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Coborrus County Transit System Finol Report — September 2015 customers are more responsive to the knock on the door than they are to the van waiting in the driveway. Recommendation: Maintain the door -to -door approach as a change would be difficult to initiate and expected time savings may never be realized. Van Lending Policy This policy appears to allow County employees, who have undergone a CCTS driver safety training program, to borrow CCTS vans when they are not planned to be used, as though they are part of the general County motor pool. Because the vans are purchased with FTA funds, such use would have to be qualified public transportation service as intended in the programs that FTA funds. Staff time is required for training drivers, logging and correcting records, etc. This practice exposes CCTS to unreasonable risk - if a vehicle is damaged while on loan, it then becomes out -of- service for its intended purpose on the following day. Recommendation: It is recommended that this policy be abandoned or refined (see the discussion, in the potential CTSP initiatives, on volunteer drivers). The goal of the Volunteer Driver program is to capture all such legitimate public transportation into the delivery of service reports like OPSTATs. All other ineligible van lending should be stopped immediately. This will require a rewriting of this policy. The Safety and Security Procedure and Plan (SSPP) related to lifts and lift maintenance Policies All vehicles utilized by CCTS will be properly inspected, serviced and maintained as determined by state regulation and county maintenance schedule. More needs to be done to spell out the standard operating procedure within the SSPP to ensure maintenance of lifts- procedures are followed. This deficiency has been duly noted in the ITRE performance review, the NCDOT safety program inspection and the most recent site visit by the Mobility Development Specialist. Recommendation: Corrective action that leads to on -time routine inspections of the lifts is required. 49 CFR §37.163, Keeping Lifts Operable, requires public entities to: Establish system of regular & frequent maintenance checks, Report failures as soon as possible, and Provide alternative transportation to persons with disabilities if the headway to the next accessible vehicle on a fixed route exceeds 30 minutes. Additional training around the driver detection of maintenance issues would help to address the reporting of failures and improve monitoring of lift maintenance deficiencies. Complaints Policy If, for any reason, a passenger wants to register a complaint, that complaint should be presented in writing to any member of the transportation staff, who will then bring the Attachment number 1 \n F -3 Page 127