Susquehanna Trailways – ADA Policy

Amended December 2015:

CUSTOMERS WITH DISABILITIES

We at Susquehanna Trailways encourage passengers with disabilities to travel with us. We are here to meet the transportation needs of all our passengers with the respect and dignity which you deserve. We provide assistance with boarding and departing the bus, special handling and transferring of luggage, and storage and retrieval of mobility devices and assistive aids.

HELP US SERVE YOU BETTER

Our sales staff is available to work with you to make your travel experience as trouble-free as possible. Please provide our sales staff with your specific assistance and/or travel needs. Our driver can better assist if you tell us what type of mobility device you have and how much it weighs. If you can climb steps and do not need a lift coach, we can more safely secure your scooter, wheelchair, walker or rollator in the luggage bay if we have details in advance. You may also request priority seating at the front of the coach. If you have hearing or vision loss, please let our reservations staff and drivers know so that we can provide appropriate assistance.

PRIORITY and WHEELCHAIR SEATING

Susquehanna Trailways has designated seating on its coaches for persons with disabilities. Other passengers may be asked to move if someone with a disability requires these seats.

NOTE: If you are sitting in a seat in a wheelchair securement area and a person with a wheelchair needs the space, you will be required to move.

LIFT-EQUIPPED BUSES

Lift-equipped buses have two securement areas for wheelchairs. Once these are full, additional riders using scooters or wheelchairs can be accommodated only if they can transfer to a seat. Susquehanna Trailways assigns wheelchair seating on a first come, first serve basis at reservation.

NOTE: The passenger and mobility device must have a combined weight of no more than 600 pounds. The mobility device must be a maximum of 30 inches wide and 48 inches long.

The Vehicle lift must also be made available for any customer making such request for loading accomodations. For example, if a customer is using a walking device/aid, this customer may request the usage of the Lift to board bus. We must assist each customer with such requests.

STORING AND HANDLING YOUR MOBILITY AIDS

Smaller mobility aids such as canes or crutches may travel inside the bus in the overhead compartment or under your seat. If your aid will not fit safely in either of these locations, it will be stored in the baggage compartment under the bus at no additional cost. We encourage you to tell us if you mobility aid exceeds 50 pounds so that we can provide the driver a ramp to load the device.

NOTE: If you learn upon disembarking from Susquehanna Trailways bus that your mobility aid has been damaged or lost, please notify the driver immediately.

TRAVELING WITH A PERSONAL CARE ATTENDANT

If you are unable to attend to your own personal needs and/or require assistance that Susquehanna Trailways employees are not required to provide, then we encourage you to consider traveling with personal care attendant.

NOTE: Drivers do not provide assistance with eating, toileting or medical care.

REST STOPS

When the bus stops at designated intermediate, rest or meal stops on the route, you may request assistance off and on the bus or other assistance such as retrieval of mobility aids.

MEDICAL OXYGEN

Medical oxygen tanks are permitted on the bus with a maximum of 4 canisters per passenger as follows: 2 canisters aboard the bus for your use and 2 canisters stowed in the baggage compartment. The maximum dimensions of any single canister cannot exceed 4.5 inches in diameter and 26 inches in height. All oxygen canisters not in use must have safety caps on the valves and must be boxed if carried as cargo. Passengers are responsible for ensuring that they have enough oxygen to complete their travel and are responsible for making arrangements for refills while enroute.

Passengers are welcome to travel with Portable Oxygen Concentrators but are responsible for ensuring that they have enough battery power to complete their travel. When booking your travel, please inquire if the coach will have electrical outlets. If so, you will still need a backup supply of battery power.

NOTE: The maximum limit on medical oxygen canisters carried as cargo is 99 pounds. As we may not exceed this federal regulatory limit, passengers bringing oxygen containers will be accommodated on a first come, first serve basis.

MEDICINE

All Medicines should be in your carry-on luggage. DO NOT PUT IT IN YOUR LUGGAGE UNDER THE BUS.

SERVICE ANIMALS

Service animals are welcome to travel with the passenger with a disability as long as the animal does not occupy a seat or obstruct the aisle. Service animals must always be well-behaved and under the control of their owners or handlers, such as on a leash or in a carrier. Susquehanna Trailways reserves the right to refuse travel to any animal which poses a direct threat to other customers or Susquehanna Trailways drivers or employees.

CUSTOMERS COMPLAINTS

Susquehanna Trailways is committed to protecting your rights. If you feel that your rights as a person with a disability under the American with Disabilities Act (ADA) were violated and you would like to file a complaint, please send a written statement to:

Amy Brooks

11 West Church Street

Williamsport PA 17701

Please include a detailed description of the incident including the bus number, date, time and location, as well as the name(s) and/or description(s) of any Susquehanna Trailways personnel you believe did not provide you appropriate assistance. You may also provide the written statement and accompanying information by email to: charters@susquehannabus.com

Susquehanna Trailways Title VI Policy and Complaint Process

Susquehanna Trailways grants equal access to its programs and services to all citizens. This document serves to make citizens aware of their rights to such access, and serves to educate citizens so that they may understand the civil rights laws that protect their receipt and benefit of such services as defined by Title VI of the Civil Rights Act 1964.

WHAT IS TITLE VI?

Title VI is a section of the Civil Rights Act of 1964 requiring that “No person in the United States shall on the grounds of race, color or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance”. Note that Title VI does not address gender discrimination. It only covers race, color and national origin. Other Civil Rights laws prohibit gender discrimination.

TITLE VI COMPLAINT AND INVESTIGATION PROCEDURES

These procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964 for alleged discrimination in any program or activity administered by Susquehanna Trailways.

These procedures do not deny the right of the complainant to file formal complaints with other State or Federal agencies or to seek private counsel for complaints alleging discrimination. Every effort will be made to obtain early resolution of complaints at the lowest level possible. The option of informal mediation meeting(s) between the affected parties and Susquehanna Trailways may be utilized for resolution. Any individual, group of individuals or entity that believes they have been subjected to discrimination prohibited under Title VI and related statutes may file separate complaints.

A formal complaint must be filed within 180 days of the alleged occurrence. Complaints shall be in writing and signed by the individual or his/her representative, and will include the complainant’s name, address and telephone number; name of alleged discriminating official, basis of complaint (race, color, national origin), and the date of alleged act(s). A statement detailing the facts and circumstances of the alleged discrimination must accompany all complaints. Susquehanna Trailways Title VI Complaint Form can be found at the end of this document. Susquehanna Trailways encourages individuals to submit Title VI complaints in writing using this form and mailing it to:

Amy Brooks

Terminal Manager

Susquehanna Trailways

11 West Church Street

Williamsport, PA 17701

In the case where a complainant is unable or incapable of providing a written statement, a verbal complaint of discrimination may be made to the Susquehanna Trailways Title VI Coordinator. Under these circumstances, the complainant will be interviewed, and the Susquehanna Trailways Title VI Coordinator will assist the complainant in completing a written statement.

When a complaint is received, The Title VI Coordinator will provide written acknowledgment to the Complainant, within then (10) business days by registered mail or hand delivery.

If a complaint is deemed incomplete, additional information will be requested, and the Complainant will be provided 60 business days to submit the required information. Failure to do so may be considered good cause for a determination of no investigative merit.

Within 15 Business days from receipt of a complete complaint, Susquehanna Trailways will determine its jurisdiction in pursuing the matter and whether the complaint has sufficient merit to warrant investigation. Within five (5) days of this decision, the Executive Director or his/her authorized designee will notify the Complainant and Respondent, by registered mail or hand delivery informing them of the disposition.

If the decision is not to investigate the complaint, the notification shall specifically state the reason for the decision.

If the complaint is to be investigated, the notification shall state the grounds of Susquehanna Trailways jurisdiction, while informing the parties that their full cooperation will be required in gathering additional information and assisting the investigator.

When Susquehanna Trailways does not have sufficient jurisdiction, the Executive Director of his/her authorized designee will refer the complaint to the appropriate State or Federal agency holding such jurisdiction.

If the complaint has investigative merit, the Executive Director or his/her authorized designee will instruct the Title VI Coordinator to fully investigate the complaint. A Complete investigation will be conducted, and an investigative report will be submitted to the Executive Director within 60 days from receipt of the complaint. The report will include a description of the incident, summaries of all persons interviewed, and a finding with recommendations and proposed resolution where appropriate. If the investigation is delayed for any reason, the Title VI Coordinator will notify the appropriate authorities, and an extension will be requested.

The Executive Director or his/her authorized designee will issue letters of finding to the complainant and respondent within 90 days from receipt of the complaint.

If the Complainant is dissatisfied with Susquehanna Trailways resolution of the complaint, he/she has the right to file a complaint in the time allotted by law with:

Federal Transit Administration; Region 3 215-656-7100 (phone)

1760 Market Street Suite 500 215-656-7260 (fax)

Philadelphia, PA 19103-4124

Susquehanna Trailways Limited English Proficiency Policy Plan

Note: The purpose of this limited English proficiency policy guidance is to clarify the responsibilities of recipients of federal financial assistance from the U.S. Department of Transportation (DOT) and assist them in fulfilling their responsibilities to limited English proficient (LEP) persons, pursuant to Title VI of the Civil Rights Act of 1964 and implementing regulations. It was prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., and its implementing regulations provide that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives federal financial assistance.

Executive Order 13166

Executive Order 13166 “Improving Access to Services for Persons with Limited English Proficiency,” reprinted at 65 FR 50121 (August 16, 2000), directs each Federal agency that is subject to the requirements of Title VI to publish guidance for its respective recipients clarifying that obligation. Executive Order 13166 further directs that all such guidance documents be consistent with the compliance standards and framework detailed in the Department of Justice’s (DOJ’s) Policy Guidance entitled “Enforcement of Title VI of the Civil Rights Act of 1964-National Origin Discrimination against Persons with Limited English Proficiency.” (See 65 FR 50123, August 16, 2000 DOJ’s General LEP Guidance). Different treatment based upon a person’s inability to speak, read, write, or understand English may be a type of national origin discrimination. Executive Order 13166 applies to all federal agencies and all programs and operations of entities that receive funding from the federal government, including state agencies, local agencies and governments, private and non-profit entities, and sub recipients.

Plan Summary

Susquehanna Trailways has developed this Limited English Proficiency Plan (LEP) to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to Susquehanna Trailways services as required by Executive Order 13166. A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English. This plan details procedures on how to identify a person who may need language assistance, the ways in which assistance may be provided, training staff, how to notify LEP persons that assistance is available, and information for future plan updates. In developing the plan while determining Susquehanna Trailways extent of obligation to provide LEP services, Susquehanna Trailways conducted a U.S. Department of Transportation Four Factor LEP analysis which considers the following: 1) The number of proportion of LEP person eligible in the Susquehanna Trailways service area who may be served or likely to encounter Susquehanna Trailways provided service; 2) the frequency with which LEP individuals come in contact with Susquehanna Trailways services; 3) the nature and importance of the program, activity or service provided by Susquehanna Trailways to the LEP population; and 4) the resources available to Susquehanna Trailways and overall costs to provide LEP assistance. A brief description of these considerations is provided in the following section.

Four Factor Analyses

The number of proportion of LEP persons eligible in the Susquehanna Trailways service area who may be served or likely to encounter Susquehanna Trailways service.

Susquehanna Trailways examined the US Census report from 2010, and, using data from Census tracts in the Susquehanna Trailways service area was able to determine that approximately 96.7% of people within Susquehanna Trailways service area age 5 and older spoke English as the primary or only language. Approximately 3.3% speak a language other than English.

The frequency with which LEP individuals come in contact with a Susquehanna Trailways program, activity, or service.

Susquehanna Trailways assesses the frequency at which staff and drivers have or could possibly have contact with LEP persons. This includes documenting phone inquiries and surveying drivers and customer service personnel. Susquehanna Trailways has had no requests for interpreters and zero requests for translated Susquehanna Trailways document. Susquehanna Trailways staff and drivers have had very little to no contact with LEP individuals.

The nature and importance of the program, activity, or service provided by Susquehanna Trailways to LEP community.

There is no large geographic concentration of any one type of LEP individuals in the Susquehanna Trailways service area. The overwhelming majority of the populations, 96.7% of residents speak English. Therefore, for the most part, LEP individuals do not use Susquehanna Trailways services. However, international students from nearby Lock Haven University do use Susquehanna Trailways fixed-route system. While none of the students have ever required language assistance, and do speak English very well, Susquehanna Trailways services are very important to these individuals in order to provide access to traveling outside of the Lock Haven University Campus.

The resources available to Susquehanna Trailways and overall costs

Susquehanna Trailways assessed its available resources that could be used for providing LEP assistance. This included identifying costs associated with subscription to the Language Line Solution Services. The costs of additional translation services such as a professional interpreter on an as needed basis, which documents would be the most valuable to be translated if and when the populations support, taking an inventory of available organizations that Susquehanna Trailways could partner with for outreach and translation efforts, and what level of staff training is needed. After analyzing the four factors, Susquehanna Trailways developed the plan outlined in the following section for assisting persons of limited English proficiency at a low cost.

LIMITED ENGLISH PROFICENCY PLAN OUTLINE

How to identify a LEP person who needs language assistance.

Below are tools to help identify persons who may need language assistance:

Examine records requests for language assistance from past meetings and events to anticipate the possible need for assistance at upcoming meetings;

When Susquehanna Trailways sponsored meetings are held, set up a sign-in sheet table, have a staff member greet and briefly speak to each attendee. To informally gauge the attendee’s ability to speak and understand English, ask a question that requires a full sentence reply;

Survey drivers and other first line staff on an annual basis at the beginning of each fiscal year regarding their experience on having any direct or indirect contact with LEP individuals.

LANGUAGE ASSISTANCE MEASURES

Susquehanna Trailways has or will implement the following LEP procedures. The creation of these steps are based on the very low percentage of persons speaking other languages or not speaking English at least “well”, and the lack of resources available in the Susquehanna Trailways service area:

When an interpreter is needed, in person or on the telephone, staff will utilize the Language Line Solution Services. This is a pay as you go subscription at $3.95/minute. We would connect the customer with a translator via phone at our costs, this gives us 200 languages to choose from. This service is available 24/7/365 at 800-752-6096 or via web at www.LanguageLine.com

SUSQUEHANNA TRAILWAYS STAFF TRAINING

All Susquehanna Trailways staff will be made available a copy of the LEP Plan and will be educated on procedures to follow. This information will also be part of the Susquehanna Trailways staff orientation process for new hires. Training topics are listed below:

Understanding the Title VI policy and LEP responsibilities;

Documentation of language assistance requests;

How to handle a Title VI and /or LEP complaint.

OUTREACH TECHNIQUES

Susquehanna Trailways does not have a formal practice of outreach techniques due to the lack of LEP population and resources available in the service area. However, the following are a few options that Susquehanna Trailways will incorporate when and/or if the need arises for LEP outreach:

If staff knows that they will be presenting a topic that could be of potential importance to an LEP person and/or minority person or if staff will be hosting a meeting or a workshop in a geographic location with a known concentration of LEP and/or minority persons, meeting notices, fliers, advertisements, and agendas will be printed in an alternative language, based on known LEP in the area.

Key print materials will be translated and made available at the Susquehanna Trailways Administration facility and in communities when a specific and concentrated LEP and/or minority population is identified.

MONITORING AND UPDATING THE LEP PLAN

This plan is designed to be flexible and is one that can be easily updated. At a minimum, Susquehanna Trailways will follow the Title VI Program update schedule for the LEP Plan.

Each update should examine all plan components such as:

How many LEP persons were encountered?

Were their needs met?

What is the current LEP population in Susquehanna Trailways service area?

Has there been a change in the types of languages where translation services are needed?

Is there still a need for continued language assistance for previously identified Susquehanna Trailways routes? Are there other programs that should be included?

Have Susquehanna Trailways available resources, such as technology, staff, and financial costs changed?

Has Susquehanna Trailways fulfilled the goals of the LEP Plan?

Were any complaints received?

As part of the monitoring and update plan, Susquehanna Trailways will track the activity of usage of its services by LEP persons and requests for assistance from Customer Service and Operator staff, and record information from passenger surveys which will identify the language spoken by passengers and their need for assistance. Susquehanna Trailways will also maintain communication with municipalities in its service area to identify LEP individuals who may have moved into a part of Susquehanna Trailways service area and may require assistance. These municipalities will also be instructed to contact Susquehanna Trailways with any requests they may receive for language assistance.

DISSEMINATION OF THE SUSQUEHANNA TRAILWAYS LIMITED ENGLISH PROFICIENCY PLAN

Susquehanna Trailways Notice of Rights under Title VI to the public is available in the Susquehanna Trailways Administration facility lobby area located at our main terminal at 11 West Church Street, Williamsport, PA 17701.

Copies of the LEP Plan will be provided upon request. LEP persons may obtain copies/translations of the plan upon request.

Any questions or comments regarding this plan should be directed to the Susquehanna Trailways Title VI Coordinator.

Amy Brooks, Title VI Coordinator

Susquehanna Trailways

11 West Church Street

Williamsport, PA 17701

Phone: 570-322-5361

Fax: 570-322-2338

customerservice@susquehannabus.com

NON-ELECTED COMMITTEES AND COUNCILS:

Susquehanna Trailways does not appoint Board of Director Members nor any other committee or subcommittee structure.

EQUITY ANALYSIS STATEMENT:

Susquehanna Trailways has not performed a major construction project since the last Title VI update so no equity analysis had been performed. Susquehanna Trailways will perform an equity analysis for all future qualifying construction projects.

LIST OF TITLE VI INVESTIGATIONS/COMPLAINTS/LAWSUITS:

FY 10/11 – None

FY 11/12 – None

FY 12/13 – None

FY 13/14 – None

FY 14/15 – None

FY 15/16 – None

Susquehanna Trailways

TITLE VI SERVICE POLICY

It is the intent of Susquehanna Trailways to ensure full compliance with Title VI Regulations. The information has been reviewed, updated and adopted as policy by the Susquehanna Trailways Board of Directors; at board meeting of July 1, 2014.

SERVICE POLICY STANDARDS:

The FTA requires that all Scheduled Route operators develop quantitative standards for a variety of indicators. Susquehanna Trailways has developed the following indicators:

Vehicle Capacity for each motorcoach

Susquehanna Trailways offers daily scheduled route service using 40-45′ motorcoaches. Seating capacities are 46-55 passengers. All motorcoaches are equipped with wheelchair lifts, to accommodate on demand service at our company approved stops. When we are hauling a ADA passenger that requires a wheelchair seat in coach, seating capacity is reduced by four seats per secured wheelchair passenger. It is Susquehanna Trailways policy to avoid standees. Susquehanna Trailways travels both rural routes and interstates and per DOT regulations Standees are not permitted over interstate routes. Susquehanna Trailways operates extra buses (“doubles”) when high ridership is reserved or anticipated. High ridership is experienced on holidays and weekends.

On Time Performance

Below are Susquehanna Trailways performance standards for all scheduled routes.

On-Time Departures –

Susquehanna Trailways buses shall depart no more than ten minutes late from any scheduled and published departure time. Susquehanna Trailways shall strive to meet a minimum of 76% of bus departures within zero to five minutes, and 94% on-time performance for up to ten minutes.

Operating Ahead of Scheduled Times –

No bus shall depart a designated time point prior to its scheduled time.

Cancelled Trips –

Susquehanna Trailways shall strive to complete 100% of our operating schedules. Susquehanna Trailways has the right to cancel or alter a schedule in the event of inclement weather that could result in dangerous road conditions. Any such schedule changes will be posted on company website. (www.susquehannabus.com)

Failure to pick up Passenger –

Susquehanna Trailways shall attempt to not miss any passengers that are waiting at a designated bus stop.

Transit/Stop Amenities

Susquehanna Trailways determines stop location of all routes throughout our route schedules. Susquehanna Trailways stops locations include terminal locations (owned and independent), store fronts, restaurants and highway flag stops. All stop locations can be found on company website with mapping capabilities (www.susquehannabus.com). Any stop amenities or improvements will be given priority at those stops that have the highest ridership numbers. ADA improvements will be given priority.

Vehicle Assignments

Susquehanna Trailways operates 40′ motorcoaches that seat 46 riders; 45′ motorcoaches that seat 55 passengers. All motorcoaches are equipped with wheelchair lifts, underneath compartmentalized storage and a lavatory. Any motorcoach assigned to daily routes will comply with FTA standards. Any bus can be assigned equally to any of our daily routes served. Distribution of buses throughout the scheduled routes will not be based on age/condition but rather the needs for that particular route.

Service Animals

Susquehanna Trailways shall allow passengers with disabilities who use service animals to board bus with service animal regardless of fare category. Operators may ask any passenger if their animal is a service animal and/or if the animal assists them with their disability, but may not require certification or identification for service animals. Passengers using service animals must keep their animals under control and the animal must not pose a threat to other passengers. Failure to do so may result in the passenger being requested to exit the bus.

Transporting Oxygen and/or Respirators

Susquehanna Trailways allows for portable oxygen and respirators to accompany passengers on buses for medical purposes. A maximum of four (4) canisters may travel with the customer. The maximum dimensions for each container may not exceed 4.5 inches in diameter and 26 inches in length. Exemptions of size may be authorized after written request has been provided to Susquehanna Trailways Safety & Compliance department. Passengers are responsible for ensuring they have enough oxygen to complete their travel and are responsible for making arrangements for refills if necessary en route. Oxygen canisters must be stored in protective cases with safety caps on the valves.

Susquehanna Trailways as part of full compliance with FTA Title VI requirements, will post the below public notice. The public notice will be posted in the following: All Transit Vehicles, Company Website, Company agencies and terminals.

Public Notice Placard for Posting:

Notifying the Public of Rights Under Title VI

SUSQUEHANNA TRAILWAYS

Susquehanna Trailways operates its programs and services without regard to race, color, and national origin in accordance with Title VI of the Civil Rights Act. Any person who believes he or she has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with the Susquehanna Trailways company.

For more information of Susquehanna Trailways’ civil rights program, and the procedures to file a complaint, call: 570-322-5361; email: customerservice@susquehannabus.com or tickets@susquehannabus.com. Visit our home office/terminal at 11 West Church Street, Williamsport, PA 17701. For more information, visit www.susquehannabus.com.

A complainant may file a complaint directly with the Federal Transit Administration by filing a complaint with the office of Civil Rights, Attention: Title VI Coordinator, East Building, 5th Floor-TCR, 1200 New Jersey Avenue, SE, Washington, DC 20590.

If information is needed in another language, call 800-692-6314.