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.

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.