Location: Anderson, SC
Date of Final Review: April 6, 2009

Electric City Transit (ECT) - Lift Maintenance Transmittal Letter

April 6, 2009

Mr. Keith R. Scott
Transit Director
Electric City Transit
401 South Main Street
Anderson, SC 29624

Dear Mr. Scott:

Thank you for your response to the Federal Transit Administration’s (FTA) letter and preliminary report of findings of the Americans with Disabilities Act of 1990 (ADA) compliance review of Electric City Transit’s (ECT) fixed route services, initiated on July 8, 2008. Enclosed is the Final Report. As of the date of this letter the Final Report became a public document and is subject to dissemination under the Freedom of Information Act of 1974.

Enclosed with this letter is a progress table listing FTA’s understanding of the corrective actions either planned or taken by ECT in response to the preliminary findings contained in the draft report. If you feel that our summarization of corrective actions is inconsistent with your response, please inform us in writing as soon as possible.

Following most of the areas where findings were made, we have:

• Identified responses that adequately address the finding
• Requested documentation of results and outcomes
• Requested ECT to clarify specific corrective actions based on ECT’s response to the report findings

Please use the enclosed table as the format to report progress to FTA on the corrective actions that ECT has completed or intends to implement as a result of our findings. Please identify each response by item number (e.g., 1.1, etc.). The requested documentation, along with updates on the status of implementation of proposed corrective actions, should be provided in quarterly reports to FTA. Each report should include the planned and actual completion date of the corrective action; the current status and contact person information for each corrective action; and specific reporting requests cited in this letter and on the enclosed table. The first report will be due on April 15, 2009, and should include data for the months of January through March 2009, and any actions completed prior to that date that have not already been addressed. Additional reports will be due by July 15, 2009 and October 15, 2009 and each calendar quarter thereafter until FTA releases ECT from this reporting requirement.

We recognize the progress that you have made in responding to the findings of the review as presented in your January 23, 2009, letter. In addition to these efforts, we request that your first progress report more fully respond to the following finding, which is also addressed in the progress table. This is not an exhaustive list of open findings, for that, please see the progress table.

6. Bus Specifications

3. Finding: Inspection of two vehicles representative of the fleet suggests that the buses used in service comply with the 49 CFR Part 38 specifications for transit buses with some exceptions:
The Opus does not have a continuous overhead handrail.

ECT Response 1/23/2009: Install at least one overhead handrail, continuous to the back of the bus. All ECT buses have handrails and in the areas the rails are not continuous all buses have seat handles on all seats in between.

Further reporting: In your next quarterly progress report, please provide an update on the status of this corrective action.

The applicable regulations are at 49 CFR § 38.29 (the regulations are incorporated in the Vehicle Inspection Checklist, Attachment G of the draft report). Setback handles are desirable, but the regulation does not make them a substitute for an overhead railing that is continuous for the length of the bus.

We appreciate the cooperation and assistance that you and your staff have provided us during this review. Should you have any questions about the enclosed report, the reporting table, or this letter, please contact Ms. Kim Zapfel, Equal Opportunity Specialist, at (202) 366‑1713 or at her e-mail address: kim.zapfel@dot.gov.

It would be helpful if you would provide a copy of all correspondence to this office to the FTA Regional Civil Rights Office at the following e-mail address: frank.billue@dot.gov.

Sincerely,

Cheryl L. Hershey
Director
Office of Civil Rights

Enclosures
Ms. Yvette G. Taylor, FTA Region IV Administrator
Mr. Frank Billue, FTA Region IV Civil Rights Officer