Thank you for standing by. Welcome to the Access to Over-the-Road Buses conference call. At this time all participants are in a listen only mode. Later we will conduct a question and answer session instructions to be given at that time. If you should require assistance during the conference, please press star followed by 0. I would like to turn the conference over to your host, Jennifer Bowerman.
Good afternoon, everyone. Welcome to the ADA Distance Learning Program. This session is specific to access to over-the-road buses. It''s a collaborative program of the Great Lakes, Mid-Atlantic, Great Plains, Southwest, and Pacific Disability and Business Technical Assistance Centers. At this point I would like to introduce our speaker for today, Marilyn Golden. Marilyn is going to speak specifically to access to over-the-road buses. Marilyn is an analyst at the Disability Rights Education Defense Fund, otherwise known as DREDF, one of the nation''s foremost centers on law and policy specific to disability rights. They have offices in Berkeley and Washington. Marilyn has been closely involved with the ADA both in stages of proposal, the passage and currently now implementation. She is a highly involved trainer and nationally renowned on the ADA. She was the principal author of the DREDF publication, the ADA Implementation Guide, otherwise known as the DREDF Blue Book and also known throughout the United States as DREDF curriculum on the ADA. We are pleased to have Marilyn with us today to speak to the subject. She has written a number of articles that summarize the recent final regulations for over-the-road buses and hope to use her expertise to clarify some of the issues in this particular topic.
Thank you, Jennifer. I can start with some great news for the disability community regarding private companies using over-the-road buses and the Greyhound issue. As many of you know, the American Bus Association which is the trade association for Greyhound and many other private transit companies, had sued the Department of Transportation over this final rule for over the road buses mere days after the rule was published, on September 28 of 1998 almost exactly one year ago. But just last week the U.S. District Court of the District of Columbia granted summary judgment for the Department of Transportation, that is the DOT, meaning DOT won its case at the district court level. This regulation has withstood the industry''s court challenge. Even though an appeal is expected, this is an important victory. My remarks today will roughly follow the summary of this regulation that I wrote. If you are by your computer you can go to DREDF''s web site if you like, there is also a link on the Great Lake''s web site, I believe, but you can go to DREDF web site at www.dredf.org and under alerts you can find the summary of DOT''s final regulation on over-the-road buses. I will more or less follow that as I make my remarks. The regulation has a lot in it. So I will have to skim the surface and you can help me to provide more depth in the question/answer session. So what is this regulation, which has now been upheld in court? In many respects, the regulation which we kept calling new, is a year old now. I''m not sure it''s new anymore, new to a lot of us, though, this regulation is a victory for people with disabilities. It''s not perfect, but there are a lot of good things in it. This regulation applies only to over-the-road buses or OTRBs used by private companies. OTRBs are high floored buses with a baggage compartment underneath. The most obvious example is Greyhound buses. OTRBs being high floor with a baggage compartment underneath are unlike regular transit buses, which have always had a lower floor and do not have a baggage compartment underneath. Every other kind of transit other than over-the-road buses used by private companies is already covered by DOT''s earlier regulation. So transit vehicles which are not over-the-road buses, not OTRBs, in other words urban transit buses and other vehicles such as large vans, rail cars, para-transit, all these things are already required to be accessible to various degrees under earlier rules that we won''t be going over today, unless you ask questions about it during the question/answer session. What is included in this regulation is Greyhound, plus other private inter city bus provider-that''s companies providing service from one city to another, charter bus companies, that''s when a group rents a bus, tour bus companies like Gray Line tours, airport shuttles and other private companies which use over-the-road buses or OTRBs. This regulation did not go into effect immediately. There is a phase in period of two years which we are now halfway through. Until the new regulation goes into effect, OTRB companies which is what I will call private companies that use over-the-road buses, OTRB companies must comply with the current requirement in the ADA regulation. That means that on 48 hour advance notice, they must provide boarding assistance to people with disabilities. They have to get you on, carry you if necessary, if you need that and want that, and they must transport passenger''s wheelchairs among other requirements. By the way, we learned that Greyhound often fails to provide these required services already today thanks to a rider survey a couple of years ago which showed Greyhound making lots of mistakes. Things may have improved since then, I don''t know. It''s important for people with disabilities to ride Greyhound, certainly it works sometimes and that''s the only way they will learn. What''s new? Beginning October of the year 2000 for services provided by large companies such as Greyhound, or October 2001 for services provided by small companies, all new buses purchased or leased by fixed route OTRB companies must be accessible, which will usually mean equipped with a lift. Now I said the phrase "fixed route." That means those transit systems that run along prescribed routes according to fixed schedules, Greyhound being the biggest example. Half of the fleets of these large OTRB operators must be accessible by October 2006 and the entire fleet by October 2012. However, the Secretary of the Department of Transportation can grant a time extension beyond the 6 and 12 year dates if the company has not obtained enough accessible buses in the six to 12 years to meet the 50 percent or 100 percent requirement and has not loaded up on inaccessible buses in the two-year phase in and has otherwise effectively complied with the regulation. So there is possibly a time extension for how long it can be before the full fleet is accessible, there is no exception to the fact that after October of 2000 for big companies and October of 2001 for small companies, any newly purchased over the road bus has to be accessible. That''s a huge, important victory. Now one year later, beginning in October of 2001 for large companies, and October of 2002 for small companies, fixed route over the road bus companies must provide service in an accessible bus to a passenger who requests it with 48 hours advance notice. This is really important because it''s a big change. As of today, Greyhound and similar companies can require 48 hours advanced notice in order to carry you on, if you have a mobility impairment and need that carrying. But beginning in October in 2001, with 48 hours notice you can get not just carried but actually get an accessible bus, a lift equipped over the road bus, Greyhound or other companies. Again they are allowed to require 48 hours advance notice for that. This is an interim requirement that continues until the over the road bus fleets are 100 percent accessible. It''s a good thing that before the entire fleet is accessible the regulation provides people with disabilities a way to get accessible service by calling up and requiring the company to get an accessible bus to you for the date and place and time that you want to travel. There are some more lenient rules for small fixed route companies. And we can discuss these a bit more during the question/answer period or I will get back to them if I end up having time. We have talked about fixed route. What are the rules for demand responsive service when an over the road bus is used in response to a request. For example what happens if your church groups rents an over the road bus to make a trip or if you sign up for a sight seeing tour? Beginning October 2001 for large demand response providers and beginning in October of 2002 for small ones, charter and tour companies and other demand responsive providers must provide service in an accessible bus to a passenger who requests it with 48 hours advance notice. At rest stops, over the road bus companies must provide passengers time and assistance needed to leave and re-enter the bus to use the facilities whether or not the bus is accessible. Plus, if a bus company owns, leases, controls or contracts with the rest stop facility, then the bus company must make sure the facility itself meets the ADA accessibility requirements. What if these rules aren''t followed? Under this regulation the company must pay you a hefty fee. If a passenger requests advanced notice service and the company doesn''t provide the service, in a timely manner when it''s needed, the company must pay compensation to the passenger. The first time a given company fails to provide the required service, it pays the passenger $300. The second time the same company fails to provide any passenger the required service, it pays the passenger $400 and so forth, until $700 is required compensation for the fifth time the company fails to serve a passenger as required. So it goes from $300 to the next time the same company fails to provide service to any passenger with a disability, it goes to $400, then $500, then $600 and then $700. It doesn''t go above what is the required compensation for the 5th time the company fails to serve any passenger as it''s required to do. Now how can you show the company that you made the request? Or that you get the compensation? DOT has proposed paperwork requirements such that the company would have to give you a filled out form confirming your request as soon as you make the request and another filled out form if you show up but the service isn''t provided. This paperwork requirement is proposed but hasn''t been made final yet. We are expecting a final rule on those in the next few months. The rules will be very important and we hope that they will not only require the companies to provide the forms, but also require the company to give the passenger some kind of confirmation number in case the form doesn''t arrive in the mail, the form can be faxed or e-mailed, if the passenger has those facilities, otherwise they will have their confirmation number. Again, these are all things the disability community has requested the rule to contain and we will have to wait and see what the final rule will say. Other than the information collection requirements that I just now mentioned, everything else I have talked about and will talk about, however, is already finalized in the final DOT regulation. It''s only the information collection requirements that we don''t know about yet that one piece. The compensation, the financial compensation is already a requirement. The financial compensation must be paid within seven working days of the failure to provide service. And the financial compensation applies to quite a lot of things. It''s not only if you request an accessible bus. After October of 2001 for large companies and 2002 for small and don''t get that accessible bus, it also applies to the demand service providers if you don''t get the accessible bus there, if you give 48 hours notice. It also is required if the service is not provided to a passenger with a disability because the lift does not work, because of poor maintenance or any other reason. The disability community knows very well the problems of nonfunctioning lifts of transit agencies which have maintenance problems. So this particular regulation actually requires financial compensation in that case. Another subject which will apply to almost any trip that''s very long has to do with what''s called interlining. Interlining is if you can''t take your whole trip on Greyhound, say, because Greyhound doesn''t go to the small city you want to go to, but another regional carrier does, there is something called interline where you may start your trip on Greyhound but at a certain city transfer to another company''s bus. If you need an accessible bus, the company you book the trip with or buy your ticket with, must effectively communicate with each of the other companies involved in your trip to provide accessible service through all segments of an interline trip, which again is when a passenger transfers to another company''s bus to complete a trip. There is a detailed training requirement in this regulation. Companies have to train employees and maintain lifts and other access equipment and the training has to include a number of issues that DOT has listed in the regulation and that I can go into more detail on in the question/answer if you wish. There is also a pretty good lift maintenance requirement. The companies are required to perform maintenance checks of lifts, to cycle the lifts, that is, regularly and frequently to make sure that they work. And the company is supposed to take the lift out of service if it''s broken and fix it. If there is no other bus with a lift to replace that bus in service, so that the transport would have to be cut to everyone if the bus was taken out of service, the company can keep that bus in service with a broken lift for up to five days. Even so, the company operating the bus with the broken lift is not excused from paying the compensation to any passengers that needed the lift during that time. This maintenance requirement is about roughly comparable to the maintenance requirements for other vehicles under the ADA. The enforcement of these provisions is the same as in Title III of the ADA. One must file a complaint with the Department of Justice or can file a lawsuit. Now that''s to bring a complaint of discrimination, not just to get your financial compensation for lack of service. That''s not even considered enforcement, that''s considered part of the regular part of the service. And you get that from the company that denied the service to you. But if in the traditional sense of enforcement, you want to bring some kind of action against the company that fails to comply, one can file a complaint with the Department of Justice or a lawsuit in federal district court. Advocacy will be very important in implementation and everyone is encouraged to educate companies where you live about these requirements. Before we open it up for questions, and go in a little bit deeper, I want to mention that if you have follow-up questions after this telephone conference is over or if you want a form for filing a complaint of discrimination with the Department of Justice, there is a number of places you can call. You can of course always call your DBTAC, the Disability and Business Technical Assistance Center at the 800-949-4232. You can also call the ADA hotline at DREDF, the Disability Rights Education and Defense Fund, 800-466-4232. DREDF is also available to conduct training on this rule or on any aspect of the Americans with Disabilities Act. You can call us at our regular non-hotline number, at 510-644-2555. For the DREDF office or you can also e-mail DREDF at DREDF@DREDF.org. Jennifer do you want to open up for questions?
Sure. The first question actually Marilyn is a fax that came in looking for clarification. When the regulation states an effective date such as October 2000 or October 2001, when does the provision go into effect? Is that October 1?
That''s a good point. The specific day would be October 28th. Because the regulation was originally published on September 28th of 1998. And it had a two-year phase in. So the provisions become effective-the regulation had a 30-day phase in until it became effective to October 28th, and then by statute the regulation can''t require the companies to do the things until two years. That was something DOT didn''t have discretion over. They had to allow the companies those two years. So that''s why it becomes October 28th of 2000 or 2001
Great, that''s helpful.
I was wondering, Marilyn, what is the name of the district court case so I can pull it up on the Internet?
The district court case, I have been trying to pull it up myself. But the district court case is American Bus Association Inc. v Rodney Slater or ABA v Rodney Slater, he is the Secretary of the Department of Transportation and was the Secretary when this rule came out. In addition to all the disability groups that did advocacy and tons of credit for this regulation, I will use this opportunity to say that certainly the disability community and largely other groups protesting made a huge impact in moving this rule towards completion. DOT would probably never have done it without. But within DOT, DOT as many people know, was late in promulgating this rule and previous Secretaries of DOT had hesitated to put out such a controversial rule because the disability community wanted one thing and of course the industry wanted something else. So a lot of credit from the DOT side really does go to Secretary Slater, who had the courage of his convictions to stand by the civil rights of people with disabilities and require a fairly strong rule.
That''s great, Marilyn what we will do is track down that case on the Internet, too, so when people go in to get the transcript if they want we will also put a link if we can locate it on the web. Another phone question?
Can you kind of give us an idea what''s the difference between a large company versus a small company as there is quite a difference in the regulation between those two defined companies.
The definition between the large and small companies that the ADA regulation uses is the same definition that is used in that industry. So it has a technical definition that is already familiar in the over the road bus industry. You are a large carrier if you have gross operating revenues of $5.3 million or more annually. If you have less, you are considered a small carrier. Greyhound is certainly a large carrier. There are many other companies, both tour companies and inter-city bus companies and few others that are large carriers. There are quite a few small carriers.
Are we looking at over-the-road buses and the number of tie down spaces specifically to the number of existing seats already on that bus?
The Access Board promulgated final rules that DOT adopted along with this regulation. For full sized over-the-road buses it generally requires two securement locations.
One of the other things that you were talking about as far as the definition of an accessible bus in many circumstances that''s seen as a lift. Now what about companies that might be using some type of external device that might not necessarily be part of the bus or it might not necessarily follow the bus. Are there specific guidelines for that or is there, you know, feeling one way or another on using or placement of those devices?
The technical standards do allow for other means of making these buses accessible. For example, it is possible to have extensive ramping systems or high platforms as you would have at a rail station with a bridge plate to make an over the road bus accessible. But you would have to have one everywhere the bus makes a stop. That is not easy to do or consistent with the normal use of an over the road bus. So, I don''t think it''s very likely that that will happen very often. So it''s certainly legal, assuming that those facilities are available everywhere the bus stops. I don''t know how practical that is, I haven''t heard of companies intending to do it, though there could be some that are. Usually companies use its buses in so many different ways that they are not going to be able to accomplish access that way.
Private nonprofit organizations that provide transportation to emergency shelters within our area, can they negotiate with a paratransit system to provide transportation for wheelchair users or does the obligation fall upon the private nonprofit organization to make the necessary modifications?
This is a question about the general ADA requirements for non-over the road bus specific transit. It''s a good question. Private organizations that provide transportation such as the nonprofit group you refer to have their own specific requirements. If they are providing a fixed route or if they are an organization that''s primarily in the transit business, and they are providing a fixed route service, service that operates on a fixed schedule, then the vehicles must be accessible. Any newly purchased vehicles after the ADA''s original regulations enactment date, which was in 1991. Many of these services, however, are demand response. The vehicles route is based on who it needs to pick up that day. Or even if it''s the same every day they would reroute if there was a different customer base. Those are the on demand response services. They have what''s called equivalency standard and it means that any time they bought a new bus since that 1991 date which by now many of them have, it''s been eight years, I would probably venture to guess that most of them have. As time goes by, there will be fewer and fewer that haven''t. If they were buying a new bus at any time since the 1991 date that bus or vehicle, then, had to be made accessible unless they could show that they already have enough vehicles in their fleet. The people with disabilities with an equivalent quality service, in other words as quickly as efficiently in as short a time as many people as needed. If they can''t show that they have enough accessible vehicles to do that, then the new vehicle had to be accessible. And they had to make each new vehicle accessible until the time they could show they could provide equivalents service with the accessible vehicles they had. Now there may be times when these organizations don''t have to have their own accessible vehicles as long as they can get someone else''s. But they do have to provide equivalent service. It has to be service that is as high quality as they provide non-disabled people. And if it is remiss in any characteristic, where the service is not as good, that is a violation.
Why don''t we continue to allow people to queue in, we are going to go over to our chat room and I understand there is a question over there. On-line visitor: The two tie downs seems inadequate. Where did that number come from?
I''m not sure, but it''s probably there to be consistent with regular urban buses. City transit buses, so to speak, also require generally two tie downs. In the context of regular urban transit I know that in some cities are tie downs are frequently full and people are having to wait till the next bus. I hope the day comes soon when over-the-road buses on Greyhound and other inter-city carriers are used so frequently by people who need the wheelchair areas that they prove to be not enough. The industry certainly doesn''t seem to think the ridership will be very high. I look to your question to indicate that will be false.
My question is you had mentioned, Marilyn, five days, to repair a lift for an over the road carrier. Is that the same regulation for an intracity fixed route system?
The rule is a little different. But let me clarify the over the road bus rule. That is only if the company doesn''t have a spare vehicle to put in. Usually they do. Urban bus systems, those bus transits maintain a roughly 15 percent spare ratio, that means they have that many vehicles in abeyance. You can imagine there are all kinds of reasons why a vehicle can''t run on a certain day. Things breakdown. So only if Greyhound or other companies like that don''t have this spare ratio can they keep the lift in service for five days. I doubt if once a number of years have passed Greyhound would be able to legally use that. Certainly some of the smaller carriers may have a longer period in which it''s legal to use that. To go to your question in terms of the city bus, the regular urban transit buses, the rule is that it''s similar but not exactly the same. The rule is that first of all, the vehicle has to be taken out of service before the next service day if the lift is broken. They are allowed to keep that bus in service only if there is no spare vehicle to take its place such that service would be reduced to the general public. In big cities that is really going to happen, even in medium and small sized cities a lot times that won''t happen. If it is in fact true that there is no spare vehicle, then the transit agency in a city or town, can run the bus with a broken lift for five days in cities where the population served is under 50,000. Or for three days in a city where the population served is 50,000 or more.
I have two phone questions. What is the definition of an accessible bus, does that include the restrooms and is that also for different types of disabilities whether it''s visual or hearing? Does it cover all disabilities?
Good question. The ADA law itself did not require over-the-road buses to provide access to the restrooms unless that could be done without decreasing the number of seats on the bus. And so DOT really did not have the discretion to require accessible restrooms on over-the-road buses which is what made the issue of rest stops so critically important. And DOT''s proposed rule that public comment was solicited on, did not require the companies to help people with disabilities to exit the bus and use the facilities on rest stops unless the bus was inaccessibl-hich clearly was a huge problem and the disability community wrote a lot of letters and made their voices heard and DOT changed that in the final rule and requires exiting in rest stops. You also asked about multiple disabilities. Certainly there are many things in this regulation, not just the Access Board''s rule but also DOT''s rule. For example, one of the many fine print things in this regulation that I didn''t cover in my summary is that over the road bus companies have to write equivalent reservation systems. So that would mean reservation systems by TTY, for example. The ADAPT rider survey on Greyhound, found Greyhound to be unresponsive to the TTY number that it advertises so that''s a violation of this rule. Also the Access Board''s technical standard have a number of requirements for these buses that do serve people with disabilities other than mobility impairments. For example, there are certain lighting requirements and contrast striping required on the bus stairs. Also the lift has to be appropriate for people who are standing, people who are mobility impaired but can walk still want to use a lift because they can''t or have a hard time climbing the steps into a bus. Those individuals have the right to use the lift and the Access Board''s technical standards require those lifts to be accessible as they have come to be called standees .
Yes, independent living in Concord. I happen to be a chair user and I have to use a self propelled chair. Finding that most of the local transit buses, the tie downs are inadequately spaced for the self propelled chairs, what is the requirement for the accommodation of tie downs?
The tie downs or securement devices were required to be provided when the original ADA regulation came out. I think still though it''s a little bit different today, there was at that time so little standardization and such a proliferation of different kinds of devices out there, that the ADA technical standards didn''t provide what kind of device they had to have, but required that they had to accommodate all common wheelchairs. That''s not just an opinion word, but has a legal meaning. Common wheelchairs was any wheelchair that fit on that 30 by 48 inch lift that is required on a bus that meets the ADA technical standard, motorized chairs, manual, self-propelled chairs, three wheeled scooters, if they fit on the lift. We all know that the securements out there don''t fit a lot of the wheelchairs out there. The requirement for the new buses has always been that they have to secure any common wheelchair and I gave that definition, such that it''s restricted to moving no more than two inches in any direction during travel. And for vehicles that were bought since the ADA was effective, if they don''t, then there is a violation that can be brought to bear. There are a lot of other rules on securement. The transit agency is allowed to require the individual in a wheelchair using a wheelchair to be in a securement area but if the securement device doesn''t fit their chair, the transit agency still has to let you ride. That of course doesn''t help you if you need the securement to have a safe ride. And people with disabilities are encouraged to utilize the ADA''s enforcement rules otherwise to advocate, you know, hard in order to get securements which are really the only way a lot of us can have a safe ride. The ADA does not require buses to carry more wheelchair users than securement locations. So they don''t have to let you ride in the aisle or elsewhere other than a securement location even if the securement locations are full as was implied by an earlier question.
I was on a brand new public transit bus yesterday. And it would be almost impossible if not totally, to put my chair into the securement area. I tried for about ten minutes and it just wouldn''t happen. And having gone on public transit other places, it''s not safe not to be tied down or secured down. I don''t like to be pugnacius about it, but it''s not a safe situation. It''s a brand new bus, I mean they just took delivery in the last couple of weeks.
Well, this is a good illustration of what we always say, which is that the ADA doesn''t necessarily end discrimination. What it does mean is that when discrimination happens, there is something you can do about it. You can always use the ADA''s enforcement provisions in the situation you are describing, which sounds like a regular public transit situation. Inter-city, you would use the enforcement requirements under Title II of the ADA, which can include filing an internal grievance with the transit agency, filing a complaint with the Department of Justice, or filing a lawsuit. And any of these actions can be taken at any time. You have to take it within 180 days of the incident of the discrimination. There is also a lot of advocacy that can be done by you alone or other people with disabilities or ideally in some kind of disability organization whether it''s one that already exists or one that you create yourself of riders. You can be very effective advocates by working with or protesting against, whatever style you choose to use to argue for your rights with that transit agency because it doesn''t sound like the situation is right. Very often when we get questions we say something is illegal and they say but it''s happening. Of course it''s happening. But there are things you can do about it and we encourage you to do these things.
Hi, Marilyn. You partly already answered this question in regard to accessibility of bathrooms, but in light of your previous answer, what obligations would providers have to provide accommodations or policy modifications to provide unscheduled stops for people with disabilities?
Unscheduled stops are an important question. Especially on express bus runs that don''t have stops. Of course there are these inter-city buses like Greyhound and other companies will have rides that are supposed to be quicker because they don''t have rest stops. Everybody else can get up and use the restroom, people with mobility impairment, especially wheelchairs can''t do that. Implicit in Ken''s question, with the bus on an express run or if they are at a place where there isn''t a scheduled rest stop, can the individual request an unscheduled rest stop? Some comment in the disability community told DOT in the commentary that they thought that the bus should have to make an unscheduled rest stop to allow people with disabilities to use the restrooms outside the bus. DOT in the end did not require transit companies to do this. They required them to make a good faith effort. But not, not to do it. They did make one interesting set of words, which is that if they don''t grant the request, they are required to explain to the passenger why not. They owe the passenger an explanation for a decision not to make a stop. I''m not sure how much good that does us, but I thought it was interesting that it went to that extent.
Marilyn, I have a question about requirement for the varying compensation paid to the passengers. It comes in different levels as you explained from $300 to $700. But who keeps track of those violations? It sounded like the phraseology that you were using is that if not this compensation goes up per violation, not if it happens to the same passenger over and over again or did I misunderstand you?
You understood correctly. And you have asked a very good question. Certainly if it happens to the same passenger over and over again or somebody the passenger knows then that''s a way to know. The regulation doesn''t really give a provision to find out. How to do it? Certainly if its happened to you, that''s a good way to know. If it has happened to people that you know, it''s a good way to know. It would be good for disability organizations to establish some kind of information focus where people could get information about that. I think organizations like DREDF or ADAPT certainly could easily find out for Greyhound once these rules are in effect. It will happen very quickly to get up to five. And that information should be available. If you are talking about a smaller local carrier, a small tour bus company in a historic town, something like this, it may be difficult to find out. And the regulation really doesn''t give us a good way to do that. It''s something we would have asked for had the compensation been in the proposed rule, but the financial provisions that we are talking about only came about in the final rule. So they are what they are.
Marilyn I have one last faxed in question: does getting on and off the bus include assistance for all disabilities such as visual impairment and so forth, or does that only include a person that may be using a wheelchair?
Certainly under the general Title III regulation which certainly covers Greyhound, or any other over the road bus operator that''s private, if the company has some kind of a policy where they don''t help people on, they would certainly be required to modify that policy to assist somebody with a different disability than one specifically covered in the DOT regulation. But to answer the question about whether the DOT regulation itself includes that requirement, I would have to go back to really the current ADA regulation provide boarding assistance, it says individual with a disability, so that really is anyone with a disability.
We are just about out of time here. I''m wondering Marilyn do you have any final or closing comment you would like to provide?
I might just say a moment about the small companies, nobody asked about that. But there are two things small companies get a little bit easier. Instead of acquiring accessible buses, small fixed route companies can provide equivalent service, that means they can get a van or different vehicle as long as it''s truly equivalent service, quick, same places, same cost, available, fast, etc. And the other thing is that if a company operates mostly demand response service but a little bit of fixed route they are allowed to use the 48 hour demand response rules. The only other thing would be it''s been a pleasure first of all to be here and I thank the DBTACs for the opportunity. It''s also a great pleasure to hear the names and voices of many friends who called in. I thank you for giving me and DREDF the opportunity to participate.
We were pleased that you had the time to lend your expertise, you have definitely cleared up a lot of issues and questions people had on this particular topic. So we look forward to hopefully another session on just general provisions for transportation. So we will look to that in the future. Just as a wrap up to all of our sites: I believe we had about 83 sites call in today. If you have additional questions that you didn''t feel were quite answered or we didn''t get time to, please consider calling your regional DBTAC at 800-949-4232. And I would like to encourage all of you to also contact your regional DBTAC as we will be kicking off the ADA Distance Learning 2000 program on October 19th. These programs are sponsored by the Great Lakes, Mid-Atlantic, Great Plains, southwest, and Pacific Disability and Business technical assistance centers. So if you call your regional DBTAC they will be able to give you more specific information on the sessions we have coming up and logistics for registering in that. Again thank you so much, Marilyn, for calling in and to all of our site coordinators for calling in for today''s session.