant programs and perhaps formula funds for smaller rural areas.

by Michael Perkins on Mar 31, 2010 8:19 pm • linkreport

After our efforts to purchase only lift-equipped buses, install bumpy tile and train gap protectors, and install elevators at every rail station, how many qualify for ADA paratransit under category 2? Hardly any, right?

If we got the region to pitch in as Metro desires and build accessible curb ramps, wheelchair lift pads and accessible bus stops, we'd significantly reduce the people that qualify under category 3.

There are new iPhone apps and technology that can help people find out what bus to take and when to exit.
That should reduce the amount that qualify under category 1.

by Michael Perkins on Mar 31, 2010 8:29 pm • linkreport

Thanks Penny for today's article and yesterday's. A great voice - yours - to hear on this subject.

Personally I find it discouraging that some people are satisfied with a so-called public transit system that only serves a majority and not the public at large. Whether the system fails to serve people in certain neighborhoods or of certain races or of certain income levels or of certain abilities, it fails to serve the public, and we should hope for better.

I didn't know about the statory cap ob paratransit fees, at double the regular fare. I suppose that means a public transit agency needs to estimate it's expected paratransit trips and costs when it sets general fares, so that the majority of users who don't use paratransit help fund the minority of users on paratransit. I wonder if it works out to more than 5 cents per standard fare that goes toward covering paratransit ... And I am presuming the paratransit costs more to operate per trip. Personally I am willing to spend 5 cents per fare to ensure that paratransit users continue to receive access to what should be a fully public system.

by Graham S on Mar 31, 2010 10:36 pm • linkreport

@ Michael Perkins

How does an Iphone app help the blind? or anyone with bad eye sight.

Touchscreen anything plus blind or bad vision = fail

That would be like the blind leading the blind

How many blind people can use a phone ?

Then how many of those could use a phone with no buttons and no ability to tell what was pressed.

How many could afford it plus the subscriptions which would be about $ 80 for the cheapest or the ipod touch and they would be of no real use

Unless the app is 100% audio/voice activated wont help and if it says everything it will annoy everybody else on the bus.

If you have a cognitive issue could you even use the phone ?

What help does telling you where to go via a map or gps do when your on a bus unless the bus tells you where you are?
You might not be able to see the street signs, bus may detour, the display in the bus may be off.

by kk on Mar 31, 2010 11:04 pm • linkreport

Thank you for this breakdown.

The ADA, in my view, will be viewed by future generations as part of long slide into degeneracy. What started out as a way get get the low hanging fruit (bigger bathroom doors?) has turned into a mutli-billion expense for a small minority of people.

OK. Fox News views off. What I find lacking in numbers.

For instance, I am still curious about the number of people who use MetroAccess. As best as I can tell, there were about 2.1M trips, but how many users?

The projected cost is 101 million for 2011, which is a huge jump from 2010 (85 million). WMATA made about 5 million in revenue, so we are talking about a 95 million dollar loss.

And how much capital and other spending is being done for making the regular system accessible for disabled -- and things like shuttle buses when elevators are out.

As far as I can tell, WMATA's proposed budget thinks the changes to the accessibility rules will shave off $10 min costs.

by charlie on Apr 1, 2010 12:05 pm • linkreport

ADA improvements help EVERYONE: people pushing strollers, those with rolling luggage and older adults. As the baby boomers age, our infrastructure is going to need more improvements. One day you or a loved one may be in a wheelchair, have a visual impairment or have a hard time walking long distances. You will be glad that MetroAccess is available once this day comes.
ADA paratransit costs can be better managed with innovative practices -- something that Metro has failed miserably at.

by AF on Apr 5, 2010 10:39 am • linkreport

Like I always say, if you have not gone through a disability of a loved one or one yourself, you don't really know the needs of that person. My daughter has mainly cognitive disability from a traumatic brain injury, along with vision problems, walking, etc., etc. How could an iPhone help? She can barely understand how to use it! She has come a long way but I am her main driver EVERYWHERE. STS just denied her, even with letters from doctors which clearly explain her disability. I am so upset. How could she ever become independent. What if I am not around, who will help her. A beautiful 26 year old whose life was tragically changed after a car accident. Its so not fair. People just don't understand. I broke my wrist and had to beg for rides for her to take her to school. Now she is planning to try to start working and I guess I am going to have to dedicate my whole life to taking her to work. I have faith that she will improve to where she would not need this help, but what if she doesn't? I can appeal but I hate to beg! I am so so mad at the system. Should I appeal and try fighting for her rights?

by Maria Noda on May 10, 2011 5:15 pm • linkreport

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