Data Collection Recommendations

Input on Section 5310 Performance Measures

The American Association of State Highway and Transportation Officials (AASHTO) appreciates the opportunity to submit comments on FTA’s “National Online Dialogue: Seeking Input on Section 5310 Performance Measures.” AASHTO represents the 50 State Departments of Transportation as well as the Transportation Departments in the District of Columbia and Puerto Rico.

 

In the spirit of providing comments based upon field experience and expertise on behalf of the states, AASHTO proposes the following recommendations for your consideration.

 

Overall Comment

 

AASHTO strongly recommends that FTA approach the collection of asset data and performance measures for the Section 5310 program at the designated recipient level. There are multiple reasons for this:

 

• Some state DOTs have one hundred or more Section 5310 subrecipients (An illustrative list includes: Arkansas-120, Illinois -225, Wisconsin-101, California-215). As directed by federal law, these subrecipients are often not transportation professionals, but non-profit agencies that provide transportation services in support of their core mission of meeting the basic needs of elderly individuals and individuals with disabilities – employment, training, medical care, shopping, community engagement, etc. Overwhelming them with data collection (and validation) effort may result in many of them leaving the program and a loss of services to the individuals the Section 5310 program is trying to assist. Those subrecipients that remain will find the data collection effort burdensome and difficult to meet, taking time away from their core mission of providing essential services to elderly individuals and individuals with disabilities.

• AASHTO is concerned that FTA has greatly underestimated the amount of staff effort that each designated recipient and the FTA will need to dedicate to adding Section 5310 subrecipient data to the National Transit Database (NTD) or other reporting venues used by FTA. Based on our discussions with State DOTs, many if not most Section 5310 subrecipients are not already subject to NTD reporting. (For example, in California less than 7% of their Section 5310 subrecipients are also 5311 subrecipients, South Carolina 12%, Wisconsin 4%. In Arkansas, only one of the 120 Section 5310 subrecipients is a 5311 subrecipient and in Montana none of its 17 Section 5310 subrecipients receives Section 5311 funds.)

• Most importantly the level of effort that would be needed for FTA to collect, validate and manage data for all subrecipients is not justified. The Section 5310 program is granted to a designated recipient. Each designated recipient should focus on the contributions of their individual subrecipients to their program as a whole. FTA should focus on the results delivered by each designated recipient and its data collection effort should reflect that focus.

 

Responses to Specific Questions

 

1. What are the three most valuable ways in which Section 5310 funds can be used to meet the transportation needs of seniors and people with disabilities?

 

Actual use of the funds (i.e., exactly how the funds are programmed – operating assistance, vehicles, etc.) depends on the location and should be determined by each designated recipient with its subrecipients.

 

The two most valuable overall uses of the funds are:

1) Provide essential transit services in areas where there is no public transportation and

2) Provide supplemental transit services in areas where there is public transportation but it is unavailable, insufficient, or inappropriate.

 

2. What performance measures best reflect the value and benefits of the Section 5310 program (e.g., number of customers served, types of projects funded, increased ridership, increased capacity, number of trips, increased service via expanded or additional routes, number of accessible vehicles, expanded personal mobility defined as individuals being able to get to more activities and/or additional support to customers)?

 

AASHTO recommends FTA develop measures that show – at the designated recipient level – how their Section 5310 funded programs fills in gaps and/or supplements transit options available for elderly individuals and individuals with disabilities in addition to what is made possible through the two formula programs (Sections 5307 and 5311). In other words, measures that show how the services funded by the designated recipient as a whole, provide essential transit services in the designated recipient’s area either because public transportation is unavailable and/or the available public transportation is insufficient or inappropriate. Specific ideas on how to approach performance measurement of this program are provided in our response to question 4.b.

 

Under any set of performance measures, FTA would collect the needed data from designated recipients only, i.e., states for the rural and small urban areas, and large urban agencies for their urbanized areas. FTA should focus on the outcomes of total programs each designated recipient delivers as a whole in terms of adding transportation options that would not be available absent the Section 5310 program. Measurement and evaluation of the contributions of individual subrecipients should remain the responsibility of the designated recipient.

 

2.a. If you receive Section 5310 funds either directly or indirectly, what impact has the program had on your passengers’/clients’ mobility options?

2.b. Does your organization or agency already collect and report performance measures not currently required by FTA, and if so, what are they and would you recommend these for other Section 5310 grantees?

 

AASHTO defers to the comments of individual designated recipients and subrecipients

 

3. Please describe the extent to which your agency has or would be able to collect data to report on the following performance measures:

a) Increased geographic service area;

b) Improved quality of transportation service provided;

c) Increased hours of service for seniors and people with disabilities;

d) Increased ridership (i.e., number of rides as measured by one-way trips); and

e) Increased accessibility (e.g., increased number of accessible vehicles).

 

FTA should not attempt to collect this information at the subrecipient level. This data should be collected at the designated recipient level. FTA should develop “definitions/guidance” for these measures and then place the obligation on each designated recipient to apply those definitions and collect and validate the data and roll it up for a total recipient report. Considerable judgment will have to be used to determine the validity of each subrecipient’s data and the designated recipient may need to correct/adjust (or even disallow) subrecipient data before rolling it up for the designated recipient’s entire area. Of the list above, we believe ridership and number of accessible vehicles will be possible to collect and validate. In our response to 4.b. we also suggest a way to approach geographic coverage, however we anticipate great difficulty in collecting that data in a consistent manner.

 

As our response to 4.b. indicates, the Section 5310 program should be measured in terms of how it adds to/supplements the two formula programs. It is important to note that FTA should not anticipate increases in Section 5310 ridership, geographic coverage, accessible vehicles, etc. over time. For State DOTs, this program sustains existing services; expansion should not be expected without increased funding. In addition, Section 5310 transportation service is funded, in a large part, with non FTA funds, so, overall transportation service is impacted by the level of funds available from other non FTA funds.

 

4. Should FTA combine the reporting requirements of Section 5335(c) into a single requirement for recipients of Section 5310? The proposed method would use the National Transit Database (NTD) system for recipients of Section 5310, Section 5311, or Section 5307 to report on behalf of their sub-recipients.

 

AASHTO does not support combining all of the performance measure related and asset/ inventory reporting requirements into a single NTD reporting requirement for the Section 5310 program. Section 5310 NTD reporting should be narrow in scope and limited to data directly and exclusively related to the language in Section 5335(c), specifically “transit asset inventory and (if available) condition assessment conducted by the recipient.” All NTD reporting should be rolled up at and reported as a total for each designated recipient. As noted in our overall comments, there are states with over 200 subrecipients, many of which are not subject to NTD reporting now. AASHTO believes FTA is underestimating the significant additional burden that will be placed on itself and its designated recipients to begin NTD reporting at the subrecipient level for the Section 5310 program. Performance measurement reporting should remain outside of NTD.

 

4.a. If not, what approach should FTA consider for implementing the requirements of Section 5335(c)?

 

Section 5335(c) requirements can be met by requiring designated recipients to report information rolled up at the designated recipient level. By way of illustration, the data to be reported in NTD by each designated recipient on an annual basis would be along these lines of:

 

1) Annual dollar amount of Section 5310 funds invested:

a) vehicles

b) construction of new facilities

c) expansion, improvement or rehab of existing facilities

d) equipment

e) mobility management

f) operating assistance

g) contracted services

2) Total number of active (remaining useful life) vehicles in the Section 5310 funded fleet (but not by vehicle type)

a) Percent accessible

3) Average age and miles of the active (remaining useful life) Section 5310 funded fleet

 

In its comments on the FTA’s National Public Transportation Safety Plan, Public Transportation Agency Safety Plan and Public Transportation Safety Certification Training Program; Transit Asset Management” Advance Notice of Proposed Rulemaking (ANPRM), AASHTO recommended that State of Good Repair be limited to revenue vehicles, defined as “fit for purpose” and measured by vehicle age and/or miles. Our recommendations (2) and (3) above for Section 5310 NTD asset reporting are consistent with the approach we recommended for the transit asset management rulemaking.

 

4.b. If not, what approach should FTA consider in making recommendations to Congress on collecting quantitative and qualitative data to support performance measurers for the Section 5310 program?

 

Annual performance reporting should be done at the designated recipient level and should remain outside of NTD. In response to the specific data suggested by Congress under Section 5310(h), AASHTO suggests annual performance reports along these lines:

 

Ridership

 

Total annual ridership for services supported by the designated recipients Section 5310 program, excluding ridership already reported under Section 5311 and 5307 program.

 

Accessibility Improvements

 

Total dollar amount invested by the designated recipient in each of the following accessibility improvements (subject to further definition by FTA), in the reporting year:

• Purchase of ADA accessible vehicles to replace existing non-ADA accessible vehicles that have reached their useful life.

• Modification of an existing vehicle already in service to make it more accessible, including addition of lifts, changing 600 pound capacity lifts to 1000 pound capacity lifts and other technologies (such as automated announcement technology).

• Physical Improvements, other than vehicles, i.e., additions or changes to transportation facilities, sidewalks, or technology that impact availability of transportation services as a result of project implemented in the current reporting year.

 

Geographic Coverage

 

The total geographic area for each designated recipient might be defined, calculated and reported as follows:

 

Definitions

 

1. Number of counties or communities within the designated recipient’s area that:

a. Have only Section 5310 supported transit services (i.e., no transit supported by Section 5311 or 5307).

b. Have supplemental Section 5310 supported transit services (i.e., the county or community) that is also served by fixed route and/or general public demand response service supported by Section 5311 or 5307.

2. Population of counties or communities within the designated recipient’s area that:

 

Calculations

 

3. If the Section 5310 supported service is county-wide, the total population of those counties with:

a. Only Section 5310 service

b. Supplemental Section 5310 service

4. If the Section 5310 supported service is less than county-wide, the total population of the communities (townships and/or municipalities) within the county that have

a. Only Section 5310 supported service

b. Supplemental Section 5310

 

Reporting

 

Total population calculated in (3) and (4) above and the percent that population is of the designated recipient’s total population (for their Section 5310 service area) would be the data that each designated recipient reports to NTD.

 

Service Times

 

AASHTO believes it would be impossible to collect valid service time information from each subrecipient. Regardless of any definition of service time that FTA generates, it will be difficult to apply that definition to hundreds of subrecipients, whose service times may vary considerably from subrecipient to subrecipient and even within a subrecipient from day to day. The data will not be consistent and will not be valid rolled up at the designated recipient or national level. Geographic coverage should be the key measure for the Section 5531 program nationwide. While service times might be used by a designated recipient to evaluate the effectiveness of a specific subrecipient’s program, it will be ineffective as a national program measure.

 

Service Quality

 

For Section 5310 services, geographic coverage, and accessibility of the vehicle are the most significant quality measures. Additional service quality measures are not needed and would difficult to collect and validate.

For Section 5310 services, geographic coverage, and accessibility of the vehicle are the most significant quality measures. Additional service quality measures are not needed and would difficult to collect and validate.

 

 

As always, AASHTO is available and willing to participate in additional dialogue with the FTA as you continue to develop approaches for your Report to Congress and in developing final guidance.

 

 

Sincerely,

 

 

Shailen Bhatt

Secretary, Delaware Department of Transportation

Chair, AASHTO Standing Committee on Public Transportation

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Idea No. 63