East Building, 5th Floor - TCR
U.S. Department 1200 New Jersey Ave., S.E.
of Transportation Washington, D.C. 20590
May 13, 2009
Mr. Stephen J. Del Guidice
Transit Bureau Chief
Division of Transportation
Department of Environmental Services
2100 Clarendon Boulevard, Suite 900
Arlington, VA 22201
Dear Mr. Del Guidice:
Thank you for the cooperation that you and your staff provided during the Americans with
Disabilities Act of 1990 (ADA) compliance review of the Arlington Transit’s (ART) fixed route
services, initiated on March 10, 2008. Enclosed is the Final Report of the ADA review conducted
by Planners Collaborative, Inc. As of the date of this letter the Final Report became a public
document and is subject to dissemination under the Freedom of Information Act of 1974.
Enclosed with this letter is a progress table listing FTA’s understanding of the corrective actions
either planned or taken by ART in response to the preliminary findings contained in the draft
report. If you feel that our summarization of corrective actions is inconsistent with your
response, please inform us in writing as soon as possible.
Following most of the areas where findings were made, we have:
Identified responses that adequately address the finding
Requested documentation of results and outcomes
Requested ART to clarify specific corrective actions based on ART’s response to the
Please use the enclosed table as the format to report progress to FTA on the corrective actions
that ART has completed or intends to implement as a result of our findings. Please identify each
response by item number (e.g., A.1, etc.). The requested documentation, along with updates on
the status of implementation of proposed corrective actions, should be provided in quarterly
reports to FTA. Each report should include the planned and actual completion date of the
corrective action; the current status and contact person information for each corrective action; and
specific reporting requests cited in this letter and on the enclosed table. The first report will be
due on April 15, 2009, and should include data for the months of January through March 2009,
and any actions completed prior to that date that have not already been addressed. Additional
reports will be due by July 15, 2009 and October 15, 2009 and each calendar quarter thereafter
until FTA releases ART from this reporting requirement.
We recognize the progress that you have made in responding to the findings of the review as
presented in your January 23, 2009, letter. In addition to these efforts, we request that your first
progress report more fully respond to the following findings, which are also addressed in the
progress table. This is not an exhaustive list of open findings, for that, please see the progress
D. Bus Operations
5. Finding: Operator interviews and ride-alongs both suggest that, compared with operators
who rarely encounter wheelchairs on their routes, operators who frequently encounter
wheelchairs on their routes have a better understanding of how to communicate with
customers with disabilities, better facilitate bus placement, and better understand the
boarding, deboarding and securement processes. However, during actual field observations on
a route where wheelchairs are common, an operator was not able to demonstrate full
proficiency in the securement process.
6. Finding: All bus operators interviewed said they had received training in wheelchair boarding
and securement. However, responses on what to do in the event that a wheelchair lift failed to
operate varied, indicating that the training is insufficient.
7. Finding: The review team observations of boarding/deboarding wheelchair customers during
the ride-alongs indicate that current hands-on training is insufficient to maintain even a basic
level of proficiency, particularly among operators who rarely see wheelchair customers. A
lack of proficiency in securement of wheelchairs - evidenced by taking much too long and
being unable to complete securement without direction from the passenger or a supervisor
regarding where to attach the securements - is the most serious deficiency.
ART 1/30/2009 Corrective Action for Findings D.5, D.6, and D.7: The operator training
program and periodic retaining emphasize the operation of lift and securement equipment.
Drivers are instructed to record on the DVIR and report immediately all lift and securement
equipment failures including those during pre-trip inspection. Refresher training is conducted
quarterly – last completed November 2008.
The County will resume quality control reviews in 2009 using “mystery” riders to ensure that
operators have the ability to operate lifts and securement equipment properly. The County
will conduct the next mystery rider quality assessment in Spring 2009
Clarification of Corrective Action: These findings are particularly important, as they
concern the actual performance of bus operators in serving customers with disabilities.
Therefore, the results of the mystery rider assessment are needed to assess the
effectiveness of the corrective actions, particularly training. ART should consider
having some of the mystery riders board with wheelchairs, both on NABI-served routes
that frequently see wheelchair customers and on routes served by lift-equipped Fords.
Further Reporting: Please provide all mystery rider reports in the quarterly progress
report following the observations.
We appreciate the cooperation and assistance that you and your staff have provided us during this
review. Should you have any questions about the enclosed report, the reporting table, or this
letter, please contact Ms. Susan Clark, Equal Opportunity Specialist, at 202-493-0511 or at her
email address: firstname.lastname@example.org.
It would be helpful if you would provide a copy of all correspondence to this office via e-mail to
Ms. Deborah Haines, the FTA Regional Civil Rights Officer, at email@example.com, or
Ms. Sandra McCrea, Chief of External Operations, at firstname.lastname@example.org.
Cheryl L. Hershey
Office of Civil Rights
Ms. Letitia A. Thompson, FTA Region III Administrator
Deborah Haines, FTA Region III Civil Rights Officer