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MID-ATLANTIC ADA CENTER WEBINAR

“FREQUENTLY ASKED QUESTIONS ABOUT THE ADA

AND ALTERNATE MODES OF TRANSPORTATION”

MAY 4, 2016

1:00 P.M. CST

Note: This text is being provided in a realtime format. Communication Access Realtime Translation (CART) or captioning are provided in order to facilitate communication accessibility and may not be a totally verbatim record of the proceedings.

Slide 1

>> MODERATOR: We are ready to get started.

>> NANCY HORTON: Thank you so much, Claudia. My name is Nancy Horton. I'm with the Mid-Atlantic ADA Center. I'd like to welcome everyone. Thank you for joining us, as we are going to talk about frequently asked questions about the ADA and alternate forms of transportation. We are privileged to be joined by our presenters Kristi McLaughlin and Julie Dupree, and I will introduce them shortly.

Slide 2

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Slide 3

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Slide 4

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Slide 5

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Slide 6

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Slide 7

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Slide 8

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Slide 9

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Slide 10

Please consult the reminder e-mail that you got about this session for instructions on obtaining a certificate of participation, if you need that. You will need to listen for the continuing education code, which will be announced at the conclusion of the session. Requests for continuing education credits must be received by 12:00 p.m. Eastern Time, on May 5, 2016.

Slide 11

Now we are going to get started with our session on frequently asked questions about the ADA and alternate forms of transportation.

Slide 12

Your presenters today are Julie Dupree and Kristi McLaughlin.

Julie is a training and technical assistance specialist for Easter Seals Project ACTION Consulting. She provides customized training to communities and individuals throughout the United States. She also facilitates Easter Seals Project ACTION Consulting three-day introduction to travel training workshop, and equips travel trainers, mobility managers, transit personnel, and disability advocates to begin or enhance customized training programs that increase travel independence and ease the burden on local paratransit services.

Prior to joining Easter Seals, Julie was a travel training program manager for Central Maryland Regional Transit, where she built community partnerships that promoted safe and independent travel, coordination and bus stop accessibility. She holds a Bachelors degree in history and political science from the University of Maryland.

Kristi McLaughlin leads a number of training initiatives for Easter Seals Project ACTION. She is an experienced trainer with extensive knowledge of the transportation provisions of the ADA. Her background includes travel training, coordination planning, writing training curriculum, and providing technical assistance regarding accessible transportation.

Kristi began her career in transportation as a scheduling clerk at Bloomington Transit in Bloomington, Indiana. She has since worked as a manager of BT Access, the paratransit system in Bloomington, and as a general manager of “Dial-A-Ride” in Niles, Michigan. She has a BA in philosophy from the University of North Carolina Charlotte, and an MS in applied health science from Indiana University in Bloomington.

With that introduction, I would like to turn the session over to Julie and Kristi.

>> KRISTI MCLAUGHLIN: Great. Thank you so much, Nancy. Thank you to everyone at the Mid-Atlantic ADA Center for having us today. We are incredibly excited to be talking about one of our favorite things to talk about and that's the ADA and transportation. This session is especially interesting in that it's modes of transportation that we don't talk about quite as often, but yet we are getting more and more questions. So we are very excited to present some of the frequently asked questions that we receive here in our office, and as well provide our best technical assistance and advice on how to work with those situations and find a good resolution.

We are a training and technical assistance center, Easter Seals Project ACTION Consulting, and as such, what we provide is technical assistance. I will give our disclaimer that we are not lawyers, and so we are not able to provide legal advice. But instead, we will be giving best practices and technical assistance based on the interpretation of the ADA and the guidance provided by the Federal Transit Administration.

Julie and I are going to be going back and forth today. I'll read her some questions, she will read me some questions, and we will provide you the answers to those, and then we are going to have a couple of spots where we will stop and take questions from you as well.

Slide 13

I'll go ahead and get us started. Julie is going to be answering the first set of questions. These are some of the most frequently asked questions that we get on shuttle service.

Slide 14

Julie, our first question is: What are the types of shuttle service that could be available?

>> JULIE DUPREE: That is a great question, and one that we get often here at Easter Seals Project ACTION Consulting. When we talk about shuttle services, what that typically means is any type of supplemental transportation service that kind of complements gaps where transit doesn't run, or helps fill gaps between areas where there might be an employer center and then the closest bus stop is ten miles away, so it fills that, fills those, “first and last mile connections,” as we call them.

But it could mean anything from an employer-run shuttle to an airport shuttle, hotel shuttle to the airport, sunrise shuttles. Sometimes we see sunrise shuttles run by local transit companies that help provide people rides to trains and bus stops before maybe the transportation services start running, if people need to get there earlier, often people who are in service jobs or need to get to a shift that might start at 4 or 5 in the morning. Oftentimes there will be also subscription buses, so people who can pay to take part in a shuttle service that, for example, picks them up from a park-and-ride and takes them to a train station or a major bus hub to then catch another service from there.

Those are a couple examples of what is available and what we mean by shuttles.

Slide 15

>> KRISTI McLAUGHLIN: Great, thank you. The important part that we are getting to is, what part of the ADA covers those types of shuttle services?

>> JULIE DUPREE: Certainly, if you have a shuttle service that is run by a public transportation provider, we are talking about Title II, so my example of the subscription bus that, if it's covered under workforce, you certainly could make the argument there that the transportation company would have to make things accessible under that. The Title III really speaks to private transportation and any supplemental services, airport shuttles, hotel shuttles and so forth. Section 37 is where you would go to find that language. Specifically, it also outlines what is covered under 37.7C, and it also outlines what is not covered under 37.7D.

And an example of what would not be covered by the ADA might be an employer-run shuttle. For example, Google and some of the other large tech companies out in Silicon Valley, California, a lot of their staff live in the suburban areas around Silicon Valley or outside of San Francisco. They run their own shuttles that they pay for, totally with their own money. There it becomes more of an EEOC type work instead of falling under the ADA.

That is an example of what is not covered.

Slide 16

>> KRISTI McLAUGHLIN: Fantastic. The next question, are airport and hotel shuttles required to be accessible? If so, what accessibility equipment is required for each shuttle?

>> JULIE DUPREE: The short answer is yes, because this falls under the ADA, they are required to be accessible. What this comes down to, if you are thinking about a shuttle service where you are not sure if it would fall under the ADA or not, you can ask yourself, is this primarily the business of transporting people? The prime function of what you are doing with that shuttle is getting people to and from the airport or transporting people to and from downtown to a trolley station or some type of aquarium or whatever the case might be, if it's primarily the business of transporting people and that is your main function, then yes, it would be required to be accessible. What that means is, lifts, ramps, driver assistance and so forth.

And basically anything that we talk about with fixed route, so if there are announcements for the next stop or you are going to a transfer point or something of the sort, you would need to make that accessible.

What is not covered in this section as well is, we talk about shuttles, but when you think about recreation, things like ski lifts are not covered, they are not made accessible as outlined by the ADA. If you are at Disneyworld and you want to take the monorail there, that is another example, because it's recreational transportation, it would not fall under this category.

Slide 17

>> KRISTI McLAUGHLIN: Thank you so much. Our final question on shuttle service: Are shuttle operators required to provide assistance for people with disabilities? And if so, what types of assistance are required?

>> JULIE DUPREE: This is another yes, because it falls under the ADA. Private transportation companies must provide service in a manner that does not discriminate against people with disabilities. What we tell people here when we get questions on shuttles is that we should go further than just saying, drivers can't discriminate or an operator of a shuttle shouldn't discriminate against somebody with a service animal or needed to store a wheelchair in a trunk, or whatever the case might be.

It should be a question of minimum requirements versus good customer service. We would really encourage drivers and companies that run these shuttles to think about it from that perspective, what good customer service means, whether that is helping somebody board, perhaps it could also be giving verbal direction to help assist somebody with getting through the entrance of the place that they are going to, like an airport, making sure you are giving that good service.

Slide 18

Kristi, I have a few questions for you.

Slide 19

We are going to talk about taxicabs. We have a lot of questions here about accessible taxis, and customer service around taxicabs. The first question is: Are taxicab companies required to purchase specially equipped accessible vehicles?

>> KRISTI McLAUGHLIN: This is a little bit of a complicated question and answer. I want to start first by talking about what exactly is an accessible vehicle, and how they are defined under the ADA.

Accessible means meeting the requirements for transportation vehicles and service as specified in the ADA. In terms of size and space, there are some pretty specific conventions to keep in mind. I'm going to give details. Please know you don't have to take as vigorous notes because all of this is available, and I'll provide you some resource information on how you can find it.

But for vehicles in excess of 22 feet in length, to give you a reference point, the large fixed route buses, those are 40-foot buses, typically speaking. So these are definitely included in that as being in excess of 22 feet in length. The overhead clearance for these vehicles between the top of the door and the raised lift or platform, where you step on to the bus, has to be a minimum of 68 inches. That makes that vehicle accessible.

For vehicles 22 feet in length or less, which is what we are talking about for taxi service, the overhead clearance between the top of the door and the platform, if it is a wheelchair lift accessible vehicle, should be a minimum of 56 inches. They may also be providing service with vans. Those vans would also need to meet that minimum of 56-inch requirement.

There are a lot of additional, very specific details in the ADA to what makes a vehicle accessible. We certainly don't have time to go into all that today. But I will tell you that the best resource and place for you to look for this information is at the U.S. Access Board. You can find their website at access-. They have a lot of really great resources there.

As far as some of the other features that make a vehicle accessible, public and private transportation providers need to maintain the vehicle in working order and the vehicle features that make the vehicles accessible and usable by people with disabilities. Some of these features, this is certainly not an exhaustive list, but some of the features are lifts, ramps, signage, systems to facilitate communication with customers with disabilities, for example, a P.A. system. These accessibility features must be repaired promptly when they are damaged or if they become out of order. When they do become out of order, the company is expected to take reasonable steps to accommodate customers with disabilities who would otherwise use the feature when it's available and working.

All of that to say, to go through all of that just to get back to the original question, are taxicab companies required to purchase accessible vehicles? A taxi service is not required to purchase any vehicle other than a sedan type of automobile, in order to add accessible vehicles to its fleet. It does not have to purchase them. No private entity actually is required to purchase an accessible sedan type of automobile.

According to the ADA requirement, private companies primarily engaged in the business of transporting people, including taxicab companies, are not required to purchase accessible vehicles when they purchase or lease used vehicles. This is in the ADA appendix D section 37.105. We try to provide the references when they are available.

Having said that, if a provider does choose to purchase an accessible vehicle, then the ADA regulations state that they must have a two-part securement system, so one to secure the wheelchair to the vehicle, and they also have to have a securement system for securing the person to the wheelchair such as a seat belt or shoulder harness. Again, for the vehicles over 22 feet in length, there have to be enough securement locations for at least two wheelchairs.

There also must be enough room inside the vehicle to permit the customer using the mobility aid to reach the securement location. They have to be able to navigate into that location. Companies should ensure that drivers are always trained to safely use any and all of the accessibility equipment on the vehicle. One of the things the ADA specifically states is that operators should be trained to proficiency on all of the use of accessibility equipment.

I apologize for the long answer. But the gist is, they do not have to purchase accessible vehicles, but when they do purchase a vehicle for the use for people with disabilities, people that use wheelchairs or other mobility devices, they have to then follow what the ADA says for an accessible vehicle.

Slide 20

>> JULIE DUPREE: Great. Thank you, Kristi, for the information. To follow up on that question, if a company chooses to purchase or lease an accessible vehicle, they must then provide equivalent service. Can you define what we mean by “equivalent service,” and what additional information you want drivers to know?

>> KRISTI McLAUGHLIN: Sure, it is the case if they choose to purchase an accessible vehicle, they have to provide a service that is equivalent to an accessible service. If they purchase something such as a van or another slightly larger vehicle or a vehicle with a wheelchair lift or ramp, then the acquired vehicle must be accessible using what is considered already, excuse me, what is already providing equivalent service.

“Equivalent service” means that any demand responsive system, when viewed in its entirety, should be deemed to provide equivalent service, which is the service available to individuals with disabilities provided in the most integrated setting appropriate.

That is the text from the ADA as it's stated. What that means is that they need to be able to provide service to people with disabilities, people that need that accessible service, but not every single vehicle that they have in service has to be accessible. As long as when a person without a disability calls for a ride, and is able to get it, and a person with a disability calls for a ride and is able to get it, then they are considered an equivalent level of service.

As far as what drivers should know, first and foremost, a taxi service and driver cannot deny a ride to an individual because of their disability if she is able to use the taxi service. If the person is using a wheelchair or other mobility aid that can be stowed in the cab, so a manual wheelchair, and the passenger can transfer from the wheelchair into a seat, then the company and the driver must provide the service, regardless of whether or not they have the accessible vehicle.

Neither the company nor the driver can require that the passenger have to wait on any wheelchair lift equipped vehicle.

Some other elements that would be, need to be considered as far as whether or not the service is equivalent, is response time. Is it taking the taxi service longer to get to a person with a disability than it is to a person without a disability? Are they charging more in fare? If they are, it's not an equivalent service. Are they providing service in the same geographic area, or are they providing service to a larger geographic area for people without disabilities? If that is the case, then we wouldn't be providing equivalent service. The hours and days of service need to be equivalent. The availability of service information, if they are providing brochures about their service or fliers, then it needs to be available also to people with disabilities.

The capability to make reservations, and so if you provide an avenue for a person without a disability to make a reservation, then people with disabilities should also be able to use that avenue to reserve trips as well.

If there is any constraint or capacity to the service being provided, so for example, if you have only one lift equipped vehicle and your demand is much higher than what you would be able to serve with one, then you have got a capacity constraint. Any type of constraint or capacity issue could result in a service that is not equivalent.

And then, any restriction that is based on the priority of the trip, so if you are restricting people with disabilities to taking only medical trips, but you don't restrict the general public in that way, then obviously, that is not an equivalent service.

The equivalency requirements don't dictate a particular response time, only that the response time be equivalent for people with disabilities and people without disabilities.

What you want to do is ask some questions of yourself. If you are a taxi provider and you want to know whether or not you are meeting the ADA standard, you want to say, does the present service that we provide meet the equivalent service standard, so ask all those questions based on response time and fare and service area, things like that, do you meet the equivalent service standard? If the answer is no, then you need to acquire an accessible vehicle or additional accessible vehicles in order to meet that equivalent standard.

If the answer is yes, then you are perfectly fine. The vehicles that you purchased from that point on, you don't have to consider their accessibility.

In asking the question to yourself though, it doesn't matter whether or not the request for accessible service has been received in the past. This is an important distinction. You don't need to already have requests for accessible service in order to think about whether or not you need to purchase accessible vehicles. You need to think about what could possibly happen, not what has happened in the past.

The ADA, just a point here, the ADA does allow for taxi agencies and other private agencies such as taxis to contract with other companies to help them provide equivalent service. If they are unable to provide that equivalent service with the vehicles and means they currently have, they are able to contract with and work in partner with other companies to meet the requirement. They are not required to do it solely within their own organization.

Slide 21

>> JULIE DUPREE: Thank you. Here is another question we receive a lot. What are the ADA requirements for service animals in taxicabs?

>> KRISTI McLAUGHLIN: This is actually, and for a long time, was a very hot topic. This has died down a little in the taxi industry. But there are still some questions about what the service animal requirements are for taxicabs.

First I'll say quickly that the definition of a service animal as written in the ADA, service animals are animals that have been individually trained to perform a task or tasks for a person with a disability. Dogs are the most common types of service animals, but other animals can also be trained to assist people with disabilities. They are allowed to ride in the passenger compartment of taxicabs with their handlers.

People with various types of disabilities use service animals. Sometimes people get the idea that service animals are primarily used for people that are blind, and yes, it is the case that there are a lot of seeing-eye service animals out there. But there are other people with disabilities that need them and there are other animals other than dogs that are able to provide that type of service. As a matter of fact, the person with a disability doesn't even have to have an obvious disability for them to be able to use a service animal.

Another thing that the ADA states is that certification or identification for the service animal cannot be required, and it is not the case that all service animals even wear any type of vest or tag or harness, that is not even required as far as noting whether or not the animal is a service animal. They may or may not have that type of identification.

As far as what policy a transit agency has for allowing service animals to ride, they absolutely do have to allow service animals to ride in the vehicle. They can have a no pet policy, that is perfectly acceptable, if they say we are not going to transport your pets. But service animals obviously are not pets. As long as the animal does follow the, or fall within the definition of service animal, it has been trained to perform a task for a person with a disability, and as long as the animal is under the control of the handler, then that animal does need to be transported in the taxicab.

Slide 22

>> JULIE DUPREE: Thank you, Kristi. Here is another question. Can a company or driver charge to stow a person's manual wheelchair?

>> KRISTI McLAUGHLIN: Let me mention the stowing of a wheelchair in general. If the company has a policy that all luggage be stored in the trunk, an exception to this policy should be made to accommodate luggage for a passenger using a wheelchair or other mobility aid that needs the trunk space in order to store their mobility device. If there is somebody that needs to store their wheelchair in the trunk, then there should be an exception to their policy for the actual luggage where it can be stored somewhere else. In this instance, it could be stored in -- luggage could be stored in the floor of the cab or seat next to the customer.

The driver cannot refuse to assist with stowing the wheelchair in the trunk. Drivers routinely assist passengers without disabilities with stowing their luggage. So it is a nondiscrimination issue. If drivers are assisting passengers with luggage, they should assist a passenger with a wheelchair in stowing the wheelchair.

They cannot charge a higher fee or a higher fare for serving a person with a disability, nor can they charge a higher fee for stowing the wheelchair.

But back to the original question, charging the same fee for stowing a wheelchair as for stowing a suitcase would be okay. In this case, they charge a fee also for stowing the luggage, and so there is no discrimination occurring here. They are charging it to people with disabilities and people without disabilities. Generally speaking though, on all the taxis I've ridden in, they do not charge a fee for stowing luggage. So in that case, they would not be able to charge a fee for the wheelchair. You have to look at it as whether or not it's a discriminating charge to a person with a disability.

Slide 23

>> JULIE DUPREE: Great. Thank you. Here is another question. Can a taxicab agency require that a person in a wheelchair use the lap belt and shoulder restraint?

>> KRISTI McLAUGHLIN: There is a broad nondiscrimination provision in the ADA which is in section 37.5 that says a company or driver cannot require a person using a wheelchair to use seat belts and a shoulder harness unless the company's policy requires the use of these devices by all passengers, including those sitting in the vehicle seats. Again, this gets to nondiscrimination. If people without disabilities are not required to do it, people with disabilities shouldn't be required to do it.

For example, if passengers without disabilities are not required to wear their shoulder belts, shoulder seat belts, then passengers using mobility devices cannot be required to use them.

A company may however establish a policy that requires all riders to use the seat belt and shoulder harness. If they provide -- if they use securement, if securement equipment is provided at all the seating locations and that is the requirement, then you can require that a person with a wheelchair use the seat belt and shoulder belt. Again, it's a nondiscrimination issue. If everyone does it, then yes, you can require that of people in wheelchairs. If not everyone is required, then you can't require it of people in wheelchairs.

Slide 24

>> JULIE DUPREE: Great. What are the ADA responsibilities for drivers of all taxicabs, whether they are accessible or not?

>> KRISTI McLAUGHLIN: Great. This is a general catch-all for everything else, as far as what taxi operators are required to do. Taxi companies and drivers must provide service in the manner that doesn't discriminate against people with disabilities. I can't say this enough. When we get into talking about private transportation, a lot of it is, what is discriminating to people with disabilities and what is not. They may not, the ADA may not specifically say that a certain thing has to be done, but if you are doing that thing and it's discriminating against people with disabilities, the ADA is going to say don't do that.

Some of the areas, examples of discriminatory service, some of these we have already talked about, are that the company or driver denying service to an individual with a disability, simply because they have a disability. That is obviously discrimination. The company or driver charging higher fares or fees to passengers with disabilities, that also would be considered discrimination. The company or driver denying a ride to a customer using a service animal, again, service animals are allowed under the ADA. And the driver charging more to stow a wheelchair than for charging to stow luggage, that would also be considered discriminatory.

In addition to these, when boarding, the customer can either wheel themselves into the securement location, this is for accessible vehicles, or they can ask the driver for assistance. The company's policy must require drivers to assist people with disabilities when boarding. This is one of those where the operator is expected to provide assistance with accessibility equipment, including the ramp, if that is necessary. This is even required if it's, if the driver has to leave his seat in order to provide the assistance that is requested.

A company's policy and drivers must permit individuals that have disabilities who do not use wheelchairs, including people that stand on vehicles that you are able to do that, to use the vehicle’s lift or ramp to enter the vehicle. This is generally speaking on larger vehicles, if a person is able to stand, they may still need the use of the lift or ramp in order to board the vehicle. This could be somebody that has a hidden disability of, knee issues or hip issues that making that first step into the vehicle or stairs into a large vehicle could be difficult.

Finally, customers using wheelchairs may have a preference for boarding a vehicle either facing forward or backward. Generally speaking, companies have an idea of what they consider safe, and may suggest to the passenger, it would be best to board facing forward, it would be best if you board facing backwards. But the ADA does give the right to the passenger to make the official decision. If they would like to board facing forward or backward, then the company should honor their request.

Slide 25

All right. I believe that this is a point, Nancy, where we wanted to stop and see if there were any questions.

>> NANCY HORTON: Great. Thank you for all that information so far. That is a lot of great information. As a reminder, folks who do have questions at this time can submit them in the chat box, or send them to ADAtraining@.

While we might be waiting for folks to type a question in there, we do have a couple questions that were submitted ahead of time. We will get started with a couple of those.

First of all, I have a question about, what is the level of accessibility required at shuttle stops?

>> JULIE DUPREE: That is a good question. Our answer is that it goes back to what type of shuttle service it is. Certainly, if you are running an airport shuttle or some type of shuttle where again the primary business is transporting people, then you would need to make that stop accessible as well, especially if there is any kind of public or county funding involved in the location that that particular stop is in.

That certainly is getting into some area where it might be harder to advocate for, for example, I'm waiting for a shuttle to come pick me up from my hotel, but the curb cut in front of the hotel does not exist, or there is an inaccessible sidewalk that is owned by the hotel, and so you can certainly make the argument that because it is a transportation service, oftentimes whether it's provided by a public transportation agency, private transportation agency or you are paying for that service through something like staying at a hotel or something that you are entitled to, because of the agreements of that service that you have received, that certainly there is the argument that you can, that should also be made accessible to really complement the whole part of somebody's trip. It just might involve a little bit more advocacy and perhaps some regulations.

>> NANCY HORTON: Great. Thank you. We have another question about taxicabs and the accessibility requirements, or how are the accessibility requirements for taxicabs affected if a taxi is used in an official capacity as an ADA complementary paratransit vehicle?

>> KRISTI McLAUGHLIN: This is a question that we often get as well. The short answer to this is, they are greatly affected by the vehicle being used in official capacity for ADA complementary paratransit service, because all of the requirements for ADA complementary paratransit service apply officially once that agreement has been made.

What sometimes happens, and happens certainly across the country now, are that taxi companies come to an agreement with a public transit agency to provide supplemental service for their ADA complementary paratransit service, which is a service that specifically is designated for people with disabilities that because of their disabilities, they are unable to take the fixed route service. There is a lot in the ADA as far as what the requirements are to meet the standards for ADA complementary paratransit service. Whenever, if and when it happens, that a taxicab agency signs an agreement or comes to agreement with the public transit agency to provide that service, then they are also responsible for providing the level of service and accessibility that a complementary paratransit service would be required to provide.

A lot of onus to that falls on the transit agency to either provide the accessibility, so for example, there is a lot in making sure that the reservation process is accessible, there is a lot in making sure that the driver assistance is provided at a level that is a bit higher than in a fixed route service, so all of those things need to be considered, and the transit agency should follow through with monitoring the taxi agency and making sure that they are providing the level of service that is required of ADA complementary paratransit.

>> NANCY HORTON: Fantastic. A lot of great information there. I do not think we have any additional questions at this time. We do of course hope to have a little bit more time toward the end to ask more questions. If folks do have questions or think of questions, feel free to submit them into the chat box, you can go ahead and type the questions into the chat box at any time. You don't have to wait for us to stop for a question period. You can submit those at any time, and they will be there for us when we get another opportunity.

But I think for now, we can move ahead.

>> KRISTI McLAUGHLIN: Thank you so much. We are going to move on, and start talking about ride sharing applications. This is sort of big in the news lately, and so I'm going to be asking some questions of Julie to answer on ride sharing.

Slide 26

The first question is: What is a ride sharing application? How do they work?

>> JULIE DUPREE: Good question. Ride sharing is an interesting term, because technically it means something like a carpool or a van pool, and often those can be funded by public transit agencies or county shuttles, things like that. But what it's morphed into when we hear ride sharing in the news now, it means transportation network companies, TNCs. Those are things like Uber and Lyft, another one called Side Car. Uber and Lyft are the largest providers of ride sharing services.

Again, kind of an interesting definition, because technically, and I'll explain what it is in a moment, but when you are getting into a vehicle and someone is picking you up and you are paying for a single ride, a lot like a taxicab, you are not really sharing your ride. But it's morphed into meaning transportation network companies. These companies are, TNCs like Uber and Lyft are growing in popularity. They have been challenging the taxicab industry lately to change a little of what they are doing. They have come in fairly quickly. They are valued at like $10 billion, more than a couple of the largest American motor companies were valued at in the last year.

They are only growing in popularity. And a lot of times, people prefer the Uber to taxicabs because there is not an exchange of cash. Everything is done through an application. When you hear the word ride sharing application or Uber or Lyft, whatever that might mean, what that really is, is an application that somebody would have on their phone. And so they would use it, they go on, GPS would determine where they are located. They put in where they are hoping to go. And what ends up happening is it connects riders and drivers together. So people who need rides connect with drivers who can give them those rides.

The interesting thing about a lot of these ride sharing applications is that they started as taxi applications. Uber actually got its starts connecting people with taxi services. And then they realized along the line, we can connect people with drivers and expand the market that way.

Another way that you sometimes see this is in rural ride sharing programs, so we have our Uber and Lyft, and there are many places, it's hard to find cities that don't have some kind of transportation network company that is working or providing services in that region. But if a small town, for example, one in Iowa that I was in about a year ago does not have them, they have an ordinance they passed that didn't let some of these transportation network companies in. So they had, there are some areas that develop rural ride sharing applications and programs. Like a good example is Lawrence On Board which is in Lawrence, Kansas. What this is, is drivers go through a background check, and riders go through a similar background check, and they get little cards. If you are needing to get to the grocery store, you could, they call it urban hitchhiking, but you could call and get a ride, or have a card where you go up to somebody at the grocery store, and they connect you with a person who is willing to give you a ride through this program.

There are examples of high tech ride sharing, like Uber and Lyft or through iPhone or Smart phone, and then some smaller communities have also found innovative ways to do similar services as well.

Slide 27

>> KRISTI McLAUGHLIN: Great. Our next question: Do companies using ride sharing applications follow the same ADA rules as taxicabs?

>> JULIE DUPREE: This is a really,really hot question. The short answer is no. Right now, there has not been any ruling as to whether the ADA applies to these transportation network companies or not.

Various lawsuits have been filed about the ADA's role in these transportation network companies. These companies argue, and certainly we are just presenting the facts here, we are not taking sides, but many of the companies who have had lawsuits filed against them argue that the ADA does not apply to them, because they are an application service, and they connect riders and drivers with each other. What they are saying basically is we are not the ones who are giving the rides. We are not running the ride service. We just develop this cool app on your phone, and Bob who needs a ride from 14th and K Street gets connected with Sally who is a driver who is three blocks away, and that she provides that ride.

There is a lot of questions that come up around them arguing that they are just a technology service, and certainly what we are seeing right now is, in the current lawsuits that are happening, is that many people are making the case that yes, the ADA should apply. Currently, there are lawsuits that have been filed regarding service animals. So with some people, for example, there is a lawsuit in California where somebody was denied a ride because they had a wheelchair that wouldn't fit in a driver's car. Someone else filed suit against Uber and Lyft, because they weren't receiving driver assistance, and they had to basically board in the back of someone's car, and then pull their wheelchair in after them, and that caused harm to them. So they are suing because basically they didn't get any assistance from the driver, where just a little bit of assistance might have helped them out.

The last one that you might have heard in the news, that's out of all of these that have been in the news, you might have heard the most about, is the case also in California, where a service animal was asked to, somebody asked a person using a service animal to put that animal in a trunk, throughout the duration of their ride, because they didn't want to get dog hair in their car. What's happening here, and what we are seeing is, I think, the groundwork for an eventual, we can't predict either way, but what we tell people quite often is that at some point, I think it's hard for TNC companies to deny, to continue to deny that the ADA doesn't apply to them, and to keep saying, we are not actually providing transportation, because the primary service of anybody opening an Uber app or Lyft app is to get a ride. It is just a different kind of ride, and it's changing that landscape.

What is tricky, though, is because the ADA hasn't, doesn't apply to these transportation network companies, you don't have your things like the nondiscrimination mandate or equal opportunity, reasonable modification. So it really comes down to, what kind of driver do you have, and has that person received the training, the disability education or basic ADA knowledge to, at the end of the day, provide a good service and do the right thing to help a person who is paying for that ride.

Slide 28

>> KRISTI McLAUGHLIN: Our next question, what could ride sharing application companies do to be more accessible?

>> JULIE DUPREE: I just mentioned one, and that is driver education. Because this is still new territory, in the grand scheme of things, if ride sharing applications and transportation network companies could provide education for their drivers about disabilities, that would be wonderful. Some of them do. Developing perhaps the more in-depth program, I know a part of the training that Uber drivers receive is a few on-line modules about the ADA, it actually doesn't specifically say the ADA but it is about disability and how to serve people with disabilities, and the different types of disabilities that you might encounter. That is a start. But certainly, going more in-depth and providing in-depth education would be great.

Survey all your riders to determine accessibility needs, so if you find that people are using your services in a particular area, asking them, what could we do to make this more accessible, just involving people with disabilities, and all riders in helping to make those suggestions.

We do see some recent initiatives by the transportation network companies to make things a little more accessible. An example in New York City right now is Uber Access, that is a part of Uber, and essentially what it is, you can click a box that requests an accessible vehicle. If one is available, then it will be matched with a driver who has an accessible vehicle that might meet your needs.

Another example of this is Lyft accessible vehicle dispatch. This goes back to the individual driver, as well, that good customer service is important, supporting people with disabilities is important. But certainly, these companies can also continue these larger scale initiatives like Uber Access and the accessible vehicle dispatch. Another example of things that they can do to be more accessible is to try to recruit more drivers who have accessible vehicles. Currently, at Uber Access in New York City, at any point in Manhattan there are two accessible vehicles and Uber drivers who are driving the vehicles. Certainly, if there is some kind of incentive or a way to attract people who have accessible vehicles, that is something that these companies could also be doing to expand their accessible fleet.

Lastly, of course, including disability groups in planning, a lot of the counties and cities where Uber and Lyft and related companies have been entering or trying to enter, they have different committees and planning organizations that talk about the rules they might impose on the TNCs, and how they are going to handle these folks coming into their area.

Including disability groups and people with disabilities who are potential riders or current riders, either of TNCs or taxicabs or just in general, is great for your planning processes.

Of course, to close on the ride sharing component here, what I think we will be watching in the next year or two years is how this upcoming litigation goes, how the courts rule about the cases that I mentioned earlier, and then certainly one thing is for sure, that these transportation network companies aren't going anywhere. They are really taking the industry by storm. They have really surprised the taxi industry. It's certainly trying to find ways to evolve and see it as a service that people want to use, despite some of the flaws that you can argue that they have. Certainly, it will be interesting to see where it goes.

>> KRISTI McLAUGHLIN: Thank you so much.

Slide 29

>> JULIE DUPREE: I have questions for Kristi on rail.

Slide 30

Can you define commuter rail, heavy rail and light rail? And what are the differences between all of them?

>> KRISTI McLAUGHLIN: This is a good question in that, I think there is a lot of discrepancy in the industry on these terms. I often hear people use them in different ways. I think this probably has to do with how rail has evolved over the years, not only just in the U.S. but across the world as well.

Here is sort of a little definition of each one and what you might find as far as how each one is used.

Commuter rail is generally a short haul service, shorter trips. It is a passenger service, provided in the metropolitan or sometimes suburban areas. It may cross state lines or other jurisdictional lines. It usually travels for distances in excess of ten miles, and provides more seating to accommodate passengers traveling longer distances. Some of the other characteristics include that you may find that commuter rail has reduced fare programs for people with disabilities. They may provide multi-day tickets that offer a break, versus buying a single ticket for every trip for every day. They have peak service which is usually offered in the morning and afternoon commute times, during the week, for people traveling to and from work. And they may share track with either freight trains or inner city rail trains.

Some examples of commuter trains or commuter rail are the Long Island Rail in New York, the Marc Train in Maryland, the Metro Rail in Chicago, Cal Train in San Francisco, Trinity Railway Express in Dallas Fort Worth, and the UTA Frontrunner which serves Salt Lake City. That is a general idea of commuter rail.

Heavy rail is also a passenger service, but it has the capacity for a much higher level of traffic. It runs on an electric railway that is separate from all the other rights of way of traffic, and generally has a very sophisticated signaling and high platform loading system. It's important to note that the FTA regulations don't actually use the term heavy rail. They use the term, rapid rail. It is defined as a subway type of railway that is operated on exclusive private rights of way with heavy level platform stations. You may see rapid rail interchangeably with heavy rail.

It may also operate on an elevated or a grade level track that is separated from other tracks, that is another thing you may see with heavy rail. Examples of either rapid rail or heavy rail are the MBTA subway in Boston, SEPTA, which is in Philadelphia, Pennsylvania, Marta, which is in Atlanta, Georgia, the Metro Rail in Miami, RTA rapid transit in Cleveland, the Metro Rail here in Washington, D.C., and of course maybe the most famous one is the New York City subway.

Light rail is, our last type of rail, it's sometimes described as an evolution of the trolley. In many ways it still sort of looks like a trolley. There is usually one to three cars. They operate on a railway that is mostly separate from other rights of way. There are level boarding which means that there is a level boarding process for people with disabilities or that have mobility needs. Some of the examples of light rail are Uni Metro in San Francisco, Metro Rail in Los Angeles, Max Light Rail in Portland, the San Diego trolley in Dart, or excuse me, the San Diego trolley and then Dart in Dallas, and Metro Link which is in St. Louis.

Slide 31

>> JULIE DUPREE: Are rail stations required to have working elevators and escalators?

>> KRISTI McLAUGHLIN: Escalators generally speaking aren't considered accessibility features. I know that you can argue that a person can stand on an escalator and that would prevent them from having to walk stairs and that is absolutely true. But generally speaking, it's not considered an accessibility feature and there isn't a requirement under the ADA for providing escalators at rail stations. They are not even required.

Elevators, on the other hand, are considered to be accessibility features. They are specifically accessibility features that are intended to make multi-level stations accessible to people that use wheelchairs or other mobility devices.

Rail stations that were in existence prior to the ADA, which was signed in 1990, were required to be made accessible if they were designated as a key station. That is really important, especially today because rail stations and rail systems, as you all probably know, can be around for a very long time without having major updates. What was designated at that time as a key station is very important, in that those are required to have working elevators. They generally, key stations are generally those that have higher levels of traffic. They may be at transfer points to other rail lines or other modes of transportation or possibly could be at the end of the line, at the end of the rail line.

For stations that were constructed after the passage of the ADA, including those being constructed now and in the future, there is a higher standard of accessibility. They are required to be designed for accessibility from the start, which is the case with not only the development or construction of rail, but with all new construction.

The ADA also has a requirement for the maintenance of the accessibility features. This sort of gets to, do they have to have working elevators and escalators. The requirement is that for elevators they should be maintained in operable condition. They need to be repaired promptly when they are damaged or if they become out of order. And reasonable steps need to be taken to accommodate people with disabilities who would otherwise use the elevator. The most common method of this type of accommodation is to provide a shuttle service, so for example, with the elevator out at a typical stop, they would provide a shuttle service from the next available station with an elevator back to the initial station where the elevator was not operational. That does happen quite frequently at transit stations where the elevator isn't working.

Many providers send out alerts, either via text message, possibly by e-mail, they may post something on to their website to say that the elevator is not working, but there should be some method in which the passengers that need that accessibility are able to find out whether or not the elevator that they need is in working condition, and if not, what the accommodation being provided is.

Slide 32

>> JULIE DUPREE: Thank you. Here is another question. What types of assistance are required of station attendants for people with disabilities?

>> KRISTI McLAUGHLIN: Station attendants are there for all customers, and especially with their questions or concerns about using rail; a lot of people use them to help navigate the system, especially people that may be traveling or visiting. But it also needs to be made equally available to passengers with disabilities. If there is a service that the service station attendant provides to people without disabilities, they should be providing it to people with disabilities. Some of these services could include assisting passengers using kiosks to purchase fare. I'll tell you I have a time with that one on traveling. I'm used to it in my home station or my home system, but when I'm traveling, that can be hard to figure out.

Assistance in using fare gates should be provided; in finding elevators or rest rooms or water fountains; if there is any need for directions to the appropriate train platform; if anybody needs information regarding schedules or routes. And each system is going to have its own boarding and alighting process, so the process in which people use to board the train and to get off of the train, especially for people that need accessibility, there may be a special type of process that is used in the station, and the station attendant should be able to help with that.

In some stations, operators or conductors may be available to provide this type of assistance as well. Sometimes you will see additional staff, not just station attendants that can be able to provide assistance, and certainly, if there is assistance that is needed from the platform onto the train, then operators need to be trained to provide that type of assistance, following the system's procedures, if they are requested of that type of assistance.

>> JULIE DUPREE: Thank you. To piggyback on that, what are the ADA requirements for platforms and boarding?

Slide 33

>> KRISTI McLAUGHLIN: To really fully answer this question, I'd have to give a lot of technical specifications. It is one of those where there are a lot of detail that goes into what the actual requirements are. I'll address the highlights and point you to resources that may help you find additional information, if you need it.

As of February, I believe February 1, in 2012, any of the new or altered stations are now required to meet the new performance standard, accessible standards that individuals with disabilities, including those who use wheelchairs, must have access to all accessible cars available to people without disabilities. What is available to people without disabilities should be available to people with disabilities. If people without disabilities can board accessible cars then people with disabilities should be able to board them as well. T

The next part of the new regulations address how we are to board accessible cars. If stations do not share a track with freight, then this performance standard should be met by providing level boarding, which means there is no step up into the train. It should be level with the platform where people are waiting. Level boarding is important in making cars accessible for people that use wheelchairs or other mobility devices.

If the track is shared with freight, the performance can be met in one of five different ways. There can either be level boarding, which is the preferred, obviously. There also are things called car borne lifts, and these are lifts that are specifically made for rail cars, getting people into rail cars that are using mobility devices or wheelchairs. That is a piece of equipment that can be provided to make that standard or to meet that standard.

Agencies can use a bridge plate, which is exactly what it sounds like, in that it bridges the gap in between the rail car and the platform, and it's a plate, generally speaking something probably metal, that can be used to help the person board the vehicle.

Many high platforms are also a type of accessibility equipment that can assist, and this is a platform -- I wish I could show you pictures. I should have put pictures on there, because these things, and again they are what they sound like, this is a platform that is going to assist a person in a wheelchair to get from the actual platform of the rail station into the rail vehicle.

Then there are station based lifts. And the difference between the car borne lifts and station based lifts are really where you find them. You have a car borne lift that is on the car and comes out, and will allow somebody on the platform to get on the lift, and the lift is put back into the car. And the station based lift is based and housed at the station versus in the car.

Entry level boarding for all accessible cars on the train is the preferred method, as I've already said. That is the easiest and fastest, most efficient way for passengers with wheelchairs or mobility aids to board the train.

The second considered most preferable way are car borne lifts. But however, if the provider wants to use one of the other options, then those would allow them to meet the standard.

If you are in search of greater detail, like I said, there are tons of technical specifications for the accessibility of platforms and boarding. You can either give us a call at Easter Seals Project ACTION Consulting, or there is a FTA which is Federal Transit Administration final rule document that is available. You can Google “rail station final rule,” and it should be the first thing that comes up. That is another place that you can look for additional information. Or, again, the Access Board is a great place to go. So access-.

Slide 34

>> JULIE DUPREE: Thank you, Kristi. Another question here, are rail cars required to have wheelchair securement systems?

>> KRISTI McLAUGHLIN: This is an easy, quick answer. The answer is no. Rail cars are not required to have wheelchair securement systems. They are required to have space for mobility devices. So a space, a person in a wheelchair or with a mobility aid boards the train, there is supposed to be a space available for them to ride the train. But the actual securement system is not a requirement.

You will see agencies that have them and that is perfectly fine. There are a few different options that they have, generally speaking. The one I've seen the most is there is a metal clasp that when a person in a wheelchair backs into it, it wraps around their wheel and holds the wheelchair in place, very simple as far as them being able to secure their own wheelchair to the train. But again it's not a requirement.

Slide 35

>> JULIE DUPREE: One last question on rail. Is the rail operator required to provide assistance to a person with a disability boarding a rail car if requested?

>> KRISTI McLAUGHLIN: Yes. It actually is reasonable for the rail operator to provide assistance in boarding and alighting from a rail vehicle when it's needed. The rail operator, generally speaking, is in the front of the train, and a lot of stations or systems may have in place a policy that, for this type of accessible service or assistance, you would need to be boarding that front train, and in which case, you can request the assistance from the operator.

When, however, stations are unattended, and if there is no conductor available, if the conductor cannot be found or is not available at that time, the operator is typically the only person there to assist. It's definitely important that they know that it is a requirement that they provide that assistance if it's needed. But this is something that is generally requested from the passenger, and not something that is assumed that will be needed unless the request is made.

Slide 36

All right. We left what is the most important section for last, at least that’s what I think. We are going to be talking about bike sharing programs, and the accessibility of those.

Slide 37

Julie is going to answer these questions and then after this section, we will be able to take more questions from you.

What is bike sharing? How does it work?

>> JULIE DUPREE: All right. This is Julie's personal opinion, but I think bike sharing is really cool. But you have to make sure it's accessible. Bike sharing is growing in popularity. It means a service, a network of bikes around a particular town or city or college campus, and there are different docking stations. For example, here in Washington, D.C. we have Capital Bike Share. All around the city, there are at least over a hundred different docking stations. Somebody can, for example, arrive in Washington, D.C. into Union Station, come off the train, get on a bike that is part of the Capital Bike Share network, and they can ride that bike anywhere in the city, and dock it close to wherever they are going. We see a lot of these around, definitely around the major cities. We see some smaller towns that are developing these bike sharing programs, having a service made available, and then also on college campuses as well.

It's definitely grown in popularity. It mainly focuses on serving two main populations. The first are commuters and people seeking to make connections to their first and last mile commutes. That is like my earlier example about getting to a train station, or the train or bus only gets you so far, and you take a bike share bike to get to work in the morning or doctor's appointment or some place where you know you can get there quicker than walking perhaps, or taking public transit, but it's a choice that people are making to take, using a bike.

It’s really a mobility management concept, connecting to people's first and last mile, and also we are seeing that the second main population that uses bike sharing are tourists or visitors of a city. It can be a great way to get around usually for a low fee. It is $8 or $12 a day, where you can have a bike and keep it out for about a half hour at a time, and for that fee, basically you can ride a half hour, dock it somewhere, like the Washington Monument, and then go get a bike from another docking station, ride a second bike from Washington Monument to a museum or whatever the case might be.

It's really meant for short bike rides. What it doesn't cover is somebody wanting to have the same bike all day long for $12; I think sometimes that charges them upwards of a hundred or more dollars. That is how the network works. These docking stations are typically, they range in size, having eight or ten bikes to 25 or more. Typically, people who use them regularly are members of the bike share service, and there is an annual fee usually $75 to $100 to use the bike share service.

Some communities that aren't large enough to have the programs that have the docking stations and the bikes and the technology, where you can put your credit card in and sign a bike out for half an hour or whatnot, some communities are kind of reinventing this to fit their needs.

One example is in Montgomery County, Pennsylvania. Parts of it are fairly rural. They have developed a library network system that they call their rural bike share program. What that means is all the libraries in the county have bikes that people can come check out for a day. They can ride them around town, do whatever they need to do, as long as it's back by a certain time to any different, any library location, not necessarily the one they checked it out from, it's a network of bikes. That complements the bike sharing concept, because one of the main pieces of bike sharing is that you are -- there is all these stations around a particular city or campus, and so you are not necessarily taking the bike from station A, going to the store, doing what you need to do and returning it to that place. You can return it to any dock in the city in the network of the system that you are using.

Slide 38

>> KRISTI McLAUGHLIN: The big question, does the ADA cover bike sharing programs?

>> JULIE DUPREE: All right. I got some of the hot topic questions here between TNCs and bike sharing programs. The short answer is, that right now, we don't know. This is a little bit more, you can make the argument that certainly it depends on how these programs are funded, whether or not the ADA applies. I think similar to transportation network companies, like Uber and Lyft we are eventually going to see some type of ruling that it does apply. But right now, technically, the answer is no, or not really, or we are not sure.

The Department of Transportation and the Department of Justice don't directly address bike sharing programs, or how to make them accessible. But certainly, what some people argue is that you have your Title II protections and Section 504 nondiscrimination protections. That goes back to, how does the money flow. When a bike sharing program comes into a particular city, are they using any public funds? Is the county giving money to the program, to get it started? Or is a certain percentage of a bicycle fleet covered by city funds or taxpayer dollars? Looking at how these programs are funded, which more often than not involves some type of state and federal funding to get them started, you can definitely make the case that there should be some type of protection under the nondiscrimination. To include disability groups in your planning as well, to kind of make this case known, is good practice.

Slide 39

>> KRISTI McLAUGHLIN: And the last question, I think it is, oh, two more, sorry, next to last question: What exactly is an accessible bike?

>> JULIE DUPREE: This is where it gets really cool. Definition of an accessible bike is fairly interesting, because bikes are so customized. Simply having a tricycle for somebody who might have difficulty bending over a bike or limited upper body strength, for example, where a tricycle would help accommodate their needs, that might not be the same type of accessible bikes for someone else. There are different types of bikes that are customized. Similar to any mobility device, people, individuals who have their own bikes customize them to meet their specific needs.

A couple of examples of accessible bikes are hand bikes, so on these bikes, the bulk of the pedaling is done with your hands instead of your feet. E bikes or “E” stands for electric or basically what they are is motor assisted. If you are somebody who wants to ride a bike to get somewhere but can't pedal for very long, you use an E bike, and on each rotation of your legs, the bike is going to go further unless you are not having to do as many revolutions with your legs.

Trikes I mentioned, less of an upper body requirement. Lastly, another example is tandem bikes, or what is commonly referred to now as side-by-side bikes, so these are bikes where oftentimes both people pedal, but one is responsible for steering; another way to assist somebody.

An accessible bike, what is interesting about the topic is, there really are -- a lot of the larger bike share programs say we already have these bike share docks, we have bikes that aren't necessarily accessible, or they are trying to find something about the bike that they can say it's accessible because the seat is comfortable, or whatever it might be. We are really in the very early stages of making some of these bike share programs and stations accessible.

I know Baltimore, Maryland is working on having a 50 percent E bike fleet within the next two years. That will be neat to watch. There is also other best practices going on around the country, that I heard about through some wonderful people, a wonderful leader at the Milwaukee county commission for people with disabilities, in Wisconsin. If you want to learn more about accessible bike share and some examples of what is going on, and the various campuses and towns that have really led the charge to make bike share stations and programs accessible, they are really awesome people there.

I thought I would give them some credit where it's very well deserved.

Slide 40

>> KRISTI McLAUGHLIN: Our last question: What can bike sharing programs do to be more accessible?

>> JULIE DUPREE: Great question!

This is a similar answer to what I mentioned earlier about transportation network companies. Certainly, including people with disabilities in your planning, so if you are a city that doesn't have a bike sharing program and you want to start one, getting the perspective of people with disabilities and including them throughout all phases of your planning is very very important, good start. Making sure you keep an open mind, so don't -- if you are looking to get this program or expand something you are already doing, try not to say, it would be too costly to have these different types of bikes, or in the example of a hand bike, it can be a few thousand dollars, well, try to keep an open mind to the fact that people with disabilities live in your community, that these are sometimes -- have public dollars involved in them, and make sure that you are providing that good service. Remember how the money flows as well.

Another example that I wanted to mention about these bike sharing programs is that in addition to how they are funded in terms of getting them started and the maintenance and upkeep, remember that people are also paying for the service. So if somebody, whether they have a disability or they don't, they are paying the same annual fee or the same daily fee to utilize that service.

Another thing that companies, that some of the bike sharing programs are starting to offer that we are seeing is what I kind of called bike share paratransit, where they will say, you know what, we do have one trike, for example, and if you call us 24 hours before you need to go somewhere, we will be happy to bring that to you in a van and we will drop it off and we will pick it back up from you when you are done with it. That is certainly a good start. But it's one of those things where, to make the services as close to what they look like for people without disabilities and for everybody else who is using the system is really what we are looking for. Certainly, a good start, but eventually, I would love to see a day where somebody with a disability can be at a bike share station or a dock and see a couple different types of accessible bikes, and choose the one that best fits their needs.

Slide 41

>> KRISTI McLAUGHLIN: With that, Nancy, I think we can take a few more questions.

>> NANCY HORTON: Great. Thank you for so much information. We do have a few questions. We do not have a lot of time, as we are coming up on the bottom of the hour. I think but we may have time for one or maybe two.

Our first question is, some car rental companies at airports are a distance away from the airport. Could customers with disabilities request that the car rental agency pick them up at the airport entrance, so they don't have to walk to get all the way to the car rental office? Could that be an ADA issue?

>> KRISTI McLAUGHLIN: I think it probably depends is the answer. If they have a shuttle that they are providing for everyone to get from the airport to the car rental location, then that nondiscrimination aspect of the ADA is going to come in.

The car rental shuttles that I have taken personally recently have all been the larger fixed route use bus that is have wheelchair lifts and ramps and they are fulfilling the requirements in that way. If a shuttle is not provided for anyone, then that type of system or service would not be required for people with disabilities. It really comes down to whether or not it's considered a discriminatory practice based on what they do for the people in general, so their general public getting to their office.

>> NANCY HORTON: Great. Thank you. Great answer. Maybe one more quick question. The question is, is there any kind of limit or requirements related to how many wheelchairs could be accommodated on light rail trains, example in a local situation, the questioner says in Sacramento they have a light rail system that only allows maximum of four wheelchairs on each train.

>> KRISTI McLAUGHLIN: That actually, I believe, is above the standard. The standard for rail cars is that there be at least two locations for mobility aids, wheelchairs to be positioned.

So the four would be above what the minimum requirement is, although I will remind everybody that the ADA provides the minimum requirements. And we are always pleased and happy to hear when agencies go above and beyond what the requirements state.

>> NANCY HORTON: Okay. Great. We do have a couple more questions. I'm sorry we didn't get to everyone's questions. That's often the way when we have so much information.

Slide 42

We do want to remind folks that if we didn't get to your question, feel free to contact your regional ADA center, call us at 800-949-4232, wherever you are in the country. We also have here some contact information for you all to get in touch or stay in touch with Easter Seals Project ACTION Consulting. You have all of this in your materials, Facebook, Twitter, their E-mail list.

Slide 43

We want to thank everyone for joining us today. We especially want to thank Julie and Kristi for all of this fantastic information, their expertise that they have shared with us. There is information here to be able to contact them.

Slide 44

Again, here is contact information for the ADA center. If you have questions, general questions about the ADA, contact your regional center. If you have questions specific to today's presentation, you will want to contact us here in the Mid-Atlantic region. If you are outside of our region, you can call us directly at 301-217-0124. Find us on-line at .

Slide 45

The continuing education code for today's session is “wheels.” Wheels. Please consult your webinar reminder e-mail message for further information on that.

And thank you once again everyone for joining us, and thank you so much to our presenters. This concludes today's session.

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