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February 10, 2014

Why curb-to-curb service is simply not enough

by Joe Zavisca - Also by this author

In many American cities, ADA complementary paratransit service is still evolving. It has been more than 20 years since the passage of the Americans with Disabilities Act, and many transit agencies continue to struggle with the quality of service, costs and difficulties encountered in contracting the service.

One of the most basic policy decisions an agency must make involves whether to provide door-to-door, or only curb-to-curb service. The more I work in the field, and the more I get to know real people with disabilities, the more I believe that door-to-door service is the way to go. Why? Because in many cases, curb-to-curb is simply not enough.

RELATED: "METRO's 2013 Paratransit Survey."

In retrospect, I think it is fair to say that most transit agencies were dragged kicking and screaming into the provision of demand-responsive paratransit. A majority of agencies chose the option of providing curb-to-curb service. What many of them lacked, however, was an understanding that the key phrase in the ADA regulations was not curb-to-curb or door-to-door, it was origin to destination:    

•    The basic mode of service for complementary paratransit is demand-responsive, origin to destination service... The local planning process should decide whether, or in what circumstances, this service is to be provided as door-to-door or curb-to-curb service.
— 49 CFR, Part 37.129.

In a recent survey of the websites of 34 agencies, 14 say that they provide door-to-door ADA service, 16 are clearly curb-to-curb and four are unclear. Of the 16 agencies that identified themselves as “curb-to-curb,” only six specifically mention that they will provide additional (i.e. door-to-door) service upon request. Interestingly, two of the largest agencies in the country prohibit going beyond the curb.  

There have been a number of clarifications issued by the Federal Transit Administration on the subject of origin to destination service, since at least as early as 2005. Here is one of the most definitive:

•    The U.S. Department of Transportation issued an item of “Disability Law Guidance” entitled Origin-to-Destination Service, dated Sept. 1, 2005. The purpose of the guidance, as stated in the introduction, is to answer the question: “What are the obligations of transit providers to ensure that eligible passengers receive ‘origin-to-destination’ service?”
The document discusses the subject at length and concludes:

•    Under the ADA rule, it is not appropriate for a paratransit provider to establish an inflexible policy that refuses to provide service to eligible passengers beyond the curb in all circumstances. On an individual, case-by-case basis, paratransit providers are obliged to provide an enhancement to service when it is needed and appropriate to meet the origin-to-destination service requirement. We recognize that making individual, case-by-judgments may require additional effort, but this effort is necessary to ensure that the origin-to-destination requirement is met.  

The above also comes with a corresponding requirement that reasonable efforts be made to inform the riding public that such additional service is available.

Given the requirements for “origin-to-destination” service, the choices are to have door-to-door service all the time or some of the time. If the choice is “some of the time,” then the policy is “curb-to-curb, and if you want help from there you have to ask for it.” In addition, such a policy must be communicated to customers, and it must be understood by staff and drivers, as well as customers. It seems complicated and fraught with potential problems.  

If you have to provide door-to-door service some of the time, why not just do it all the time? Wouldn’t that be a far better policy decision?

For additional information on this topic, read the related White Paper: "The Benefits of Door-to-Door Service in ADA Complementary Paratransit."

Zavisca is an independent consultant specializing in paratransit. He can be reached at joe@joezavisca.com.

In case you missed it...

Read our METRO blog, "Bus simulation, ensuring its proper place in a training curriculum."

Joe Zavisca


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  • George H. Bagnetto[ February 10th, 2014 @ 1:32pm ]

    While I agree with most of Mr. Zavisca comments, I think it only fair to include the below ADA guidance language also. "It should be emphasized that the regulation does not require a general change in a provider’s basic mode of service from curb-to-curb service to door-to-door service. It should also be emphasized that transit providers are not required to take actions to accommodate individual passengers’ needs that would fundamentally alter the nature of the service or create undue burdens. In this respect, the Department interprets the scope of transit providers’ origin to destination service obligation analogously to the general obligations of public entities under the ADA to provide program accessibility. For example, the Department does not view transit providers’ obligations as extending to the provision of personal services. Drivers would not have to provide services that exceed “door-to-door” service (e.g., go beyond the doorway into a building to assist a passenger). Nor would drivers, for lengthy periods of time, have to leave their vehicles unattended or lose the ability to keep their vehicles under visual observation, or take actions that would be clearly unsafe (e.g., back a vehicle down a narrow alley in specific circumstances that would present a direct threat to safety). These activities would come under the heading of “fundamental alteration” or “undue burden.” As a recently retired Commissioner of an upstate New York Public Transit property, I believe most transit managers want to do the right thing and assist people in the disabled community as much as is practical and reasonable within the resources of the transit property. The important words in the ADA guidance in my opinion are; "fundamentally alter the nature of the service or create undue burdens". Many smaller transit properties simply cannot afford door to door service, to do so would require bus monitors or helpers, especially if the consumer needs to have help climbing stairs

  • Bob[ February 12th, 2014 @ 10:56am ]

    1. the Complementary Paratransit rule is probably the most misinterperted, misunderstood and abused regulation in ADA. 2. paratransit is an economic blackhole that will suck the resources of a transit agency to the bone 3. in the preamble of 49CFR37 it says "The ADA is a civil rights statute not a transportation or social service program statute. The ADA clearly emphasizes non discrimaniatory access to fixed route service with complemetary paratransit acting as a safety net. for people who cannot use the fixed route system. UNDER THE ADA COMPLEMENTARY PARATRANSIT IS NOT INTENDED TO BE A COMPREHENSIVE SYSTEM OF TRANSPORTATION FOR INDIVIDUALS WITH DISABILITIES" (emphasis mine, fed reg Vol 56, No 173 pg 45601) No transit system that I am aware of strictly follows the requirements of the 49CFR37 and bow to the do good presure from the outside. Paratransit has turned into a private taxi service for the few and almost excludes those who it was intended to serve. part of the problem is too few "Disabled trained transit professionals" are involved in the running of these systems. and it has turned into a gravy train of "professional instructors" that really don't get it. now before anyone starts yelling . I have retired now . I have a degree in transportation engineering (40+ yrs) . I have run private, public mainline and paratransit systems . I sat on the committee that advised and wrote the ADA regs . and I am a disabled person myself! so I know what I speak of reread the actual ADA regs and consider following them Bob

  • CE Case[ February 13th, 2014 @ 9:02pm ]

    Weighing in as a seasoned professional Paratransit driver whose wife is also disabled, I would offer the additional insight that every scenario is different and even repetitive scenarios can change frequently if for no other reason but because of weather. An individual capable of transporting themself from curb-to-door or visa versa independently in good weather may not be able to if snow and/or ice are present. Progressively degenerating health and/or a medical condition can also change the need of the individual passenger even on a daily basis. Quite simply, the most important factor in ADA Paratransit services is a competent, well-trained driver capable of making good decisions in the field based on guidelines made in legislation. My employer almost immediately adopted a door-to-door policy because it became readily apparent that our mission wasn't complete until all passengers had successfully completed their ENTIRE trip. Door-to-door is defined as door of the bus to door of the destination. No stairs, no opening or closing locks/doors, no entering any premise either private or public etc. Door-to-door only. Not all passengers require this service, but a passenger left sitting in a wheelchair on an icy sidewalk ten feet away from the door and unable to reach the door has not indeed completed their trip and furthermore, may actually find themselves in a compromising situation that may include danger. I won't even get into liability factors here except to say the fastest way to "suck the resources of a transit agency to the bone" is through litigation. In my humble opinion, Paratransit operators should offer door-to-door services when deemed necessary to any and all passengers and that final decision should be given to the driver. He or she is the one out on the actual scene which gives the driver far more insight as to the actual situation than someone sitting at a desk or in a committee meeting.

  • Edie Biro[ February 25th, 2014 @ 7:42am ]

    We provide door to door and most of the time door through door, although there are many of our customers that need a PCA or companion to assist them beyond the lobby. There is an expectation that the operator is responsible beyond the door, and we continually try to educate our customers and caregivers of ours and their responsibility.

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Heather Redfern

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Scott Belcher

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Joel Volinski

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Brian Antolin

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Joe Zavisca

Joe Zavisca is an independent consultant specializing in paratransit service.


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Communications Director, Mobility Lab

Paul Mackie is communications director at Mobility Lab, a leading U.S. voice of “transportation demand management.”


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White Papers

Mass Transit Capital Planning An overview of the world-class best practices for assessing, prioritizing, and funding capital projects to optimize resources and align with the organization’s most critical immediate and long-term goals.

The Benefits of Door-to-Door Service in ADA Complementary Paratransit Many U.S. transit agencies continue to struggle with the quality of ADA service, the costs, and the difficulties encountered in contracting the service, which is the method of choice for a significant majority of agencies. One of the most basic policy decisions an agency must make involves whether to provide door-to-door, or only curb-to-curb service.

Mass transit mobile Wi-Fi & the public sector case study How Santa Clara Valley Transportation Authority successfully implemented Wi-Fi on its light rail and bus lines

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