AMERICANS WITH DISABILITIES ACT
PARATRANSIT PLAN FOR CITY OF COLUMBUS, INDIANA
Revised June 16, 2022
Definition of Complementary Paratransit Service
The Americans with Disabilities Act regulations require City of Columbus, ColumBUS Transit, as a public entity that operates a fixed route system, to provide complementary paratransit services to individuals with disabilities (that is, service that is comparable to the level of service provided to individuals without disabilities who use the fixed route system). See 49 CFR Sec. 37.131 (a).
Americans with Disabilities Act of 1990 and of 2008
The Americans with Disabilities Act of 1990 (ADA) prohibits discrimination and ensures equal opportunity and access for persons with disabilities. It provides the general framework and approach for ending discrimination for persons with disabilities. The stated national goals of the ADA are to guarantee that persons with disabilities have equality of opportunity, a chance to fully participate in society, ability to live independently and be economically self-sufficient.
Section 223 of the Americans with Disabilities Act of 1990 requires that public entities that operate non-commuter fixed-route transportation service also provide complementary paratransit service for individuals unable to use the fixed-route system. The regulations 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. ADA complementary paratransit standards are provided for in 49 CFR Sec. 37.123 of the Code of Federal Regulations.
In general, the law prohibits public transit systems from denying individuals with disabilities the opportunity to use public transportation services, when they are available. It prohibits public entities from providing services that discriminate against persons with disabilities. The ADA requires the development of programs that will ensure the integration of all persons into the public transportation system, and thus all of the opportunities transportation makes possible. The goal is to ensure non-discriminatory, equitable, accessible and safe public transportation, enhancing the social and economic quality of life for people with disabilities.
Specific actions must be taken by public transit agencies to avoid discrimination. For example, the law requires that:
- All newly purchased or leased vehicles used in fixed-route service must be accessible to persons with disabilities.
- Public agencies which provide fixed-route public transportation service also must offer similar complementary paratransit services to individuals with disabilities who are unable to use the fixed-route system.
- New facilities must be accessible.
- Alterations to facilities must include features to make them accessible.City of Columbus, ColumBUS Transit complies with all requirements of the Americans with Disabilities Act.
Service Provided by the City of Columbus, ColumBUS Transit
ColumBUS Transit operates fixed-route bus and paratransit services (called Call-a-Bus) from 6:00am to 7:00pm Monday through Friday, and 6:00am to 6:00pm Saturday. The system has a fleet inventory of five (5), heavy-duty, 30-foot, diesel buses for fixed-route operations, and five (5), 12-passenger converted vans for paratransit service. All vehicles are wheelchair accessible, thus all fixed routes are wheelchair accessible.
Current fixed-route service includes four (5) routes. These routes have one-hour headways, and carry about 220,000 passenger trips annually.
Call-a-Bus is an “origin to destination” demand-response service that is provided for persons who, because of disability, are unable to access the fixed-route bus service.
Columbus is a fairly compact community. The street network pattern is primarily a grid-system. The five existing public transit routes have a lengthy configuration. Each of the route buses leaves from Mill Race Transit Center, a transfer station near the downtown, at five minutes after the hour as a timed-transfer point. Similarly, routes 1-4 outbound buses have a common terminus at the Target Store in the Columbus Shopping Center.
Services Provided by other Entities
Five other organizations were identified as providing some level of paratransit service in the City of Columbus. These are:
- Area XI Agency on Aging – providing transportation for persons over 60 and for those on Medicare going to a medical appointment.
- Development Services Inc. – Provides service to consumers of their agency for work related purposes.
- Head Start – Provides service to low income children to attend Head Start programs.
- Mill Race Center – Service in support of the center.
- Bartholomew Consolidated School Corporation – Provides school bus transportation, including 17 accessible vehicles.
Rules for ADA Eligibility for Complementary Paratransit Services
ADA complementary paratransit service must be provided to all passengers described as being ADA eligible under 49 CFR Sec. 37.123. ADA eligibility includes the following:
- Any individual with a disability who is unable, as a result of a physical or mental impairment (including a visual impairment), and without the assistance of another individual (except the operator of a lift or other boarding assistance device), to board, ride or disembark from an accessible vehicle in the fixed- route system. Included in this category are individuals with mental or visual impairments who cannot navigate the fixed-route system.
- Persons who cannot use vehicles without lifts or accommodations. These persons are eligible for paratransit service if accessible fixed-route vehicles are not available on the bus routes in which they need to travel, when they need to travel during operational hours of ColumBUS Transit. (All ColumBUS Transit fixed-route vehicles are accessible).
- Persons with specific impairment related conditions that cannot travel to a boarding location or from a disembarking location to their final destination. The condition must prevent the person from using the fixed-route system. Conditions that make getting to the fixed-route bus stop “more difficult” do not grant eligibility. Second, architectural barriers (such as no curb cuts) are not under the control of ColumBUS Transit, and environmental barriers (such as distance, terrain, and weather) do not, when considered alone, confer eligibility. If, however, travel to or from a boarding location is impossible when these factors are combined with the person’s specific impairment-related condition, conditional paratransit service will be provided to eligible passengers.
Call-a-Bus ADA Eligibility Certification Process
Applications for Call-a-Bus ADA eligibility for ColumBUS Transit’s complementary paratransit service are available at ColumBUS Transit’s office located at The Mill Race Station, 850 Lindsey Street, Columbus, Indiana 47201 or a request for an application to be mailed can be made by calling the ColumBUS Transit office at (812) 376-2506. Applications are also available for download from ColumBUS Transit’s website located at www.columbus.in.gov by clicking on the “Departments” tab, then on “ColumBUS Transit”. This site also includes hours of operation, holiday schedules, fares, and route information.
There is a two part application (see Appendix A) which you must complete before you are allowed to use ColumBUS Transit Call-a-Bus service. The first part is the Applicant’s Questionnaire to be filled by the applicant or someone on the applicant’s behalf. The second part is the Medical Professional’s Questionnaire, where a medical professional familiar with the applicant answers questions about his or her ability to use fixed route bus service. ColumBUS Transit uses this information to determine eligibility for using the Call-a-Bus Service.
Once the completed application is received, ColumBUS Transit will notify the applicant within twenty-one (21) days of his/her eligibility status. If a determination has not been made within 21 days of receiving the completed application, the applicant will be treated as eligible and will be provided service until ColumBUS Transit determines their eligibility. The applicant will receive a letter verifying whether they are eligible for service or not, and if so, what type of eligibility, and for how long. If the eligibility is limited or denied, ColumBUS Transit will state specifically the reason for the limitation or denial. For visually-impaired customers, a phone call will be made in addition to the letter.
Under conditions where the applicant satisfactorily shows the Medical Professional’s Questionnaire cannot be completed in a reasonable time due to protracted appointment dates or other causes beyond the control of the applicant, ColumBUS Transit staff will make a temporary determination regarding eligibility based only on the Applicant’s Questionnaire. If granted, it will extend until 21 days after the provided appointment date. If not granted, it will be reconsidered as a new application once the completed Questionnaire is received.
Types of Eligibility
There will be three (3) types of eligibility: Temporary Eligibility, Conditional Eligibility, Full Eligibility. There can also be Temporary Conditional Eligibility. Temporary Eligibility will expire on a specified date determined by ColumBUS Transit staff based on the application information. Full Eligibility is not eternal, but will expire in a maximum of 5 years. A Conditional Eligibility, for example, may allow individuals to take Call-a-Bus trips to certain destinations due to inaccessible infrastructure, where other destinations can be accessed successfully by the individual using the fixed-route system. Certain weather conditions like snow or high temperatures may also determine criteria for Conditional Eligibility.
ColumBUS Transit can request any or all customers to reapply at any time based on health conditions or after legal or policy changes, among other reasons, but must give 90-day minimum notice of expiration in writing. These requests cannot be arbitrary or capricious, discriminatory, or unreasonably frequent.
Eligibility Determination Process
Eligibility will be determined by trained ColumBUS Transit staff and will be based on ADA eligibility standards described in 49 CFR 37.123 and 49 CFR 37.125. Regulation 49 CFR 37.125(a) states, “The process shall strictly limit ADA paratransit eligibility to individuals specified in 37.123 of this part.” The Transit Coordinator will review applications to ensure that due process has been observed. The applicant will receive a letter describing their eligibility. If eligibility is denied or limited, the letter will describe why they were denied or provided limited service, and how they can appeal the decision. The letter will be sent in the format requested in the application.
Appeals Process for ADA Eligibility
If the applicant disagrees with the determination, he/she may appeal the decision. The appeals process will be carefully explained to all applicants who are rejected or granted limited eligibility. The following steps will be used to appeal the eligibility determination:
- The applicant will have sixty (60) days to file an appeal with the Transit Coordinator, which can be mailed, emailed or presented in person to the ColumBUS Transit Mill Race Station.
- An appeals committee consisting of the Transit Coordinator, MPO Director, the City Director of Operation and Finance, and a selection of two peer Call-a-Bus customers will investigate all eligibility appeals. The Transit Coordinator may collect additional information as part of the review. The applicant will have the opportunity to be heard in person or may submit all his/her arguments in writing or an accessible format. The appeals committee will have fourteen (14) days from the date of the appeal to render a decision. After fourteen (14) days, the applicant will be presumed eligible until a decision has been reached. The applicant will be notified by letter, and other methods requested.
- If a customer appeal is denied and the applicant believes the ADA paratransit eligibility process was unfair, the applicant can file a complaint with the Federal Transit Administration Office of Civil Rights, 1200 New Jersey Avenue, SE, Washington D.C. 20590 (866) 377-8642 (Voice) (800) 877-8339 (TTY)If you are interested in becoming a peer member of the Appeals Committee, please contact the Operations Assistant.
ADA Eligible Visitors Policy
Visitors not from this jurisdiction may be able to use Call-a-Bus. Visitors who are ADA eligible with another transit system may use Call-a-Bus services. Visitors shall provide ColumBUS Transit with documentation that (1) they are not residents of Columbus, and (2) they are paratransit eligible elsewhere. If they cannot show ColumBUS Transit staff they are eligible elsewhere, but can show sufficiently they are a visitor and are disabled, they may use Call-a-Bus services for up to 21 different days for one (1) year. If the visitor needs further service, he/she must apply for Call-a-Bus eligibility.
Meeting the Requirements of the Americans with Disabilities Act
Under ColumBUS Transit Paratransit Service Plan, the level of service provided to persons determined to be ADA eligible is similar to ColumBUS Transit’s fixed-route bus service. Six service criteria are included in the regulations. The following is a description of how ColumBUS Transit’s paratransit service meets or exceeds the service criteria:
ADA complementary paratransit service is provided to all origins and destinations within the service area defined as the city limits of Columbus. For Columbus Transit, the basic service is not only centered on each fixed-route and extending ¾ of a mile to either side of the fixed-route, but also includes all areas within the city limits of Columbus.
As stated in the regulations, pick up times will be negotiated with ADA eligible passengers to make scheduling more efficient. As a shared-ride service, Columbus Transit is allowed to negotiate within a one-hour window on either side of the requested pick up time. Any negotiation of time will be discussed with the passenger prior to pick up. The vehicle can arrive up to thirty (30) minutes after the agreed upon time.
Paused Fare Structure:
All of ColumBUS Transit service fares have been paused indefinitely.
There are no priorities for trip purpose.
Hours and Days of Service:
ADA complementary paratransit service shall be offered during the same days and hours that Columbus Transit offers fixed-route service. As of the adoption of this Plan, the hours of operation are Monday-Friday 6:00am to 8:00pm, and Saturday 6:00am to 6:00pm. These hours are subject to change without a change to this document.
Hours and Days of Reservation Requests:
Telephone reservation requests are accepted Monday – Friday 8:00am to 4:00pm, Sunday reservation hours are also 8:00am to 4:00pm, but these may be taken by voicemail.
Reservations can be made from three (3) weeks before the trip to the day before the trip.
There are no capacity constraints at this time. Call-a-Bus has strict service standards that are adhered to. Call-a-Bus strives to accept every trip request.
ColumBUS Transit does not limit the number of Call-a-Bus trips an eligible passengers can make.
Personal Care Attendant Policy
Personal Care Attendants (PCA) will be permitted to accompany ADA eligible riders on ADA eligible trips at no charge. ColumBUS Transit will require that passengers state the need for a PCA when they schedule their trip. ColumBUS Transit does not provide PCA’s.
One guest will be allowed to accompany an ADA eligible complementary paratransit passenger on their ADA eligible paratransit trip. More than one guest will be allowed on a space available basis. The PCA is not considered to be a “guest” or companion. All guests, family members, companions, or friends are required to pay the applicable paratransit fare.
Columbus Transit’s Origin-to-Destination Assistance Policy
It is the policy of ColumBUS Transit to provide paratransit services within the City limits of Columbus. Transportation service is provided by ADA accessible buses or vans. To ensure timely service, ColumBUS Transit’s paratransit services are considered curb-to-curb. Operators are trained to provide minimal assistance only.
Drivers will help to and from the door if Personal Care Attendant, friend, family member, or companion have been asked but are not available, and such special assistance has been requested the day before the trip or earlier.
To ensure timely service, passengers are encouraged only to bring what they can carry on their own or with the assistance of a PCA.
Call-a-Bus has a 30-minute pick-up window from the scheduled pickup time to arrive. Customers must board within 5 minutes of the vehicle that arrive within the 30-minute window. Drivers can leave after waiting 5 minutes if the customer does not appear.
- If the Call-a-Bus vehicle will be more than 15 minutes late for a scheduled pick-up time, ColumBUS Transit will make every effort to let the Customer know.
To cancel reservations, passengers should notify dispatch as soon as possible, but at least one (1) hour before their scheduled transport time.
Description of the Public Participation Process
ColumBUS Transit, in an effort to solicit full public participation, has defined a comprehensive public participation process.
The city also solicited the input of persons with disabilities in the development and implementation of the ADA paratransit service through the City’s Transit Advisory Committee (TAC) which consists of service agencies and disabled riders that utilize the paratransit service (see Appendix B). The TAC was substantially involved in the development of the proposed changes to the plan. Minutes of TAC meetings can be found in Appendix C.
The city conducted a public hearing to solicit public comment on this Plan and the changes herein. This was held on Monday, April 1, from 2:00pm to 6:00pm. The Plan was available in hard copy at the ColumBUS Transit Mill Race Station and the City Hall Clerk/Treasurers office, and online. Notices were also up at the Mill Race station and on all the buses. The legal notice, the notice in the buses, and the comments/responses from the Public Hearing and during the public input period can be found in Appendix D [pending completion].