DLRP Webcast February 12, 2003 Transportation and the ADA Presenter: Marilyn Golden >> Rachel: Good afternoon, everybody and welcome to the webcast on transportation and the ADA, providing nondiscriminatory service in fixed route and paratransit services. My name is Rachel Kosoy. I'm with the disability law resource project, your host for today's event. I'm the one who will be moderating the webcast or otherwise voicing your questions to the presenter. And shortly, I will be introducing our fabulous presenter, Marilyn Golden. First I want to quickly address a few technical issues. If anybody has technical difficulties today, please give us a call. We have people standing by to help you out at (713)-520-0232. Okay, I also want to tell you that Marilyn Golden will present for about 45 to 50 minutes. At the end of her presentation, she will take and answer your questions. Now, in order to submit a question, you can click the submit question button at the bottom of your real one player screen, or you can simply address an E-mail to webcast at ILRU.org. So please go ahead and send those now or at any point during the presentation. We will address them pretty much on a first come, first serve basis. Now, I just want to say I know that with Marilyn's last webcast two weeks ago on transportation, we received many more questions than could be answered live. So I wanted to let you know that a transcript of those questions with answers will be posted on the website on the archived website of that webcast. And, again, today, if we run out of time before getting to all your questions, we will do the same thing for today's webcast. All right, now, let's move on so we can get as many questions as possible answered. Today's topic is transportation and the ADA, providing nondiscriminatory service in fixed route and paratransit services. Our presenter is Marilyn Golden. She is a policy analyst at the Disability Rights Education and Defense Fund, fondly known as DREDF. She has been closely involved with the Americans with Disabilities Act throughout all the stages of its proposal, its passage and now during its implementation. Since the ADA's passage, Ms. Golden has continued to play a key role in policy development on a federal level in the areas of transportation and architectural barriers. She was appointed by the president to the Access Board in 1996 and she has served on it since that time. She has also conducted numerous, numerous trainings on all parts of the ADA and we are certainly lucky to have her teach us today. So, Marilyn, I hand it over to you. >> Marilyn: Thank you, Rachel and thank you to DLRP for inviting DREDF to be part of this webcast. Today's subject is not all of the ADA's transportation requirements, but actually a somewhat narrow, yet very important section of the ADA's legal requirements which for lack of a better name we at DREDF have dubbed nondiscrimination in service delivery. I think you have access to the materials that ILRU has posted for this webcast. They consist of two outlines, one is DREDF's general outline of all the ADA's transportation requirements in several formats, and the other is all of the ADA requirements that relate to transportation but aren't specifically in the transportation regulation at the ADA because they relate to other programs as well. And that's that second outline that's also posted in several versions. And we may have time to look at what's in there. The other material that's posted, which is the last thing on the list, is a complaint form from the Federal Transit Administration, which can be used to submit an administrative complaint. You fill it out and print it and send it to the address on the form and that is a way to utilize your formal -- one of the two main formal enforcement procedures available to people with disabilities under the ADA. That is filing of the administrative complaint with the Federal Transit Administration. Two weeks ago on the webcast we talked a lot about FTA and the short story is that while you can't always solve every problem and especially the large complex ones with administrative complaints, very often they are useful enforcement tool for very specific problems, particularly if it's a clear case of discrimination, and particularly if in is an ADA policy that's simply not being complied with. And also it's an effective enforcement tool if people submit them in quantity. People in a particular city submitting numbers of complaints because that can bring larger FTA action, such as for FTA, the federal transit administration, to pay for an assessment of ADA -- particularly paratransit in a particular city. So anyway, those are your materials, and there is a flag right in the middle of the list. It says section for presentation providing nondiscriminatory service, and if you click that, it will take you right to the part of the ADA transportation outline that I'm going to focus on. This outline really contains just major points. I'm going to be going into issue that is are not listed on it. If you want a more complete and in-depth document from DREDF about the ADA, which includes all the transportation material and a lot more, can you purchase DREDF's ADA manual, also known as the "Bluebook". We use it in our in-depth training. Some of you may have them either by purchase or being at one of those trainings and if you're interested in DREDF's ADA manual, you can E-mail DREDF at DREDF.org. The rules I'm going to give you cover both publicly funded transit and privately funded as well, unless I state otherwise. Of course within each of those major categories of publicly funded and privately funded transit, there is both fixed route service like the bus, the city bus which runs on a fixed route according to a fixed schedule, whether or not you do anything to make the vehicle come, or demand response service wherein you have to do something, make a phone call, flag the vehicle or something of that nature in order to get the vehicle -- a ride on the vehicle. Examples of demand response service are things like taxis or paratransit, and these rules cover all those categories unless otherwise stated. The first thing on your outline is maintenance, but before we go to maintenance, I want to just address nondetermination at the most general level and that being when or when not can service be denied. The ADA basically -- the basic rule of course is that service cannot be denied and the question that comes up, are there any narrow circumstances under which service can be denied? And the ADA regulation gives transit agencies one area, and one area only, where service can be flatly denied. And that is if an individual with a disability engages in violent, seriously disruptive or illegal conduct. This happens rarely and in fact I know a few circumstances where this has legally been conducted, although it may happen here and there. The regulations explanation quickly comes back and states the transit agency may not refuse to provide service because the individual's disability results in an appearance or an involuntary behavior that may offend, a no or inconvenience employees of the transit agency or other persons. Clearly cannot base exclusions on stereotypes, generalizations of that disability. A question that we get a little more often that comes up more often is can a transit agency require -- require that an individual travel with an attendant? And the answer there is that they may do so only when it's an accommodation to the previous circumstance I just named. When the individual engages in violent, seriously disruptive or illegal conduct, and it would be legal to exclude them anyway, but if the transit agency chooses to provide service under the condition that an attendant accompany the individual to mitigate the problem, that is not illegal for the transit agency to do. Now, when I say they cannot deny service, I do not mean to imply that paratransit has to be offered to every one who wants it unless they engage in violent, seriously disruptive or illegal conduct. As many of you know there, are other rules in the ADA saying who is eligible for the paratransit service and today's webcast won't go into them but those rules certainly stand. I'm talking about other than these eligibility rules that the ADA sets up. There are some more specific applications of this issue of denial of service that have come up in DREDF's experience that I just want to share with you, where we are reluctantly agreeing that service can be denied and where we're saying that it can't be denied. For example, there have been cases on paratransit of some people with Alzheimers or other similar conditions. And their disability requires that they need to be met. May the transit agency deny service to such an individual who they've had experience with and needs to be met and is not being met? That's a gray area that I think in a case-by-case basis the transit agency could legally do it. Another example, also rare, is a disruptive service animal. I want to talk a little bit later about service animals because there is more things to say about them. But much more common is the complaints we receive of where service is being denied where we think that it's not legal. One common area is if an individual say is riding paratransit and is bringing a child and the paratransit vehicle will not permit a car seat for the child and denies service on that basis. We do not believe that this can be said to be legal under the ADA and our view is the transit agency must either provide the car seat oral how the individual with the disability to bring a car seat. There have been some denials based on the amount of stuff an individual is carrying, and in discussion over this one, we've ended up interpreting that a reasonable amount of groceries or belongings parallel to what somebody can bring on the bus would be legal. There are a lot of questions about traveling with children or children being the client, say for paratransit or for the bus. And we've ended up concluding and looking at the situation that a parent can have a child be their companion. A child can be the person with the disability who is eligible for paratransit and have an adult be the come pain on, and that any age policies cannot be more restrictive than the transit agency would be on their fixed route service. Okay, why don't we move into the area of maintenance which you see on your outline. Transit agencies are required by the ADA to maintain an operative conditions those features or facilities in vehicles necessary to make them accessible. This includes elevators in the train station as much as it does lifts and ramps on the bus. Accessibility features must be repaired promptly when an accessibility feature is out of order the transit agency must take reasonable steps to accommodate people with disabilities who would otherwise use the feature. And then we have a basic concept from the ADA that is important in all of its maintenance provisions. Isolated or temporary interruptions in service or access due to maintenance or repairs are not considered discrimination under the ADA. Anything can break once, but a pattern of such interruptions in service or an overly long interruption in service could be discrimination. Now we have additional rules that specifically relate to publicly funded bus transit. Transit agencies are required to establish a system of regular and frequent maintenance checks for lifts and I should add for ramps. Many buses these days of ramps and also for kneeling features on the bus. Maintenance checks sufficient to determine frequent enough to determine if these mechanisms are operative. Lifts, when they're cycled, and ramps also when they're cycled, should be cycled with weight on them. Maintenance checks are often called cycling because you just operate the lift or ramp and that should be done with weight on it as it would have if there is a rider. The transit agency is required to ensure that vehicle operators report by the most immediate means available any failure of a lift or ramp or kneeler to operate in service. When the device is discovered to be inoperative, the transit agency must take the vehicle out of service before the beginning of the vehicle's next service day and ensure that the equipment is repaired before the vehicle returns to service. That's a pretty strict rule. You basically can't run the bus another day if any of these devices are broken. Now, the ADA allows an exception that has made things a little more complicated. An exception, if there is no spare vehicle so that taking the vehicle out of service would reduce transportation available to the general public. If that would happen, the transit agency is allowed to keep the vehicle in service with an inoperable lift or ramp or kneeling feature for no more than five days if the transit agency serves and area of 50,000 or fewer in population or three days, three days in service if the transit agency serves an area of more than 50,000 people in population starting on the day where the lift is discovered to be inoperative. Now, that raises the issue, of course, of spare vehicles, a spare ratio. Most transit agencies, particularly urban areas, keep a hefty spare ratio of vehicles, something like 15 percent. There are standards in transit for spare ratio. If something based on a transit agency's size, they are reporting to the FTA as a condition for getting federal money. So most of your cities should not need to use this exception, particularly as time goes on, because then more and more of the vehicles are accessible. As most of you will know, the ADA requires new vehicles to be accessible and most bus fleets have been replaced since -- since the A.D. required new vehicles to be accessible. So usually this exception should not be needed. If a lot of transit agencies -- if a lot of buses in your transit agency are showing up with inoperative equipment and if it is alleged that this exception is being used, you might really want to ask your transit agency about their spare ratio and if it's claim that there is none, investigate closer because most urban areas of any size do have a spare ratio. There is one more rule on this which is that if there is inaccessible equipment and, therefore, somebody cannot ride the bus when they should be able to, if the head way to the next accessible vehicle on the route is greater than 30 minutes, in other words, if the wait is more than 30 minutes, the transit agency is required to promptly provide alternative transportation which is usually paratransit. All right, those are the basic maintenance requirements. Let me move into the complicated area of lift and securement use and lay out the basic rules for you. I know there will be a lot of questions on this, and in fact we've already received some. The basic rule is that all common wheelchairs and their users must be transported in transit agency vehicles. In other words, you can't deny somebody the ride because of something about their chair. It's too heavy, it's too big. As long as it fits into the category of quote-unquote common wheelchairs. The definition of a common wheelchair are those that can fit on a lift or ramp, which complies with the specifications in DOT's technical standards. Those standards require a 30 by 48 inch lift or ramp, and that weigh no more than than 600 pounds when occupied. It includes three wheel scooters, definitely, and there is more specifics about common wheelchairs in the Department of Transportation technical standards for lifts and ramps which are the same as the Access Board's tech anymore al Stan ARDS. Can you find them on DOT's web side or the Access Board's website. The transit agency is not required to permit wheelchairs, wheelchair users to ride in places other than designated securement locations in the vehicle where those exist. So they do not have to allow you to ride in the aisle or outside the areas where there are tie-downs. The transit agency had been required to use securement systems to ensure the wheelchair remains in a securement area. Now, this was subject later to interpretation from FTA. And I'll go into that in a minute, which that deviated slightly from that rule. At any case, historically, the situation was that transit agencies must use the securement systems, but if the securement cannot accommodate a particular wheelchair or other device, transportation cannot be denied to the person. So if the securements don't work for the chair, the person using the chair must still be allowed to ride. And further, passengers may not be -- while securements of the chair may be required or other mobility aids, passengers may not be required by the transit agency to use a seat belt unless all passengers in the vehicle are required to use seat belts. Now, on the bus we know of no transit agency that requires all riders to use seat belts. And so on the bus, people with disabilities who use mobility equipment, are not -- may not under the ADA be required to use a seat belt. Staff may suggest it, but they cannot require it, and if you refuse to do it, they cannot deny you the ride. The change that occurred is that a policy that came out from the Federal Transit Administration stated that a transit agency may establish a policy that securements will not be required, and if your transit agency has that policy, then you are allowed to refuse securements and still ride. Most transit agencies still require securement, but I think there is a small number that do not require it and therefore it's -- people with disabilities are allowed to refuse it, but it's not one by one. You can't have one individual refusing it and the transit agency requires it of everyone else. Within a single transit agency, that agency is allowed to make a particular policy. So if you have a lot of people in your city who don't want to be secured, you can advocate to have the transit agency establish a policy that securement is not required. Now, this doesn't mean the people who wanted to be secured won't be, nor does it mean the people who need help won't be. It's definitely voluntary and if people want securement, the transit agency is absolutely required to secure and to assist with securement. The transit agency may recommend but may not require that a person with a disability using a wheelchair or other mobility device transfer to a wheelchair seat. There is people with disabilities who can't or don't wish to transfer, and it cannot be required. The staff of the transit agency must assist people with disabilities with the use of securement systems, also ramps and lifts. If necessary for the driver to leave the seat to provide such assistance, they have to do it. And one of the questions we received was if I need the driver to stand beside the ramp or the lift as it's going up and down or as I'm going in and out of the vehicle, are they required to do it? And this is an application of the rule I just said. So, yes, if you want any kind of assistance upon going into the bus, the driver has to provide it and they have to get up and provide it, if needed. The transit agency is required to permit people with disabilities who do not use wheelchairs, for example, people who are mobility-impaired that are walking to use the lift. You do not need a wheelchair to use the lift. If you need the lift or the kneeler or the ramp based on any disability, you can use it. I don't know how many of you can hear the chore us in our house. I'm giving this webcast at my home office and we have a variety of dogs and cats, so you can ignore the songs. Let's see, where were we. There they go. Another rule -- this has come up actually recently. Wheelchair users often have a preference for entering a lift or a ramp platform in a particular direction either backwards and forwards and we have transit agencies that say no you must go on backs wards or forwards and the ADA's regulation analysis stated clearly that if the individual has a preference, the transit agency must allow it unless the only way of successfully maneuvering the device onto the vehicle requires one way of doing this or unless following the passenger preference would pose a direct threat to health or safety. Okay, that's lift and securement use, and I want to go onto what DREDF calls bus stop discrimination. This was a very controversial area in the mid 90's, and we had to go through an entire potential regulation change. And in the end, DOT stood up for advocates' rights and the rights for people with disabilities and reaffirmed their original rule. Transit agencies are not allowed to refuse to permit a passenger to uses a lift or a ramp to board or disembark from the vehicle at any stop. They may not -- they may not refuse to let you use the device at that stop. What transit agencies were doing sometimes were saying we will use the lift at some of our bus stops and not at others. And that's no longer legal. They can refuse to do it under extremely narrow circumstances. If the lift cannot be deployed at the stop, physically cannot be, or unless the lift would be damaged if it were deployed, or unless all passengers for some reason, some temporary reason, are precluded from using the stop due to temporary conditions at the stop. They're not under control at the transit agency. Of course if the lift would be damaged at a stop or the ramp, it's important that transit agencies simply move the stop and that will resolve this problem. There is a training requirement. It's meager, but it's important that we have it that every transit agency must ensure that personnel are trained to proficiency. Very often when there is a discrimination complaint, it includes a training component because drivers or other staff are not acting consistently with the ADA and the failure to train to proficiency becomes another aspect of the discrimination. There is a number of other provision of service requirements that I will go through. The transit agency may not require an individual with a disability to use designated priority seats. This is something that happened closer to the beginning of the period after the ADA was passed and became effective. Out of overprotectiveness or whatever reason, individuals with disabilities who may use walkers or crutches or have other disabilities, blind individuals, bus drivers were requiring them to sit in the designated priority seats in the front and this is not legal. If the individual -- if the individual does not choose to use them. What was more of a problem, actually though, is those seats being full and drivers not asking the people in them who did not need them for a disability related reason to move. And so a clarification came, not in the original A. Z. A. regulation, but a point I think it was six or eight -- I think five or seven years later. Drivers must ask others to move from designated priority seats or securement locations if a person with a disability needs that spot. And also there must be signage on those seats that lets individuals sitting there know they may have to move if a person with a disability needs it. Another point, a transit agency may not impose any kind of financial charges on people with disabilities for providing service required by the ADA otherwise. This of course does not apply to the basic charge which is legal, which is the bus fare, the same fare everyone else pays or a paratransit, twice the full bus fare. Then we come to the issue of stop announcements. Very important rule on fixed route systems, stops must be announced at transfer points with other fixed routes, at other major intersections and destination points, and at intervals along a route sufficient to permit people with visual impairments or other disabilities to be oriented to their location. And of course any stop that is requested must be announced. The issue of announcing stops has been a very difficult thing to implement. It is usually the case, unless a transit agency has purchased automated stop calling equipment for their buses that stop calling is hit or miss, but it is definitely possible without high tech equipment for a transit agency and advocacy measures to improve the calling out of stops. I mentioned this on the last webcast but I think it bears repeating. Here are things we recommend that you advocate done with your transit agency if there are problems in the calling out of stops by fixed route bus drivers. One is to get drivers themselves involved in identifying the stops. Some transit agencies have simply hand out lists to drivers. Those lists aren't always accurate, they aren't always easy for drivers to use. There have been things about them that could have been improved that precluded good service. So that's an easy step that transit agencies should all have done. Another is to get drivers a list of the stops rather than requiring them to memorize, see street signs, no how things are worded, et cetera. The third is to install better equipment and this doesn't necessarily mean announcing equipment. A goose neck mike like on a tour bus so when a driver is at major intersection turning where no one needs to get out, they can call it out without danger. This is an example of a fairly inexpensive thing to improve service. The most important thing is progressive discipline. The same kind of discipline that a transit agency would administer to a did bus driver who disobeyed other policies. If stops are not called out, drivers should be disciplined in an increasing way over time depending on how many times the rules have been violated and to know if it's happening, transit agencies may have to do closer monitoring of the calling out of stops. We've been asked about the issue of drivers accommodating hearing impaired people in the calling out of stops, and we don't have extensive policy interpretation on that point, but at a minimum, we would certainly say that drivers should inform otherwise gesture or some way inform hearing impaired people who have identified themselves for specific stops that the individual requested. Another rule that is particularly important in certain kinds of transit agencies, when vehicles for more than one bus route serve the same bus stop, the transit agency is required to provide a means by which an individual with a visual impairment or other disability can identify the proper vehicle to enter or be identified to the vehicle operator as a person seeking a ride on a particular route. So this is something that the bus or bus driver does to let, say, a blind pedestrian know that the particular bus has stopped. The driver can call out the open front door, what route it is. The driver can check with the people remaining at the stop, which of course is not needed if no one is waiting. It really serves a twofold purpose. It provides an essence -- an alternate format to the route designation and destination signs. If three routes stop at a certain stop, there is probably a sign there that is not accessible to visually impaired people. But the driver calling out the route provides that. The other thing is that it prevents pass bys. If a blind individual is sitting at a bus at a bus stop, thinking that the bus that pulled up is No. 48 and it's not their bus, but it's actually No. 4 2 and it is their bus. If a driver does nothing, the blind person can just sit there and miss their bus. Similarly, to a driver just passing by a wheelchair user and not stopping. So this is a bit of a protection. Another rule here is the transit agencies must permit service animals to accompany people with disabilities in vehicles and of course also in facilities. And I want to say a little bit more about the service animal rule because there are some complexities that come up with it. There are handouts on this from the Department of Justice. They are applicable to transportation as well, and if people wish, we can give you information on how to get them and I'm sure these are service animals that the DLRP project has and can make available. Any guide dog, signal dog or other animal individually trained, that's important phrase, individually trained to provide assistance to someone with a disability regardless of whether they've been licensed or certified by anyone. Written documentation may not be required as condition of providing service to somebody accompanied by a service animal. The service animal has to be permitted to accompany somebody anywhere they go on the vehicle, and someone is violating the ADA if they refuse based on local health department regulations or other state and local laws. We've had a lot of refusals by taxicabs and that basically is illegal under the ADA. The more complex questions come up for acting out kinds of animals and I want to just basically read this to make sure it's conveyed precisely because I think the Department of Justice rule is very good here and very precise. It's from a Q. and A. document and I'm just say, what if a service animal barks or growls at other people or otherwise acts out of control? And the answer is that you may exclude any animal, including a service animal when that animal's behavior poses a direct threat to the health or safety of others. For example, any service animal that displays vicious behavior towards others may be excluded. But one cannot make assumptions about how a particular animal is likely to behave based on their past experience with other animals. And if an animal can be excluded for these reasons, the person with the disability should still be able to participate if the animal is not there. And then the final question that I think is important that I'll read part of, the question is asked, can I exclude the animal that doesn't really seem dangerous but is disruptive? And DOJ states that there are only a very few narrow circumstances when one would be required not to accommodate an animal. And that's not likely to occur in a transportation setting. The one example they mention is when a dog barks during a movie. That animal could be excluded, which is obviously more applicable to the public accommodation realm than the transportation realm. To finish up here, there is just a few more. The transit agency must ensure that accessibility related equipment or features are used when they are needed. Before the ADA, for example, we had a report from one of the cities in southern California. California already had a requirement that new vehicles had to be accessible. A number of years in advance of the ADA. We heard reports that a particular city had bought accessible buses but wasn't using the accessibility requirement. They were bolting the lift down and not using it. So they had bought in compliance with the law. California did not have all the details that the ADA has, which the ADA has in part because of these earlier circumstances that occurred that we wanted to use the ADA to prevent. So you can't just refuse to use the equipment that is there. And you can't refuse to use those vehicles either. We've heard reports recently that in some cities that require accessible taxis which the ADA doesn't require, but some city ordinances do, a taxi company is purchasing the vehicles but they're not running the vehicles in service. If taxis were required by the ADA, it would be a violation of the section. Let's see, certainly adequate communications have to be available for transit agencies, and that can include auxiliary aids such as TTY's for say arranging paratransit rides. If the TTY is there but it's not used, that's a violation. If people call on the TTY, people have to answer the TTY phone and not answering it is a violation of the auxiliary aids requirement. Transit agencies may not prohibit individuals with disabilities from traveling with respirators or portable oxygen supplies and similar equipment. Transit agencies must ensure that adequate time is provided to allow people with disabilities to complete boarding or disembarking from the vehicle. Union contracts cannot stand in conflict with the requirements of the ADA. We have heard reports, for example, that bus drivers' unions contracts are stating that the drivers don't have to get up, for example, to facilitate assistance needed by a person with a disability. Not legal under the ADA. Oh, my goodness the animals are getting excited but they'll have to wait until the webcast is over. It's important to remember that all the miscellaneous provisions of the ADA that apply to all of the ADA also apply to transit. That includes things like retaliation and harassment. There are a lot of reports, for example, in paratransit that the dispatchers or drivers threaten retaliation if individuals complain about service. The threatened retaliation can be considered harassment and whether or not it occurs, it in itself is a violation of the ADA separate and additional to any other discriminatory circumstances that may or may not have been there in the first place. And if an individual says they're going to complain -- let's say an individual with disability impaired transit says they're going to complain about something and let's say that it wasn't even really a violation of the ADA. So maybe a person thinks it is but it's not. Say the person thinks that paratransit fares have to be as low as fixed route when the rule is they can be as much as twice. Let's say the person is going to complain about the fare, but the fare is legal. If there is retaliation against that person because of the threat of complaint or if there is harassment, and we would consider the threat of retaliation to be harassment, that in and of itself is a violation, even if the complaint the individual is going to make would not have been about a circumstance that truly is a violation of the ADA. Rachel, how did I do in terms of getting done in time for questions? >> Rachel: I think you did great. Can you hear me? >> Marilyn: Yes. >> Rachel: I think you did great. You're exactly on time. And we've got a bunch of questions coming in. So you ready for me to just get started? >> Marilyn: Sure. >> Rachel: And I think you have answered some of them along the way. The first questions have to do with ramps coming from buses and then I've got a second part of the question that deals with obligations of the drivers. This comes center Springfield Illinois where they have been purchasing buses that have a ramp rather than a lift. The problem they say is that even though the accessibility -- well, the accessibility guidelines basically confuse them because these ramps, when they're extended to ground level are too steep to be safely negotiated and the accessibility guidelines do refer to height and, you know, degree of incline, but they're not sure if that refers to the degree when there is a curb or not a curb and what about when the buses can't use the kneeling position? And apparently in Illinois or in this town, the drivers are instructed not to use the kneeling feature when it's less than 30 degrees. So would you like to comment on that? >> Marilyn: Yeah, there is a lot in here and actually we got this question early and I did some looking into it. It is true that the ADA's vehicle technical requirements allow a ramp that is one unit's rise and four units lead. Which is a steeper ramp. It is not allowed to be any steeper than that, but that is pretty steep. One problem the Access Board had is that there is really a limitation in how long ramps can be. An inherent limitation because of the technical engineering of the bus. They're limited to three feet -- 44 inches being probably one of the longer ones. Now, when the bus pulls up to a curb and is the ramp is extended to a curb, that's usually not as steep as is being reported here. It's usually not one in four. It can be one in four if there is no curb particularly if a kneeler is not used. It's true that it is allowed to be one in four which is steep. Remember that if the person needs assistance, the driver is required to get out. So while it is ideal to get out and help them -- so while it is idea for individuals to be able to board the bus on their own, if for whatever reason the curb is not being used, it is too steep, the driver's assistance is required. That's not ideal, but it is something that people get the right to ride. The other thing and I checked with technical staff at the Access Board is that it is not legal to use that ramp in a condition where the ramp is steeper than one in four. So if the kneeler is not being used and there is no curb, and it's steeper than one in four, the deployment of a ramp under conditions where the ramp is steeper than one in four is a violation of the ADA. Then they have to use a curb. They have to use a kneeler. If they have weather problems using the kneeler, they have to deal with them. They would need to modify that policy and many of you may know that in titles 2 and 3 of the ADA there is a requirement that organizations covered by the ADA, whether it's privately funded organization such as a business or nonprofit or a public agency like a transit agency, if they have policies that end up discriminating, they have to modify those policies or procedures. And a prohibition of using a kneeling feature in a situation where the refusal would create a situation where the ramp is steeper than one in four is a violation. And the policy would then have to be modified. I think that addresses all of the aspects of that. >> Rachel: Yeah, I think you did a good job of addressing that because it was a very long question that I tried to pair a phrase which wasn't easy. Okay, I think you've also addressed some of the other questions that came from Springfield. Lastly, it seems like they would find it helpful if you could paraphrase the securement requirements as well as the calling out of stops requirements. It sounds like the bus drivers there are inconsistent in doing that. >> Marilyn: Well, you mean in helping? Helping with the securement? >> Rachel: Yes. >> Marilyn: Oh, I see the question. Okay, the concerns over securement issues yes, we've heard a lot about this. There is a lot of unevenness, and I think problematic activity and maybe violations of the ADA by transit agencies that are not securing chairs well, particularly power chairs. The Access Board's standard is a performance standard. What it says about securements is that when attached in accordance with the manufacturer's specifications, when a securement device that is is attached in accordance with the manufacture's specifications and the chair is secured, the chair is not able -- is not allowed to be able to move under normal vehicle operation more than one inch. So there is some if's in there. One is under normal vehicle operations. It doesn't include unusual swerves or the bus going up on the curb. And it also must be attached in accordance with the manufacture's instructions. This is not the manufacturer of the wheelchair, the manufacturer of the securement device. Of course there is a couple of complicating factors. If the vehicle doesn't fit the chair, people are unsecured because the transit agency is not allowed to deny them a ride. That's a problem, and we encourage advocacy to get better securement devices. FTA allows -- and as I said before, they allow a transit agency to establish a policy of not requiring securement, but that again is up to the individual. Now, we had recently -- we add DREDF had recently gotten some other questions about types of securement devices and how they're not accommodating the kinds of motorized chairs that have a casing all around the lower rear equipment. So there is really not a place to grab onto and we've checked with experts that were close to and have been informed that there really are securement devices on the market that will accommodate just about any chair. You have to have knowledge about where you can attach the strap and also a good securement device, there are even some good securement devices that people have used with scooters. Scooters definitely pose probably the most difficult securement challenges, but it is required. The ADA does not spell out in detail the technical specifications for securements in terms of what they have to look like. It's only the performance standard that I stated and of course securement technology has changed since the ADA became effective and it continues to change. So a transit agency may have securement devices that were state of the art eight years ago, but are not state of the art today. Having those devices may not -- may not be a violation. The bus -- they may have been state of the art when the bus was bought, but advocacy is a good idea to get better securement devices. >> Rachel: Okay, great. I'm going to move onto other topics here. A lot of these questions have to do with attendants and costs. So the first question is how is the need for an attendant determined? A passenger may not need an attendant but states that they do so that they can get their friend or additional passenger to not pay or to pay the companion fare -- yeah, to not pay. >> Marilyn: Well, in a paratransit context, there are rules about this, and I want to consult actually the regulation because I want to be sure that we get it exactly right. During eligibility, transit agencies are allowed to look closely at this issue. And I'm looking for the exact rule, but I believe what it is is that the eligibility determination process -- yes -- oh, that's not it. Necessity for an attendant can be part of what the eligibility process ascertained. The question comes up how are they ascertaining? And I don't know frankly if state of the art paratransit eligibility determinations includes foolproof methods for ascertaining whether a statement that I need an attendant in order to travel is really true. >> Rachel: Now -- go ahead. >> Marilyn: If they can't judge accurately, then I think they have to believe you. >> Rachel: Then does the person with the disability who requires an attendant, do they need to have something in writing that the bus driver could check so that they do allow the attendant on? >> Marilyn: Well, on a bus it's less of an issue. Because on a bus, attendants are not free. They're free only on paratransit and only when the individual requires the attendant in order to travel, not just during the bus ride, but anywhere. If you're going to school for the day, and you need assistance using the rest room at school. So your attendant comes with you, you don't need them on the bus, but you need them when you get to where you're going, FTA absolutely recognizes that as legitimate. It's the transit agency's problem for figuring out if that attendant is necessary. On paratransit, if you need an attendant in order to travel, they can ride for free. If not, they must pay because any paratransit ride you're allowed one companion, and if you need the attendant in order to travel, then the attendant does not count against your one companion. You can have someone else, whether it's your friend, your child, your date, whoever. >> Rachel: Okay, great. And you answered another question in there, too. Okay, this next question has to do with fares as well. So this situation is when the transit authority is providing paratransit feeder service to a fixed route, may the paratransit and the fixed route both require the normal fare, or are they required to provide for one of those fares to be free? >> Marilyn: If paratransit is going to blend in with use of a fixed route because it's a feeder service, then you're paying your fare on the bus and paratransit -- well, paratransit is allowed to require twice the fixed route fare. So I would say that paratransit -- that whole ride can cost you at the most twice the fixed route fare. So the paratransit route ride can charge one and the bus can charge another or if the fare for the fixed route portion is less than the fare for the whole ride would be, they can work it out however. They are allowed to charge up to twice the fixed route fare if paratransit is involved, but they can't charge more. So they can't charge you twice the fixed route fare once you get on the feeder service vehicle and then again on the bus. >> Rachel: Okay, and is it up to the transit authority then to communicate that so that the person with the disability isn't told they need to pay on both? >> Marilyn: Sure. Absolutely. I mean, the issue would come if service is denied. You know, is it illegal for them to ask you to pay? Let's say they're misinformed. If they ask you to pay too much or too many times, is that illegal? Well, I don't know. I mean it certainly would be a lack of good training, but is it legal to deny you a ride because you won't pay because you already paid the maximum you should have to pay? Certainly not. >> Rachel: Okay, I can anticipate some trouble there. >> Marilyn: It is complicated. I think that feeder service, which is a great idea, has proven difficult because people end up waiting very long at the transfer site. >> Rachel: Well, there actually was a question about, you know, does that transfer time have to be limited? >> Marilyn: Certainly in paratransit feeder service, if there are routinely very long waits at the transfer point, that would be an illegal capacity constraint just the way that unduly long rides and significant numbers or significant numbers of denials and other things like that or significant dispatcher hold times, over and over again. Those are all illegal capacity constraints and I think undue waiting at the transfer point time and time again would certainly again also be an example of a capacity constraint. >> Rachel: Okay. I have two other questions related to the same topic. Relating really to the transferring and those are must the transfer site be a sheltered area? And then if there are no curb cuts at that transfer site, is paratransit required to transport passengers who use wheelchairs to get to the area? >> Marilyn: Well, in terms of shelter, there are no rigid ADA requirements for bus stops or transfer points unless they're new. If bus stops are new, there are, of course, technical requirements for them just like any new construction under the ADA. And it's not good to have transfer points that are exposed to the weather during bad weather. This is an advocacy point. Is it discrimination under the ADA? I think if it is excessive, you could call it an illegal capacity constraint. And in terms of curb ramps, if there are no curb ramps in an area, is paratransit required to transport passengers using wheelchairs to that area? I think the implication here is -- I would normally take the bus, but where I'm going doesn't have ramps, so I need paratransit so they can get me to the top of the curb. That's a question about eligibility really. Environmental barriers which can include the lack of curb cuts can form the basis of paratransit eligibility under the ADA. >> Rachel: Okay, anything else you want to say on that one before I move on? >> Marilyn: No. >> Rachel: Okay. I have another question that is sort of connected. It has to do with fares, and that's can a transit provider charge a person with a disability more if they're using a fixed route? Like when they're using a fixed route are they allow to double the fare the same way they are for paratransit? >> Marilyn: You mean someone who is eligible for paratransit using the fixed route? No. >> Rachel: Let's see -- >> Marilyn: Can I just add? If they did charge more, that would be an example am of the prohibition that I stated earlier that they're not allowed to charge additional funds of people with disabilities for providing services required by the ADA. Or services needed to accommodate them. >> Rachel: That makes good sense. Here is an interesting securement question. And this has to do not with people who are using wheelchairs, but people with other mobility devices. And the question is, are transit systems allowed to require that those devices have securing brackets on them so that those devices can be safely secured? And if not, how are the lawsuits prevented when a device moves in a vehicle and injures the passengers? >> Marilyn: Well, I'm not -- what kind of device do you mean? >> Rachel: I don't know. >> Marilyn: You're not sure? It's not in the question. >> Rachel: That's a very good question. >> Marilyn: Well, say it again. >> Rachel: I suppose it could be crutches or walkers or canes. >> Marilyn: Well, those devices are not required to be secured. So I guess the question here is really then if they don't have to be secured, what about liability if that device, you know, slides and hits somebody? >> Marilyn: I would think that this comes under the same general kinds of liability policies that face any passenger for any device on a bus sliding or moving or other heavy objects that are brought on inadvertently hurting someone. I don't think it's an ADA question, but the brackets is a different issue. Some transit agencies have wanted to require people who ride the bus using their wheelchairs to consent -- they want to require the individual with the disabilities to consent to having brackets attached to their wheelchairs that weren't there before in order for those wheelchairs to be secured more easily. And the transit agency -- no -- cannot require people to allow their wheelchair to be somehow modified by the transit agency. Where I live in the Oakland, Berkley area of California, our local transit agency has a very innovative and interesting program wherefore people who ride the bus it is a voluntary program where the transit agency at their expense will do the kind of things this question describes, such as adding brackets to your chair so that in turn your chair can be secured. So if you have a chair that's difficult to secure but you want it secured, where I live, you can go to the transit agency and they have to -- they are willing to work with your chair and do things to your chair that will make it more easily securable, but it can't be required. >> Rachel: Okay. >> Marilyn: And people may want to inquire with AC transit based in Oakland, California about that program and advocate for your own transit agency to have a program like that. >> Rachel: I haven't heard of it other places. That's interesting. Okay, I'm going to keep going because we have a lot of questions. Is there any statistical safety data available regarding the use of seat belts by wheelchair users and by all passengers? >> Marilyn: Oh, I just remembered that there is something I forgot to mention about seat belts. If the question applies to the bus, no, because we know of no bus systems where passengers are required to use seat belts. However, the seat belt issue is difficult on paratransit because generally speaking -- in fact almost always the vehicles used are much smaller than buses. They are usually vans or cars, and both vans or cars the physics of those vehicles means that the dangers of not wearing a seat belt are much higher, and so my understanding is that on paratransit, lots of paratransit vehicles do have policies that all passengers must use seat belts and where they do, they may require that of people with disabilities. I don't know of any statistical data about people with disabilities and seat belts, but there is certainly all kinds of data that seat belts are important safety features on vans and cars. But again, the ADA aspect of this is that even on a paratransit van, if nondisabled passengers are not required to use seat belts, then disabled passengers cannot be required to use them either. There are some people with disabilities whose disability makes it problematic for them if they use a seat belt and that's the reason for that rule. But the ADA chooses to treat that very similarly to fixed route, and fixed route on the bus, nondisabled passenger seats are bolted down so your chair can be secured, but their bodies are not required to be seat belted and so people with disabilities aren't either. >> Rachel: Okay. The next question -- let's see, it's very long so I'm going to try to paraphrase so bear with me. This comes from a woman in New Jersey who has sensory and cognitive impairments which result from traumatic brain injury. So some of the things that she deals with on vertigo, auditory processing disorder, sensitivity to light, noise and movement. And her questions relate to that she believes that cognitive and sensory impairments like hers are not included in the service model. She has -- one of the points she makes is that the lifts -- certain lifts at rest clatter so much that they really disable her. And it seems like the noise is not addressed in the regs, and she wants to check that with you. So you want to address that first and then I'll ask the second part? >> Marilyn: Yes, the noise and clatter of the lift, it's true that that's not addressed in the ADA technical standards, but I think the other problems she may experience are addressed but just not being observed by the transit agency, and you may want to go on and say the specifics of those. >> Rachel: Okay, let me say the way -- what I saw the main points were and I know you've read this, too, so if you feel like I missed something, go ahead and put it in. I understood that her other major point really relates to paratransit making accommodations for her disability or I should say not making accommodations for her disability. And she gives a number of examples, and she said she knows that the regulations say that paratransit can keep her on the bus as they go out of her way and as they backtrack to serve other customers, but should they be required to modify that policy to accommodate her disability? And so I think that was the key example, but I think the concept as a whole is interesting if you can comment on do they need to accommodate, you know, modify and accommodate for disabilities? >> Marilyn: There are a number of ways of kinds of accommodations that are -- maybe we'll just call them rests frequently needed and just a little bit out of the ordinary that people have asked for that FTA has had a chance to rule on, things like can't ride at the back of the vehicle or can't ride at the front of the vehicle, and in this one, can't go as far as others. In the past, FTA has not been willing to accommodate some of them. They have not been willing to say that it's required that a transit agency, say, sends out the newer vehicles that are less rickety or that are smoother or have bigger windows or openable windows or what have you that accommodate a disability. They won't say that you have to use X. vehicle because they figure that -- and it's true -- as bad as paratransit service can be, paratransit services are quite complex and challenging to administer and run, and FTA was reluctant to require transit agencies to have to send a particular vehicle on top of everything else they're juggling. But on the issue of accommodating somebody with a more direct route, the problem is that nobody wants to sit on the paratransit vehicle for a long time, but for somebody whose disability goes beyond just an inconvenience of being on longer but actually exacerbating or causing a problem because they have to go longer while other people are taken to their rides, FTA recently said that when they -- you know, when they can easily do so without denying rides to other passengers, you should try to take into consideration this kind of need. So I would say, similarly, FTA should say the transit agencies should try to accommodate this. I'm just applying a recent interpretation in one particular administrative complaint that I read about. I was pleased to see it. They weren't willing to say no, you know, it's always illegal if you don't accommodate the person, but they did tell the transit agency they should try and it would be good perhaps for the person to get that interpretation and advocate with it to their transit agency. And by the way, if people have questions after this webcast, they can contact -- E-mail DREDF at DREDF.org and we can try to help them. >> Rachel: Okay, great. I do get a question -- since you keep talking about the FTA, I'm going to bump this question up a little. What's the difference between FTA and the DOT? >> Marilyn: Good question. FTA, the federal transit administration is a component of the U.S. Department of Transportation. DOT is a larger agency that includes other things. It includes for example, the FAA, the federal aviation administration, which many of you know administers and enforce the Air Carrier Access Act. It includes the Coast Guard. It includes the federal railway administration which runs Amtrak. It includes the federal highway administration, so DOT has a lot of operating administrations. FTA is one of them and FTA is the one that has to do with bus and paratransit and also rail transit other than Amtrak. >> Rachel: Okay. That was helpful. Now, DOT actually puts out the regulations, but FTA enforces them? >> Marilyn: Exactly. Good point. And they enforce -- DOT puts out the regulations for both publicly funded and privately funded transit. Publicly funded transit is enforced by FTA, which is a part of DOT. Privately funded transit, such as greyhound and airport shuttles and all the other -- taxis -- they are -- those rules are enforced by the Department of Justice. And in fact the Department of Justice did a good settlement within the last year or so on super shuttle, which is an airport shuttle service in a lot of cities that didn't have enough accessible vehicles. >> Rachel: That's good to though. That was really helpful. Okay, the next question -- I believe you really answered it in your presentation, but maybe you can repeat it to help these folks. This question has to do with their transit system not using the TTY. It sounds like they have a TTY, but they don't answer it, and then the deaf consumer has to use relay, which takes longer, is more difficult for them because of the language difference so they want to know what are the guidelines regarding calls from consumers who are using TTY's? >> Marilyn: That's an interesting question. On the one hand, the ADA does require auxiliary aids and services and that means that communications have to be accessible to people with hearing and vision and other communication disabilities. So they have to have an equivalent way of communicating with individuals who are deaf. If they have a TTY, they should be answering it. And if many disability rights areas, not just in paratransit, we've had challenges when agencies have TTY's and getting them to use them properly. But, on the other hand, I have to say clearly that if a transit -- if a paratransit system requires deaf people to call in on the relay service, that's not illegal. They're not required to have a TTY. They may use the relay service. So then the question would come up if they choose to have a TTY, but they're not using it very well, and deaf people are then having to call on the relay, is that I will legal? Maybe it is, and maybe it isn't. It is certainly illegal if the deaf individual does not have a way, but paratransit requires -- some paratransit systems require people -- every one to be on hold a long time. And so deaf individuals using a TTY line aren't guaranteed a shorter call than other individuals with disabilities. >> Rachel: Now, what if using the relay isn't really providing equivalent access for them? >> Marilyn: If using the relay does not provide equivalent access, that's discrimination, although it should. I mean, if the staff just doesn't understand relay and hang up or they won't slow down so that the relay operator can catch everything they're saying or things like that, that's discrimination, but if dispatchers are using the relay service in the manner that they should and the communication is occurring, that is a legal option. >> Rachel: Okay. I think that was important information for those folks. The next question comes from Anchorage, Alaska where there are no underlined accessible taxis. Since each vehicle is privately owned under a different permit, they do not feel that ADA applies. Does it? >> Marilyn: The ADA really falls down in the areas of taxis. The ADA does not require accessible taxis and people have had to use local ordinances and gone to public utilities commissions and all kinds of things like that to get requirements for accessible taxis. One interesting circumstance that came up the other day is that in some cities, taxi services are choosing to use vans. The ADA does regulate vans. So if vans are used by taxi companies, accessible vehicles may be required. What's not required by the ADA is accessible vehicles if the taxi companies are only using automobiles. >> Rachel: Okay, and if the taxi service is using vans, what are the requirements for them? Do they all need to be accessible? A certain percentage? >> Marilyn: That brings us to every one's favorite chart. >> Rachel: I know that chart. >> Marilyn: Anyone who has been at a DREDF ADA training is rolling their eyes over the chart. If people run their outlines on their computer screens, this is the basic DREDF transportation outline all the way down to the very, very bottom and go up a little bit from the bottom. It's not on the very last, but pretty close, like the second or third screen up, there is a chart for privately funded service, and the rules are also given in the text. Basically, if taxi service, which is demand response, uses vans, new vehicles either have to be accessible or the company has to provide equivalent service. For example, having a contract with some company that has accessible vehicles providing that service. And the service has to be equivalent in terms of the time it takes. In other words, if it takes 20 minutes to get a taxi, then it can only take 20 minutes to get an accessible ride. But again, that's only if the taxi system uses vans any way does the ADA require access. If they use cars, the ADA does not require that they get an accessible taxi. >> Rachel: Thank you. I'm not in as much fear of the chart. The chart is great once you really understand it. >> Marilyn: Unfortunately, I only explain one line of the chart. >> Rachel: We have a couple more questions. I think we can squeeze them in. This next question has to do with buses which have advertising that sort of wraps around the bus and it covers the windows. Now, they don't completely obscure your vision through the windows, but it sort of -- I don't know how to describe it -- they don't really describe it. >> Marilyn: It partially obscures, perhaps. >> Rachel: Yes, thank you. So they say that while this only partially obscures most people's vision out of the bus, that for people who have visual impairments, darkening the window or creating a glare that this really is an impairment for people with visual impairments. And so they want to know if the ADA addresses viewability from bus windows? >> Marilyn: Not as such. I'm thinking now about whether some other part of the ADA can be used in the situation. And nothing is coming to my mind right away. Although others may have -- I mean you could call this a barrier, a communication barrier if you need to see your stop, but then the calling out of stops is required. I don't know if the A. Z. A. can be used to preclude that kind of advertising. I don't -- I'm not coming up with away. >> Rachel: I think everybody could write in and say that it's very annoying. >> Marilyn: Get all your friends to write in and say you don't like this add. >> Rachel: I don't have visual impairment and I find those annoying. >> Marilyn: Good old fashioned advocacy can work as well as the ADA on some things. >> Rachel: That's my personal opinion. Now, back to some announcements actually. I'm not sure where these people are writing from, but where they are, oftentimes the drivers that have those electronic stop announcement equipment, they quote, disable it by really turning the volume down and is this prohibited in the same way that having no announcement system would be? >> Marilyn: That's a good question. Announcement systems have to be used, and if they're not hearable, they're not being used. So if they're not hearable to, let's say, the average passenger who is listening hard or at least listening, you know, fairly hard, you don't have to crane your ears for every whisper, but if a moderate amount of attention to listening means you can't hear it, and you're not hearing impaired, then stops are not being announced. Now, do you have to sit close? Maybe you like to sit at the back and you'd have to sit close to hear it? I don't know how to address that. If you have to sit close to the front of the bus to hear your announcement, you should probably be sitting there. In general, if people on the bus can't hear the announcements that's the same as not announcing the stops. For them to be called implies that they can be heard. >> Rachel: Got it. Okay, I'm going to try to squeeze in this last question. I'll try to talk fast but not too fast. >> Marilyn: We have a few more minutes. >> Rachel: We have a few minutes. Okay, this refers back to something you were talking about in the outline. It comes under lift and securement use. That No. 3 there, which says the transit agency is not required to allow wheelchair users in places other than designated securement areas. And then -- and it goes on, but the question is, does that piece contradict something which you pointed out lower down under other service provision requirements which says that the transit agency may not require an individual with a disability to use designated priority seats? >> Marilyn: Oh, that's a good question, and I should have been a little bit clearer. It's true that securement devices are often co-located with designated priority seats. I think this is in a situation where the person with the disability involved could use other seats and prefers to; but no, if the individual is a wheelchair user, they can be required to stay in the securement location. Even if they'd rather be further back on the bus and even if they can go further back on the bus because it has a wide aisle or the securement locations are full, that's the main time wheelchair users want to be somewhere else because they still want a ride, and the ADA does not guarantee us the right to ride if you're using a wheelchair outside the securement location. The kinds of priority seat nonrequirement situations that I meant were say a visually impaired individual who wishes to ride a few seats back or a person who uses crutches or something like that may wish to go back and sit where several of her colleagues are, and the driver says, no, you must sit up here. And she could go back there and the driver is requiring her, at least instructing her to sit up front. That's the kind of discrimination that that part of the rule is intended to prevent. >> Rachel: Okay. Got it. I'm going to squeeze one more in. Ready? This comes from somebody who is the chair of the Delaware elderly and disabled transit advisory committee, and they're having trouble influencing their transit system. So she wants to know if this issue that she's upset about is an ADA issue. And it has to do with cell phone use. She said that drivers on the paratransit are using their cell phones while driving passengers. There have been a lot of complaints and she's trying to figure out how to enforce this and wants to know if it's an ADA violation. >> Marilyn: I'm not clear on what problem it's causing. If the concern is that -- just as in general, you know, not even thinking about the ADA, people driving and using cell phones at the same time creates -- it's dangerous to drive that way, if that's what the individual means, I think they should complain to the paratransit system and the transit agency and FTA that the drivers are driving dangerously because they're using their cell phones. That would be the same as they should do in any situation of a driver driving dangerously, whether it's a bus driver or a paratransit driver. But transit agencies are precluded from illegal driving by laws other than the ADA. And there is nothing -- and laws and policies I should say, other than the ADA, and there is nothing specific to the ADA that I can say that affects this. But that doesn't mean it's okay for them to do it. Drivers should not be driving unsafely and people should be complaining about it. And there is nothing wrong with using the ADA process. For example, it would be interesting to submit a complaint like that and see what the FTA did. >> Rachel: That's helpful. All right, we did it. We squeezed all the questions in that I've received so far. If any questions are a little late incoming, again, we will answer them and post them up on the website as well as E-mail them the response to you individually. So fear not, if you didn't squeeze in under the time line here, but Marilyn, I really want to thank you. I think that you were able to cover an immense amount of material and questions in a fairly short period of time, and I can tell from the number of questions we got in what an important webcast this was and how important this information is. So thank you so much and I'm glad that all of you were able to join us today. The disability law resource project is very proud to have brought this to you; and we do hope you will fill out some evaluation forms. And one thing we've done new with Marilyn's two webcasts is having our captioning in upper and lower case as opposed to all upper case. So people who use the captioning, I would love to hear back from you about whether that is easier for you to read, do you prefer that? And Marilyn, do you have any closing comments? >> Marilyn: Thank you for your kind remarks. Thank you also for letting DREDF and myself participate. It was a lot of fun. We're glad to do it. >> Rachel: Great. Okay, everybody, have a great day. Bye-bye.