particularly pronounced. 34 However, the competent authorities only assessed the rationality of the vehicle to manpower ratio based on the fact that rehabilitation buses need backup vehicles to support dispatch needs,35 clearly neglecting the shift-based nature of bus drivers’ work. (2) The service coverage in certain counties and cities is less than 5%, 36 and in some cases, the coverage has even seen a decrease, rather than an increase. (3) Some counties and cities are unable to expand their budgets due to financial restrictions, thus limiting the number of times persons with disabilities under their jurisdiction can utilize the services 37 . Some local governments even limit the number of service reservations that persons with disabilities can make, on the grounds that they bear the entire burden of funding.38 (4) The data in the CRPD Second Report include vehicles that have exceeded the driving mileage, reached the replacement period and those lent to institutions and groups.39 Likewise, it includes drivers who do not provide full-time rehabilitation bus services in the calculation of manpower40. This can lead to the risk of overestimating resources and misjudging the rationality of resource allocation. (5) Rehabilitation buses are public buses that provide transportation service to persons with disabilities, yet their operating hours are not comparable to regular buses, and are often limited to 8 a.m. to 5 p.m., Monday to Friday. 34 35 36 37 38 39 40 In 2016 and 2017, the ratio of rehabilitation buses to drivers was 1:0.92, but in 2018 and 2019, it had dropped to 1:0.90. Moreover, in 2019, there were 12 counties and cities where there were far fewer drivers than vehicles, out of which 6 even had ratios lower than 1:0.8. As stated by the MOTC at a conference held by the NHRC, the appropriate vehicle to driver ratio is 1:1.2. However, according to the MOHW, rehabilitation buses require the backup vehicles to support dispatch needs. Roughly 1 backup vehicle is required for every 10 vehicles. The overall ratio of vehicles to drivers is 1:0.90, which is within reasonable range. From 2016 to 2019, the overall coverage rate of rehabilitation bus service increased from 5.52% to 10.48%. However, based on observations, service coverage in 2019 was less than 10% in 18 counties and cities, out of which 13 did not even reach 5%. For example, in 2019, a service recipient utilized the services 33 times on average. But in 5 counties— Yilan County, Changhua County, Nantou County, Yunlin County, and Chiayi County—the average usage is lower than this. Service recipients in Nantou County averaged fewer than 10 trips per year due to the “two days per person per week” limitation imposed on the service, which is provided by the County Government free of charge. As stated by the MOHW: Non-rental rehabilitation buses are official vehicles. The mileage of certain buses has exceeded the limit of 125,000 km, but the buses have not reached the replacement age. For buses which have reached the replacement age, no new drivers will be hired at this time to prevent drivers from having no buses to drive when these buses are written off. The rehabilitation bus service in Kinmen is offered by drivers in rotation hired by the Bus and Ferry Management Office. 35