CHAPTER 3
Planning and Designing an Alternative Service
While some aspects of alternative services are more common than others, there is no one “best” or “preferred” template for an alternative service (see Chapter 10 for a discussion of the variations identified in this research project). A transit agency interested in providing an alternative service should consider following a process that starts with planning. This involves considering and defining the objectives of the alternative service and how it might be provided, understanding and complying with applicable federal regulations and guidance, determining the budget for the service, and developing an evaluation plan.
Planning
Define, Document, and Evaluate Objectives
Why is the transit agency considering an alternative service? What are the reasons and motives behind providing such a service for ADA paratransit riders? It’s important to understand these points at the beginning and to define and document those objectives.
As shown in Figure 3-1, the two most common motivations for an alternative service are to reduce the overall costs of transporting paratransit customers and provide an on-demand mobility option for those customers. The third most common motivation—reducing the demand for paratransit service—traces back to the first motivation about reducing cost.
No doubt providing an on-demand/same-day mobility option for paratransit riders will improve the level of service for these riders compared to ADA paratransit’s next-day service. The anecdotal feedback from riders by way of the rider focus groups and other testimonies collected in the case studies evidence how alternative services have made a significant difference in the lives of ADA paratransit customers. And while the alternative service can be structured so the subsidy per trip is less than the cost per trip on ADA paratransit, riders are likely to take new trips on alternative services beyond those they would have taken on the ADA paratransit service. So whether or not there is an overall cost reduction stems from whether the savings from the mode-shift trips is greater than the additional subsidies associated with induced trips. Also, there are other ways (e.g., trip limits) to tip the scales so the collective amount of trip-making
by ADA paratransit customers increases without additional cost, or even at a lower cost. These are things to keep in mind when considering and defining objectives for an alternative service.
The relationship between the two most common objectives was a central question for this study, and the research team developed a data tool to help transit agencies explore that (see Chapter 6). This tool can be used when considering budget for an alternative service and testing different options for the subsidy (more on subsidies below). The tool can then be used once an agency has real-world experience with the service and data on trips and costs, to estimate the impact on the overall budget for ADA paratransit.
When the objectives for the alternative service are being considered, it’s a good idea to think about how those objectives will be reviewed and assessed once the service is implemented. Do the objectives lend themselves to evaluation? What are the metrics that measure whether the objectives have been achieved? See Chapter 5 for more on assessment and evaluation. Figure 3-2 depicts the evaluation schema used by Broward County Transit for its alternative service.
Learn from Other Transit Agencies
Transit industry experience with alternative services is growing as these services become more prevalent. It’s important to take advantage of this and reach out to other transit agencies that have implemented an alternative service. The 18 transit agencies that responded to this research project’s survey are listed in Chapter 9 and may be resources.
If you reach out to other transit agencies for their experience, you might also request copies of the agreements they used for their alternative service, to serve as examples and possibly tailor for your own use. See Appendix B for examples obtained through this research project.
Discuss with Advisory Group and Key Disability Community Stakeholders
Once you have a starting point with objectives for the alternative service, discuss the plan with your disability advisory group and key stakeholders in the disability community.
How might the alternative service benefit your ADA paratransit riders? What would be the advantages (and perhaps disadvantages) to your riders? Do your riders have experience with any local transportation providers that might be options for providing the alternative service? If so, is that good experience?
Ensure Policy Board Support
Implementing an alternative service, especially if considering using TNCs, may be a very new undertaking for a transit agency. Be sure your policy board understands what you are planning. In some cases, the motivation for pursuing an on-demand service with TNCs may actually come from the policy board or decision-makers.
Recognize and Address Issues for Internal Follow-Up
Providing an alternative service raises issues that require discussion and consultation within your transit agency. What should the transit agency require for insurance? What about legal liability for your transit agency in case of an accident? Be sure to talk to your risk management and legal departments. This is particularly true if working with a TNC, as these companies are relatively new compared to the more established for-hire transportation companies such as taxis.
Insurance is an important issue. Private transportation providers adhere to their own insurance requirements; for example, taxi companies typically have to meet insurance levels set by the local regulatory body (the city or county). Are these levels adequate for your transit agency? Would requiring insurance coverage at the same level that you require for a contractor operating ADA paratransit service price out some of the prospective local transportation providers that might be options for providing an alternative service? Transit agencies have taken different approaches for insurance. Figure 3-3 shows the responses regarding vehicle insurance provided through the study’s survey.
What about any labor unions—might they have concerns? Curtis et al. (2019) reported that two transit agencies had indicated labor union concerns. In both cases, however, the TNCs were not planned to provide an alternative service: in one case, TNCs were being planned to replace low-performing fixed routes and in the other, first mile/last mile service.
One of this study’s surveyed transit agencies did report labor concerns as one of the challenges it faced in planning its alternative service. According to this agency, one of its labor unions voiced concerns about plans to use TNCs for an alternative service as the union felt this would result in a need for fewer dedicated drivers (and that would then lead to fewer union members). While this was not the case, the union nevertheless made its concerns clear.
Budget and Funding
Discuss options and resources to fund the alternative service. Are there grant programs or other available funding sources to support an alternative service? What are the constraints on those funds? Is there a budget the alternative service must meet? The case study transit agencies used different funds to support operations of their alternative services, including FTA Section 5310.
As part of the planning process, you may also want to consider the extent to which the alternative service creates new trips that your ADA paratransit riders would not have taken otherwise. The convenience of an on-demand service may create new demand, referred to as induced demand.
If one of the objectives of your service is to help reduce the overall costs for ADA paratransit (or to provide more trips without increasing the budget), it may be useful to estimate the extent of the new trip-making and the estimated cost of those new trips and compare that with the savings from the mode-shift trips taken on the alternative service but that would have been taken on the ADA paratransit service. That estimate will depend, of course, on how you set the fare and the maximum subsidy per trip and whether there are any additional limits you make on trip-making on the alternative service.
This project’s data tool lets you estimate the induced demand and potential costs of that demand (see Chapter 6).
Design
How should the alternative service be structured? There are several options; Chapter 10 presents the different ways transit agencies have approached designing and implementing their alternative services, with advantages and disadvantages. If you are still considering how your alternative service might be structured, Chapter 10 provides useful information.
Provider-Side or User-Side Subsidy?
Consider the advantages and disadvantages of the two types of subsidies for the alternative service—provider-side versus user-side—and determine the preferred approach.
There is no best method to provide the subsidy. Provider-side programs are more common and allow the transit agency more control over service quality through the provider contracts, while user-side programs entail less administrative effort for the transit agency and give riders more flexibility. Also, without contracts, a user-side subsidy program may not deliver enough data to adequately monitor the program (although this can depend on the technology used). Do your stated objectives for the alternative service suggest one type of subsidy program over the other? Does your transit agency have the staff and time to administer a provider-side subsidy program? Is less administrative effort and time more realistic?
Consider Potential Providers
Are there local providers that may be appropriate? What about the national TNCs? What input and advice did you receive if you contacted other transit agencies with an alternative service?
The options for providers of the alternative service that currently operate in your community may suggest which subsidy program is more appropriate. Are there well-managed local taxi companies? Do they operate any WAVs? Are Uber and Lyft available in your community? Assessing the transportation market should recognize that the COVID pandemic has impacted the for-hire transportation industry across the country; some smaller companies went out of business and others are rebuilding their driver ranks.
If your transit agency currently uses any contractors for nondedicated service to support the ADA paratransit service, perhaps one or more of these contractors might be considered options to also provide the alternative service. If so, be sure the provider has adequate capacity for both types of service, and ensure there are no incentives or disincentives in an agreement, such as the rate structure, that causes the provider to favor one type of service over the other.
If considering TNCs, it’s good to identify what the companies typically offer, including driver qualifications, driver training, provision of WAVs, and options for riders without smartphones and riders who are unbanked.
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Wheelchair-Accessible Service
The transit agency may require that TNCs arrange for WAV service through a third party, or the transit agency may contract directly with a separate provider operating WAVs. In the latter case, transit agencies have used taxi companies that operate accessible taxicabs and NEMT companies that operate WAVs. Another option, though the research team did not encounter this, is for the transit agency to provide accessible vehicles to an alternative service provider that lacks WAVs, perhaps selling retired-but-with-remaining-useful-life vehicles to a provider for a nominal amount.
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Trip Requests
If trip requests are decentralized and go directly to providers, customers who do not have a smartphone or access to the Internet must be considered. This effectively means a call-in option needs to be available (in the case of taxis this is seldom an issue as most taxi companies accept service requests by phone).
For TNCs, you may wish to directly provide a backup call-in option. Typically, this is done in one of two ways: (1) the transit agency directly provides this backup call-in option through its ADA paratransit call center; in this case, there is a separate call-in number that goes to staff who have a link to the TNC technology and enter the called-in information as a TNC request. This is called concierge service. In cases where the customer can choose between two or more TNCs, a concierge link to each TNC would need to be provided to that staff. Or (2) the transit agency would require a backup call-in option in its contract with the TNC(s). Some national TNCs provide this already, not only for alternative services but for microtransit services too. Some TNCs also have a subcontract for a call-taking function.
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Fare Payment
For riders who are unbanked—lacking a credit or debit card—TNCs may allow payment with a prepaid debit card, sometimes also known as cash cards. These are readily available at national chain drugstores and convenience stores. The only downside of this option is that a
customer may have to take and pay for a round trip to reach such an establishment. That said, if it’s a location where errands are regularly made, adding one more to-do item would address that argument.
Consider an RFI and/or Public Meeting to Gather Information about Providers
It may be useful to consider issuing a request for information (RFI) to local and other transportation providers to obtain feedback from their perspective. Figure 3-4 shows the front page of an RFI issued by WMATA.
A variation of an RFI is a public meeting where local and other transportation providers are invited to listen to the transit agency’s plan for an alternative service and given the opportunity to ask questions and provide input. Such a meeting may be in addition to a formal RFI.
The Regulatory Framework
A critical step in planning and designing an alternative service is to review and understand the regulatory framework and ensure the planned design of your service will comply.
The framework includes federal laws, regulations, and guidance that transit agencies must follow with an alternative service for ADA paratransit riders. The laws, regulations, and guidance are identified and explained in Chapter 8, but it is also important to check the FTA website for new information and guidance; as of 2022, this is published on the Shared Mobility page (see https://www.transit.dot.gov/shared-mobility).
This chapter identifies regulatory issues the surveyed transit agencies found most challenging when they planned and implemented their alternative service. For more complete information, see Chapter 8.
Americans with Disabilities Act (ADA)
The ADA applies regardless of whether there is federal funding involved, and it applies to both public and private transportation providers. To be specific, this is the ADA at large and not the specific guidelines unique to ADA paratransit.
When a transit agency enters into an arrangement of some type with a private provider such as a TNC or taxi company to provide an alternative service, the “stand in the shoes” requirement does not apply when the transit agency only provides subsidies to the private provider to underwrite its riders’ use of the private providers’ service, such as those given to ADA paratransit riders for alternative on-demand taxi and TNC services. However, a transit agency partnering with a TNC or taxi company for the provision of service is responsible for ensuring service meets ADA requirements.
The six service criteria that ADA paratransit must meet do not apply to an alternative service. This is because alternative services are by definition provided on a same-day and typically on-demand basis, which goes beyond the next-day service requirement for ADA paratransit.
Service Equivalency Criteria
The ADA’s seven service equivalency criteria do apply to an alternative service. These should not be confused with the six service criteria for ADA paratransit.
The ADA’s regulations on service equivalency address the requirement that demand-response services (which is what alternative services are), when viewed in their entirety, must provide people with disabilities, including wheelchair users, the same level of service as those without disabilities, as measured by seven criteria:
- Response time
- Fares
- Geographic area of service
- Hours and days of service
- Restrictions or priorities based on trip purpose
- Availability of information and reservations capability
- Any constraints on capacity or service availability
The key fact for a transit agency planning an alternative service for its ADA paratransit riders is this: the FTA has determined that all rider subsidy programs administered by transit agencies—including those provided only for ADA paratransit-eligible riders—must be operated in a way that provides equivalent service to individuals with disabilities, including individuals who use wheelchairs (see https://www.justice.gov/usao-ma/pr/mbta-resolves-allegations-ada-violations).
Service Equivalency Criteria Versus ADA Paratransit’s Six Service Criteria
Unlike the six service criteria that apply to ADA paratransit, the seven service equivalency criteria are not intended to frame service to be complementary to a transit agency’s fixed-route service. As one example, the fare for an ADA paratransit trip can be no more than twice the undiscounted fare for a comparable fixed-route trip. This is not the case for an alternative service trip. That fare can be set at a level determined by the policy of the transit agency. It may mirror the fare for an ADA paratransit trip, but it can be more (or less). For the fare, service equivalency means the fare must be the same for all riders, including riders who use wheelchairs. The rider who uses a wheelchair cannot be charged more because it takes longer for the rider to board and deboard, or because the accessible vehicle costs more to operate and maintain. Setting fares for an alternative service is discussed in more detail later in this chapter.
Of the service equivalency criteria, response time merits additional attention. Response time receives the most attention among the service equivalency requirements because it can be the most challenging to meet. It may be more challenging to ensure that an on-demand service provided with taxis and/or TNCs has an equivalent response time for an ADA paratransit rider who requires a WAV compared to an ADA paratransit rider who can use a taxi sedan or TNC sedan. As the transit industry is well aware, there are far fewer WAVs than sedans operated by taxi companies and TNCs.
When transit agencies began using TNCs in the mid-2010s, the U.S. DOT issued guidance in the form of a Dear Colleague letter in 2016 regarding response time. The letter reminded transit agencies of their obligation to provide equivalent service for riders who use wheelchairs when using TNCs, and specifically of the requirement for an equivalent response time.
The FTA has provided further guidance on its website, with information on shared mobility and the ADA. According to the FTA, should a transit agency partner with a TNC for demand-response service, the agency must ensure, among other requirements, that a rider who needs an accessible vehicle “would not have to wait longer for service” than a typical ridesource user for a similar trip (FTA 2016).
The two ways to address the service equivalency requirement are (1) to ensure there are enough WAVs available; and if that is not possible, (2) to impose a one- or two-hour advance reservation policy for all riders. The need to evidence service equivalency also suggests that the
transit agency must be in a position to evaluate whether the WAV and non-WAV response times are equivalent.
Title VI of the Civil Rights Act
Transit agencies must ensure their alternative service complies with Title VI of the Civil Rights Act of 1964, a federal law that prohibits discrimination on the basis of race, color, and national origin in programs and activities that receive federal financial assistance. Compliance with Title VI has been broadened through regulations to include requirements that transit agencies receiving federal funds must ensure their programs and services do not result in disproportionately adverse impacts on minority populations and limited English proficient (LEP) persons.
For an alternative service, key Title VI issues relate to fare payment and access to trip reservations. Using a TNC generally requires a rider to have a credit/debit card and a smartphone, which not everyone has. This means the alternative service must give riders without a credit/debit card and/or smartphone a way to use the service.
The FTA’s Drug and Alcohol Testing Requirements
Federal transit law requires transit agencies receiving funding through the FTA’s urban and rural grant programs to comply with drug and alcohol testing of staff in safety-sensitive positions, including those operating, dispatching, and maintaining revenue service vehicles. Vehicle operators are the primary staff impacted by the regulations.
The requirements also apply to the contractors and subcontractors of transit agencies. The arrangements for contractors and subcontractors may be formal, such as a written contract, or an informal arrangement “that reflects an ongoing relationship between the parties,” per the FTA’s website.
These requirements apply to alternative services providers, barring the taxicab exception.
What Is the Taxicab Exception?
The taxicab exception provides an exemption from the FTA’s drug and alcohol testing requirements under certain conditions when a transit agency is contracting with taxi companies and/or TNCs. The condition is this: when riders select their own transportation provider from among at least two providers under contract, the taxicab exception applies. The FTA provides useful guidance on the taxicab exception on its website, www.transit.dot.gov/regulations-and-guidance/shared-mobility-faqs-controlled-substance-and-alcohol-testing-requirements.
Important points for a transit agency to know when designing an alternative service are:
- If the alternative service has only one provider, the FTA’s drug and alcohol testing requirements apply, and you must ensure your contractor complies with them.
- If the alternative service has two or more providers and riders can choose which provider they want for their trip, the taxicab exception applies. The transit agency itself (or through its ADA paratransit contractor) cannot assign a rider’s trip to a provider.
Since some of the current alternative service programs use a TNC and a taxi company, with only the taxi company offering WAVs (and taking phone reservations and cash payment), the FTA provides guidance for situations where “a public transit agency contracts with two or more ridesourcing companies [TNCs] as well as one or more taxicab companies in order to ensure the service is available for all passengers,” stating that “while some passengers may have only one choice, this does not change the fact that many passengers will have more than one choice, and so the taxicab exception will apply to all of the providers” (FTA 2018).
National Transit Database
Transit agencies receiving funding through the FTA’s urban and rural grant programs are required to report operating, financial, and asset data to the NTD. Reporting requirements are spelled out by the FTA annually in the NTD manual, and it’s important to follow each year’s manual when reports are prepared as data and reporting requirements may, and have, changed year to year.
Transportation service provided through alternative services—which is service provided under contract to a transit agency—is defined as “purchased transportation,” assuming the service meets the full definition per the NTD (see Chapter 8 for the details on the definition).
Purchased transportation is categorized into three types (NTD 2020):
- Taxi service (TX). Purchased taxi service may be operated with nondedicated vehicles, such as is done for an alternative service. Or taxi service may provide dedicated ADA paratransit service for a transit agency, in which case it is reported in the third category, purchased transportation—general (PT).
- Transportation network company (TN). The NTD refers to this service as a “special type of service” that is provided by a TNC for a transit agency using nondedicated vehicles.
- Purchased transportation—general (PT). This is service purchased from a public or private transportation provider that does not fit the first two categories. PT services include all purchased transportation services that use dedicated vehicles, including those operated by a taxi company.
What does this mean for reporting alternative services data to the NTD? Given the formal definition of public transportation, the 2020 NTD manual requirements for data reporting appear to limit transit agencies’ ability to report data on their alternative services, particularly given the requirement that the service be shared-ride. Generally, transit agencies’ alternative services using nondedicated providers such as TNCs and taxis are not shared-ride.
If a transit agency designs its alternative service such that it meets the applicable NTD reporting requirements—e.g., shared-ride service, not a pilot, specified data submitted by the providers—then a transit agency should be able to include data from the alternative service in its annual NTD submission, which means the provider contracts need to specify the collection and reporting of data required by the NTD.
Finalize Design and Policies for the Alternative Service
Various policies provide structure for the alternative service, with guidelines for riders’ use. To finalize the design, consider options for those policies, which are listed and outlined below. A more complete discussion of the policy options is provided in Chapter 10.
Determine Subsidy Level
When setting the subsidy, consider not only your budget for the alternative service but the pricing structure of the provider(s) that will provide the trips and the types of trips your ADA paratransit riders may want to take. If you are using a taxi company, for example, what is the rate structure (i.e., the drop charge and mileage charge)? What would the cost be for the types of trips the alternative service will support in your community? This may depend on how the service area is delineated, one of the key policies to consider.
For Provider-Side Subsidy
How much is the transit agency going to subsidize each trip? Will there be a cap on the cost of each trip, with riders responsible for any cost over that cap? Should there be a base fare and, if so, what should it be?
While the research found a range of approaches, the most frequent approach was to require an initial or base fare, which can be equivalent to the ADA paratransit fare but doesn’t have to be, and then set a dollar limit on the maximum payment (subsidy) per trip and require riders to pay any overage.
The survey responses showed base fares varied from less than the ADA fare to equal to the ADA to more than the ADA fare (one transit agency set the base fare at twice the ADA fare). This is not to say there has to be a base fare, but most alternative services have one.
Based on the research, the maximum subsidy per trip was generally relatively modest, with the transit agency providing $9–$18 of the trip cost, with $15 the most frequent in this range. Two agencies provide a much higher subsidy per trip—$27 for one and $38 for the other—and two agencies use a mileage-based subsidy.
A consideration regarding setting the maximum subsidy per trip is how far the base fare plus the maximum subsidy will allow a rider to travel. The higher the maximum subsidy per trip, the more places a rider can go. For planning purposes, experience in the industry suggests most riders opt to take trips that do not require them to pay a fare overage (although the pandemic changed this for some alternative services, with riders willing to pay for longer trips with a fare overage because they wanted the assurance of an exclusive ride). Accordingly, it may be more cost-efficient to scale down the maximum subsidy per trip if most common destinations can be reached at a lower subsidy level.
This points to the importance of setting the subsidy with consideration for the relationship between riders’ cost for an alternative service trip versus cost for an ADA paratransit trip. Riders may weigh how far they can travel for a base fare (if any) against the maximum subsidy provided for a trip. Say, for example, riders must pay the overage for trips longer than five miles. If unwilling or unable to pay the base fare plus overage, those riders will choose ADA paratransit for their longer trips. This results in shorter trips being diverted to the alternative service and longer trips—trips that are more difficult to group together and that also increase average trip length—staying on ADA paratransit. This impacts productivity, which may increase the cost per ADA paratransit trip.
One transit agency recommended looking for changes in riders’ trip patterns, particularly unpredicted ones, with an alternative service that may impact the ADA paratransit service and the resulting cost-efficiency of the alternative service.
For User-Side Subsidy
Typically the subsidy is provided per month. How much is the subsidy, and how much is the rider’s responsibility? Will riders be able to carry over any leftover funds at the end of the month if they do not use up the full subsidy amount? If so, should there be a time or dollar limit on carryover funds?
Among the surveyed transit agencies, only two had user-side subsidy programs, both providing a monthly subsidy. One of the programs provides a subsidy up to $300 per month, with the rider paying 20% of that total and the transit agency the remaining 80%. The second program provides a monthly subsidy of $80, with riders paying 50% of that total.
Trip Limits?
Should there be any trip limits for a provider-side subsidy program? Either for each eligible rider or for the total trips per month or both? Trip limits are to do with budget control and cost-reduction; if you have a budget limit for your alternative service program, a trip limit might help you stay in budget.
The research found one of the transit agencies began its alternative service with no trip limits but realized with experience that the on-demand nature of the service was creating enough demand that the budget for the program became a concern. Trip limits were then imposed.
Another case study agency started out with a uniform trip limit for all riders. The transit agency later converted to a system where an individual’s trip limit was tied to their history of ADA paratransit trips. The concept was that the transit agency didn’t want to subsidize hundreds of TNC trips for a rider who only made one ADA paratransit trip per month.
User-side subsidy programs do not need trip limits because one of features of such programs is that riders decide themselves how to use the monthly funding allotment. Riders may take more less costly trips or fewer more costly trips.
Service Policies
The research found considerable variation on the policies transit agencies use to structure their alternative services; see Chapter 10 for a more complete discussion of service policy options.
Service Area
Should the service area for the alternative service mirror your ADA paratransit service area or extend beyond that? Configuring the service area may depend on the area served by your ADA paratransit service; it might follow the ADA regulations with ¾-mile corridors around fixed routes or might extend to serve an area beyond what the ADA requires, e.g., an entire county.
Using the same service area as ADA paratransit simplifies user information and marketing, and it increases the likelihood that the alternative service trip might otherwise be taken on ADA paratransit, which would help with cost reduction for the ADA paratransit service. If, however, the ADA paratransit service area conforms to ADA requirements, covering a larger area with the alternative service will give riders the opportunity to reach destinations beyond those they can reach with next-day ADA paratransit. Providing such opportunities may be one of the objectives of the alternative service.
While unlikely, if there are no constraints on the service area, a rider could potentially use the program to take a very long trip out of the defined service area, paying out of pocket once the maximum subsidy is reached.
Service Span (Days and Hours)
In addition to the service area, you will need to decide the service span—days and hours—to structure the alternative service. This could be the same as your ADA paratransit program, or it could be more or less.
Setting the days and hours the same as ADA paratransit is a straightforward approach and facilitates user information and marketing, in the same way as delineating the service area as the ADA paratransit service area does.
If the days/hours are greater, riders have more opportunities for trips beyond those possible with ADA paratransit, but this increases the cost exposure for the transit agency unless other limits are imposed. Several of the surveyed transit agencies set their service span as 24/7, particularly if using taxi companies as providers; riders can use the alternative service for trips at any time on any day of the week. This is the most expansive approach to the service span.
Days/hours less than ADA paratransit is a conservative approach and may be appropriate for a pilot to test use and demand. After the pilot operates for a while and trip demand and cost are evaluated, increasing the service span could be considered.
With a finalized design, next steps involve preparing procurement and contract documents; see Chapter 4 on implementation.
Checklist
Listed here are the key elements involved in planning and designing an alternative service. While not all the elements may apply in your situation, this list may be helpful as you work toward a final design for your alternative service.
□ Define and document the objectives for providing the alternative service.
□ Discuss and refine the plan for the alternative service with advisory groups, key disability community stakeholders, and your policy board.
□ Understand the applicable federal regulations and needs for compliance, consulting with your risk management and legal departments.
□ Determine adequate insurance coverage level for your transit agency, working with private providers in the alternative service program.
□ Develop a budget for the alternative service that considers grant programs and other funding sources to support the service.
□ Estimate the impact of the alternative service on the budget, including consideration of induced demand.
□ Determine if the alternative service will be a provider-side or user-side subsidy program.
□ Consider potential providers that would be appropriate options for the alternative service, which may include local providers or national TNCs; considerations should include provision of wheelchair-accessible service, trip requests, and fare payment options.
□ Consider ADA criteria as well as the roles and responsibilities in fulfilling service criteria between the transit agency and service partners.
□ Consider Title VI and drug and alcohol testing requirements and their applicability to the alternative service.
□ Consider any needs for reporting data on the alternative service to the NTD, planning for how this data will be gathered from the service partner(s) and included in NTD reporting.
□ Develop an evaluation plan for the alternative service that defines metrics of evaluation, procedures and responsibilities for measurement processes, and evaluation frequencies.
□ Determine the appropriate subsidy level for the alternative service and whether there will be trip limits built in.
□ Determine the structure of service policies for the alternative service, including specifics on the service area and service span.