Transportation Coordination: Benefits and Barriers Exist, and Planning
Efforts Progress Slowly (Letter Report, 10/22/1999, GAO/RCED-00-1).

Pursuant to a legislative requirement, GAO provided information on
federal agencies that provide nonemergency human services
transportation, focusing on: (1) the benefits and incentives to human
services transportation coordination; (2) the Department of Health and
Human Services' (HHS) and the Federal Transit Administration's (FTA)
efforts to identify barriers to transportation coordination; and (3)
HHS' and FTA's efforts to enhance transportation coordination through
state and local transportation planning.

GAO noted that: (1) transportation coordination can reduce federal
transportation program costs by clustering passengers, utilizing fewer
one-way trips, and sharing the use of transportation personnel,
equipment, and facilities; (2) in addition, people in need of
transportation often benefit from the greater and higher quality
transportation services available when transportation providers
coordinate their operations; (3) the most concerted effort by HHS and
the Department of Transportation (DOT) to identify barriers occurred in
1988; (4) at that time, acting through a Coordinating Council
established in 1986, the agencies identified 64 factors that
transportation and human services representatives believed were barriers
to transportation coordination; (5) for each barrier, the Council
offered a federal response that, in some cases, simply attempted to
clarify misunderstandings about program requirements; (6) other
responses, however, did not resolve the barrier because the issues
required legislation, needed additional study, or were outside of the
control of the Departments; (7) the Coordinating Council held
transportation meetings with most states in 1995 and 1996, but when
barriers were addressed in these meetings, the comments were often
limited to a word or phrase; (8) this level of generality made a federal
response difficult, and none was undertaken; (9) since 1996, HHS and DOT
have been directed by congressional committees to advance state and
local transportation coordination through joint planning guidelines that
would address issues such as the expanded use of public transportation;
(10) in response, HHS and DOT, through the Coordinating Council, began
developing planning guidelines in the spring of 1997; (11) while some
progress has been made, the joint planning guidelines are still under
development; (12) the Departments recognize that progress on the
guidelines has been slow and have assigned a contractor to work with
agency officials so the guidelines could be issued by the end of 1999;
(13) the agencies have also concluded that as an entity, the
Coordinating Council needs to be strengthened; (14) the two departments
are working on a draft strategic plan for the Council that not only
lists goals and objectives, but specific tasks intended to make the
goals and objectives a reality; and (15) however, this strategic plan
has been in draft for several years, and it is unclear if and when any
of the plan's proposed tasks will be undertaken.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-1
     TITLE:  Transportation Coordination: Benefits and Barriers Exist,
	     and Planning Efforts Progress Slowly
      DATE:  10/22/1999
   SUBJECT:  Transportation operations
	     Cost control
	     Federal aid for transportation
	     Intergovernmental relations
	     Mass transit operations
	     Interagency relations
	     Strategic planning
	     Public assistance programs
	     Redundancy
IDENTIFIER:  Medicaid Program
	     HHS Community Transportation Assistance Project
	     FTA Rural Technical Assistance Program

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Cover
================================================================ COVER

Report to Congressional Committees

October 1999

TRANSPORTATION COORDINATION -
BENEFITS AND BARRIERS EXIST, AND
PLANNING EFFORTS PROGRESS SLOWLY

GAO/RCED-00-1

Transportation Coordination

(348124)

Abbreviations
=============================================================== ABBREV

  HHS -
  FTA -
  DOT -
  TEA -
  MTA -

Letter
=============================================================== LETTER

B-281617

October 22, 1999

The Honorable Phil Gramm
Chairman
The Honorable Paul S.  Sarbanes
Ranking Minority Member
Committee on Banking,
 Housing, and Urban Affairs
United States Senate

The Honorable Bud Shuster
Chairman
The Honorable James L.  Oberstar
Ranking Democratic Member
Committee on Transportation and
 Infrastructure
House of Representatives

For several decades, many human services agencies have provided
special transportation services for seniors, persons with
disabilities, and others through programs funded and administered by
the Department of Health and Human Services (HHS).  For example,
program-related transportation services have enabled elderly people
who no longer drive to get to sites offering nutrition services,
ensured that isolated children receive benefits from Head Start
programs, and transported clients to community health centers and
welfare recipients to jobs.  Local human services agencies providing
these services have often purchased and operated their own vehicles
or purchased transportation services from others.  The estimates of
overall spending on transportation by HHS programs in fiscal year
1998 ranged from about $2 billion to $3.5 billion.\1

Similarly, the Federal Transit Administration (FTA), within the
Department of Transportation (DOT), awards grants to local transit
operators to provide assistance for general public transportation
systems, such as bus and subway systems, and also makes awards for
special purposes, such as grants and loans for the special needs of
elderly individuals and individuals with disabilities.  FTA's overall
expenditures for transportation services are estimated to exceed $4
billion for fiscal year 1998. 

HHS' and FTA's transportation investments, which totaled over $6
billion in fiscal year 1998, often failed to complement each other
because of a lack of coordination.  Coordination can range in scope
from the shared use of local facilities, equipment, training, and/or
maintenance services to the consolidation of various public and
social service providers' transportation services.  As HHS and FTA
have recognized, the lack of coordination among human services
transportation providers and public transit operators contributes to
the duplication or overlapping of transportation services.  Thus,
particular clients may be left unserved or underserved, while
transportation providers serving other clients may have excess
capacity. 

Section 3034 of the Transportation Equity Act for the 21\st Century
(TEA-21) (P.L.  105-178) requires that we report on federal agencies
that provide nonemergency human services transportation.  As agreed
with you, we reviewed (1) the benefits and incentives to human
services transportation coordination, (2) HHS' and FTA's efforts to
identify barriers to transportation coordination, and (3) HHS' and
FTA's efforts to enhance transportation coordination through state
and local transportation planning. 

--------------------
\1 HHS' and the Federal Transit Administration's estimated
transportation expenditures, as cited in Current State and Local
Practices in Planning for Coordinated Transportation, Volpe National
Transportation Systems Center, Department of Transportation (final
revised draft, May 1999). 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Transportation coordination can reduce federal transportation program
costs by clustering passengers, utilizing fewer one-way trips, and
sharing the use of transportation personnel, equipment, and
facilities.  In addition, people in need of transportation often
benefit from the greater and higher quality transportation services
available when transportation providers coordinate their operations. 
A study by the Community Transportation Association of America, a
nonprofit transportation association, presented five case studies
that showed significant reductions in the average cost per passenger
and vehicle hour as a result of transportation coordination.  In one
instance, the local human services agency's average cost per
passenger trip decreased from $7.92 to $4.06, and the average cost
per vehicle hour declined from $12.83 to $6.89.  In addition, the
five case studies showed that following transportation coordination,
there was an increase in the number of trips per month and total
trips per passenger hour, while the total number of vehicles in the
agencies' fleets held steady or declined. 

The most concerted effort by HHS and DOT to identify barriers
occurred in 1988.  At that time, acting through a Coordinating
Council established in 1986, the agencies identified 64 factors that
transportation and human services representatives believed were
barriers to transportation coordination.  For each barrier, the
Council offered a federal response that, in some cases, simply
attempted to clarify misunderstandings about program requirements. 
Other responses, however, did not resolve the barrier because the
issues required legislation, needed additional study, or were outside
of the control of the Departments.  More recently, the Coordinating
Council held transportation meetings with most states in 1995 and
1996, but when barriers were addressed in these meetings, the
comments were often limited to a word or phrase.  This level of
generality made a federal response difficult, and none was
undertaken. 

Since 1996, HHS and DOT have been directed by congressional
committees to advance state and local transportation coordination
through joint planning guidelines that would address issues such as
the expanded use of public transit services to deliver human services
transportation.  In response, HHS and DOT, through the Coordinating
Council, began developing planning guidelines in the spring of 1997. 
While some progress has been made, the joint planning guidelines are
still under development.  The Departments recognize that progress on
the guidelines has been slow and have assigned a contractor to work
with agency officials so the guidelines could be issued by the end of
1999.  The agencies have also concluded that as an entity, the
Coordinating Council needs to be strengthened.  To this end, the two
Departments are working on a draft strategic plan for the Council
that not only lists goals and objectives, but specific tasks intended
to make the goals and objectives a reality.  However, this strategic
plan has been in draft for several years, and it is unclear if and
when any of the plan's proposed tasks will be undertaken.  In order
to focus and expedite the work of the Coordinating Council, this
report recommends that HHS and DOT issue a prioritized strategic plan
by a specific date and increase accountability for achieving the work
outlined in the strategic plan through an action plan and an annual
report on the Council's work to the Secretaries of HHS and DOT. 

   BACKGROUND
------------------------------------------------------------ Letter :2

In many cities, there are numerous public and private providers of
specialized and paratransit services,\2 often funded by multiple
agencies or funding sources.\3 All too often, state and local
agencies are unaware that they are, in certain cases, providing
transportation services identical and parallel to those of another
agency.  As participating agencies coordinate, the current schedules
and passenger loads for each carrier/provider are analyzed to
identify where opportunities exist to consolidate routes, develop
ride-sharing or comingling agreements, and eliminate duplication and
thereby realize efficiencies of scale. 

During oversight hearings on rural transportation in 1985, a
congressional committee heard testimony prompted by concerns about
the lack of transportation coordination between federal programs such
as those managed by DOT and HHS.\4 Witnesses documented the
complexity of the problems, such as a wide range of programs, diverse
client populations, different administrative practices, and different
agencies involved at federal, state, and local levels.  Federal
agency heads, state officials, and program operators also cited
instances where coordination had improved the cost-effective delivery
of human services.  They called, almost in unison, for federal
leadership to halt fragmentation, duplication, and the waste of
taxpayers' dollars.  One solution proposed by DOT during the hearings
was the establishment of a joint coordinating council between DOT and
HHS. 

In October 1986, the Secretaries of Health and Human Services and
Transportation signed an agreement establishing a Joint DOT/HHS
Coordinating Council on Human Services Transportation (Coordinating
Council).  The Coordinating Council was established to improve the
efficiency and effectiveness of specialized and human services
transportation by coordinating related programs at the federal level
wherever possible and promoting the maximum feasible coordination at
the state and local levels.  The two Departments agreed to work in
concert to promote five goals that include achieving the most
cost-effective use of federal, state, and local resources for
specialized and human services transportation, and six objectives
that include removing barriers that adversely affect the coordination
of transportation services.  In 1998, the Council was renamed the
Coordinating Council on Mobility and Access, which, in recent years,
has tried to convene for quarterly meetings.  Officials from various
HHS and DOT program offices support the Council on a part-time basis,
and their efforts are supplemented by assistance from contractors. 

The Coordinating Council has sought to encourage state-level actions
to promote coordination as a key strategy in its effort to promote
the coordinated delivery of transportation services.  In 1986, when
the Council was established, only seven states reported any
involvement with transportation coordination, according to DOT
officials.  State involvement has increased over the years.  A 1999
draft report prepared for the Coordinating Council cited various
policies for coordinating transportation at the state level,
including executive orders establishing statewide coordinating
committees and interagency agreements.\5 For some states, however,
the relevance of the activity listed in this draft report for
coordinating transportation was unclearï¿½examples included no formal
agreement, an expired executive order, and informal interagency
cooperation. 

In recent years, the Congress has endorsed increased transportation
coordination, as reflected by several provisions in TEA-21 supporting
this coordination.  For instance, one provision directs DOT to
encourage transportation coordination through the metropolitan
planning process.  Another provision states that eligible projects
funded through job access and reverse commute grants are to be part
of a coordinated public transit-human services transportation
planning process.  In addition, another TEA-21 provision provides
that to the extent feasible, governmental agencies and nonprofit
organizations that receive assistance from government sources other
than DOT for nonemergency transportation services shall coordinate
the design and delivery of transportation services and be included in
the planning for those services. 

--------------------
\2 Paratransit service is more flexible than conventional fixed-route
transit service but is more structured than the use of private
automobiles.  It most often refers to wheelchair-accessible,
demand-response van service. 

\3 Human services transportation systems developed primarily out of a
lack of available service for agency clients, and this need continues
in many areas, as HHS notes that 40 percent of counties do not have
any public transit service. 

\4 Hearings on Rural Transportation:  The Role of Public and
Non-Profit Providers, U.S.  House of Representatives, Committee on
Public Works and Transportation, Subcommittee on Oversight and
Investigation (May 1985). 

\5 Survey of State Coordination Programs and Policies, American
Public Works Association, Ecosometrics Inc., and National
Transportation Consortium of States (draft, Apr.  1999). 

   TRANSPORTATION COORDINATION HAS
   BEEN SHOWN TO HAVE NUMEROUS
   BENEFITS
------------------------------------------------------------ Letter :3

Coordinated transportation services encourage efficiency by
clustering passengers, utilizing fewer one-way trips, and reducing
costs through the shared use of personnel, equipment, and facilities. 
As the Coordinating Council notes, transportation coordination can
also improve overall mobility within a community, particularly in
instances when human service agencies are separately providing
transportation for their own clients.  Coordination works by reducing
the inefficiencies arising from the disparate operations and service
patterns that often result from a multiplicity of providers.  As the
Council observes, coordination can lead to significant reductions in
per-trip costs.  Furthermore, people in need of transportation often
benefit from the greater and higher-quality transportation services
available when transportation providers coordinate their operations. 

In a comparison of the cost and efficiency of transportation services
before and after coordination, a 1992 study by the Community
Transportation Association of America,\6 funded by HHS and FTA,
presented case studies from five sites that showed dramatic
reductions in passenger trip costs and vehicle-hour costs after
coordination activities were undertaken.\7 In addition, the study
showed an increase for all five sites in the number of passengers per
vehicle hour and for total trips while the number of vehicles in the
fleet held steady or decreased.  Table 1 shows the results of the
study. 

                                         Table 1
                         
                         Comparison of the Cost and Efficiency of
                         Transportation Services Before and After
                         Coordination/Consolidation at Five Sites

                           Grand Rapids/
           Howard County,   Kent County,     Washington      Greenville     Pitt County,
                Md.            Mich.        County, Pa.     County, S.C.        N.C.
           --------------  --------------  --------------  --------------  --------------
Measure    Before   After  Before   After  Before   After  Before   After  Before   After
---------  ------  ------  ------  ------  ------  ------  ------  ------  ------  ------
Average     $7.92   $4.06   $6.11   $5.70  $28.46   $6.25   $6.31   $2.01   $7.13   $3.59
 cost per
 passenge
 r trip
Average     12.83    6.89   26.27   18.94   22.24   13.28   21.36   12.15   10.66   12.06
 cost per
 vehicle
 hour
Average     2,236   4,713  12,180  54,762   2,800   6,300  12,558  15,850   3,880   5,126
 trips
 per
 month
Average       2.1     3.4     4.3    12.8     2.9     9.1     2.4    6.04     1.5    3.36
 passenger
 per
 vehicle
 hour
Number of      12      12     132     132     N/A     N/A      65      12      41      15
 vehicles
-----------------------------------------------------------------------------------------
Legend

N/A = not applicable

Source:  An Analysis of Human Services Transportation:  America's
Other Transit Network, CGA Consulting Services, Inc., for Community
Transportation Association of America (Feb.  1992). 

Medicaid transit pass programs initiated at several locations around
the country provide another example of the value of increased
transportation coordination.  Medicaid is the largest source of
funding for medical and health-related services for America's poorest
people.  In 1996, it provided health care assistance for more than 36
million persons, at a cost of $160 billion.  As HHS officials noted,
federal regulations mandate that each state Medicaid agency must
describe how the agency will ensure necessary transportation for
clients to and from providers for clients without their own
transportation.  The most frequent users of Medicaid-funded
transportation services are disabled individuals, elderly persons,
children who are receiving counseling or other services on a regular
basis, and individuals who travel regularly to medical appointments
for services such as dialysis, mental health treatment, chemotherapy,
or physical therapy if they are severely disabled.  When Medicaid
provides participants with paratransit service, it often costs about
10 times the cost of transit fares.  But instead of paying for
paratransit services for physically able clients, HHS and DOT note
that Medicaid could provide these clients with monthly bus passes, if
they can access a bus route.  HHS' Health Care Financing
Administration sent a letter to state Medicaid Directors in December
1996 advising them that a monthly bus pass program can be used if it
is cost-effective and appropriate to the individual's needs and
personal situation.  In the summer of 1999, HHS and DOT issued a
brochure on the results of Medicaid bus pass usage in six states. 

According to DOT's Volpe Center, a notable example of the merits of
such an approach is the Metro Pass program in Dade County, Florida. 
The Dade County program encourages those Medicaid recipients who can
use the public transit system to use the monthly Metro Pass, which
gives them unlimited transportation on the fixed-route system at a
cost of $30 to $50 per month (including administrative fees).  A
sample calculation of monthly savings from the use of the Metro Pass
program is provided in table 2. 

                                Table 2
                
                    Comparison of Medicaid Recipient
                Transportation Costs Before and After a
                           Metro Pass Program

Time period             Registered  Number of   Cost per
October 1998            users       trips       user             Total
----------------------  ----------  ----------  ----------  ----------
Before Metro Pass       5,084       52,752      $15.28 per    $806,051
Program                                         trip

After Metro Pass        5,084       Unlimited   $38.05 per    $193,458
Program                                         month\a

Total cost savings for                                        $612,592
October 1998
----------------------------------------------------------------------
\a Average cost of monthly pass. 

Source:  Current State and Local Practices in Planning for
Coordinated Transportation, Volpe National Transportation Systems
Center, Department of Transportation (final revised draft, May 1999). 

As table 2 shows, and as estimated by the community transportation
coordinator for Florida's Dade County, the program saved
approximately $600,000 in October 1998.  Furthermore, the local
coordinator estimates that the program has saved $24.6 million since
its implementation in 1993. 

HHS and DOT reported that on the basis of states' experiences so far,
if 1 percent of the Medicaid recipients in the nation's 20 largest
metropolitan areas were shifted to transit passes, the savings would
be about $215 million per year.  Furthermore, HHS and DOT projected
that additional fares to transit agencies in the nation's 20 largest
metropolitan areas would be from $21 million to $43 million annually. 
However, HHS and DOT cautioned that while transit passes offer the
opportunity of multiple trips per month at great savings to the
Medicaid program, local conditions would affect specific breakeven
points.  Such conditions include the proportion of Medicaid
recipients in the local community, the number of medical trips per
month required, and the local costs of monthly transit passes. 

--------------------
\6 The Community Transportation Association of America is an
organization consisting primarily of rural and small community
transportation providers, and it serves the dual role of
transportation industry representative and mobility advocate. 

\7 See An Analysis of Human Services Transportation:  America's Other
Transit Network, CGA Consulting Services, Inc., Community
Transportation Association of America (Feb.  1992). 

   HHS' AND FTA'S EFFORTS TO
   IDENTIFY AND RESOLVE BARRIERS
   TO TRANSPORTATION COORDINATION
   HAVE BEEN LIMITED
------------------------------------------------------------ Letter :4

When HHS and DOT formed the Coordinating Council in 1986, one of the
primary objectives established for the Council was the elimination of
barriers to the coordination of transportation services.  In this
context, the Council undertook an early effort to identify and
respond to 64 factors that transportation and human services
representatives believed were barriers to transportation
coordination.  For each barrier, the Council offered a federal
response that in some cases simply attempted to clarify
misunderstandings about program requirements.  Other responses,
however, did not resolve the barrier because issues required
legislation, needed additional study, or were outside of the
Departments' control.  More recently, the Coordinating Council held
transportation meetings with most states in 1995 and 1996, but when
barriers were addressed in these meetings, the comments were often
limited to a word or phrase.  This level of generality made a federal
response difficult, and none was undertaken.  However, the Council is
undertaking several general efforts to improve transportation
coordination.  For example, the National Transit Resource Center,
funded by HHS and FTA, disseminates information on transportation
coordination, and HHS is funding another effort related to reporting
and recording burdens that may be thwarting transportation
coordination. 

      MOST CONCERTED EFFORT TO
      IDENTIFY BARRIERS OCCURRED
      OVER A DECADE AGO
---------------------------------------------------------- Letter :4.1

In 1988, the Coordinating Council initiated a nationwide effort to
identify statutory, regulatory, and programmatic barriers to the
coordination of transportation services.  With the assistance of 10
Regional Working Groupsï¿½each group included one transportation
representative and one human services representative from each of the
statesï¿½the Coordinating Council solicited the viewpoints of a broad
array of individuals and organizations, including transportation
providers, local human services agencies, state agencies, and
industry associations.  The Regional Working Groups forwarded these
findings to the Coordinating Council, which, in turn, submitted them
to the appropriate offices within HHS and FTA.\8 A total of 64
barriers were identified.  For each barrier, the Council offered a
federal response that in some cases simply attempted to clarify
misunderstandings about program requirements.  Other responses,
however, did not resolve the barrier because issues required
legislation, needed additional study, or were outside of the
Departments' control.  Examples of the issues that were identified as
barriers along with the federal responses follow. 

--------------------
\8 The Urban Mass Transportation Administration had responsibility
for transit at this time but was renamed the Federal Transit
Administration, which is the term used throughout this report. 

         UNCERTAINTY REGARDING
         FEDERAL RESPONSIBILITIES
         FOR TRANSPORTATION
-------------------------------------------------------- Letter :4.1.1

One barrier to transportation coordination that was identified was
unclear federal roles and responsibilities for transportation,
particularly when individuals are clients of multiple programs.  This
can lead individual programs to attempt to shift their client
transportation costs to other programs, thus reducing the former's
own costs.  For example, several states expressed concern that FTA
funds were being used to transport clients of human services
programs, thus replacing state or local funds that had formerly been
provided through HHS programs.  HHS and FTA did not address this
issue head on.  Instead, they noted that it was impossible for them
to control the amount of funding that local human services agencies
elect to devote to clients' transportation or to prevent reductions
in their transportation expenditures.  HHS and FTA noted that the
larger question--ï¿½Where does DOT's responsibility end and HHS'
begin?ï¿½--in the area of specialized or human services transportation
is also unanswerable, except to say in broad terms that there is
joint responsibility and that both Departments acknowledge this. 

         FRAGMENTED ACCOUNTING AND
         REPORTING
-------------------------------------------------------- Letter :4.1.2

Another barrier cited was the lack of standardized accounting and
reporting procedures.  Many states complained that there was no
standardized accounting system that human services providers can use
for all of their federal programs.  In addition, they said that
different programs have different reporting requirements, resulting
in excessive paperwork for small operators and too many financial and
program audits for the same system.  In their view, this fosters a
lack of accountability and coordination at the state level.  In
response, HHS and FTA pointed to simplified accounting procedures
that they have suggested for use by rural and specialized
transportation.  Furthermore, FTA and HHS noted that they would
continue to discuss existing reporting requirements and explore the
development of more common performance standards, accounting, and
reporting for all transportation components of FTA and HHS programs. 

         UNCERTAINTY IN USING
         RESOURCES FOR OTHER THAN
         PROGRAM CONSTITUENTS
-------------------------------------------------------- Letter :4.1.3

Some grantees stated that they believed that governmentwide
regulations prohibit the use of equipment (vehicles) and facilities
acquired under one grant to meet some of the needs of projects
supported by different grants.  HHS responded by noting that while
there have been statutes governing individual grant programs that
restricted use of grant equipment and facilities to activities
supported by the grant, there is no general governmentwide regulation
prohibiting shared use.  HHS also noted that the governmentwide
ï¿½common rulesï¿½ on the fiscal and administrative aspects of grants
require only that first priority for use of the equipment or
facilities go to the grant project. 

         PROHIBITION AGAINST
         CHARGING FARES UNDER THE
         OLDER AMERICANS ACT
-------------------------------------------------------- Letter :4.1.4

Some states believed that elderly riders should be charged a fare to
provide the needed local match for federal money.  HHS noted,
however, that the Older Americans Act strictly prohibits means
testing and denial of services because an older person cannot or will
not pay for services.  HHS noted that it proposed changing this
provision in the past, but the necessary legislative action has not
been taken.  Nonetheless, HHS stated that each older person receiving
a service under its programs should have the opportunity to make a
contribution, but only the individual older person should determine
whether to contribute and how much. 

      RECENT EFFORTS TO FOLLOW UP
      ON EARLIER BARRIER
      IDENTIFICATION HAVE BEEN
      LIMITED
---------------------------------------------------------- Letter :4.2

Since the 1988 effort by the Coordinating Council, little action has
been taken to identify and resolve transportation coordination
barriers, and problems continue to be reported in realizing
transportation coordination between HHS and FTA programs.  For
example, the Council took no specific action after a 1992 Community
Transportation Association of America report, funded by HHS and FTA,
used two focus groups to identify factors that prevent or impede
transportation coordination.  Among the most significant issues cited
by focus group participants were those dealing with unclear federal
guidelines on vehicle use by riders outside the funding agencies'
constituencies, a prohibition against charging fares under the Older
Americans Act, the lack of uniform cost measurement systems, and
record-keeping and accounting burdens. 

In 1995 and 1996, HHS and DOT sponsored another nationwide
transportation coordination outreach effort.  State transportation
coordination meetings were held in 9 of 10 national regions,\9 which
were attended by national and regional representatives of HHS and
DOT, their counterparts within the states, plus other invited experts
and guests.  Topics addressed at some of the meetings included
respective levels of progress toward interagency coordination of
transportation services, barriers to coordination, important problem
areas and issues, and plans for action.  This effort differed from
the 1988 effort in that not all the states addressed barriers to
transportation coordination.  Furthermore, when barriers were
addressed in these later state meetings, the comments were often
limited to a word or a phrase, such as ï¿½turf protectionï¿½ or
regulations.  This level of generality made a federal response
difficult, and none was undertaken.  However, the meetings did
encourage transportation coordination efforts in some states.  In
particular, DOT noted that the meetings held in Maryland and New
Jersey stimulated vigorous statewide efforts to develop coordination
mechanisms, such as a state coordinating council.  In addition, HHS
noted that several items were identified for federal action following
these regional meetings, such as case studies on how to incorporate
services for Medicaid clients into local public transportation. 

While not planning any systematic efforts to identify the extent of
transportation coordination barriers, the Council is undertaking
other general efforts to improve transportation coordination.  For
example, the Community Transportation Assistance Project, funded by
HHS, and the Rural Technical Assistance Program, funded by FTA,
support, among other efforts, a National Transit Resource Center that
compiles and disseminates information to help agencies and
communities develop better access and more cost-effective
transportation.  The Rural Technical Assistance Program, for example,
supported the development of a training video entitled Transportation
Coordination:  A Guide to Making It Work for You that promotes the
benefits of coordinated community and human services transportation
by showing interviews with a number of individuals working in, or
served by, such systems.  Another effort is a 1996 report funded by
the Community Transportation Assistance Project that identifies
transportation funding sources in federal programs.\10

Furthermore, on occasion, specific barriers to transportation
coordination are discussed at HHS and DOT coordinating meetings.  For
instance, the issue of burdensome reporting and record-keeping was
discussed at a July 1998 planning meeting, which led HHS to task a
contractor, Ecosometrics, Inc., with doing some preliminary work at
four locations to better analyze the problem.  In the summer of 1999,
the contractor was analyzing the results from these case studies.  An
initial finding from the case studies is that it is not so much any
particular requirement that creates concerns but, rather, the weight
of them together that frustrates transportation providers.  In
addition, the case studies indicate that the role of state reporting
requirements may be contributing to reporting burdens to a greater
extent than federal requirements.  HHS considers these case studies
to be the first phase of a larger project.  HHS officials noted that
they had received a draft report for this first phase of the project
and expect to receive the final report by October 31, 1999.  A
representative of Ecosometrics stated that his firm expects to
continue this effort with more case studies in 2000. 

One recent communication tool employed by the Coordinating Council
that could have an impact on the elimination of coordination barriers
is an Internet site developed for the Council by a contractor in the
spring of 1999.  The Council's Internet site contains information
about the Coordinating Council, the reasons for coordinating
transportation services, transportation coordination strategies, a
listing of publications about coordinated transportation, and related
sites of interest.  The site also solicits questions or comments
about the Coordinating Council, thus providing an opportunity to
clarify misconceptions that could be hampering transportation
coordination efforts.  The utility of the site for resolving
barriers, however, is limited by two design weaknesses.  First, as of
August 1999, the Council's Internet site had not yet been linked to
the main HHS or FTA Internet sites, although it can be accessed
directly when the specific Internet address is known
(www.ccamweb.org).  Second, while the site is designed to enable
users to search on key words, our tests indicated that this design
component was not working.  HHS and FTA officials recognized the
site's weaknesses and said the Internet site is still developmental,
and they hope to develop the search feature for the site as well as
develop a ï¿½frequently asked questionï¿½ section that could help to
mitigate barriers to transportation coordination. 

--------------------
\9 Region 9 did not hold a meeting, but two of the Region 9
statesï¿½Arizona and Nevadaï¿½attended meetings held in other regions. 

\10 Building Mobility Partnerships:  Opportunities for Federal
Funding, prepared for the Community Transportation Assistance Project
by the Community Transportation Association of America (May 1996). 

   IMPROVED TRANSPORTATION
   COORDINATION THROUGH STATE AND
   LOCAL PLANNING GUIDANCE NOT YET
   REALIZED
------------------------------------------------------------ Letter :5

The Coordinating Council has been working on developing joint state
and local planning guidelines to advance transportation coordination,
as directed by congressional committees since 1996.  While some
progress has been made, the joint planning guidelines are still under
development and have a tentative issue date set for the end of 1999. 
In addition, TEA-21 directs DOT to encourage transportation
coordination through the metropolitan planning process.  A revised
DOT planning regulation is expected to address transportation
coordination, and DOT expects to issue a proposed rule by the end of
1999.  The Departments also recognize that the Coordinating Council,
as an entity, needs to be strengthened.  To this end, the two
Departments are working on a draft strategic plan for the Council
that not only lists goals and objectives, but specific tasks intended
to make the goals and objectives a reality.  However, this strategic
plan has been in draft for several years, and it is unclear if and
when any of the plan's proposed tasks will be undertaken. 

      TRANSPORTATION COORDINATION
      PLANNING GUIDELINES STILL IN
      PROGRESS
---------------------------------------------------------- Letter :5.1

Since 1996, congressional committees have repeatedly directed HHS and
DOT to develop guidelines for state and regional planning to achieve
specific transportation coordination objectives.  For example, in
reports accompanying the DOT appropriations bills for fiscal years
1997 and 1998, the Senate Committee on Appropriations noted that the
coordination of transportation for persons with disabilities,
seniors, and others funded by HHS programs or by public transit
authorities must be planned and implemented at the state and regional
levels in order to ensure cost-effective service delivery and improve
access to HHS program services.  Specifically, the Committee directed
the Secretary of Transportation, working with the Secretary of Health
and Human Services through the Coordinating Council, to develop
guidelines for state and regional planning to achieve specific
transportation coordination objectives, including, but not limited
to,

  -- the joint identification of the transportation needs of human
     services clients and the appropriate mix of transportation
     services to meet those needs,

  -- the expanded use of public transit services for human services
     transportation, and

  -- cost-sharing arrangements for HHS program clients transported by
     Americans With Disabilities Act paratransit systems based on a
     uniform accounting system. 

In the spring of 1997, the Coordinating Council established a working
group to develop transportation coordination guidelines.  The working
group focused on three principal efforts.  First, a report on
developing a framework for state and local human services
transportation planning was prepared by a consultant.\11 The report
noted fundamental differences in the role of transportation for the
recipients of funding from HHS and DOT.  As the report explains,
transportation is the primary or even sole mission for most of the
recipients of FTA funds; whereas, many recipients of HHS funding are
multiservice organizations.  For these multiservice organizations,
transportation is seen as an ancillary service enabling them to
accomplish their key missions; transportation is only one of many
services offered to their clients.  For FTA, the report identifies
and provides background information on seven programs.  For HHS, the
report identifies and provides background information on 12 primary
programs that frequently purchase transportation services or at times
provide transportation services to program clients.  As the report
notes, although transportation activities vary significantly among
the 12 HHS programs, many of these programs are required ï¿½to reflect
the principles of devolution.  This means they operate with minimal
Federal guidance on transportation issues, including planning
requirements, program review, priority setting, service provision,
and oversight.ï¿½ Recognizing the challenge of modifying the planning
processes within the differing program cultures, the report presents
various options for obtaining more coordinated planning, such as
policy statements in support of coordinated planning efforts and
technical assistance on coordinated planning practices and
strategies. 

Second, in order to receive stakeholders' input at an early stage in
the development of the planning guidelines, the Council convened an
advisory panel workshop on July 1, 1998.  The advisory panel included
representatives from transit authorities, health care
representatives, and representatives from state and local
governments.  Key points expressed by the stakeholders at this
meeting included the following: 

  -- More coordination in the planning process would increase the
     cost-effectiveness of human services transportation efforts. 
     Planning is critical to starting, improving, or expanding the
     coordination of services.  Coordinated planning should promote
     the free flow of information necessary to design more responsive
     transportation systems. 

  -- Coordination is difficult, and it is a lot of work.  Many people
     need to be convinced that it is worth the effort.  Most agencies
     do not have the basic facts and figures needed to analyze their
     own transportation services, particularly with respect to fully
     allocated costs.  A data- intensive approach yields many
     benefits. 

  -- Public transit services for human services agencies' programs
     and their clients may decline without a commitment to coordinate
     planning and resources.  Growing elderly populations accentuate
     the need for additional services. 

  -- Financial and other incentives are needed to support
     transportation coordination efforts, and these incentives could
     include added consideration during grant reviews, special
     recognition through the Coordinating Council, and departmental
     recognition efforts. 

Third, DOT's Volpe Center conducted an effort in support of the
development of the joint planning guidelines.  On the basis of a list
of selected states and urban and rural areas believed to have
experience in coordinating transportation services, staff of the
Volpe Center conducted telephone interviews with representatives from
the candidate areas to gather information on the history and
background of transportation coordination efforts in their areas. 
Thereafter, Volpe staff conducted a second round of interviews
focusing their efforts on developing 15 case studies of
transportation coordination.  The case studies were used to examine
broad coordination strategies, such as the joint identification of
clients' needs, shared planning resources, and the establishment of
cost-sharing arrangements, that can be used as part of a process for
coordinating transportation services of human services and transit
agencies. 

For instance, the Volpe Center study notes that the joint
identification of clients' needs can contribute to a coordinated
approach to transportation service delivery in a number of ways. 
When the needs of each agency's clients are regarded collectively,
the participants are then able to take the first step in scoping the
size and breadth of the coordinated system.  The clients' needs will
include the type of transportation needed, the origins and
destinations of trips, and the timing and frequency of required
trips.  Once participating agencies have this information, they will
be able to adjust existing paratransit services or create new
services as needed while achieving efficiencies through the
comingling of clientele or coordinated dispatching of services.  The
study cited the Mass Transportation Authority (MTA) in Flint,
Michigan, as an example of achieving efficiencies through a comingled
clientele.  MTA provides public transportation for the Flint School
District (except for special education) and comingles school children
with the general public at a considerable cost savings to the
district.  Formerly, it cost the district $660 per student for
transportation on an annual basis.  Now, MTA provides that service at
$264 per student. 

Following the consultant's and the Volpe Center's reports, HHS and
FTA officials planned to have their staff develop and distribute
draft guidance through a multistep comment process.  The status of
the guidelines is addressed at periodic Council meetings along with
comments about the need to bring this effort to closure.  For
instance, the FTA Deputy Administrator noted at an April 1998
Coordinating Council meeting that HHS and FTA have been working on a
number of transportation coordination issues over the years,
including the joint planning guidelines, and that these efforts need
to be brought to closure.  However, the development of the guidelines
stalled, and, in the spring of 1999, HHS and DOT officials decided to
have a contractor assist them in developing an initial draft of the
guidelines. 

A first draft of the guidelines was prepared on July 30, 1999.  The
draft provides introductory information about coordination and how
interest in coordination has developed over time.  The draft also
contains a checklist of general steps needed for a coordinated
planning process, such as the need to understand and document the
transportation needs and resources of the local area and involve the
local community in the planning process.  Other material excerpted
from the reports to the Council from the Volpe Center and
Ecosometrics, Inc., consists of background information on primary HHS
programs providing transportation services and FTA programs, a
discussion of planning requirements, and actual case studies of how
coordinated planning has led to more cost-effective transportation
services in different communities.  However, it remains unclear how
these guidelines, as drafted, will fulfill their intended purpose,
which is to assist state and local officials in achieving specific
coordination objectives, including, but not limited to, (1) the joint
identification of clients' transportation needs and the appropriate
mix of transportation services to meet those needs, (2) the expanded
use of public transit to deliver human services transportation, and
(3) cost-sharing arrangements for program clients transported by
paratransit systems based on a uniform accounting system. 

The guidelines will likely become more responsive to these objectives
as they become fully developed and refined after reviews and
revisions by various HHS and FTA program officials and outside
parties via the Council's new Internet site.  After comments are
received and considered by HHS and FTA, the guidelines will be
issued.  HHS officials estimate that the guidelines will be issued by
the end of 1999. 

--------------------
\11 Recommended Framework for Developing State and Local Human
Services Transportation Planning Guidance, Ecosometrics, Inc.  (Sept. 
22, 1998). 

      TEA-21 ENCOURAGES
      TRANSPORTATION COORDINATION
      PLANNING
---------------------------------------------------------- Letter :5.2

In addition to directing HHS and DOT to develop joint guidelines on
transportation coordination during the appropriation process, TEA-21
has several provisions supporting coordinated transportation
planning.  For instance, one provision directs DOT to encourage
transportation coordination through the metropolitan planning
process.  In response to TEA-21's planning provisions, DOT officials
plan to issue a revised planning regulation.  According to DOT, the
transportation community provided extensive input on planning and
environmental issues during a TEA-21 outreach effort conducted by
DOT's Office of the Secretary during 1998.  In order to focus and
continue discussion by partners and stakeholders, the Federal Highway
Administration and FTA prepared a paper entitled ï¿½TEA-21 Planning and
Environmental Provisions:  Options for Discussion.ï¿½ The document
presents issues and implementation options relative to the planning
and environmental provisions of TEA-21.  However, the document does
not address the TEA-21 provision that directs the Secretary of
Transportation to encourage each metropolitan planning organization
to coordinate, to the maximum extent practicable, the design and
delivery of transportation services within the metropolitan planning
area.  According to FTA planning officials, this provision was not
initially included in the options for the discussion paper because
the legislative provision referred to encouraging rather than
requiring coordination.  These officials noted, however, that the
revised planning regulation is expected to address the coordination
issue.  As of August 1999, the planning regulation was still under
development, but FTA officials expect to issue the notice of proposed
rulemaking by the end of 1999. 

Furthermore, FTA officials note that a coordinated planning
environment may be advanced through other TEA-21 provisions and
federal transportation coordination efforts.  For instance, a TEA-21
provision provides that to the extent feasible, governmental agencies
and nonprofit organizations that receive assistance from government
sources other than DOT for nonemergency transportation services shall
coordinate the design and delivery of transportation services and be
included in the planning for those services.  Another TEA-21
transportation coordination provision relates to job access and
reverse commute grants and requires each application for funds to
reflect coordination with and the approval of affected transit grant
recipients.  As an FTA official noted, advancing transportation
coordination efforts becomes easier when a new program, such as job
access and reverse commute grants, provides additional funds and
links the receipt of the funds to the concept of transportation
coordination. 

In addition, the Coordinating Council sent a memorandum to HHS' and
FTA's regional offices on August 20, 1999, directing them to develop
regional action plans that include plans to promote transportation
coordination guidelines.  Regional Working Groups were instrumental
in the Coordinating Council's early efforts to identify statutory,
regulatory, and programmatic barriers to the coordination of
transportation services.  However, according to Coordinating Council
members, only some regional groups continue to address transportation
coordination, but the hope is that the recent memorandum will
stimulate activity by all 10 Regional Working Groups. 

      PROPOSED STRATEGIC PLAN TO
      STRENGTHEN THE COORDINATING
      COUNCIL STILL NOT FINALIZED
---------------------------------------------------------- Letter :5.3

The Coordinating Council was established in 1986 to improve the
efficiency and effectiveness of specialized and human services
transportation by coordinating related programs at the federal level
wherever possible and promoting the maximum feasible coordination at
the state and local levels.  HHS and DOT agreed to work in concert to
promote the purpose of the Council through five goals and six related
objectives.  A Council goal, for example, is to achieve the most
cost-effective use of federal, state and local resources for
specialized and human services transportation, and one of the
objectives is to remove barriers that adversely affect the
coordination of transportation services. 

In 1995, HHS and FTA officials began efforts to strengthen the future
work of the Council by providing it with a draft strategic plan- -a
blueprint- -for advancing transportation coordination.  The draft
strategic plan list goals and objectives, as well as specific tasks
intended to make the goals and objectives a reality.  A draft of the
Council's strategic plan shows that its efforts would be
significantly expanded to 6 goals, 27 objectives, and 30 related
tasks- -an ambitious undertaking, particularly since there is no
prioritization of the goals, objectives, or tasks.  One proposed goal
is to achieve the most cost-effective use of federal, state, and
local resources for transportation.  Accompanying objectives for this
goal include (1) maximizing opportunities for coordinating
transportation program resources at federal, state, and local levels;
(2) reducing the duplication of services; (3) identifying and
encouraging cost-effective transportation services, and; (4)
developing rapid response capabilities for implementing new
technologies for transportation and/or access to community services. 

Several of the proposed tasks in the strategic plan relate to
barriers.  For instance, one proposed task is to identify regulatory
barriers to coordination.  Another proposed task would highlight the
work of the Council through an annual report on efforts to reduce
barriers, disseminate transportation coordination information, and
note special projects.  An additional proposed task would be to have
action plans and annual updates submitted from each member agency to
the Council. 

HHS' and FTA's attention to the development of this strategic plan
has been sporadic, and there is no set date for finalizing the
strategic plan.  Although the need to issue this plan in the near
future was noted at a June 1996 Council meeting, the strategic plan
for the Council continues to languish in a draft state, thus it is
unclear when proposed tasks would be undertaken.  Furthermore, given
the difficulties the Council has experienced in bringing issues to
closure, the scope of the strategic plan- -6 goals, 27 objectives,
and 30 tasks- -could prove to be an overwhelming agenda, particularly
given the lack of any prioritization within the strategic plan. 

   CONCLUSIONS
------------------------------------------------------------ Letter :6

Transportation coordination has the potential for realizing more
efficient and cost-effective transportation services.  While the
Coordinating Council has a long record of supporting transportation
coordination initiatives, the Council's efforts have been erratic and
slow to produce results.  A draft strategic plan for the Coordinating
Council has a number of good ideas for moving the Council forward,
such as an annual report for the Council, which, at a minimum, should
include a report on barriers, dissemination efforts, and special
projects.  However, the draft strategic plan for the Council entails
6 goals, 27 objectives, and 30 tasks, which is a broad and perhaps
overwhelming agenda, given the Council's past level of performance
and the lack of any prioritization within the strategic plan. 
Furthermore, the strategic plan could continue to languish in draft,
since there is no set issuance date. 

Congressional committees have repeatedly directed HHS and DOT to
develop guidelines to enhance transportation coordination through
state and local planning since 1996; these guidelines remain under
development and now have a tentative issuance date set for the end of
1999.  Also under development is a revised planning regulation that
is expected to reflect a TEA-21 provision directing that DOT
encourage each metropolitan planning organization to coordinate, to
the maximum extent practicable, the design and delivery of
transportation services within the metropolitan planning area. 
However, since both of these efforts remain works-in-progress, it is
unclear how, if at all, they will reinforce each other. 

While efforts are under way to have the 10 Regional Working Groups
develop action plans, HHS and FTA are not instructing these Regional
Working Groups to assess barriers to transportation coordination.  In
addition, no similar action agenda exists for the Coordinating
Council.  However, the Coordinating Council recently developed its
own Internet site, which has the potential to be a powerful
communication tool, providing information on a host of coordination
issues including barriers to coordination.  The utility of the site
for resolving barriers, however, is limited by two design weaknesses. 
First, as of August 1999, the Council's Internet site had not yet
been linked to the main HHS or FTA Internet sites, although it can be
accessed directly when the specific Internet address is known
(www.ccamweb.org).  Second, while the site is designed to enable
users to search on key words, our tests indicated that this design
component was not working. 

   RECOMMENDATIONS
------------------------------------------------------------ Letter :7

In order to improve transportation coordination through better
planning and enhanced accountability, we recommend that the Secretary
of Health and Human Services and the Secretary of Transportation (1)
require the Coordinating Council to issue a prioritized strategic
plan by a specific date, (2) charge the Coordinating Council with
developing an action plan with specific responsibilities, and (3)
require an annual report from the Council on its major initiatives
and accomplishments.  As part of these planning efforts, the agencies
should also (1) make sure that transportation coordination planning
efforts under development reinforce one another, (2) direct the
Regional Working Groups to assess barriers to transportation
coordination, and (3) make information on coordination barriers and
strategies for overcoming the barriers readily available through the
Council's Internet site. 

   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

We provided DOT and HHS with a draft of this report for their review
and comment.  DOT generally agreed with the draft report that
measures could be taken to expedite some of the Coordinating
Council's actions and sharpen its strategic planning and management
processes.  DOT, however, stated that the draft report did not
sufficiently recognize the Council's accomplishments or the progress
that has been made to improve transportation coordination.  We
recognize that progress has been made and conclude that the Council
has a long record of supporting transportation coordination
initiatives.  But we also conclude that the Council's efforts have
been erratic.  Furthermore, many of the examples of the Council's
accomplishments in improving transportation coordination cited by DOT
were already recognized in our draft report.  We agree with DOT that
regional meetings may have led to improved coordination efforts in
some states and have incorporated information in our draft report to
reflect this point.  Moreover, we expanded our discussion on the
Transit Resource Center and its funding sources as a result of DOT's
comments.  The complete text of DOT's comments appears in appendix I. 

HHS generally agreed with the report's recommendations.  However, HHS
stated that the draft report presented a narrow interpretation of the
work of the Coordinating Council and noted that the draft report
failed to recognize HHS establishment of the Community Transportation
Assistance Project, which it considers to be the backbone of HHS'
technical assistance efforts on transportation issues.  While the
draft report recognized the Transit Resource Center, which receives
funding through the Community Transportation Assistance Project, we
have added a more detailed reference to the Community Transportation
Assistance Project.  HHS also commented that our draft report did not
recognize the significance of the transportation planning guidelines
under development.  Our draft report traced the history of the
development of these joint guidelines.  On the basis of this first
draft of the guidelines, we believe that the way that they will
fulfill their intended purpose is unclear.  However, we note that the
responsiveness of the guidelines to their intended purpose will
likely be strengthened as they become fully developed and refined
after reviews and revisions by various HHS and FTA program officials
and outside parties.  The complete text of HHS' comments appears in
appendix II.  Furthermore, HHS made additional technical
clarifications, which were incorporated into the draft report, as
appropriate. 

   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9

To review the benefits and incentives to human services
transportation coordination, we analyzed state, regional, and local
best practices in human services transportation for the benefits
realized and the incentives that have fostered coordinated
transportation.  We discussed the benefits and the incentives with
HHS and FTA officials participating in the Joint Coordinating Council
and with consultants for the Council, and we reviewed federal
research directories and reports, including reports at the National
Transit Resource Centerï¿½a national transportation clearinghouse.  To
review the efforts that HHS and FTA have taken to identify and
address barriers to coordination, we tracked barriers identified
through surveys and state outreach meetings, HHS and FTA regional
input and Coordinating Council meetings, and the federal response to
barriers or perceived barriers identified through these sources.  We
discussed the barriers or perceived barriers with HHS and FTA
officials participating in the Coordinating Council and with
consultants for the Council, and we reviewed transportation
coordination reports.  To identify HHS' and DOT's actions to
facilitate planning processes that enhance transportation
coordination efforts, we focused on HHS' and FTA's efforts to develop
coordinated guidelines.  We reviewed their primary effortsï¿½reports
and meetings---expected to contribute to the development of the
guidelines and monitored the progress of the guidelines through
discussions with HHS and FTA officials and attendance at Coordinating
Council meetings.  We also considered provisions in TEA-21 that would
reinforce planning efforts aimed at transportation coordination and
discussed these issued with FTA officials. 

We performed our review from September 1998 through August 1999 in
accordance with generally accepted government auditing standards. 

---------------------------------------------------------- Letter :9.1

We are sending copies of this report to the appropriate congressional
committees; the Honorable Donna E.  Shalala, Secretary of Health and
Human Services; the Honorable Rodney E.  Slater, Secretary of
Transportation; and other interested parties.  We will also make
copies available to others on request. 

Please call me at (202) 512-3650 if you have any questions.  Major
contributors to this report were Yvonne Pufahl and Ron Stouffer. 

Phyllis F.  Scheinberg
Associate Director,
Transportation Issues

(See figure in printed edition.)Appendix I
COMMENTS FROM THE DEPARTMENT OF
TRANSPORTATION
============================================================== Letter 

(See figure in printed edition.)

(See figure in printed edition.)

(See figure in printed edition.)Appendix II
COMMENTS FROM THE DEPARTMENT OF
HEALTH AND HUMAN SERVICES
============================================================== Letter 

(See figure in printed edition.)

(See figure in printed edition.)

(See figure in printed edition.)

*** End of document. ***