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					Comments Received on “DRAFT PTAC Proposals for Funding Formula January 19, 2006”
All comments received through January 31, 2006
Location         Comment (If the Comment is in the form of a question, the answer follows)
The following comments are based on notes during the VTC and may not be precise
Atlanta           Oppose the proposed change from 80% Need/ 20% Performance to 50%/50%.
                  In the past there was some discussion of 70%/30% which would be more reasonable.
                  Will the rulemaking process be completed in time to apply to the allocation of funds for
                  fiscal 2007?
                  (Answer: Yes)
Austin            Concern that we are not looking at the impact of past investments. Investments in transit
                  are similar to investments in roadways. Both require maintenance to keep in good condition
                  for performance. Need to increase dollars for those that need to maintain past investment
                  as well as those who want to make a new investment. A concern we have is if systems
                  gaining large amounts of funding use those dollars efficiently.
                  Oppose the revised split for State funds in urban/rural from 35%/65% to 40%/60%. The
                  total dollars spent per capita for rural is significantly less than the dollars spent per capita
                  for small urban. This is a reduction in State funds premised on an increase in Federal funds
                  for rural that has not actually happened.
                  Oppose the proposed change from 80% Need/ 20% Performance to 50%/50%. Please look
                  at incremental change. First we need to scrub the quality of the performance data reported.
Corpus            How many urban systems grew to more than 200,000 population in Census 2000?
                  (Answer: One)
                  Are there any other state funding sources for transit in urban cities that grow above 200,000
                  (Answer: By statute, if the urban area is not part of a transit authority, the urban provider is
                  eligible for state public transportation funds; there are no other state funding sources for
                  urban areas >200,000 population.)
                  Oppose the proposed change from 80% Need/ 20% Performance to 50%/50%. Does not
                  really benefit. The requirement for a local match is cumbersome.
Fort Worth        The proposal is to use the population of seniors and persons with disabilities for need (for
                  providers that restrict service to only seniors and persons with disabilities). What population
                  is used to calculate performance indicators?
                  (Answer: The service eligible population - seniors and persons with disabilities)
Houston           Concern about the proposed change from 80% Need/ 20% Performance to 50%/50%.
                  Need to have a transition rather than immediate change.
                  Opposed to requirements for local match.
                  Should take changes only as far as page 51 (reference is to the proposal to change rural
                  performance indicators)
                  Suggestion on ways to use unspent dollars:
                  • Fleet/capital
                  • Data tracking systems for performance data
                  • Training of operators and PTC on performance data collection and reporting
Paris             What is the timeline for presentation of the PTAC proposal to allocate a portion of the
                  additional 2006 Federal Section 5311 funds by formula?
                  (Answer: the process to present the proposal to the Commission has begun. The proposal
                  has been placed before Commission staff for action)
                  Do not support the proposal to change the split of State funds for urban/rural from
                  35%/65% to 40%/60%. Yes, rural providers are expecting to receive more Federal funds,
                  but those funds have to be matched. The State funds are a very important source to match
                  Federal dollars.
                  For 5307 funding, how are the two urban systems proposed to be split treated by the
                  federal government?
                  (Answer: Midland and Odessa are separate urbanized areas and receive separate 5307
                  funds. The Hidalgo County Urbanized Area includes a number of smaller cities, one of
                  which is McAllen. The Hidalgo County Urbanized Area receives one 5307 allocation for a
                  large urban area [greater than 200,000 population])

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Location      Comment (If the Comment is in the form of a question, the answer follows)
              PTAC could consider aligning the state policy about funds for cities >200,000 to the Federal
              How are the funds for performance allocated?
              (Answer: the dollars for performance are allocated pro rata according to how each
              provider’s performance compares to all others for each performance indicator. The data for
              each performance indicator are arrayed for all providers. Each provider is given an
              allocation value that is calculated based on how that provider’s performance indicator
              compares to the sum of the performance indicators of all providers. The allocation values
              for each of the three performance indicators are summed according to the relative weight of
              each [the current formula provides for equal weight for each indicator] and the total
              allocation value is multiplied by the funds available to arrive at the funds per provider.)
              The use of revenue miles twice in the performance indicators for urban providers
              discriminates against urban providers with a small population and geographic boundaries
              for the urbanized area that are established by the Census.
              (Response: TTI understands the comment is referring to a situation where the urbanized
              land area is relatively large as compared to the population. More revenue miles are
              required to provide service to the land area and this may be disproportionate to the
              population. In such a case, the passengers/revenue mile indicator may not be favorable to
              the provider; however, the revenue miles/operating expense may be to the provider’s
              advantage. One reason to include multiple performance indicators is to consider a balance
              of indicators to measure performance.)
              The local match requirement is disadvantageous to small, poor areas.
Pharr         Operators in the Pharr District will evaluate the presentation materials and submit
              comments independently.
              Have you modeled impacts for individual systems?
              (Answer: Yes, TTI has worked with PTN to develop a spreadsheet model that does run
              estimates of the funding for each provider according to different funding scenarios. At this
              point in the process, there are many scenarios under analysis. TTI presented the data to
              PTAC and the information is available for review by others in another file. TTI does want to
              emphasize that all calculations are preliminary and subject to change due to assumptions
              and also due to pending revisions to the performance statistics being used in the
              What is the source of the population numbers used in the calculations?
              (Answer: U.S. Census 2000)
              Is performance by provider compared to the previous year’s performance?
              (Answer: No. The performance of each provider is compared to the performance of all
              providers in the same tier [the tiers are urban and rural in the current formula])
              Harlingen Express is not strictly for seniors and persons with disabilities as referenced in
              the presentation.
              (Response: TTI did review the web site and understands the Harlingen Express is intended
              primarily for seniors and persons with disabilities but the general population can ride on a
              space available basis.)
              Are the performance statistics analyzed system-wide or by mode (for example, fixed route
              and ADA paratransit).
              (Answer: The performance statistics are reported for all services operated by the provider)
              The change from 80% Need/ 20% Performance to 50%/50% is a drastic change. So is the
              discussion of requiring a local match. These changes would impact Hidalgo County
              systems. Need to transition into these changes.
              Support the use of discretionary funds for growing areas and transit intensive urban areas.
San Antonio   Oppose the revised split for State funds in urban/rural from 35%/65% to 40%/60%. Agree
              with comments made by someone from Austin District earlier.
              The proposed change from 80% Need/ 20% Performance to 50%/50% is too much. With
              the change in Medicaid, many systems could lose a lot of ridership due to a change in the
              provider of Medicaid services and will suffer in the performance indicators.
Tyler         Oppose taking away the 5-year limit on transition to formula target. Previously heard that it
              would take East Texas up to 15 years to transition fully. Should not take that much longer

2/5/2006                                                                                                 2
Location             Comment (If the Comment is in the form of a question, the answer follows)
                     than others.
                     (Response. The information on the transition time required given the proposal to transition
                     annually without a term limit is available to evaluate this point.)
Waco                 The proposed change from 80% Need/ 20% Performance to 50%/50% and the revised split
                     for State funds in urban/rural from 35%/65% to 40%/60% with the change in Medicaid is too
                     much to absorb.
Amarillo             When can providers see the numbers that these changes will generate?
Austin               (Answer: Data is available in another file).
Amarillo             Why not use data from the National Transit Database (NTD)?
                     (Answer: NTD data has not been reported by all agencies historically; however, as NTD
                     becomes more broadly available, it will be used. In the interim, TxDOT staff has designed
                     data collection and reporting systems that largely mirror NTD)
Austin               Request for data on the performance statistics used to distribute 2006 funds.
                     (Response: PTN will provide the information requested)
Dallas               Request time next Wednesday during Semi-annual Meeting with providers for further
                     (Answer: PTAC Vice Chair John Wilson made a presentation to the meeting participants;
                     TTI was available to answer questions and discuss the comments of individual providers.)
Houston              We need additional dialogue. There may be more comments. Providers need more time to
                     review the material. The information was not in a format that could some were able to
                     review. Need a time for more discussion at the Provider Semi-Annual meeting.
                     (Response: An opportunity for additional dialogue was provided at Semi-Annual Meeting.)
Pharr                Concerned that February 3 is not enough time to comment.
                     (Response: The February 3 date the next meeting of PTAC. This is only one step in a
                     process to present proposals and receive public comment. Persons commenting are
                     encouraged to review again the timeline for rule-making – and specifically the opportunities
                     for public comment – illustrated on slide 76 of the VTC presentation)
San Antonio          Would like to see numbers out to 2010. With the proposal to change transitioning to
                     -10% and +20%, we may never get to target formula. How long does transitioning take?
                     (Response.: The information on the transition time required given the proposal to transition
                     annually without a term limit was provided in materials for PTAC and is shared in another
                     file to evaluate this point.)

The following comments based on Comments to or emailed directly to PTN or TTI
Norman Schenck, New formula to be based 50% on system efficiencies, this leans money to the cities with
Tyler              major transit contracts. Have no idea how this will affect our dollars, as we are measured
                   against all other urban systems in the state, last year we did fair against the
                   competition, but when it becomes 50% of our allocations instead of our current 20% we
                   might be tempted to cut out non efficient service, i.e. Mrs. Smith’s trips cost us way to
                   much, she always goes by herself from one side of town to another, and thus she spends a
                   lot of time and miles on her trip. Thus it could hurt the system to do too many trips for Mrs.
                   Smith (highly speculative, but a possible scenario). The intent is to reward systems that are
                   highly efficient. But how do we become more efficient if the needs of our ridership limit us,
                   do we start denying trips that are too inefficient?

                     New formula may require local match for state dollars, to continue the trend of TxDOT in
                     encouraging local participation in highway or transit projects
                     This could really hurt our system. Example:

                      Tyler Texas Example
                      assumes 80/20 match for state dollars
                                               Current            Proposed
                      FTA $                    $1,000,000         $1,000,000
                      State $                    $322,000          $322,000
                      State Match $                      $0          $64,400

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Location   Comment (If the Comment is in the form of a question, the answer follows)
            City Match $ FTA             $233,000          $168,600
            City Match $ State                  $0                $0
            Total                       $1,555,000        $1,555,000

            FTA Match                     $555,000         $490,600
            grant dollars available     $1,000,000         $883,964
                                        $1,555,000        $1,374,564
            loss                                           $180,436
           % increase in city $ to keep level                27.64%

           Just like all the other losses that the city of Tyler has suffered, this new idea would be
           another loss of $180,000 at a time when fuel cost went up last year by $35,0000, medical
           insurance cost this year went up 30%, Vehicle insurance up 10% ,Utility bills went up over
           10%, phone service cost up over 5%, labor cost for building maintenance up over 15%,
           tire cost up 10%, etc. At what point can the city continue to maintain service when our
           match funding is going down. At some point this means we will have to begin reducing our
           service levels, either by cutting out Saturday service, or reducing the number of service
           hours in a day. It would probably mean the end of our night time service which is currently
           being funded by a generous grant from the Commission. Going to the city council and
           asking for another $64,400 to match the state dollars is an option, but they have other city
           functions that require funding, most of which do not have grants to allow them to leverage
           city dollars. I understand the need to show city “buy in” to transit. But when other cities get
           to count local match which includes contracts with large universities or other entities, how
           can Tyler whose only local match is from the cities general fund (plus fare box), compete.
           Or how do we compete against Laredo who has a dedicate sales tax that brings in over
           $6M per year.

           New formula may move $1.4 M from rural program to urban program (since rural program
           gets an extra $7 in Federal dollars this year.
           Although I welcome the idea of moving to a 60/40 split as it has a chance of helping Tyler, it
           sure seems like it would be a huge mistake. If we have an extra $7M coming to systems in
           the form of FTA 5311 money, don’t we need to show the need to the Feds and won’t that
           require new match money? If anything those systems will need a larger source of local
           match, including state funds.

           I really appreciate the VTC this morning. It is a great format to share information among
           providers. I sure would have loved to see potential impacts shown graphically, didn’t need
           to see system names. The bar graphs that were included were helpful. I assume that
           PTAC will actually be shown real numbers, so that they know the $ impact any proposed
           changes will make to transit systems state wide. Continual changes to the formula sure
           make planning impossible, my first budget for next year is due the end of March and final
           budget the middle of May, long before I will have a real number for the state. I’ve guessed
           the last two years and have gotten fairly close, this year I don’t even know how to guess. I
           don’t have a way to estimate the potential changes. If there is someway we could be given
           guidance to help those of us that have budgets due to the city early it would be highly

           Tyler has found a way the last two years to maintain and even increase service levels when
           faced with loss of state funds. But, we’ve fine turned our ability to leverage state funds with
           FTA $ as far as we can, and now the loss of $1 of state funds roughly translates into the
           loss of $3 of FTA funds for a total loss of $4. So when the numbers are run, and Tyler
           looses $1000, remember the real loss to the system is $4000, not $1000.

2/5/2006                                                                                                4
Location             Comment (If the Comment is in the form of a question, the answer follows)
Dave Marsh,          The 65/35 split for state funds was devised originally in recognition of the federal funding
Capital Area Rural   levels for rural transit being much less per capita than urban. This anomaly stems primarily
Transportation       from the late entry to federal transit authorizations of federal formula funds for rural areas,
System (CARTS)       and is not based on the relative merits of each program. While federal rural transit funding
                     has made some significant gains in the last 2 reauthorizations, it still lags behind when
                     funding is compared to small urban funding on a per capita basis. Using the figures
                     provided in the TTI presentation for population and the FTA Apportionments as published in
                     the December 20 Federal Register the per capita federal funding for urban transit is $9.61
                     ($33,863,274/3,522,467) and for rural transit $4.94 ($28,379,729/5,738,107). This is not a
                     true reflection of the per capita investment though, as all of the 5307 dollars go the UTDs,
                     but that is not the case with RTDs. If you take the high figure that PTAC recommends as
                     the “new” formula funding level ($20 million) the net federal funding per capita for rural is
                     only $3.48. Taking the current cap that limits the RTD funding formula to $13 million that
                     was used in the 2006 allocations for RTDs the per capita number goes down to only $2.27,
                     less than ¼ of the per capita investment made for small urban. It is not equitable to further
                     reduce funds to RTDs in light of the significantly lower federal investment per capita. In
                     fact, if any change is made it should be to increase the RTDs share of the state funds to
                     equalize the disparity that exists.
                     For comparison purposes let’s follow that scenario to see what the numbers should be. We
                     will assume for this exercise that the higher ($20 million) figure is available to RTDs. You
                     will note in the figure below that even if ALL of the state appropriation was given to the
                     RTDs, the total per capita investment for the RTDs would still lag behind the UTDs. The
                     RTDs do not need any more reductions, and the UTDs cannot justify any increases at the
                     RTDs expense.

                      population          5,738,107
                      population          3,522,467

                                         rural         urban
                      Federal            20,000,000        33,863,274
                      State              28,741,000                 0
                      Total              48,741,000        33,863,274
                      Per Capita               $8.49            $9.61

                     Moving in the space of one year from an 80/20 to a 50/50 ratio on need vs. performance is
                     too rapid a transition. It is also premature to put more reliance on performance prior to
                     establishing a credible reporting and data verification process, when it is appears that
                     discrepancies now exist in the data reported and used to determine funding allocations. An
                     objective review of the reliability and accuracy of the data and reporting requirements now
                     in place is an essential step prior to adjusting the ratios, so we can really try to improve
                     performance. The review can be followed up with recommendations to uniformly collect
                     and report performance measures that directly relate to those used to measure the
                     performance standards selected for funding decisions. Let’s make sure we do it right, and
                     that we set up a logical order of steps to do so. The object is to improve performance, so
                     we need to be sure we know how to measure it uniformly, and give the providers an
                     incentive to improve, and an avenue with which to do so. That does not exist now as too
                     much confusion exists on the performance criteria and how they relate to day to day

                     It is reasonable to expect that each local government should have a financial interest in the
                     transit provided in their respective jurisdictions. But to require that providers match state
                     dollars with local dollars (state dollars that were originally appropriated to make sure we
                     could match all the federal dollars available to out state) would set up a circular calculation
                     that would be difficult to manage and set up accounting complications that do not seem

2/5/2006                                                                                                           5
Location         Comment (If the Comment is in the form of a question, the answer follows)
                 necessary. If PTAC wants to set a minimum local investment, then it should devise a way
                 to do that directly, not set up a new matching program that would be difficult for both the
                 state and the providers to administer.

                 General comment: If the PTAC were the doctors and the RTDs the patient it would be my
                 observation that the doctors commenced to operating prior to arriving at a diagnosis. The
                 RTDs are now in their 3rd surgery and I hold fading hope of their recovery from these
                 ministrations. With the significant changes in the Medicaid RFP, the emergence of the
                 regional planning processes and the day to day requirements of getting service on the
                 street all RTDs are challenged. When will we stop and take a broader look at things and try
                 to find ways to foster public transportation in rural areas? It does not seem a climate for
                 that now exists.

Beverly Lutz,    Very well said!!! [Reference to comments above from Tyler]
AACOG             I think they need to leave things alone so we can digest the last formula changes. This is
                 way to many changes at one time...and they still expect us to pay before we receive
                 funds...when our funds may change at any time..!!!
                  Leave things are they are and help us get everyone to the level of funding that they should
                 be first.
J.R. Salazar,    1) CTRTD is opposed to the inclusion of a local match requirement.
Central Texas    This would be detrimental to Rural agencies whose county and local governments simply
RTD              do not have adequate funding to provide local match
City And Rural   for Transit Districts.
                 2) Recommend that an adequate reporting system be in place prior to the implementation
                 of the 50/50 split for performance measures for Rural
                 Transit Districts. Recommend a period to phase in performance

                 3) CTRTD feels that prior to changing the split between Rurals and Urbans to 60/40 from
                 65/35, all Rural Transit Districts should be assured that the significant increase in federal
                 funds will result in a net positive gain for all Rural transit Districts. We do not feel that any
                 Rural transit district should lose funding when the federal government clearly supported the
                 need for increased services/funding in rural areas.
Ven Hammonds,    I appreciate very much the VTC presentation by Linda, Jeff, and Kelly. As always, very
Texoma Area      professionally done. I regret attendance was not greater, probably a result of too many
Paratransit      things going on right now ( MEDICAID RFP, everyone looking for federal FY 06 funds,
System (TAPS)    Triennial Reviews, Regional Coordination Planning, TxDOT Semi Annual Meeting, and oh
                 yes, another formula change). The efforts to insure operator participation, or at least to
                 inform operators is greatly appreciated.
                 In addition to those questions and issues I raised verbally at the end of the VTC, I have to
                 agree with the points raised and submitted via e-mail by my colleagues Norm from Tyler
                 and Dave Marsh. For emphasis I will list concerns I have

                 Too many and too frequent changes have made it virtually impossible to accomplish
                 meaningful transit planning. Rural and very small urban transit systems operations are
                 being negatively impacted. As a former high level Department of Defense planning and
                 programming officer, and one who also spent many years executing military plans from
                 concept to specific tactical operations plans, I learned to always maintain a rigid state of
                 flexibility. Changes are necessary, even vital, but those setting policy and guidance must be
                 careful to insure the changes that are made are given time to become effective before the
                 next set of changes are promulgated, or chaos results. We just changed funds allocations
                 formulae last year and new changes are coming. That is probably proper or at least
                 necessary. However, going from 80/20% "need/performance" to 50/50% all at once,
                 without clear understanding of and reliable gathering and reporting of supporting data, will
                 lead to something less that full understanding, support, and desired results. I recommend
                 at a minimum some period of transitioning from 80/20% to 50/50%. At a maximum I

2/5/2006                                                                                                        6
Location       Comment (If the Comment is in the form of a question, the answer follows)
               recommend investigation of a national industry standard of any similar practice (of 50/50%
               for allocating available funds) and at least the consideration of possible conflict of interest of
               those making the recommendation as suggested. Does any other state allocate funds
               50/50? Fifty percent funds allocation based on performance seems way too heavily
               weighted to me. Performance is fine, I personally spent most of my life in an intensely
               performance driven career. However, our business is different. We are more than a
               business that provides lane miles of concrete and bridges. Sometimes we really have an
               obligation to provide a very inefficient ride for Mrs. Smith who lives way outside of town,
               who has no local family to get her to dialysis three times a week. Or perhaps I'm wrong.
               Maybe that is no longer our job, because that is not an efficient or effective way to provide
               public transportation services. We need to be careful that we do not place too much
               emphasis on the performance, the effectiveness and efficiency and lose sight of what we
               are being told by the other side of PTN...that we are supposed to be balancing our
               "systems" service approach with our "client" service approach to service delivery. THERE

               While I operate both a small urban and a rural transit system, I support a 65/35% split of
               available state transit funds. With greater federal Section 5311 Rural transit funds
               apportioned to Texas, a greater, not lesser, need for rural state transit funds is present to
               help provide the required local match for the increased rural federal funds. Whether we
               wish it or not, the facts are that small urban cities are or have been more capable of
               providing local financial assistance for public transit that smaller rural towns and counties
               for rural public transit. Without first changing state revenue sharing statutes to provide
               greater revenues for rural towns and counties, my opinion is that we run the risk of either
               turning back unused federal funds or seeing greater federal funds being allocated to the
               largest rural or small urban transit systems based only upon ability to come up with local
               matching funds.

               Federal Funds require local matching funds. Local matching funds for federal transit funds
               can include those funds provided by the state if the state funds do not include federal transit
               funds. I do not agree that state transit funds should also require local matching funds. My
               opinion is that there is already too much Washington and Austin "control" of locally
               generated revenues. This is the heart of the donor state issue at the national level and the
               argument is equally valid here at home. The state public transit revenues are local tax
               revenues that should be returned to the cities and counties to provide services and match
               those federal funds provided by Congress for the same specific purpose, period. We have
               enough accounting problems already, we do not need any added to our plate now.

               Local match for state match, local match for federal funds, MEDICAID RFP outside of the
               Regional Coordinated Planning process (strikes many as TxDOT not following their own
               new policy! How is that coordinating?) New formula changes, going to 50% performance for
               allocation of funds, new performance measures, a new SAFETEA-LU, new federal
               programs for JARC, New Freedoms, etc. etc. For very small Small Urban and Rural
               transits, the number of changes and the rate of change is about to the point of
               unmanageable. We do not have the staff and therefore the ability to absorb, even though
               we understand the necessity for change. Therefore many feel like victims. There are limits
               if we are to avoid chaos and progress with meaningful change. I don't know who, but I
               totally agree with whomever once said : "Change is inevitable, Progress is not." We need
               to make sure what we are about is progress, not change for change sake.

Judy Phelps,   Changes are taking place in communities throughout Texas - aging population, population
Amarillo       density, income, etc... We can all agree:
                 The amount of funds to provide public transportation is inadequate.
                 Passengers must endure long headways on the fixed route and paratransit.

2/5/2006                                                                                                       7
Location          Comment (If the Comment is in the form of a question, the answer follows)
                    Public transportation is important.
                    Public transportation providers can not maintain current service levels if funds are cut.

                  If TXDOT desires a formula that will encourage each agency to perform better, develop
                  goals specifically designed for that agency that will address problem areas. For example, if
                  you take the other approach and use passenger trips (or miles or farebox revenue, etc...)
                  no matter how hard my staff and I work at Amarillo City Transit, we will never be able to
                  compete with Laredo and the number of trips they can provide simply because of Amarillo's
                  geographic location.

                  If you must consider performance measures, then measure each provider against
                  themselves. Even this approach is not without its flaws and will not give a true picture of
                  performance. There are many factors that will affect the cost of providing public
                  transportation (on a day to day basis) that is out of control of the provider. Factors such as
                  fuel prices, vehicle maintenance costs (which has a direct relationship according to the age
                  of the fleet), employment in the community and agency funding levels within the community
                  just to name a few.

                  I realize that TXDOT is also interested in agencies that are successful in accumulating
                  additional operating and capital funds thru contributions in the community. For example, an
                  agency would be rewarded if they successfully negotiated a contract with a manufacturing
                  plant (or other entity) that would pay a transportation provider to shuttle their workers to and
                  from the plant (or other entity). Once again, using these types of programs only reward
                  communities that have those opportunities and punishes communities that do not have
                  those types of employers in their service area.

                  The City of Amarillo's local match has more than doubled over the past few years. The
                  local match increase coupled with an increase in the fuel budget (last year Amarillo City
                  Transit's fuel budget was more than $150,000 over budget) has put public transportation in
                  a precarious situation.

                  Potter County has the highest mortality rate in Texas for counties with a population of
                  100,000 or greater. Nearly 20% of citizens in Potter County live 100% below the poverty
                  level. The state average is 15.4%. 12.6% of Amarillo's population is over 65 and the state
                  average is 9.9%. There are 37,182 persons with disabilities in Amarillo (22,148 in Potter
                  County and 15,034 in Randall County). A survey conducted by Amarillo's Public Health
                  Department found that 21% of their clients ride public transportation in order to access their
                  services. These statistics underscore the importance of public transportation to the citizens
                  of Amarillo and their lack of resources.

                  Many of Amarillo's citizens are among the poorest in the state and many have significant
                  health problems. Because of these issues, many of Amarillo, Texas's poorest citizens are
                  unable to afford a car, insurance, upkeep and fuel. This translates into a true dependence,
                  based on need, for public transportation.

                  In closing, I recommend that you use the funding distribution used by Congress - when
                  Federal public transportation dollars are distributed and printed in the Federal Register. Do
                  not compare one system to another - every public transportation provider operates in a
                  unique environment.

Jacque Wolske,    Ditto comments by Amarillo
Heart of Texas
Robert Wood,      Thank you for allowing us to comment on the new formula for the rural and specifically the
Sherman-Denison   small urban (<200,000 pop) transit systems in TX.
Texoma COG        It was evident by the 77 page slide show that a lot of effort has gone into these decisions.

2/5/2006                                                                                                         8
Location   Comment (If the Comment is in the form of a question, the answer follows)
           However I would like to make a few observations, as the smallest (solely) Texas urban

           First, I would tend to agree with what Norman C. Schenck of Tyler Transit System has said
           in his e-mail. Unfortunately, I am a little exacerbated by the quick deadline to respond to
           the PTAC meeting.

           1.     I am not sure why is there a problem with transit system data. During the video
           meeting a question was raised why this performance data could not come from the NTD,
           since most everyone urban area with 12 or more vehicles must report. The answer given
           was that “some” transit agencies do not report to the NTD. The solution calls for every
           agency to be burdened with providing TxDOT with its particular data needs. Why not just
           ask those who are currently not reporting to report the needed NTD to TxDOT? The
           solution provided by TxDOT seems to make work for all the majority. I thought the goal
           was to increase efficiency? Now does more data reporting (i.e. paperwork) help meet that
           goal? The ones who will now have to give the NTD type data would have to give it in either
           solution, but by using already available NTD data “should” reduce needless paperwork for
           the majority.
           (Response: The urban providers who report National Transit Database data should be able
           to report the same data for TxDOT performance reports. The intent of TxDOT is to use
           comparable if not identical data. Historically, rural providers do not report NTD data. Rural
           providers are the majority of transit providers receiving funds.)

           2.     This new formula shows vast swings in funding allocations. Some agencies will
           receive “more than a 100% increase” while others will receive a 50% decrease. This
           seems a little extortionate. Simple statistical analysis would suggest that something may
           be wrong with a formula or data which provides such great disparity in outcome. But I think
           that everybody knows that on more than one occasion transit funding has seemed a little
           odd. So I applaud the effort to correct the method, I just wonder about the means getting to
           the desired “acceptable” allocations.

           Naturally I was concerned after I heard from TxDOT that the Sherman - Denison urban area
           might receive a 10% reduction for each of the next 5 years 50%, based on this new
           formula. It is unfortunate that the small urban transits have not even seen the data from
           this years (FY2006) allocations. So I was motivated to looked deeper at this formula; after
           doing so it seems to be inherently flawed in its allocation methods.

           Please let me explain. And yes, I do know a little about math and statistical analysis having
           a Bachelor’s degree in Industrial Engineering and an Masters in Business Administration. I
           understand that you can “make” the numbers work for you, but I also know that basic
           mathematical principles should not be violated. We seem to be comparing apples and
           oranges: They are both fruits but....are we comparing fixed route to demand response, high
           density areas vs. lower density areas.........some combination in between?

           First a fact: The Census Bureau decides the geographical area for federal transit funding,
           not the cities, not even TxDOT. Yes, I know there is some boundary fudging going on, in
           order to better serve the citizens of Texas.

           3.   So, lets look at a geographical example using the new formula.

           Now, according to page 49 of your slide presentation, 35 % of the formula allocation will be
           based on passengers / revenue mile. But how does this account for differing geographical
           size (i.e. one location may be required to travel greater distances for the same basic trip:
           One city may have a less dense population)? This example is somewhat similar to
           Gorden’s example of cutting Mrs. Smith’s trip because it requires the agency to travel
           longer distances and thus penalizes that agency just because they might have to travel
           longer on any given trip.

2/5/2006                                                                                                9
Location          Comment (If the Comment is in the form of a question, the answer follows)
                  But the problem goes deeper than that.

                  Lets say in City A, there are 5 passengers to be pick up in one (1) mile (Note: I may have
                  misunderstood something but given the time restriction on commenting, I must go with what
                  I heard presented at the video conference), hence we have 5 passengers / 1 revenue
                  mile. Giving what appears to be a score of 5 (5 ÷ 1).

                  Now if City B has a larger geographical boundary as determined by the Census Bureau,
                  you might have to travel 2 miles to pick up the same 5 passengers, with all other variables
                  equal. Then according to the new formula City B will have 2.5 score (5 ÷ 2). Therefore
                  City A receives what looks like a 2 ½ times better score or performance - for no other
                  apparent reason other than one area is geographically smaller than the other. Therefore it
                  would appear that less dense cities may be penalized under this formula. Urban density
                  data may be found at:

                  But it does not stop there, since City B had to travel further, it has increase operating costs
                  which may affect other “efficiency” ratings. Worse City B can do nothing about its Census

                  4. Then there is the part about local match. In addition to Norman’s comments, it is hard
                  to justify higher taxes, so I was surprised that TxDOT wants to force the local governments
                  to raise taxes (or take $ from some other program) in order to meet some unspecified
                  criteria by including a requirement for local match for state transit $. 25% of the formula =
                  local funds / operating expense. Since City B has higher operating costs - again not by its
                  own design - for a less dense area, its proportional (i.e. same amount of funds per capita)
                  local match will not be properly accounted for. City B local match formula scoring will be
                  diluted because of higher operating costs, which further discriminates against City B.
                  Indeed I wonder if any formula base on local funds will pass Environmental Justice issues
                  because poorer urban areas (i.e. lower medium income) will be discriminated against
                  because they did not contribute as much local match as richer areas. Isn’t this the whole
                  issue behind the Robin hood educational mess.

                  Indeed given the difference in geographical density it is even statistically possible for City A
                  with its higher density and less operating costs to actually receive a higher score than City
                  B even if City B contributes more of its tax revenue (as a percentage) towards public
                  transit. If by some chance TxDOT feels that the Census formula somehow averages out
                  and makes each urban area of the same density (which it does not) then why change the
                  federal Census funding formula in the first place?

                  Again, wishing we had more time to discuss this ( < 72 business hours - got to travel to
                  Austin for the TxDOT PTN meeting).
                  Thank you.
Norman Schenck,   Reading this great analysis makes we wonder why we can’t leave well enough alone for a
Tyler             few years. We really don’t know how the current formula will work out in time. I know we
                  had some issues that needed adjustments, but wow, to keep changing every year makes
                  planning really difficult.

                  Remember, I came from Alabama with no state support. So I may show concern about
                  these changes, but I really appreciate the support the state gives public transit, both at the
                  district level with our PTC’s and the state staff.

Roxanne           We have a problem with the 5 year transition period being removed. Prior to the 5 year
McKinley,         Transition Period, it would have taken ETCOG 15 years to be fully funded. If this is
East Texas COG    removed, what will happen? With the removal of the 5 year transition, there is a cap of 20
(ETCOG)           on annual adjustments.

2/5/2006                                                                                                       10
Location           Comment (If the Comment is in the form of a question, the answer follows)
                   If this is the case and ETCOG's annual current allocation (both Fed and State) is $788,231,
                   how many years would it take us to get to 100% funding?

                   We also agree with the many comments made at Friday's VTC on the 50% Need/50
                   Performance change. Everyones performance is based on the accuracy of reporting, yet
                   no training has been provided on the new reporting requirements. Are the numbers being
                   reported being audited by anyone? Trips, miles, operating expenses, local
                   revenue? Before we make the drastic jump from 80% Need/20 Performance to 50%
                   Need/50% Performance we need to make sure everyone is reporting the same thing.

                   Will Rural Operators be compared to themselves or other Operators?

                   Texas demographics are so varied, there is no comparison to North, South, East or West,
                   yet the need for Rural Public Transportation is needed in all areas. Mrs. Jones that needs
                   to go to the doctor in West Texas might need to travel 60 or 70 miles, yet the Mrs. Jones in
                   East Texas might need to travel 20 or 25 miles, no matter how far it is, we all need to get
                   our clients where they need to go.

                   Let us not forget who it is we are trying to serve, the Rural General Public.

Judy Phelps,       Can you please let us know how much money each system would gain/lose with this
Amarillo           formula (a table that would list the allocation for each city based on this formula)? We need
                   to know this information as soon as possible.
                   (Response: Preliminary data will be available after review by PTAC and verification by
                   PTN. A word of caution - all data for 2007 is preliminary subject to verification of
                   performance data reported for 2005 by providers. )

Rob Stephens,      We were unable to make comment during the teleconference due to technical difficulty and
Concho Valley      appreciate the opportunity to make comment at this time.
Council of
Governments        First and foremost we support and commend the efforts of TXDOT staff, members of PTAC
(CVCOG) and the    and the Transportation Commission for moving forward with discussions on how to improve
Concho Valley      transit services to our communities and applaud the effort to bring more equity in
Rural Transit      distributing scarce resources to the diverse and ever growing need in our communities.
District (CVRTD)   This is an incredible challenge that presents incredible opportunities; however, we have a
                   few concerns.

                   1.      It is our opinion that the most important single goal for formulary changes is to
                   encourage and reward local financial participation in the delivery of transit services in our
                   communities. Encouraging local participation helps our focus remain on growing the
                   resources available to transit in our communities while encouraging innovation,
                   entrepreneurship, accountability to our communities, trusting working relationships,
                   partnerships in decision making, and long term buy-in for the well being of our communities.

                   While this goal is mentioned in the proposed changes to the formula the urban performance
                   indicator is decreased from 33% to 25% and at the same time the small urban systems are
                   given extra state funds to offset the local participation requirement. We understand the
                   short term benefit to solve the small urban crisis and the challenge this represents;
                   however, this conceivably could be interpreted as a tactical (short term) victory but a
                   strategic (long term) error. In other words let's be careful not to construct a quick fix that
                   will only have to be revisited and repaired again next legislative session as we discover we
                   made a lateral move or a step backward from our principle goal. Increasing participation of
                   local governments and the addition of local funding to the formula increases the
                   effectiveness of the service by injecting accountability of the service to the local community
                   and local elected officials.

2/5/2006                                                                                                      11
Location   Comment (If the Comment is in the form of a question, the answer follows)
           Our focus should be finding ways to increase and diversify our financial commitments and
           share the responsibility with our communities to deliver the best possible services. I believe
           our focus has shifted from providing effective and efficient service to creating an effective
           and efficient distribution formula that equitably distributes a finite resource to an infinite and
           diverse need. It would seem more constructive to reward and provide incentives to
           encourage local participation that will in the long run provide the state and the local
           communities what they really desire – "Better Service". And who better to decide what
           better service means in our communities than the people that live in our communities?

           2. It is hoped that great care will be taken to encourage efficiency and effectiveness and
           not discourage it by making changes to the formula for the sole purpose of consistency and
           tactical maneuvering to gain short term relief.

           An example would be the proposed split of the small urban systems in the panhandle and
           the lower Rio Grande Valley for consistency purposes. On the surface this provides
           consistency in application of the formula (arguably effectiveness and efficiency as well) and
           relief for the small urban systems to recover more from the limited state revenue resource
           in order to match federal funds with state money in the absence of local support. This
           inevitably buys time for the systems to continue to operate status quo. As a result, small
           urban systems are not encouraged or moved to explore other financing tools and
           mechanisms available to them (i.e. sales tax usage, local government participation, and or
           moving through the coordination continuum all the way to consolidation of services with
           other providers). Surely these systems and communities are not diverse and large enough
           as to require two sets of executive directors, managers, fiscal agents, dispatchers, and

           Inevitably, this action sends the wrong message to the transit provider and the local
           communities. How can we ask a state government and its sponsoring agency to financially
           support the planning, and service delivery options chosen by a local government if that
           local government is not willing to share the responsibility, define the roles of the stakeholder
           communities, and commit financially to the choices it makes? I have noted this approach
           from presenters in the last several years and the resulting response from the commission. I
           believe our position is shared.

           3. While performance measures are vital at some point to move into a more effective and
           efficient transit system, we are not now structured in a way which allows us to capture and
           validate the necessary measurements to assure any form of compliance with any standards

           I don't believe that we are ready for a 50% performance allocation. This is hard for me to
           say because we are committed to providing excellent service and have never been troubled
           by performance measures. If you will consider the transition period as a time to PLAN and
           make tough adjustments and to build an infrastructure and process that will accommodate
           reliable and accurate data to base funding decisions, I believe the end product will be worth
           waiting for. You have at this time a possible legacy affect that can possibly skew
           performance. Systems that have had more than adequate resources in comparison to their
           counterparts across the state could conceivably have an advantage in performance
           measure criterion. While of course those that have received less than adequate resources
           over the years will be at a disadvantage. Smaller steps toward the 50% performance
           weighting will offset any legacy affect and skewing of performance measurements.

           4. Finally in the big picture we should be working to spend the effort to expanding the
           resources and growing the pie by actively planning for comprehensive service delivery,
           encouraging local participation and funding looking for ways to coordinate and consolidate
           services and becoming more efficient while cautious that we don't spend a majority of our
           time developing a formula design and interpreting skill set while at the same time mustering
           political coalitions and will to adjust and tweak a fair and equitable distribution formula every
           two years. The customer could get lost in this maze.

2/5/2006                                                                                                 12
Location            Comment (If the Comment is in the form of a question, the answer follows)
Dietrich R.         ....the new formula to be based on 50% performance places fledgling small urbanized
Johnson,            transit systems at a complete disadvantage. I don't think you can compare larger transit
Longview            systems with small as well as start up systems. It is extremely important for agencies to be
                    creative and innovative as you think about providing transportation services to citizens -
                    what is not ok is setting systems up to fail - there has to be a better way to view this without
                    having to compete - there will never be a sense of equity regarding population, geographic
                    area and other related factors that are unique to each system and community. If
                    performance measures must be considered then allow each system to establish
                    performance goals and objectives that are related to the communities they serve - a
                    universal approach is not fair and it will not be an enhanced or value-added approach.
                    Everyone who's in the public transporation business is aware of a need to strategize and
                    create opportunities for maximum utilization of resouces. Please don't place
                    transit services in a positon to reward the big and powerful systems - each agency is
                    unique and let's find a way to fund transit services that are truly needed.

Lisa Cortinas,      Urban Formula Comments
Golden Crescent
Regional Planning   1. Performance Indicators
Commission          Local funds/operating expense 25% TOO HIGH            SUGGEST 15%
                    2. Urban Providers w/Population >200,000 If we are to continue allowing cities that
                    exceed 200,000 population to remain in the small-urban formula program some further
                    restrictions should apply. Some suggestions: Tier them out as well. Allow them to
                    continue receving funding but only for a designated time period, and funding should
                    transition out each year. ex: Year 1 - 100,000 Year 2 - 50,000 Year 3 $0.

                    3. Leave the funding allocation proportioned at 35% urban / 65% rural.

                    4. Changing the 80% need and 20% Performance to 50/50 is too great of a change. I
                    agree that 20% may not be much of an incentive, but to smaller operators it is. Since this
                    performance formula was only put into place this fiscal year, we don't have enough data
                    yet to gage whether it was effective or not. Why are we in a hurry to change it now?

2/5/2006                                                                                                         13

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