Inappropriate Treatment of Disability Issues in Bus Network Redesign

Complaint to FTA April 15, 2023 | Susan De Vos

Introduction
One of the many problems with Madison, Wisconsin’s planned bus network redesign (see www.madisonbusredesign.org and www.busadvocates.org) for documentation), has been its inattention to the voice of disabled people and others with mobility limitations. Bus stop accessibility is a major concern, and Madison’s paratransit service is being misrepresented to shore up inadequacies.

I write here because our city’s Department of Civil Rights will not deal adequately with this issue. When I communicated concern to the city’s Disability Rights and Services Specialist over a year ago (early 2022), she advised me to testify with others at a special session of the city’s Equal Opportunities Commission. We did. But she did not then follow up with me, and when I tried, told me that she was too busy to talk further.

Bus Stop Accessibility
A major problem with the planned redesign is poor bus stop accessibility. The redesign was initially touted as separate from a complementary and side running Bus Rapid Transit system. Special BRT buses would run in the same side lane as local buses, and they would use a new source of operating funds. Now instead, the BRT is planned to run in a center lane, and it will use operating funds currently devoted to the operation of local buses. This has reduced funds for local buses, eliminates many current routes, and will require risky and time-consuming transfers.

By running in the center of a street, people transferring between Bus Rapid Transit and a local bus line will have to cross half of what is often a wide and heavily trafficked street. If this is challenging for even sighted and rapid walkers, think of what this means for someone who is visually impaired or a slow walker/wheeler.

Additionally, remaining bus stops will be further away from a potential rider’s origin and/or destination. Transit planners claim the added distance to be only an average of a few blocks, but the reality is that they do not know. They measured distance “as the crow flies” using census block groups, only requiring that an edge of that block group be within a quarter mile of a bus stop. As block groups are often at least a square mile, that means that even when considering distance in terms of inches on a flat map, the nearest stop could well be over a mile away. Considering distance this way also discounts such real impediments as a new need to cross a busy street, navigate a steep incline, traverse an area without a sidewalk or curb cut, go around fences, deal with winter conditions, or find one’s way in the dark.

Misuse of Paratransit
Whenever the issue of access was raised at one of the time-limited virtual supposed “community meetings” (during which transit planners talked and showed maps most of the time, leaving little time for actual discussion or feedback), planners would display little or no understanding of the paratransit program. They would cavalierly brush off access concerns by saying that many people could use paratransit instead.

Yet shifting costs to the paratransit program is little more than an accounting trick that actually increases overall monetary and social costs to the community, is much more burdensome on users, suppresses travel by people at risk of isolation, stigmatizes people with special needs and is a major step backward in our quest for an inclusive society. Planners’ exclusive focus appears to be their bottom line, not the welfare of the community.

First consider the monetary costs. On the community level, the average cost of a paratransit ride can be more than ten times that of a fixed-route bus ride. Metro’s 2019 Annual Report estimated the average paratransit ride to cost $46.10 compared to $3.85 for a regular bus ride. On the individual level, a one-way paratransit fare is $3.25 compared to a regular adult bus fare of $2.00 and a senior/disabled bus fare of $1.00. The fare for 20 paratransit roundtrips cost $130.00 compared to $32.50 for an unlimited 31-day senior/disabled mainline pass.

For the user, paratransit is far inferior to the regular mainline transit even when someone is willing to apply and deemed eligible (having filled out a written application and gone through an in-person assessment). Rather than being decided spontaneously, rides must be scheduled at least a day in advance. Adhering to a schedule is impossible as rides are subject to a 20-minute pick-up window after which travel time is undetermined (since they are shared rides).

The biggest cost is segregation. For years, Metro had been making buses more accessible and inclusive while simultaneously maintaining a paratransit service for those who could not use mainline buses. Mainstreaming as much as possible, paratransit was meant to be a last resort, not a first resort. For instance, mainline buses kneel for ramps, are equipped with tie-downs, have visual and verbal stop enunciators, and have poles strategically placed for unsteady passengers to grab. The GPS system enables visual impaired users to have special apps to provide real-time information. And guess what? We talk to each other as we ride the bus.

Lack of Representation in Citizen Oversight
Until a few years ago, Madison’s transit agency was overseen by a Commission that had a seat for a disabled or elderly person. The Commission itself had an ADA Transit Subcommittee (upon which I served). The city drastically changed transportation oversight in 2018. That included defining “equity” so narrowly as to neglect the Americans with Disabilities Act. Even so, Madison’s new Transportation Policy and Planning Board started with a disability representative. After she resigned in 2019 however, she was not replaced.

That the disabled community’s voice has been muzzled is also clear from the results of a hastily arranged survey of disabled people conducted shortly before the plan’s initial approval on June 6, 2022. Although too hasty for much response or for responses to influence plans, 50 fixed-route disabled riders responded. All but two of those 50 respondents found the proposed plans wanting. Overall themes/concerns included 1) having to walk further, 2) having to cross streets, especially in winter, 3) having to travel further to the bus using a wheelchair, 4) the affordability of paratransit, 5) The need for benches at stops, and 6) taking away independence by making it more necessary to ride paratransit. One comment was:“To put it bluntly the proposed redesign is horrible for the disabled community in Madison. It is definitely a step backward for Madison Metro's accessibility goals. … Madison Metro fails to realize that the disabled (and elderly) cannot walk long distances …”

The lack of participation in what is supposed to be a democratic process has been unfair. The redesign was initially approved rather than paused June 6, 2022. The vote to pause the plan was tied, forcing the Chair to break the tie. If a disability representative had been at the table and voted against the plans, the plans would not have gone forward. This glaring gap needs to be rectified before anything legitimate can be designed.