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Download this file (bus_rule_fria.pdf)Bus Rule FRIA

Final Revised Accessibility Guidelines for Buses, Over-the-Road Buses, and Vans (36 CFR Part 1192, Subpart B)

Nov. 9, 2016

Table of Contents

1. Executive Summary
2. Introduction
3. Background
 3.1. Existing Regulatory Requirements for Buses, Vans, and OTRBs
 3.2. Announcements on Fixed Route Buses – History of Compliance Issues
 3.3. Growing Use of Intelligent Transportation Systems by Transit Agencies
 3.4. Final Rule – New or Revised Accessibility Requirements with Cost Impacts
4. Overview of Cost Methodology
 4.1. Automated Stop Announcement Systems – Large Transit Agencies
 4.2. Other Accessibility Requirements - Over-the-Road Buses
 4.3. Small Business Analysis
5. Cost Model: Discussion of Significant Estimated Elements
 5.1. Vehicles
  5.1.1. Transit Agencies and Vehicles Used in Fixed-Route Bus Modes
  5.1.2. OTRBs
 5.2. Automated Announcement Systems
  5.2.1. Initial Costs – Onboard Equipment and Backend Systems
  5.2.2. Training and Other Labor Costs
  5.2.3. Operations & Maintenance
  5.2.4. Mid-Life Software Upgrade
 5.3. Over-the-Road Buses – New Requirements for Onboard Accessibility Features
  5.3.1. Unit Costs
  5.3.2. Likelihoods for Incurring Compliance Costs
  5.3.3. Operation & Maintenance
6. Benefits: A Qualitative & Quantitative Perspective
 6.1. General Discussion
 6.2. Threshold Analyses – Automated Announcement Systems
7. Costs: Results & Discussion
7.1. Summary of Results
 7.1.1. Annualized Costs of New Requirements
  7.1.2. Annualized Costs for Automated Announcement Systems under Primary Scenario  by Transit Agency Category (Tiers I, II & III)
  7.1.3. Annual Costs for New OTRB Accessibility Requirements
 7.2. Additional Cost Studies: Stress Tests for Selected Assumptions
  7.2.1. Unit Costs for Automated Announcement Systems
  7.2.2. Number of Large Transit Agencies Likely to Incur Costs under Automated  Announcement Systems Requirement
  7.2.3. Percentage of OTRBs Operating in Fixed Route Service
  7.2.4. Likelihoods of Changes that Incur OTRB Compliance Costs
8. Alternative Regulatory Approaches: Large Transit Agencies and the VOMS 100 Threshold
9. Small Business Analysis

Data Tables for Figures
End Notes

Appendices

Appendix A: Large Transit Agencies Over VOMS 100 Threshold for Fixed-Route Bus Modes (2014 NTD Data)
Appendix B – Unit Costs: Automated Announcement Systems
Appendix B-1: Initial (One-Time) Costs for Onboard Bus Equipment
Appendix B-2: Initial (One-Time) Costs for Backend System
Appendix B-3: Training Cost Assumptions/Labor Costs
Appendix B-4: Annual Costs – Operation & Maintenance
Appendix B-5: Mid-life Software Upgrade Costs
Appendix C – Unit Costs: New Accessibility Requirements for OTRBs
Appendix D – OTRB Accessibility Requirements: Likelihood of Incurring Costs
Appendix E-1: Annual Costs for Automated Announcement Systems under Primary Scenario by Transit Agency Category (Tiers I, II & III)
Appendix E-2: Annual Costs for Automated Announcement Systems under Low Scenario by Transit Agency Category (Tiers I, II & III)
Appendix E-3: Annual Costs for Automated Announcement Systems under High Scenario by Transit Agency Category (Tiers I, II & III)
Appendix F-1: Annual Costs for Over-the-Road Buses (OTRBs) under Primary Scenario
Appendix F-2: Annual Costs for Over-the-Road Buses (OTRBs) under Low Scenario
Appendix F-3: Annual Costs for Over-the-Road Buses (OTRBs) under High Scenario
Appendix G: Small Business Data
Appendix H: Federal Statistics on Prevalence of Certain Categories of Functional Disabilities, U.S. Non-Institutionalized Population
Appendix I: Data Sources and Methodology for Threshold Analyses of Automated Announcement Systems
Appendix J: Key Characteristics of Transit Agencies Reporting Bus Modes of Service (2014 NTD Annual Data)

List of Tables

Table 1 – Total Number and Percentages of Small Businesses in Four OTRB-Related NAICS Codes
Table 2 – Assumed Characteristics of Large Transit Agencies Subject to Automated Announcement Requirement, by Category (Tiers I, I & III)
Table 3 – Assumed Characteristics of "New" Large Transit Agencies that Cross VOMS 100 Threshold during Regulatory Timeframe
Table 4 - Estimated Size of Total OTRB Fleet in the United States, 2015
Table 5 - Estimated Hourly Wages for Vehicle Operators and Mechanics
Table 6 - Estimated Annual Wages for IT/GIS Specialist and IT Project Manager
Table 7 - Estimated Mid-Life Software Upgrade Costs (Onboard Equipment & Backend Systems)
Table 8 – Per Vehicle Unit Costs for Equipment Related to New OTRB Accessibility Requirements
Table 9 – Likelihood of OTRB Incurring Compliance Costs under Each New Accessibility Requirement, Per Vehicle
Table 10 – Estimated Annual O&M Costs for new OTRB Accessibility Requirements
Table 11 – Estimated Population Ranges for Certain Functional Disability Categories among U.S. Non-Institutionalized Persons Derived from Census Bureau and CDC Disability Statistics
Table 12 Annualized Cost of Revised Accessibility Guidelines for Buses, Vans, and OTRBs, All Regulatory Years (3% and 7% Discount Rates)
Table 13 - Annualized Costs of Automated Announcement Systems Requirement for Large Transit Agencies (Tiers I, II & III)
Table 14 – Per-Vehicle Annualized Costs of New OTRB Accessibility Requirements
Table 15 - Impact of Increase in Number of Large Transit Agencies Expected to Incur Compliance Costs under Automated Announcement Systems Requirement on Annualized Costs of Final Rule
Table 16 - Impact of Increase in Assumed Proportion of OTRBs Used in Fixed Route Service on Per-Vehicle Annualized Costs
Table 17 - Impact of Increase in Likelihoods that OTRBs Will Incur Compliance Costs under New Accessibility Requirements on Per-Vehicle Annualized Costs
Table 18: Comparison of Estimated Service Area Populations and Bus Ridership by Persons with Disabilities Using Three Different VOMS Thresholds (Based on 2014 NTD Annual Data)
Table 19: Estimated Federal Capital Funds Available for ADA-Related Bus Transit Projects by NTD Transit Agency Size Category (Based on 2014 NTD Data)
Table 20 - Comparative Annual Per-Firm Costs of New OTRB Accessibility Requirements
Table 21 – Comparative Ratios of Annual Per-Firm Costs to Payroll
Table 22 – Comparative Ratios of Annual Per-Firm Costs to Sales Receipts

List of Figures

Figure 1 - Annual Costs of Final Revised Accessibility Guidelines for Buses, Vans, and OTRBs (Nominal Dollars)
Figure 2 - Total Costs by Category of Accessibility Requirement (Nominal Dollars)
Figure 3 - Breakdown of Annual Costs of New OTRBs Accessibility Requirements under Primary Scenario (in Nominal Dollars), by Regulatory Year
Figure 4 - Impact of Increase in Unit Costs of Automated Announcement Systems Requirement on Per-Agency Annualized Costs (Stress Test #1)


1.   Executive Summary

This final regulatory assessment (Final RA) estimates the incremental costs of, and qualitatively describes the benefits from the U.S. Access Board (Access Board)'s final rule, which revises and updates accessibility guidelines for buses, over-the-road buses (OTRBs), and vans.  (In the final rule, buses, over-the-road buses, and vans are collectively referred to as "non-rail vehicles.")  The Americans with Disabilities Act (ADA) requires the Access Board to issue guidelines for transportation vehicles—including buses, over-the-road buses, and vans—to ensure that new and remanufactured vehicles are readily accessible to and usable by individuals with disabilities.   See 42 U.S.C. § 12204.  These guidelines serve as the basis for enforceable accessibility standards issued by the United States Department of Transportation (DOT).  Id. § 12149.

In 2010, the Access Board issued a notice of proposed rulemaking (NPRM) for proposed revisions to its existing transportation vehicle guidelines applicable to buses, vans, and OTRBs, which had been originally issued in 1991.  Most of the revisions reflected in the proposed rule were stylistic or editorial only, and were not expected to have a cost impact.  One requirement, however, was expected to have a cost impact—the requirement that transit agencies over a specified size threshold provide automated stop and route announcement systems on their large vehicles operating in fixed-route service.  To accompany the NPRM, the Access Board thus prepared a preliminary regulatory assessment (Preliminary RA) that evaluated the estimated costs of the automated announcement systems requirement.

After the close of the NPRM comment period, the Access Board reviewed and considered comments received in response to both the NPRM and the Preliminary RA.  Based on this review, revisions have been incorporated into the final rule.  A detailed discussion of the final rule and the Access Board's responses to comments relating to the substance of the proposed regulations can be found in the preamble to the final rule.  This Final RA incorporates changes to estimates, assumptions, and certain aspects of the cost methodology.  These changes were made, among other things, to address comments on the Preliminary RA, incorporate changes in the final rule, or refine modelling assumptions based on updated research or data sources.

The Final RA largely follows the cost methodology used in the Preliminary RA, with some adjustments.  In sum, the Final RA estimates the incremental costs of the automated announcement systems requirement, as well as four accessibility requirements (or sets of requirements) that are newly applicable to OTRBs—namely, identification of accessible seating and doorways, exterior destination/route signage, public address systems, and stop request systems.  Costs related to these latter four requirements were not assessed in the Preliminary RA, which only evaluated costs related to the proposed requirements for automated announcement systems.  Other revisions and updates reflected in the Final RA's cost methodology include: use of three (rather than two) cost scenarios—low, primary, and high—when estimating incremental costs of the final rule; incorporation of the four new OTRB-specific accessibility requirements into the cost model; evaluation of the cost impact of the automated announcement systems requirement using three size-based "tiers" (Tier I, II and III) for large transit agencies; and, addition of a small business analysis.  The Final RA also includes a qualitative discussion of the expected benefits of the final rule, given that, for a variety of reasons, benefits accruing from the final rule cannot be reliably monetized.

In terms of results, the Final RA shows that, over the studied 12-year regulatory timeframe, annualized incremental costs from the revised accessibility guidelines for non-rail vehicles are expected to range from $2.3 million to $8.0 million, depending on the cost scenario and discount rate.  Presented below is the annualized incremental cost of the revised guidelines under each of the three respective cost scenarios using 3% and 7% discount rates:

Discount Rate

Low Scenario ($millions)

Primary Scenario ($millions)

High Scenario ($millions)

3%

$2.6

$5.0

$8.0

7%

$2.3

$4.5

$7.2

The Final RA also assesses the economic impact of the final rule from several other cost perspectives, including: annualized costs of the automated announcement systems requirement, as well as the four new OTRB accessibility requirements.  First, with respect to automated announcement systems, annualized costs range from about $44,000 (for a Tier I agency under the low scenario) to about $430,000 (for a Tier III agency under the high scenario).  Under the primary scenario, which models what are considered to be the most likely set of cost assumptions, per-agency costs for announcement systems are estimated to be as follows: Tier I - $80,659; Tier II - $154,985; and, Tier III: $264,968.  Second, in terms of the new OTRB-specific accessibility requirements, the Final RA shows that the cost impact of these requirements are expected to be relatively modest, with annualized costs per vehicle expected to range from $549 (low scenario) to $1,513 (high scenario) at a 7% discount rate.  In light of this modest cost profile, the Final RA's small business analysis finds that, while the final rule will undoubtedly affect a substantial number of "small business"-sized OTRB firms (in light of small firms' predominance in the relevant transportation, charter, and sightseeing industry sectors), its economic impact is expected to be neither significant nor disproportionate relative to other firms.

Lastly, the Final RA describes the benefits of the final rule from a qualitative perspective, and, to the extent possible, discusses a general framework for understanding the potential pool of persons with disabilities who may directly benefit from one or more of the revised accessibility guidelines.  The revised accessibility guidelines in the final rule will directly benefit a significant number of Americans with disabilities by ensuring that public transit buses and OTRBs are accessible and usable.  By addressing communication barriers (and, to a lesser extent, access barriers) encountered on such vehicles by persons with vision, hearing, mobility, and cognitive impairments, the final rule will better enable persons with such disabilities to use these modes of transportation to work, pursue an education, access health care, worship, shop, or participate in recreational activities.  Other individuals or entities, such as transit agencies, will also likely experience benefits through, for example, improved customer satisfaction attributable to automated announcement systems.


   2.   Introduction

The Access Board has prepared this final regulatory assessment (Final RA) to evaluate the likely costs and benefits of the agency's final revised accessibility guidelines for buses, over-the-road buses, and vans (final rule).  These final rules are the final step in the rulemaking process for revised guidelines for these three types of vehicles.

In July 2010, the Access Board formally began the process of updating its existing vehicle guidelines for buses, over-the-road buses, and vans by issuing a notice of proposed rulemaking.[1]  As noted in the NPRM, most of the revisions in the proposed rule were stylistic or editorial only, and were not expected to have an incremental cost impact.[2]  The Access Board did, however, propose a substantive change to the existing vehicle guidelines concerning stop and route announcements.  In sum, the NPRM proposed that transit agencies operating 100 or more buses in annual maximum service in fixed route systems (as reported in the National Transportation Database) be required to provide automated stop and route announcements on newly purchased, leased, or remanufactured large buses (i.e., buses over 25 feet in length) used in fixed route service with multiple designated stops.[3]  The Access Board, with the assistance of the Volpe National Transportation Systems Center (Volpe Center) through an inter-agency agreement, prepared a report with a preliminary assessment of the costs for the proposed new requirements for automated stop and route announcements, which was posted in the online regulatory docket (www.regulations.gov) and on the agency's website (www.access-board.gov).[4]  (Preliminary RA).  The public was given several months to submit comments on the proposed rule or Preliminary RA.  The Access Board also conducted several public hearings on the proposed rule.[5]

The Access Board reviewed and considered the comments received in response to both the NPRM and the Preliminary RA.  Based on this review, revisions have been incorporated into the final rule.  A detailed discussion of the final rule and the Access Board's responses to comments relating to the substance of the proposed regulations can be found in the preamble to the final rule.  This Final RA, as well, incorporates changes to estimates, assumptions, and certain aspects of the cost methodology.  These changes were made, among other things, to address comments on the Preliminary RA, incorporate changes in the final rule, or refine modelling assumptions based on updated research or data sources.

The Final RA estimates the impact of the final rule in terms of incremental costs and benefits for covered entities and persons with disabilities.  Costs to affected transit agencies and OTRB firms from complying with the final rule are monetized on an incremental basis, meaning the impact of the final rule relative to a primary baseline of existing regulations or industry practice.  Benefits from the final rule to persons with disabilities (and others) are, due to methodological difficulties in monetization, described in qualitative terms.  In keeping with the Regulatory Flexibility Act (5 U.S.C. § 601), this final regulatory assessment also provides a final regulatory impact analysis, which evaluates whether the revised accessibility guidelines for non-rail vehicles set forth in the final rule are expected to have a substantial economic impact on a significant number of small entities.  Lastly, appendices to this Final RA present additional information about the underlying cost methodology—most particularly its data and assumptions—as well as likely annual (or annualized) costs to regulated entities under various cost scenarios.


   3.   Background

3.1.   Existing Regulatory Requirements for Buses, Vans, and OTRBs

The Americans with Disabilities Act (ADA) requires the Access Board to issue guidelines for transportation vehicles—including buses, over-the-road buses, and vans—to ensure that new and remanufactured vehicles are readily accessible to and usable by individuals with disabilities.   See 42 U.S.C. § 12204.  These guidelines serve as the basis for enforceable accessibility standards issued by the United States Department of Transportation (DOT) that apply to the acquisition of new, used, and remanufactured transportation vehicles, and the remanufacture of existing transportation vehicles covered by the ADA.  Id. § 12149.

The Access Board issued transportation vehicle accessibility guidelines in September 1991.  See 56 Fed. Reg. 45,530 (Sept. 6, 1991) (codified at 36 C.F.R. pt. 1192) [hereinafter, "1991 Vehicle Guidelines"].  As a general matter, the 1991 Vehicle Guidelines provide accessibility requirements for boarding and alighting, onboard circulation, wheelchair spaces and securement devices, priority seating, signage, stop request systems, and public address systems.  Of particular relevance to this regulatory assessment, the Guidelines require large buses (i.e., more than 22 feet in length) that operate in fixed route systems and make multiple stops to provide a public address system that permits the driver (or recorded or digitized speech message) to announce stops and to provide other passenger information.  See 36 C.F.R. §§ 1192.35, 1192.61.

The same day, DOT adopted the 1991 Vehicle Guidelines as enforceable accessibility standards.  See 56 Fed. Reg. 45,584 (Sept. 6, 1991) (codified at 49 C.F.R. pts. 37 & 38).  With respect to stop announcements, the DOT regulations—as with the 1991 Vehicle Guidelines—require large buses that operate in fixed route systems to announce stops and provide other passenger information via public address systems.  49 C.F.R. § 38.35; see also id. §§ 37.167(b) & (c).  However, the DOT regulations also provide additional specifications for stop and route announcements on fixed route systems, specifying that covered entities, at a minimum, audibly announce: stop requests by passengers with disabilities; transfer points, major intersections, and destinations; and, "intervals along a route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location."  49 C.F.R. § 37.167(b).  These requirements apply to both public transit agencies and private transit operators engaged in fixed route service.

In 1998, the Access Board and DOT issued a joint final rule amending their respective vehicle guidelines and standards to provide accessibility requirements for over-the-road buses.  See 63 Fed. Reg. 51,694 (Sept. 28 1998) (codified at 36 C.F.R. pt. 1192, subpt. G & 49 C.F.R. pt. 38, subpt. H) [hereinafter, "1998 Vehicle Guidelines"].  As with the existing regulations for buses and vans, the final rule for over-the-road buses specified accessibility requirements for boarding and alighting, onboard circulation, and wheelchair spaces and securement devices.  Unlike those existing regulations, however, the final rule for OTRBs did not require public address systems, stop request systems, or destination and route signs.

3.2.   Announcements on Fixed Route Buses – History of Compliance Issues

Since 1991, while stop and route identification announcements on buses in fixed route service have greatly benefited riders with disabilities, effective implementation of these requirements have proven to be a challenge for many transit entities.  Under existing regulations, buses operating in fixed route service can use either vehicle operators or automated messages to provide requisite stop and route information.  Transit agencies that use vehicle operators to announce stops and routes must train vehicle operators and systematically monitor their performance to ensure compliance.[6]  Consequently, transit agency announcement programs that primarily rely on operator-based announcements have proven to be both labor intensive and have a greater likelihood of experiencing system-wide compliance problems.[7]  Operators often fail to make announcements, or, when announcements are made, there are frequently problems with the clarity, audibility, or timeliness of such announcements.  Indeed, compliance reviews conducted by the Department of Transportation show that vehicle operator compliance with the existing regulatory requirements for announcements is rarely above 50 percent.[8]  Failure to provide required ADA stop and route announcements have also spawned numerous ADA lawsuits.[9]  In sum, despite the promulgation of mandatory standards for announcements on fixed route buses more than two decades ago, significant problems still persist.  Riders with disabilities and transportation researchers continue to identify inadequate stop and route announcements as significant impediments to the use of public bus transportation by persons with disabilities.[10]

3.3.   Growing Use of Intelligent Transportation Systems by Transit Agencies

Since the early 2000s, deployment of various advanced technologies in transportation—commonly referred to as "Intelligent Transportation Systems" (ITS)—has grown substantially.  ITS generally refers to "the application of advanced information and communications technology to surface transportation in order to achieve enhanced safety and mobility while reducing the environmental impact of transportation."[11]  For public transit systems, ITS deployments generally include a "core" set of applications for Automatic Vehicle Location (AVL)/Computer-Aided Dispatch (CAD) that facilitate management of fleet operations by providing real-time information on vehicle location.  In most modern AVL systems, system components include, at a minimum: central software and IT equipment used by dispatchers for management of operations; communications hardware; onboard computer (typically, with mobile data communications capabilities); and onboard Global Positioning System (GPS) receiver and antenna.[12]  ITS deployments, moreover, vary in their respective levels of complexity and options.  According to DOT annual statistics tracking ITS deployments nationally, as of 2013, nearly 90% of fixed route buses were equipped with AVL, which represented a 177.4% increase in AVL deployments since 2000.[13]

ITS/AVL deployments for public transit also now commonly include a range of additional functionalities—either as components integral to system-wide AVL procurement or later as modular or incremental AVL system upgrades—such as electronic fare payment, automatic passenger counters, real-time "customer facing" traveler information, vehicle maintenance monitoring, and incident management.[14]  Specifically, of particular relevance to this assessment, automated announcement systems and variable (or dynamic) message signs are two ITS/AVL applications increasingly being used by transit agencies for ADA onboard stop announcements and external route identification.  According to the annual Public Transportation Vehicle Database maintained by the American Public Transport Association (APTA), the number of fixed route buses that provide automated announcements has increased from 10% in 2001 to 69% in 2015.[15]

Automated announcement systems help ensure that required ADA stop and route announcements are made, and made consistently and clearly.  Automated announcement systems also lessen the need to rely on vehicle operators for compliance, and, thereby, allow operators to pay more focused attention on driving or other operational tasks.  To be sure, automated announcement systems—as with any IT system are not infallible.  System components may break down, announcements volume may need adjustment, or mistimed announcements may necessitate revisions to geocoded stop data.[16]  Moreover, automated announcement systems need to be installed and maintained properly to be effective, and agency personnel must be trained on use of such equipment (and what to do should the system malfunction).[17]  Nevertheless, both transportation studies and FTA compliance investigations over the past ten years strongly evidence that, on balance, automated stop and route announcement systems demonstrably outperform operator-based announcement programs in terms of both ADA compliance and benefits to persons with disabilities.[18]

3.4.   Final Rule – New or Revised Accessibility Requirements with Cost Impacts

The Access Board developed the final rule after careful review and consideration of comments received in response to the NPRM and the Preliminary RA.  As with the proposed rule, most of the revisions in the final rule (relative to the existing 1991 and 1998 Vehicle Guidelines) are stylistic or editorial only, and are not expected to have an incremental cost impact.  A side-by-side chart comparing the final rule with the existing 1991 and 1998 Vehicle Guidelines is available on the Access Board's website (www.access-board.gov).  This chart identifies accessibility requirements in the final rule that have been changed (relative to existing vehicle guidelines), classifies changes as either editorial or substantive, and, if substantive, notes whether or not a changed requirement is expected to have a monetary (incremental) impact.

As an initial matter, it bears emphasis that only new or revised requirements likely to have incremental costs are evaluated in the Final RA.  That is, some provisions in the final rule may be substantively different than the 1991 or 1998 Vehicle Guidelines, but are not expected to impose additional (new) costs relative to compliance costs under the existing regulations or industry practice.  For example, under the final rule, the maximum running slope for ramps deployed to roadways is 1:6, while the existing guidelines permit such ramps to have steeper slopes (i.e., 1:4 maximum).  Compare, e.g., T402.8.1 (final rule provision governing ramp slopes in roadway deployments) with 36 CFR 1192.23(c)((5) (existing ramp slope requirements for buses and vans), 1192.159(c)(5) (existing OTRB-related ramp slope requirements).  However, due to a host of considerations, the Access Board anticipates that this revised requirement for ramps will have minimal cost impact.  These considerations include: (i) the commercial availability of low floor non-rail vehicles equipped with 1:6 ramps, ranging in size from small cutaway buses to large, heavy-duty transit buses;[19] (ii) the commercial availability of compliant (1:6) ramps at lower cost than steeper ramps;[20] (iii) the existence of thousands of low floor non-rail vehicles equipped with 1:6 ramps already in service nationwide;[21] and (iv) the listing of 1:6 ramps as the default specification for large low floor buses in the current version of APTA's "Standard Bus Procurement Guidelines." [22]

In summary, there are only five requirements (or sets of requirements) in the final rule that are expected to have an incremental cost impact—one that applies to large non-rail vehicles generally, and the remainder relating to new accessibility requirements for OTRBs.[23]  First, with respect to large non-rail vehicles, the final rule—with some minor formatting and editorial changes—retains the same approach to automated announcement systems as the proposed rule.  That is, under the final rule, "large transit entities" (as defined) will be required to provide automated stop and route announcements on all vehicles used in fixed-route bus service with multiple designated stops.  See T215.3, T704.3, T704.5.  Such automated announcement systems must notify passengers of upcoming stops and provide identifying route information in both audible and visible fashion.  Id.  Large transit agencies, in turn, are defined in the final rule as public transportation providers operating 100 or more buses in annual maximum service in fixed-route bus modes, through either direct operation or contract, as provided in required data reporting in the National Transportation Database.  See T104.4 (defining "large transit entity"); see also 49 C.F.R. pt. 37 (regulations governing the DOT-administered National Transportation Database).  These requirements for automated announcement systems are new regulatory requirements.  As noted above, while existing DOT regulations mandate public and private entities operating vehicles in fixed route service make announcements for stops requested by an individual with a disability and for other specified route information (such as transfer points and major intersections), transit agencies are not required to equip their fixed route vehicles with automated announcement systems.  See discussion supra section 3.1; see also 49 C.F.R. § 37.167(b) (DOT regulatory provisions stop and route announcements).

Additionally, for OTRBs, the Access Board anticipates that four requirements (or sets of requirements) in the final rule may have incremental cost impacts.  These four requirements relate to:

  • Signage for Accessible Seating and Doorways: Wheelchair spaces and doorways with accessible boarding and alighting features must be identified by the International Symbol of Accessibility, and priority seats (which are required only on non-rail vehicles used in fixed-route service) must be identified by signs informing other passengers that such seats are for use persons with disabilities.  See T215.2.1, T215.2.2 & T215.2.3.  While these requirements for identification of accessible seating and doorways have been in effect for buses and vans since the issuance of the 1991 Vehicle Guidelines, they are new requirements for OTRBs.
  • Exterior Destination and Route Signs: Where destination or route signs are provided on the exterior of non-rail vehicles, such signs shall be located, at a minimum, on the front and boarding sides of the vehicle.  See T215.2.4, T702.  In other words, non-rail vehicles are not required to have destination/route signage on the exterior of the vehicle.  However, if exterior route or destination signage is provided, it must be located at both locations (rather than only, for example, on the front of the vehicle).  While this exterior signage requirement has been in effect for buses and vans since the issuance of the 1991 Vehicle Guidelines, this is a new requirement for OTRBs.
  • Public Address Systems: Large non-rail vehicles operating in fixed route service with multiple designated stops must provide public address systems that are capable of broadcasting onboard announcement messages to passengers.  See T215.3.1, T704.2.  While this requirement has been in effect for buses and vans since the issuance of the 1991 Vehicle Guidelines, this is a new requirement for OTRBs.
  • Stop Request Systems: Large vehicles operating in fixed route service with multiple designated stops and that stop on passenger request must provide stop request systems that afford audible and visible notification when passengers request to disembark.  See T215.3.3, T704.4.  While this requirement has been in effect for buses and vans since the issuance of the 1991 Vehicle Guidelines, this is a new requirement for OTRBs.

This Final RA estimates the incremental cost impact of, and qualitative benefits resulting from, these four requirements in the final rule that are newly applicable to OTRBs.  The Preliminary RA, it bears noting, assessed only the cost impact of the automated announcement systems requirements proposed in the NPRM.  At the time, our preliminary analysis indicated that the four new OTRB requirements would be either cost neutral or have costs not easily monetized.  However, subsequent research and other information suggested that these requirements would, in fact, have modest incremental costs that could be monetized.  Accordingly, the Final RA includes an evaluation of the economic impact of these four new OTRB requirements.


   4.   Overview of Cost Methodology

4.1.   Automated Stop Announcement Systems – Large Transit Agencies

For purposes of assessing the likely economic (cost) impact of the revised requirement for automated stop and route announcements, the Final RA breaks down covered large transit agencies (i.e., agencies operating 100 or more buses in annual maximum service as reported to the National Transit Database) into three "tiers" based on assumed fleet size –Tier I, II and III (with Tier I reflecting the smallest fleet size and Tier III the largest).  See infra Table 2 (listing assumed characteristics of each tier).  The Final RA then uses assumptions about the relevant characteristics of each of these three tiers of transit agencies—namely, the number of large buses, fixed routes, garages, vehicle operators, and mechanics per agency—along with estimates concerning the status and nature of current ITS deployments (if any) by these transit agencies, as the framework for modeling costs.

In addition to segregating covered transit agencies into these three size-based categories, the Final RA also employs several other notable approaches to modeling costs for automated announcement systems.  First, the Final RA uses separate "low," "medium," and "high" cost estimates for most of the estimated components in the cost calculus in order to better reflect the potential range of incremental costs attributable to the requirement for automated announcement systems.  Cost elements with L-M-H ranges include: onboard equipment; backend hardware; stop and announcement database development; backend system testing; initial training for vehicle operators and mechanics; ongoing operation and maintenance ("O&M") expenses; and mid-life equipment and software upgrades.  Generally speaking, the "medium" cost estimates collectively serve as the primary baseline scenario in the Final RA when calculating incremental costs, while the "low" and "high" cost estimates respectively provide the lower- and upper-bound cost projections.  Second, based on a 12-year average lifespan for most large, heavy-duty transit buses, the Final RA uses a 12-year regulatory cost (and benefits) time horizon, with covered transit entities assumed to replace an equal proportion (1/12th) of their non-rail vehicle fleet annually.[24]  While individual transit agencies may not replace a constant proportion of their bus fleet annually, an even distribution of fleet replacement provides a representative (i.e., average) approach when abstracting across all agencies at the national level.  Third, the analysis accounts for growth over time in the number of large transit agencies that would be affected by the revised requirement for automated announcement systems by assuming that, every third year during the regulatory timeframe, one transit agency would expand its fixed route buses fleet such that it would be deemed a large transit agency subject to the requirement for automated announcement systems.

Based on these modeling considerations, calculation of total annual costs for any particular tier/category of large transit agency in a given regulatory year follows a consistent pattern.  Total annual costs for each tier represents the sum of the following costs, as applicable: annual costs for onboard bus equipment; one-time costs for development and testing of backend IT systems (including announcement databases); initial training for non-rail vehicle operators and mechanics on automated announcement system; annual O&M costs (onboard equipment and announcement databases); and mid-life equipment/software upgrade costs.

The next step in the cost modeling process, after the completion of calculations for annual costs in any given year, is to assess annual costs against a primary baseline.  In this way, the resulting net costs appropriately reflect the incremental—rather than absolute—economic impact of the final rule.  With respect to the revised requirement for automated announcements, the primary baseline is based on a conservative assessment of current ITS practice among large transit agencies nationally.  Specifically, it is assumed large transit agencies that currently equip—or that have existing contracts or funding in place to equip—all newly acquired fixed route buses with automated announcement systems as part of an agency-wide ITS program will continue to do so in the future, and that such deployments are not attributable to the final rule.  (Ongoing pilot or trial programs aimed at testing automated announcement systems on a segment of an agency's fixed route fleet would not be considered a current announcement system deployment.)  Agencies that do not yet equip (or have firm plans to equip) their newly acquired fixed route buses with automated announcement systems, on the other hand, are assumed to acquire such systems on account of the final rule.

In sum, the foregoing represents the fundamentals of the Final RA's approach to modeling costs.  Based on this model, annual costs are calculated for each of the twelve "regulatory years" and, within each of these years, separately for each of the three (i.e., "high," "medium," and "low") cost scenarios.  (Annual costs estimates for each L-M-H cost scenario are generated by respectively indulging all applicable "high" cost assumptions, all "medium" cost assumptions, and all "low" cost assumptions.)  Annual cost totals for each year (and each L-M-H cost scenario) are presented as "rolled-up" costs for each category of large transit agency (i.e., Tiers I, II & III).  Additionally, the Final RA also presents a breakdown of annual costs for automated announcement systems under each L-M-H cost scenario for each of the three large transit agency tiers separately at 3% and 7% discount rates, as well as on an annualized basis.

4.2.   Other Accessibility Requirements - Over-the-Road Buses

The methodology for assessing the economic impact of the four new requirements for OTRBs largely mirrors the cost methodology discussed above for automated announcement systems.  Separate "low," "medium," and "high" unit cost assumptions are used to estimate costs relating to the revised requirements for identification of wheelchair spaces, exterior destination/route signage, public address systems, and stop request systems.  Annual O&M costs are assumed to be a fixed percentage of total annual OTRB equipment costs using an L-M-H range.  Similarly, covered OTRB agencies or companies are assumed to replace an equal proportion (1/12th) of their non-rail vehicle fleet annually.  In addition, the "medium" cost estimates collectively serve as the primary baseline scenario, while the "low" and "high" cost estimates respectively provide the lower- and upper-bound cost projections for OTRBs.

The main differences in the cost model for the revised requirements for OTRBs relate to assumptions about affected entities (primarily, OTRB firms), type of transportation service for which vehicles will be used, and typical features.  First, since some of the new requirements apply to all OTRBs (i.e., identification of wheelchair spaces and accessible doorways with the International Symbol of Accessibility (ISA), exterior destination/route signs) while others apply only to OTRBs used in fixed route service (i.e., signs for priority seats, public address systems, stop request systems), the model incorporates assumptions regarding likely use to estimate compliance costs.  For the requirements that exclusively apply to OTRBs used in fixed route service, only that segment of the total OTRB fleet nationally is assumed to incur related compliance costs.  Additionally, the analysis also accounts for growth over time by applying L-M-H annual growth rates to the total fleet of OTRBs used in fixed route service.  Second, the cost model incorporates assumptions about current practices in the OTRB manufacturing industry.  Specifically, unit costs for OTRBs are scaled by the estimated respective likelihoods that the four new accessibility features required by the final rule are typically present on newly manufactured (or refurbished) OTRBs.  Estimates for these likelihoods were developed based on information provided by OTRB manufacturers, as well as other publicly available information.  As with most other estimated cost model components, these assumed likelihoods are applied using L-M-H ranges.

4.3.   Small Business Analysis

As required by the Regulatory Flexibility Act (5 U.S.C. § 60 et. seq.) (RFA), as well as Executive Order 13,272 (Aug. 2002), the Final RA includes an evaluation of the economic (cost) impact of the final rule on small entities.[25]  While this small business assessment necessarily draws on the Final RA's "main" cost model, it also incorporates data specific to small businesses.  In sum, this small business analysis estimates the number of small entities to which the final rule will likely apply and assesses the likely economic (cost) impact of this rule.  Key assumptions and methodologies underlying the small business analysis are summarized below.

First, the Access Board has determined that of the three types of RFA-defined small entities[26]—namely, small businesses, small nonprofit organizations, and small governmental jurisdictions—only small firms that provide transportation services using OTRBs will be potentially impacted by the accessibility requirements in the final rule.  There are no nonprofit organizations, so far as the Access Board is aware, currently operating OTRBs in fixed route service in the United States.  Additionally, by limiting the scope of the automated announcement systems requirement to large transit agencies (i.e., transit agencies operating 100 or more buses in annual maximum service in fixed-route bus modes), the final rule excludes any small governmental jurisdictions to which such requirements might otherwise apply.  "Small governmental jurisdiction," as defined in the RFA, refers to "cities, counties, towns . . . or special districts, with a population of less than fifty thousand."  5 U.S.S. § 601(5).  Based on the current (2014) National Transit Database (NTD), all of the transit agencies that report operating 100 or more vehicles in annual maximum service (referred to as "VOMS") in fixed-route bus modes have service areas or urbanized area (UZA) populations over 50,000.[27]

Second, the Access Board has determined that private firms offering OTRB-provided transportation or other services are overwhelmingly small businesses.  The extent to which the final rule's new OTRB-related accessibility requirements will potentially affect small businesses was estimated using pertinent transportation-related classification codes in the 2012 North American Industry Classification System (NAICS) in conjunction with SBA-defined small business size standards.  Businesses often operate OTRBs for a variety of purposes, but predominant uses include: provision of fixed route passenger service within or among cities, passenger charter services, airport shuttle services, sightseeing tours, and packaged tours.[28]  While these services do not squarely align with any one classification in the 2012 NAICS, they best "map" to the following four 6-digit NAICS codes: 485113 (Bus and Other Motor Transit Systems); 485210 (Interurban and Rural Bus Transportation); 485510 (Charter Bus Industry); and 487110 (Scenic and Sightseeing Transportation, Land).[29]  The SBA-defined "small business" standard for the three NAICS codes in the transit/ground transportation sector (i.e., 485113, 485210, 485510) is $15 million in per-firm average annual receipts, while the small business size standard for the fourth NAICS code in the scenic/sightseeing transportation sector (i.e., 487110) is $7.5 million.[30]

Using the foregoing SBA-defined small business size standards, data were compiled from the 2012 U.S. Economic Census (released in June 2015) to determine the number of small OTRB firms within each of these four transportation-related NAICS codes.  A more detailed discussion of the methodology used in development of these small business statistics is provided in Appendix G.  In sum, the SBA/Economic Census data show that firms within these four transit/transportation/charter/sightseeing industry sectors are overwhelmingly small businesses.  The number and percentage of small businesses in each of the four NAICS codes are provided below in Table 1.

Table 1 – Total Number and Percentages of Small Businesses in Four OTRB-Related NAICS Codes
2012 NAICS CodeNAICS DescriptionTotal FirmsSmall Business FirmsSmall Business Firms
(% of Total Firms)

485113

Bus and Other Motor Vehicle Transit Systems

625

584

93.4%

485210

Interurban and Rural Bus Transportation

397

369

92.9%

485510

Charter Bus Industry

1,265

1,211

95.7%

487110

Scenic and Sightseeing Transportation, Land

543

517

95.2%

It bears noting that the four foregoing NAICS codes encompass transportation/charter/sightseeing services provided by vehicles other than OTRBs, such as trolley buses, transit buses, or historic rail cars.  In other words, these NAICS codes are not restricted to transportation services provided exclusively by OTRBs.  However, there are no NAICS codes dedicated solely to OTRB-provided transportation, charter, or sightseeing services.  Accordingly, despite their limitations, these four NAICS codes were adjudged to provide the best statistical framework (given current data limitations) for estimating the number of small firms that operate OTRBs and, thereby, may potentially incur compliance costs under the final rule.

Lastly, the Final RA's small business analysis incorporates data from the 2012 US Economic Census in one additional respect.  Data on sales receipts and payroll for businesses in the four NAICS codes were used to derive statistics on per-facility annual receipts and per-facility annual payrolls among "small firms" and "other firms" within these respective industry sectors.  (Because the US Economic Census data is presented in 2012 dollars, these data were "brought forward" to present dollars before these comparative per-facility receipts and payroll costs figures were derived.)  The Final RA's small business assessment then uses these statistics to aid in assessing the economic impact of the new OTRB-related accessibility requirements in the final rule on small OTRB firms.  The results from this small business analysis are presented in Section 9 below.


   5.   Cost Model: Discussion of Significant Estimated Elements

5.1.   Vehicles

5.1.1.   Transit Agencies and Vehicles Used in Fixed-Route Bus Modes

As noted above, the new requirement for automated announcement systems only applies to large transit agencies—that is, entities providing public transportation that operate 100 or more vehicles in fixed-route bus modes according to annual maximum service figures reported to the National Transportation Database (NTD) [hereinafter, "VOMS 100 threshold"].  Public transportation agencies that receive or benefit from federal formula grant programs for mass transportation in urbanized areas (49 U.S.C. § 5307) or rural areas (49 U.S.C. § 5311) are generally required to report specified financial and service data annually to the NTD.[31]  Of pertinence here, the NTD includes data for four modes of service that involve fixed-route buses: traditional transit-style buses (coded "MB"), bus rapid transit (coded "RB"), commuter buses (coded "CB"), and trolley buses (coded as "TB").  The NTD is administered by the Federal Transit Administration.

To estimate the likely incremental cost from the new automated announcement system requirement, it was first necessary to determine the universe of potentially affected transit agencies.  To this end, data from the 2014 NTD were downloaded that provide, among other things, each reporting entities' VOMS by mode of service.[32]  Because the NTD's VOMS data is reported, for each transit agency, separately by mode of service and type of service (i.e., direct operation or contractor-provided transportation), for each transit agency offering more than one type or mode of fixed-route bus service, VOMS were totaled across all relevant bus mode and services.  This 2014 NTD data show that there are 99 transit agencies currently meeting or exceeding the VOMS 100 threshold, thereby qualifying as "large transit agencies" under the final rule.  These transit agencies are identified in Appendix A.

Second, to develop a baseline against which to estimate incremental costs for the automated announcement requirements, information was gathered on the current prevalence of automated announcement systems (or CAD/AVL systems) among these large transit agencies.  For purposes of this Final RA, it is assumed that transit agencies that currently equip—or that have existing contracts or funding in place to equip—newly acquired vehicles operating in fixed-route bus service with automated announcement systems as part of an agency-wide ITS program will not incur incremental costs under the final rule.  Access Board staff conducted research using publicly available information from the websites of transit agencies, equipment vendors and manufacturers, and other transit industry-related organizations, as well as supplementary information provided through communications with transit agency representatives, to assess existing (or planned) deployment of automated stop announcement systems or CAD/AVL across these large transit agencies' respective bus fleets.

From this research, assumptions were developed about the likely "inventory" of fixed-route vehicles acquired in the future by these large transit agencies that would not be equipped with automated stop announcements (absent the final rule), as well as the size and other pertinent characteristics of the large transit agencies likely to acquire and operate these vehicles.  To provide a more refined picture of estimated costs to large transit agencies for automated announcements, these agencies are modelled using three prototypical categories (tiers) based on assumed VOMS for fixed-route bus service.  The assumed bus fleet size and other characteristics of each of these three tiers is provided in Table 2 below.

Table 2 – Assumed Characteristics of Large Transit Agencies Subject to Automated Announcement Requirement, by Category (Tiers I, I & III)
 

Number of Transit Agencies
(Year 1)

Vehicles in Fixed-Route Bus Service (VOMS)

Fixed Routes

Garages

Vehicle Operators

Mechanics

Tier I

9

130

33

2

248

59

Tier II

6

273

70

5

520

124

Tier III

7

530

133

7

1,010

241

These three size-based tiers are intended to be representative of the types of large transit agencies operating fixed-route bus service in the United States.  Assumptions about the number of transit agencies per tier and their respective bus fleets operating in fixed-route bus service represent a synthesis of Access Board research (described above) and 2014 NTD data on modes of bus service.  The total of 22 large transit agencies across the three tiers, it should be noted, is not intended to reflect the actual number of large agencies that are believed (based on Access Board research) to still require automated stop announcement systems at this time.  Rather, for modelling purposes, a conservative, estimated total "inventory" of fixed-route buses assumed to need automated stop announcement equipment from all large transit agencies (approximately 6,500) was proportionally distributed across the three modelled categories of large transit agencies.[33]  Estimates of the number of fixed routes, garages, vehicle operators, and mechanics for each tier were derived by applying the same ratio of the particular characteristic (e.g., fixed routes, garages, and mechanics) to VOMS that was reflected in the transit agency sample data in the Preliminary RA (see Preliminary RA, Tbl. 5), with some small adjustments for rounding.

The model also accounts for potential growth by public transit agencies by assuming that, every third year during the 12-year regulatory horizon of the final rule, a new large transit agency will cross the VOMS 100 threshold, and, thereby, be subject to the requirement for automated announcement systems.  These "new" large transit agencies are assumed to have characteristics similar—though slightly less than—large transit agencies in "Tier I," based on the presumption that they would likely cross the VOMS threshold in an incremental fashion and thus be slightly smaller than a Tier I agency.  The assumed bus fleet size and other characteristics of "new" large transit agencies that cross the VOMS threshold during the expected regulatory timeframe of the final rule is presented in Table 3 below.

Table 3 – Assumed Characteristics of "New" Large Transit Agencies that Cross VOMS 100 Threshold during Regulatory Timeframe
 

Number of Transit Agencies
(Year 1)

Vehicles in Fixed-Route Bus Service (VOMS)

Fixed Routes

Garages

Vehicle Operators

Mechanics

"New" Large Transit Agency

0

105

27

2

115

48

Assumptions about transit agency growth with respect to the likelihood of "crossing" the VOMS 100 threshold were approximated based on review of annual NTD data from 2012 to 2014.  When a "new" large transit agency crosses the VOMS 100 threshold each third year, costs are assessed for one "new" transit agency with the foregoing characteristics under each L-M-H cost scenario.

Finally, it bears emphasis that the three-tier breakdown of large transit agencies (and their related assumptions about agency characteristics) is intended to reflect "average" large agencies likely to experience incremental costs under the new automated stop announcement requirement.  These abstractions allow for estimation of costs without knowing the particular budget, procurement, geographic, or technical IT considerations that may play into each agencies' respective decisions about ITS deployments generally, or automated announcement systems in particular.  Moreover, by segmenting large transit agencies into these three tiers, covered transit agencies will presumably get a better sense of their respective potential costs from the new automated announcement requirement than were a single "average" large transit modeled.

5.1.2.   OTRBs

There are two main estimated elements used in the cost model that relate to the "inventory" of OTRBs likely to incur incremental costs from new accessibility requirements in the final rule—the size of the U.S. OTRB fleet and the proportion of this fleet that operates in fixed-route service.

First, with respect to fleet size, estimates regarding the number of existing OTRBs were drawn from the 2014 Motorcoach Census published by the American Bus Association Foundation.[34]  This census states that, as of calendar year 2013, there were 32,811 motorcoaches in the United States.[35]  However, since this is a point-in-time figure, data from preceding Motorcoach Censuses were consulted to develop estimated growth (or contraction) rates in the OTRB industry.  This annual census data from 2010 through 2013 show that the OTRB industry has experienced some decline over the past several years in terms of total companies and vehicles.  Specifically, the year-over-year OTRB fleet size has decreased each year, with a 4-year annual average of - 3.8% growth in fleet size. [36]

However, it cannot be confidently predicted that the same market forces underlying recent consolidation and declining growth in the OTRB industry will persist long term.  Accordingly, the Final RA conservatively assumes that this trend will moderate to some extent over the 12-year regulatory horizon, with each L-M-H cost scenario using slightly different assumptions about OTRB growth rates.  Specifically, for purposes of modelling costs for new requirements in the final rule applicable to OTRBs, the respective cost scenarios assume that the total U.S. OTRB fleet will annually grow or contract as follows: - 1.0% (low scenario); 0.0% (primary scenario); 1.0% (high scenario).

Since the 2014 Motorcoach Census reflects only the size of the OTRB fleet in calendar year 2013, the foregoing growth rates were applied to the 2013 fleet size figure (32,811) to bring it forward to the present year.  This methodology results in assumptions about the current size of the OTRB fleet in the United States as provided below in Table 4.

Table 4 - Estimated Size of Total OTRB Fleet in the United States, 2015
 

Low Scenario

Primary Scenario

High Scenario

Number of OTRBs

31,836

32,811

33,804

The preceding OTRB fleet sizes are assumed for "Year 1" of the final rule.  In each subsequent year over the 12-year regulatory timeframe, the applicable growth for each cost scenario is applied to the prior year's OTRB fleet to derive the size of the OTRB fleet for that regulatory year.

Second, since some (but not all) of the new accessibility requirements for OTRBs in the final rule apply only to vehicles used in fixed-route service, it was necessary to develop estimates regarding the proportion of the OTRB fleet used in fixed-route service.  There are no definitive sources for such data.  However, based on a synthesis of information provided in various research studies, the cost model assumes that 30% of OTRBs in any given year under each cost scenario are used primarily in fixed-route service.[37] 

5.2.   Automated Announcement Systems

The cost model used in the Final RA to estimate likely incremental costs for the new automated announcement system requirement largely follows the approach used in the Preliminary RA, with three exceptions.  First, unit costs from the Preliminary RA (which was authored in 2010) were brought forward to the present.  Second, the Final RA adds a third cost scenario, thereby estimating costs across an L-M-H range.  Third, because the Final RA models costs for three sizes of transit agencies (rather than one), unit costs are scaled by size over the size-based tiers.

The assumptions and methodology underlying the Final RA's approach to modeling the incremental costs of the automated announcement systems requirement are briefly summarized below.  However, given that this analysis relies heavily on the methodology used in the Preliminary RA, review of the Preliminary RA will also likely aid in understanding the cost estimation process.  A complete list of unit costs used in the Final RA for automated announcement systems, as well as a brief description of their underlying assumptions, is provided in Appendix B.

5.2.1.   Initial Costs – Onboard Equipment and Backend Systems

The cost components for deploying an automated announcement system on fixed-route buses can be broken down into two main areas—onboard equipment, and so-called "backend" IT systems supporting the requisite stop and announcement databases.  Based on unit cost information developed by the Volpe Center, the Preliminary RA estimated costs for the automated announcement systems requirement based on "low" and "high" cost scenarios.[38]  For the "low" scenario, it was assumed that the transit agency already deploys a CAD/AVL system on its fixed-route buses, has established backend systems to communicate data, can use an existing stop database (with geocoded locations), and has operator call sheets to readily develop an announcement database.[39]  The "high" scenario, by contrast, assumed that the transit agency has no existing ITS systems in place and thus must "start from scratch" in the development of an automated announcement system.[40]

    The Final RA maintains these same sets of assumptions when modelling costs for automated announcement systems under the "low" and "high" scenarios.  The cost model also introduces, however, a "primary" (or medium) cost scenario.  This scenario has been added to reflect the fact that, since 2010 (when the Preliminary RA was published), the deployment rate for CAD/AVL on fixed-route buses has expanded rapidly.  In 2010, 66% of fixed-route buses were equipped with AVL, while, in 2013, nearly 90% of such buses had AVL.[41]  Given this high AVL deployment rate on existing fixed-route buses, it is most likely that large transit agencies affected by the new requirement for automated announcement systems will not need to "start from scratch" to comply with this requirement, but, rather, can build from an existing ITS infrastructure.  Consequently, the most likely scenario for overall compliance costs under the automated announcement systems requirement across all large transit agencies is that agencies will experience a "mix" of costs—namely, the majority of agencies will incur costs similar to the "low" scenario (because they already deploy AVL), and a few will still incur costs similar to the "high" scenario (because they do not yet have an existing ITS infrastructure).

The "primary" scenario in the Final RA is intended to capture this "mix" of compliance costs that will most likely be incurred under the automated announcement systems requirement.  Specifically, the cost model for the primary scenario assumes that one-half of affected large transit agencies will experience costs for automated announcement systems similar to the "low" scenario, and the other half will experience costs similar to the "high" scenario.  While the primary scenario could have assumed upwards of 90% of large transit agencies would experience costs similar to the "low" scenario given current AVL deployment rates, the 50/50 ratio of "low" to "high" cost assumptions was used instead to be conservative and to acknowledge that, when dealing with ITS integration issues (i.e., adding a new automated announcement system to an existing ITS deployment), things may not always go smoothly.

In practical effect, the cost approach taken under the "primary" (medium) cost scenario in the Final RA means that, for any costs which are scenario-based (i.e., have differing values under "low" and "high" cost assumptions), costs are pulled equally from the "low" and "high" cost assumptions.  There are five cost components related to initial deployment of automated announcement systems for which values differ under "low" and "high" cost assumptions.  These five cost components are: onboard bus equipment; WLAN systems; stop database consolidation and geocoding labor costs; labor costs for setting up an announcement database; and, labor costs for system testing.[42]

In terms of unit costs, all three L-M-H scenarios modeled in the Final RA include initial (one-time) unit costs to equip new buses and to set-up backend systems to support stop and announcement databases.  Unit costs from the Preliminary RA served as the framework for development of these unit costs in the Final RA, with some updating (to account for the passage of time) and adjustments (to account for the introduction of a "primary" scenario and three size-based transit agency "tiers").  In summary, unit costs in the Final RA for initial deployment of automated announcement systems reflect the following changes (relative to the Preliminary RA):

·   Updating Unit Costs from Preliminary RA to Reflect the Passage of Time: All unit costs from the Preliminary RA were brought forward to the present using the online CPI Inflation calculator tool provided on the Bureau of Labor Statistics (BLS) website;[43]

·    Incorporation of a "Primary" Cost Scenario: As noted above, the Final RA adds a "primary" (medium) cost scenario which, for unit costs that are scenario-based (i.e., have differing "low" and "high" cost assumptions), assumes that costs are pulled equally from "low" and "high" cost assumptions.  Under the primary scenario, these "low" and "high" unit costs are based on the respective "low" and "high" unit costs in the Preliminary RA, as updated by the BLS CPI Inflation Calculator;

·   Slight Upward Adjustment of Unit Costs Under "High" Scenario:  Because the primary scenario pulls costs, in part, from the "high" cost assumptions used in the Preliminary RA, a different set of "high" unit costs was needed for the Final RA.  In the Final RIA, "high" unit costs are assumed to be 10% higher than "medium" costs under the primary scenario.  Accordingly, "high" unit costs in the Final RA are calculated as follows: Unit Cost for Initial Cost Component X = (unit cost for Component X in Preliminary RA under "high" scenario) x (BLS CPI Inflation Rate) x (10%).  This slight upward adjustment in unit costs under the "high" scenario in the Final RA ensures that the upper-bound estimate for likely costs for the final rule remains a conservative estimate; and

·   Scaling of Certain Size-Based Unit Costs for Transit Agencies in Tiers I and III:  Since the Preliminary RA assessed costs based on the assumed characteristics of a single "sample" transit agency, unit costs were necessarily tailored to agencies of that one size.  The Final RA, in contrast, assesses costs across three size-based categories of large transit agencies.  Unit costs in the Final RA for some cost components thus needed to be scaled because they would not otherwise properly account for likely costs variances due to agency size.[44]  In the Preliminary RA, there are four cost components related to initial deployment of automatic announcement systems that are assumed to require scaling for transit agency size: Software & Hardware; Stop Database Setup/Consolidation; Announcement Database Setup; and, System Testing.  See App. B-2, Initial (One-Time) Costs for Backend Systems.

By design, the size (in terms of fixed-route bus fleet) and other pertinent characteristics of "Tier II" transit agencies in the Final RA mirror the "sample" transit agency modeled in the Preliminary RA.[45]  Therefore, scaling of costs is only needed when calculating costs for Tier I (i.e., relatively smaller) and Tier III (i.e., relatively larger) transit agencies.  Under all L-M-H scenarios, unit costs for Tier I agencies for these four size-dependent cost elements are scaled by .75 to reflect their relatively smaller size.  For Tier III agencies, unit costs for these same four cost elements are scaled by 1.25 to account for their larger size.

In sum, the foregoing revisions represent all changes to unit costs estimates in the Final RA for initial (one-time) costs related to the deployment of automated announcement systems.  A complete list of unit costs used in the Final RA to assess the incremental costs of the automated announcement systems requirement is provided in Appendix B, along with brief descriptions of their respective underlying assumptions.

5.2.2.   Training and Other Labor Costs

Labor costs are reflected in several cost items used to assess incremental costs for compliance with the new requirement for automated announcement systems.  First, the Final RA assumes that each transit agency initially deploying an automated announcement system to comply with the final rule will incur one-time costs to train vehicle operators and mechanics on these systems.[46]  Hourly labor costs for these occupations were derived from May 2014 Occupational Employment Statistics (OES) data published by the Bureau of Labor Statistics.[47]  The primary scenario is based on the median national hourly wage, while the low and high scenarios respectively use hourly wages at the 25th and 75th percentiles nationally.  All OES-based hourly wages were multiplied by 1.5 to adjust for benefits (which was same multiplier used in the Preliminary RA).

The resulting "fully loaded" hourly wages for vehicle operators and mechanics, as used in the Final RA, are:

Table 5 - Estimated Hourly Wages for Vehicle Operators and Mechanics
 

Low Scenario

Primary Scenario

High Scenario

Vehicle Operators

$19.55

$27.03

$35.94

Mechanics

$25.04

$31.47

$39.47

The foregoing methodology used in the Final RA to estimate wage rates for vehicle operators and mechanics mirror the approach taken in the Preliminary RA except that, here, updated (2014) OES wage data is used and percentile (rather than average) wage data forms the basis for the "low" and "high" scenarios respectively.[48]

Second, labor costs are also embedded in certain cost calculations relating to setup of backend systems.  Specifically, the respective unit costs for setting up an announcement databases and for system testing assume that the efforts of an IT/GIS specialist and IT Project Manager will be needed, with the number of hours varying by scenario.[49]  The Final RA uses wage data from the May 2014 National Industry-Specific Occupational Wage Estimates (OES) tables to derive labor costs for these IT professionals.[50]  The primary scenario is based on the median national annual wage, while the low and high scenarios respectively use annual wages at the 25th and 75th percentiles nationally.  Annual OES-based wage rates were multiplied by 1.5 to adjust for benefits.[51]

The resulting "fully loaded" annual wages for an IT/GIS Specialist and IT Project Manager, as used in the Final RA, are: 

Table 6 - Estimated Annual Wages for IT/GIS Specialist and IT Project Manager
 

Low Scenario

Primary Scenario

High Scenario

IT/GIS Specialist

$83,955

$106,890

$134,595

IT Project Manager

$119,938

$152,703

$192,282

As with training cost assumptions, the methodology used to estimate annual wages for these two IT professions mirrors the approach taken in the Preliminary RA except that, here, updated (2014) OES wage data is used and percentile (rather than average) wage data forms the basis for the "low" and "high" scenarios respectively.[52]

5.2.3.   Operations & Maintenance

Automated announcement systems—as with any IT system—require some measure of ongoing operation and maintenance (hereafter, "O&M").  These O&M efforts may take several forms.  First, transit agencies periodically update schedules and routes, which may result in changes in bus stops, and therefore, require updating of stop and announcement databases.  At many transit agencies, these updates occur quarterly.  Backend systems also require routine software and hardware maintenance.  As well, onboard bus equipment needs to be maintained and, when needed, repaired.  Information provided by transit agencies, as well as other Access Board research on the reliability of automated announcement systems, suggests that onboard equipment typically has a low failure rate.

Accordingly, the Final RA incorporates annual O&M expenses into the cost model for each L-M-H scenario.  Annual O&M costs have three components: spare parts (equipment cost); maintenance/repair of onboard bus equipment (labor cost); and periodic maintenance of stop and announcement databases and related backend hardware and software (labor cost).  A complete discussion of the assumptions used to calculate these O&M-related equipment costs and labor costs are detailed in Appendix B.  These assumptions are generally the same as those used in the Preliminary RA except for updating of labor rates to reflect current (2014) OES wage data, and use of L-M-H cost scenarios (rather than dual L-H cost scenarios).

5.2.4.   Mid-Life Software Upgrade

The final component of the cost calculus for the automated announcement system requirement concerns the likely need for a mid-life software upgrade for onboard bus equipment (i.e., integrated system controller) and backend systems.  In sum, the Final RA assumes that upgrade costs are incurred every 5-6 years, with such costs apportioned equally between the 5th and 6th in-service years.  Unit costs for mid-life software upgrades are based on cost estimates used in the Preliminary RA, as adjusted for inflation.  Additionally, because the Preliminary RA did not vary unit costs for mid-life software upgrades between scenarios, it was necessary to develop new cost assumptions for the "low" and "high" scenarios.  These new unit cost estimates were derived by using unit costs under the primary scenario as the base, then subtracting 10% (low scenario) or adding 10% (high scenario) to create a L-M-H range of cost scenarios.  (A complete discussion of the assumptions used to calculate unit costs for mid-life software upgrades to onboard equipment and backend systems is detailed in Appendix B.)

Based on the foregoing, the Final RA uses the following unit cost estimates for mid-life software upgrades to onboard equipment and backend systems:

Table 7 - Estimated Mid-Life Software Upgrade Costs (Onboard Equipment & Backend Systems)
 

Low Scenario

Primary Scenario

High Scenario

Onboard Bus Equipment
(per bus)

$142

$158

$174

Backend Systems
(per agency)

$1,390

$1,544

$1,698

5.3.   Over-the-Road Buses – New Requirements for Onboard Accessibility Features

Assessment of costs related to the four accessibility requirements in the final rule expected to have an incremental cost impact on OTRBs—wheelchair space identification; exterior destination/route signs; public address systems; and stop request systems—generally follows the same methodology used to estimate unit costs for automated announcement systems.  Cost estimates for these four requirements include one-time costs to equip new OTRBs, as well as annual O&M costs throughout the 12-year regulatory timeframe.[53]  One area in which the cost estimation methodologies differ, however, is the incorporation of the likelihood that a new OTRB will need to incur compliance costs.  In other words, estimates of incremental costs for new OTRB accessibility requirements take into account the "real world" likelihood that a typical new vehicle will both have a particular covered element and be affected by the new accessibility requirement (i.e., will incur compliance costs that otherwise would not have been incurred absent the final rule).

Key features of the assumptions underlying cost estimates for the four new OTRB accessibility requirements are summarized below.  In addition, a complete list of unit costs used in the Final RA for these requirements, as well as brief descriptions of their respective underlying assumptions, is provided in Appendix C.

5.3.1.   Unit Costs

Because the new OTRB accessibility requirements involve discrete features or pieces of equipment (rather than whole IT systems), their corresponding cost estimation calculations are also, generally speaking, less complex.  Unit cost estimates for OTRB equipment needed to comply with each of these four accessibility requirements are based on discussions with, or information provided by, OTRB manufacturers and vendors.  Unit costs simply reflect, with one exception, the cost of equipping one, new OTRB with the requisite feature or equipment.

No separate (or additive) labor costs are assumed for any of the four requirements with the exception of the requirement for identification of accessible seating and doorways with signs (i.e., priority seats) or the International Symbol of Accessibility (ISA) (i.e., wheelchair spaces and accessible doorways).  Online research conducted by Access Board staff of OTRB manufacturers' websites, along with supplementary information provided by OTRB manufacturers and transit entities, established that bus manufacturers typically install exterior destination/route signage, public address systems, and stop request systems when the bus is built per standard configuration or customer specification.  For such Original Equipment Manufacturer (OEM)-installed equipment, there is no separate labor cost.  No such practice for OEM-installed identification of accessible seating and doorways was found.  Accordingly, it is assumed that affixing the requisite signage for priority seats (e.g., sign informing transit users that such seats are for use by persons with disabilities), along with identification of wheelchair spaces and accessible doorways (e.g., sign or decal with International Symbol of Accessibility), will be an after-market installation performed by mechanics employed by the vehicle owner.  The time needed by mechanics to affix the requisite identifying signs or decals for accessible seating and doorways is, under all three L-M-H scenarios, estimated to be 30 minutes per vehicle.

Unit costs related to the new OTRB requirements were developed from information provided by OTRB bus manufacturers and equipment vendors, as supplemented by online research conducted by Access Board staff.  With respect to the signage requirements related to accessible seating and doorways, unit costs were developed solely from these sources.  For the remaining OTRB-related accessibility requirements (i.e., exterior destination/route signs, public address system, and stop request system), only unit costs for the primary scenario are based on these sources.  Unit costs for the "low" and "high" scenarios are assumed to be +/- 20% of costs under the primary scenario.

A complete list of unit costs used in the Final RA for equipment related to the four new accessibility requirements for OTRBs, along with brief descriptions of their underlying assumptions, is provided in Appendix C.  In sum, unit costs used in this analysis to evaluate the likely respective incremental costs of these four new requirements are:

Table 8 – Per Vehicle Unit Costs for Equipment Related to New OTRB Accessibility Requirements
 

Low Scenario

Primary Scenario

High Scenario

Identification of Wheelchair Spaces and Accessible Doorways

(ISA Signs/Decals)

$9

$18

$30

Priority Seating Signs

$30

$70

$110

Exterior Destination/Route Signs

$640

$800

$960

Public Address System

$600

$750

$900

Stop Request System

$240

$300

$360

5.3.2.   Likelihoods for Incurring Compliance Costs

As noted above, the Final RA's cost model does not assume that every new OTRB manufactured during the 12-year regulatory timeframe will incur compliance costs under the final rule.  Rather, only OTRBs likely to incur costs attributable to one or more of the four new accessibility requirements experience compliance costs for requisite equipment.  Compliance costs are assumed to be attributable to the final rule only if a covered OTRB would not be expected to be outfitted with the feature/equipment at issue in the normal course of business or industry practice.  Likelihoods of incurring compliance costs for OTRB accessibility requirements are thus a function of whether such vehicles (a) have a given feature/element covered by the final rule, and (b) would not typically have the requisite accessibility equipment required by the final rule.

Estimates of likelihoods for incurring compliance costs related to the four new OTRB accessibility requirements in the final rule are drawn from Access Board research, as well as information provided by OTRB manufacturers and equipment vendors.  As reflected in the table below, the relative likelihood of any particular OTRB incurring compliance costs under one or more of the four new accessibility requirements varies greatly between requirements.  This disparity reflects research-based estimates that most new OTRBs are already likely to be outfitted with equipment complying with certain accessibility requirements (e.g., stop request systems), while, for other requirements, such likelihoods are much lower or even non-existent (i.e., identification of wheelchair spaces, exterior destination/route signage).  Also playing a role in likelihoods is the intended use of an OTRB.  For example, most OTRBs used in fixed-route service as commuter buses are already equipped with exterior destination/route signs on both the front and boarding side of the vehicle, but, for OTRBs intended solely for charter use service, exterior destination/route signage on the front of the vehicle only is more the norm.[54]

Presented in the Table 9 below are the likelihoods used in the Final RA for incremental cost calculations under each L-M-H cost scenario for the four new OTRB accessibility requirements.  A full discussion of the assumptions underlying the estimation of likelihoods for each of these four requirements is presented in Appendix D.

Table 9 – Likelihood of OTRB Incurring Compliance Costs under Each New Accessibility Requirement, Per Vehicle
 

Low Scenario

Primary Scenario

High Scenario

Identification of Wheelchair Spaces and
Accessible Doorways (ISA)

100.0%

100.0%

100.0%

Priority Seating Signs

27.0%

28.5%

30.0%

Exterior Destination/Route Signs

35.0%

45.0%

55.0%

Public Address System

2.0%

5.0%

8.0%

Stop Request System

25.5%

27.0%

28.5%

In practical effect, the foregoing likelihoods work to "scale" (adjust) incremental costs for requirements so that to they reflect current industry trends and practice.   Likelihoods are applied to the number of new OTRBs in any given year as a means of estimating the number of vehicles that will incur compliance costs.  For example, the primary scenario assumes that, in "Year 1" of the final rule, 820 OTRBs will be manufactured.  With respect to the stop request system requirement, application of the 27% likelihood associated with this requirement under the primary scenario (listed in Table 9, above) leads to a total 211 ORTBs (.27 x 820) that are assumed to incur incremental costs related to the stop request equipment in that regulatory year.

5.3.3.   Operation & Maintenance

Assessment of annual O&M costs related to the new OTRB accessibility requirements proceeds according to a straightforward process.  Costs for maintenance or repair of equipment needed to comply with these accessibility requirements (e.g., window decal, public address microphone or speakers, stop request indicator) is assumed to be a percentage of annual equipment costs, with these O&M percentages varying slightly by cost scenario.

The Final RA assumes that O&M costs for equipment needed to comply with the new OTRB accessibility requirements will be incurred on an annual basis, with percentages based on total equipment costs for OTRBs in any given year.  Estimated annual O&M costs under each scenario are as follows:

Table 10 – Estimated Annual O&M Costs for new OTRB Accessibility Requirements
 

Low Scenario

Primary Scenario

High Scenario

Annual O&M Costs
(as percentage of OTRB equipment)

1.0%

2.0%

3.0%


   6.   Benefits: A Qualitative & Quantitative Perspective

The Access Board believes that the revised accessibility guidelines in the final rule will directly benefit a significant number of Americans with disabilities by ensuring that public transit buses and OTRBs are accessible and usable.  By addressing communication barriers (and, to a lesser extent, access barriers) encountered on such vehicles by persons with vision, hearing, mobility, and cognitive impairments, the final rule will better enable persons with such disabilities to use these modes of transportation to work, pursue an education, access health care, worship, shop, or participate in recreational activities.  Other individuals or entities, such as transit agencies, will also likely incur benefits through, for example, improved customer satisfaction attributable to automated announcement systems.  However, for several reasons, benefits accruing from the final rule cannot be reliably monetized.  Consequently, this Final RA summarizes the expected benefits from the final rule in qualitative, and, where possible, quantitative terms.[55]  Additionally, several threshold (breakeven) analyses are presented to demonstrate the net social value of the final rule from an economic perspective.

6.1.   General Discussion

Benefits of the final rule are particularly challenging to quantify and monetize due to multiple considerations.  These challenges include: (a) a lack of current, reliable statistics on ridership by persons with specific disabilities on fixed-route transit buses and OTRBs; (b) the fact that persons with disabilities will experience benefits differently, depending on the nature of their respective disabilities, current level of accessibility provided by the transit system or OTRB they wish to use; (c) the unknown extent to which improved accessibility of fixed-route transit buses and OTRBs may either spur new demand among persons with disabilities who do not currently ride such vehicles due to accessibility barriers that are addressed by the final rule, or increase demand among current riders with disabilities;[56] (d) the extent to which persons with disabilities have reliable access to transportation (since, even when accessible, vehicles cannot be used if a potential passenger cannot reach them); (e) personal transportation preferences of persons with disabilities, who, like all passenger, make transit decisions for multiple reasons, some of which are unrelated to accessibility; and (f) the inherent challenges posed by monetization of key benefits of the final rule, such as equity, fairness, independence, and better integration into society.

While the foregoing factors make formal quantification or monetization of the final rule's benefits inherently difficult, it is nonetheless still possible based on current information to provide a broad framework for understanding the potential pool of persons with disabilities who may benefit, to a greater or lesser extent, from new accessibility requirements in this rule.[57]  First, the most significant benefits from the final rule are expected to flow from the automated stop and route announcement systems requirement.  As discussed above, see discussion supra section 3.2, failure to announce stops and other identifying route information has been a recurring problem under the existing regulatory regime.  By requiring audible and visible notification of upcoming stops and other identifying route information through automated announcements, the new requirement is expected to deliver significant benefits to passengers with vision- or hearing-related disabilities who use fixed-route buses and OTRBs, or would use such services absent communications barriers.  Consistent and intelligible stop and route announcements, for example, may enable passengers who are blind or have low vision—for the first time—to use fixed-route service independently, or permit them to do so more reliably and with greater frequency.  Automated announcements are also expected to generate time savings by lessening (if not preventing) situations in which passengers with vision- or hearing-related disabilities disembark at the wrong stop, and then must wait for another bus (or other means of transportation) to transport them to their desired destination.  Alighting at the wrong stop may also present safety issues if the individual is not oriented to their surroundings or the stop is located in a hazardous area.  In sum, the automated announcement systems requirement will not only deliver direct and substantial benefits to fixed-route passengers with vision- or hearing-related disabilities, but will also promote fairness by ensuring a more consistent approach to announcements on fixed-route vehicles across the country.

Individuals with other disabilities may also experience benefits from the automated announcement system requirement.  Studies have shown that individuals with cognitive or intellectual disabilities also frequently face communications barriers when using fixed-route transit, and, thus will benefit from consistent, reliable stop and route announcements such as those provided by automated announcement systems.[58]  Additionally, for individuals with significant mobility impairments, automated stop announcements may mean the difference between getting off at the correct stop and getting off at the wrong stop—due to unintelligible (or non-existent) stop or route announcements—to face a physically arduous or hazardous journey to his or her intended destination (or other location that gets the trip back on track).[59]

For the new OTRB-related requirements, benefits are expected to be similar to, though perhaps not as significant as, the benefits accruing from automated announcement systems.  These four new accessibility requirements—identification of wheelchair spaces and priority seats, exterior destination/route signage, public address systems, and stop request systems—are all aimed at addressing communication barriers to use of, or use of accessible features on, OTRBs.  With required signage of accessible onboard seating, persons with mobility impairments will be able to more readily locate required accessibility seating.  Such signage may also deter passengers without disabilities from using priority seating or setting packages or strollers in wheelchair spaces, thereby ensuring their availability for passengers with disabilities.  Similarly, requiring accessible stop request mechanisms within reach of priority seats and wheelchair spaces on OTRBs operating in fixed-route service ensures that passengers with disabilities who use such seating can independently indicate their desire to disembark at the next designated stop.  Public address systems, in turn, enable passengers with hearing-related disabilities (as well as other passengers) to better understand information conveyed by the vehicle operator, which, in the event of an emergency, could be of urgent significance.  Lastly, having exterior destination/route signage on both the front and boarding sides of an OTRB aids passengers with disabilities by making it easier to ascertain a given vehicle's route, destination, or identity.  Having such signage in both locations is particularly important, for example, at transit hubs, bus terminals, areas where multiple vehicles are parked simultaneously, or other locations where traffic or terrain make circling to the front of the vehicle to view its destination/route sign difficult or hazardous.

Yet, while the foregoing benefits may be qualitatively described, several considerations defy formal quantification.  As noted above, there are multiple factors—such as lack of reliable data concerning bus and OTRB ridership levels by persons with disabilities, as well as the current status of covered transit buses and OTRBs in terms of accessible features—that would preclude quantifying the pool of direct beneficiaries formally.  Nonetheless, review of data on the prevalence of specific types of disabilities amongst the U.S. population still provides an informal sense of the relative magnitude of potential beneficiaries.  Statistics on disability prevalence vary substantially depending on the data source, methodologies employed, survey population, and data definitions.  For example, the U.S. Census Bureau and the Centers for Disease Control and Prevention (CDC) each publish statistical data relating to the prevalence of certain functional categories of disabilities in the U.S. population.[60]  Appendix H presents data excerpted from the Census Bureau's 2010 "Survey of Income and Program Participation" (SIPP) and 2014 "American Community Survey" (ACS), as well as the CDC's 2013 "Behavioral Risk Factor Surveillance System."  While these data sets all use somewhat different methodologies, as summarized in the appendix, each nonetheless breaks down its respective statistics into fairly similar functional disability categories.

 In sum, comparison analysis of the Census Bureau and CDC data sets provides the following broad population ranges for individuals with disabilities, grouped by functional disability category, who may experience direct benefits from one or more new accessibility requirements in the final rule:

Table 11 – Estimated Population Ranges for Certain Functional Disability Categories among U.S. Non-Institutionalized Persons Derived from Census Bureau and CDC Disability Statistics
Functional Disability CategoryEstimated Population Range
(Non-Institutionalized,
= 15/18 yrs.)
Percent of U.S. Population
(Non-Institutionalized,
= 15/18 yrs.)

Vision

6.8 million - 11.2 million

2.8% - 4.6%

Hearing

5.6 – 13.1 million

1.0% -  5.4%

Cognitive

2.2 million - 25.7 million

0.9% - 10.6%

Mobility

15.2 million - 31.5 million

2.2% - 13.0%

Again, not every (or even most) individuals with vision, hearing, cognitive, or mobility impairments will directly benefit from the final rule (or experience benefits in the same way), but such data nonetheless provide a starting point for a general understanding of the extreme upper-bound of the pool of potential beneficiaries.

Second, any estimate of quantified benefits would also need to scale the foregoing broad population figures by, at the very least, the likelihood that persons with disabilities will be using public transit buses and OTRBs, and, thereby, benefitting from accessibility improvements under the final rule.  There are few known sources for such data, and, the sources that do exist, have significant limitations (e.g., insufficient level of detail, relatively small sample size, older study that may not reflect current ridership levels).  Nonetheless, at the very least, these sources provide a rough sense of fixed-route ridership by persons with disabilities on public transit systems.  (No data sources were located for statistics on ridership levels of persons with disabilities on privately-owned OTRBs.)  For example, a 2013 study conducted by the Transportation Research Board of the National Academy of Science surveyed seven public transit agencies concerning ridership by persons with disabilities during the three-year period from 2009 to 2011 found that, on average, passengers with disabilities constituted 4.9% of total fixed-route ridership across all transit modes.[61]  Additionally, a 2002 national transportation survey conducted by the Department of Transportation showed that, while the majority of all bus riders use public transit service two or fewer days per week for local travel regardless of disability status, riders with disabilities—on average—use public transit buses with slightly greater frequency per week (2.5 days) than nondisabled riders (1.93 days).[62]  Several transportation-related research reports also observe that use of public transportation systems by passengers with disabilities—particularly, fixed-route transit—has risen steadily in recent years.[63]  While these data sources are not sufficiently tailored to formally quantify benefits, they do provide a rough gauge of the current level of fixed-route public transit ridership by persons with disabilities.

Finally, it bears noting that other individuals and entities, including transit agencies, may also benefit indirectly from new accessibility requirements in the final rule.  Several research studies on ITS deployments (including automated announcement systems) by transit agencies have shown that such systems often have the beneficial effect of increasing both customer satisfaction and ridership.[64]  For transit agencies that do not yet have automated announcement systems, compliance costs incurred in deploying such systems might thus be offset in part by increases in fixed-route ridership and fare revenues.  Additionally, nondisabled fixed-route bus riders who are unfamiliar with a particular route, or who may be visiting from outside the area, may find the wayfinding assistance provided by automated stop and route announcements to be helpful.

6.2.   Threshold Analyses – Automated Announcement Systems

While the significant benefits that persons with disabilities and others will derive from the new and revised accessibility requirements in the final rule are believed to be quite weighty, formal monetization of these benefits is beyond the scope of this Final RA for the reasons discussed above.  Nonetheless, to impart a rough sense of the magnitude of these benefits in relation to costs, the Access Board conducted two threshold (breakeven) analyses to demonstrate that benefits accruing from one of the key accessibility enhancements in the final rule – namely, the new requirement for automated announcement systems on large, fixed-route buses operated by large transit entities – need only be quite modest in order for their monetary value to break even with monetized costs.  (Threshold analyses could not be conducted for the new OTRB-related accessibility requirements due to the unavailability of data concerning ridership by persons with disabilities.)[65]  Discussion of these two threshold analyses follows below.  Additionally, a detailed discussion of the methodology and data sources underlying these analyses is provided in Appendix I.

The first threshold analysis explores the breakeven point between monetized costs for the automated announcement system requirement and the value of its benefits to persons with disabilities.  In sum, this analysis looks at annualized costs relative to expected annual fixed-route bus ridership by persons with disabilities in the geographical areas served by large transit entities (which are the only transit agencies subject to the automated announcement system requirement).  In this context, it is estimated that persons with disabilities in the relevant geographical areas would have to place only a small monetary value on riding a fixed-route bus equipped with an automated stop and route announcement system for the costs and benefits of this requirement to be equal.  More specifically, it is assumed that annualized costs for automated announcement systems will be $3.61 million (which represents estimated costs under the primary scenario at a 7% discount rate) and that passengers with disabilities in the relevant geographical areas will take approximately 4.1 million trips annually on automated announcement system-equipped fixed-route buses operated by large transit entities.  See Appendix I (discussing estimation of these cost and bus ridership figures).  Dividing the $3.61 annualized cost by the 4.1 million annual uses (as measured by fixed-route bus trips taken by passengers with disabilities), shows that, for costs and benefits to break even, bus passengers with disabilities need only value the safety, independence, and equity and other benefits of automated announcement systems at about .88¢ per trip.  The Access Board believes, based on its experience, that .88¢ underestimates (and likely substantially so) the value that passengers with disabilities would place on these benefits in this transportation context.

The second threshold analysis assesses the cost:benefit breakeven point for the automated announcement system requirement in terms of increased ridership of more accessible fixed-route buses (i.e., buses equipped with automated announcement systems) by persons with disabilities who formerly used paratransit for some or all of their transportation needs.  This second analysis is based on transportation surveys and reports showing that, among persons with disabilities who currently use paratransit systems, there is strong interest in using fixed-route transit service – which is more integrated (and thus is often viewed as less stigmatizing) and generally has a more reliable, fixed schedule – absent various accessibility barriers, including problems with stop and route announcements.[66]  Because operating costs for paratransit services greatly exceed those for fixed-route buses, a demand shift from paratransit to fixed-route buses would result in cost savings in operational expenses for transit agencies.     To be sure, as noted above, the extent to which the automated announcement system requirement will spur demand for fixed-route bus transit among current paratransit riders is not presently known.  However, the value of this second threshold analysis is that it does not require quantification of the demand shifts from paratransit to fixed-route buses that can be fairly attributed to the automated announcement system requirement.  Instead, this threshold analysis merely aims to quantify the shift in ridership from paratransit to fixed-route bus transit that would be needed for monetized costs of the automated announcement system requirement to break even with benefits, which, in this case, are monetized in terms of cost savings to transit agencies from reductions in paratransit operating expenses.

For purposes of the second threshold analysis, costs and benefits are monetized as follows. Annualized costs for automated announcement systems are again assumed to be $3.61 million (i.e., annualized costs under primary scenario at 7% discount rate).  On the benefits side of the calculus, it is assumed that paratransit operating costs are $40.00 per trip (which represents a mid-point estimate among the largest providers of paratransit services), and that a paratransit user takes 8 trips weekly for various purposes (e.g., commuting, visiting family, socializing, medical appointments) for an annual total of 400 paratransit trips (8 x 50 weeks, with two weeks of assumed vacation time).  See Appendix I.  Based on these assumptions, estimated annual paratransit operating expenses are $16,000 per person.  Dividing $3.61 million (annualized costs for automated announcement system by $16,000 (annual per passenger operating expenses for paratransit services), shows that, for costs and benefits to break even, about 225 current paratransit users in areas served by large transit entities would need to switch to fixed-route transit buses.  To put this figure in perspective, it is estimated that about 21.5 million persons with disabilities live in the geographical areas served by large transit entities subject to the automated announcement system requirement.  Should actual paratransit trip operating costs or usage differ from the assumptions used in this threshold analysis, the breakeven point may differ from the above, but the principle remains the same.

Based on the foregoing, the Access Board believes that benefits from the final rule, were they amenable to full quantification and monetization, would exceed the relatively modest economic (cost) impact of this rule.


   7.   Costs: Results & Discussion

7.1.   Summary of Results

The Final RA assesses the economic impact of the revised transportation vehicle accessibility guidelines in the final rule from several cost perspectives.  First, for each year of the expected 12-year term of the final rule, the Final RA estimates annual costs collectively for all requirements under the three respective cost scenarios (i.e., "low," "primary," and "high" assumptions).  Additionally, in order to afford a more complete understanding of annual costs related to the final rule, the Final RA also examines per-agency costs for the automated announcement systems requirement, and presents several "stress tests" to assess the relative impact of revising selected cost-related assumptions on overall results.  Based on the results of the foregoing cost analyses, the Access Board concludes that the final rule does not represent a "significant" regulatory action under Exec. Order 12,866 §§ 3(f)(1), 6(a)(3)(C) (Oct. 4, 1993).  Second, the Final RA also includes a separate "threshold" small business analysis to assess whether annual costs of the final rule will likely have a "significant" economic impact on "small businesses" in the OTRB industry—namely, scheduled intra- and inter-city transportation services, charter services, and scenic/sightseeing services.  The results of this small business analysis show that, while the final rule will undoubtedly affect a "substantial" number of small OTRB firms given that small firms predominate in these industry sectors, its economic impact will not be "significant" within the meaning of the RFA.  See 5 U.S.C. § 604(a).

7.1.1.   Annualized Costs of New Requirements

The annualized compliance cost for new or revised accessibility requirements in the final rule over the studied 12-year regulatory horizon are estimated to range from $2.6 million to $7.9 million when using a 3% discount rate, and from $2.3 million to $7.2 million when using a 7% discount rate.  Table 12 below shows the annualized cost of new requirements in the final rule under each L-M-H scenario at 3% and 7% discount rates.

Table 12 Annualized Cost of Revised Accessibility Guidelines for Buses, Vans, and OTRBs, All Regulatory Years (3% and 7% Discount Rates)

Discount Rate

Low Scenario   ($millions)

Primary  Scenario ($millions)

High Scenario   ($millions)

3%

$2.6

$4.9

$7.9

7%

$2.3

$4.5

$7.2

The Final RA also shows that estimated annual costs for the final rule will be substantially below $100 million for each regulatory year under all three cost scenarios, which is the threshold value for economic significance of regulatory action under Executive Order 12,866.  Annual costs for each year during the expected 12-year term of the final rule are depicted in Figure 1 below.[67]

Figure 1 - Annual Costs of Final Revised Accessibility Guidelines for Buses, Vans, and OTRBs (Nominal Dollars)

Figure 1 of 4, line graph with 3 lines, each with 12 data points.

As shown above, the highest single-year costs occur in Year 1, which is due to anticipated initial costs for large transit agencies that currently do not have (nor have firm plans to acquire) automated announcement systems to come into compliance by developing stop and announcement databases, purchasing and installing other backend hardware and software, equipping new fixed-route buses with onboard equipment, and training agency personnel.  Thereafter, for Year 2 to Year 12, costs remain relatively constant as initial announcement systems-related costs approach zero (with the exception of the one "new" large transit agency crossing the VOMS 100 threshold every third year) and ongoing operation and maintenance costs come to the fore.  Costs related to the four new OTRB accessibility requirements, on the other hand, remain relatively constant over the 12 years, with exterior destination/route signage representing the highest-cost OTRB requirement, though still significantly lower than expected initial costs for automated announcement systems.

A break-out of costs by category of requirement relative to total costs is presented in Figure 2 below.  This figure illustrates that initial (one-time) costs related to the requirement for automated announcement systems are, by far, the most significant cost item, representing about 63% of the overall cost of the final rule.  Thereafter, in terms of relative size, costs for exterior destination/route signage (17.7%) are the second-largest cost item, followed closely by ongoing (O&M) costs for announcement systems (16.7%).

Figure 2 - Total Costs by Category of Accessibility Requirement (Nominal Dollars)

Figure 2 of 4, pie chart with 7 slices.

7.1.2.   Annualized Costs for Automated Announcement Systems under Primary Scenario   by Transit Agency Category (Tiers I, II & III)

In addition to evaluating total costs of the final rule, the Final RA also examines likely annualized costs to each of the three categories of large transit agencies—Tiers I, II & III—under the requirement for automated announcement systems.  Estimated costs for announcement systems are calculated, by transit agency tier, for each year over the projected 12-year term of the final rule.  Results are broken down separately (in nominal dollars) for several announcement systems-related cost categories (e.g., one-time costs for bus equipment and backend systems, training costs, O&M costs), and then presented as rolled-up annual cost totals at 3% and 7% discount rates and as annualized values.  Complete results for these cost analyses are provided in Appendices E-1 to E-3.

Presented in Table 13 below, in sum, are per-agency annualized costs for the automated announcement systems requirement under each L-M-H cost scenario.  These annualized costs range from about $44,000 (for a Tier I agency under the low scenario) to about $430,000 (for a Tier III agency under the high scenario).  Under the primary scenario, which models what are considered to be the most likely set of cost assumptions, per-agency costs for announcement systems are estimated to be as follows: Tier I - $80,659; Tier II - $154,985; and, Tier III: $264,968.

Table 13 - Annualized Costs of Automated Announcement Systems Requirement for Large Transit Agencies (Tiers I, II & III)
 

Low Scenario

Primary Scenario

High Scenario

Large Transit Agency - Tier I

$44,208

$80,659

$129,305

Large Transit Agency - Tier II

$76,678

$154,985

$248,313

Large Transit Agency - Tier III

$129,444

$264,968

$429,715

Not surprisingly, the foregoing annualized cost figures underscore the logical cost corollary that per-agency costs directly relate to agency size, with the "smallest" large transit agencies (Tier I) experiencing the lowest annualized costs under all scenarios, and, conversely, the "largest" large transit agencies (Tier III) having the highest annualized costs.  Nonetheless, even for Tier III agencies, costs are not estimated to exceed $450,000 annually under even the high scenario.

7.1.3.   Annual Costs for New OTRB Accessibility Requirements

Unlike the automated announcement systems requirement, the new OTRB accessibility requirements do not affect a discrete set of entities.  As noted previously, there are various transportation-related industry sectors that use OTRBs for scheduled services, charter services, sightseeing, and other services.  See discussion supra section 4.3.  Consequently, it is not possible to reliably estimate costs related to the new OTRB accessibility requirements on a per-firm basis.  Thus, in terms of analyses focusing specifically on these new requirements, the Final RA examines costs on a per-vehicle and per-requirement basis.

First, the Final RA evaluates costs under the four new OTRB accessibility requirements are calculated, by requirement, for each year over the projected 12-year term of the final rule.  Results are broken down separately (in nominal dollars) for each requirement, and then presented as rolled-up totals in nominal dollars, at 3% and 7% discount rates, and in annualized values.  Complete results for these cost analyses are provided in Appendices F-1 to F-3.

Second, the Final RA assesses the costs related to the four new OTRB accessibility requirements from a per-vehicle perspective.  Annualized costs of these new OTRB requirements are examined under each L-M-H scenario, with results presented at both 3% and $7 discount rates.  The results are shown in Table 14 below.

Table 14 – Per-Vehicle Annualized Costs of New OTRB Accessibility Requirements
 

Low Scenario

Primary Scenario

High Scenario

3% Discount Rate

$631

$1,124

$1,754

7% Discount Rate

$549

$971

$1,513

As this table demonstrates, the cost of the new OTRB accessibility requirements are expected to be relatively modest under all three cost scenarios.  Indeed, annualized costs per vehicle are not expected to exceed about $1,750 under even the high scenario.

Lastly, to provide a sense of the relative cost impact of each of the four new OTRB accessibility requirements, the Final RA explores annual costs for each requirement separately.  This breakdown of annual cost is presented in Figure 3 below.

Figure 3 - Breakdown of Total Annual Costs of New OTRBs Accessibility Requirements under Primary Scenario (in Nominal Dollars), by Regulatory Year

Figure 3 of 4, stacked bar chart with 5 horizontal bars.

This figure clearly shows that the requirement for exterior destination/route signage is expected, relatively speaking, to have the highest cost among these four OTRB requirements.

7.2.   Additional Cost Studies: Stress Tests for Selected Assumptions

In addition to the foregoing annual (and annualized) cost studies—which examine the range of costs of the final rule in light of the estimated likely values for all cost-related assumptions—the Final RA also includes four other limited assessments in order to explore the relative impact of modifying certain cost-related parameters.  These analyses are intended to evaluate changes in costs from alternate assumptions.  These changes are not intended to model realistic values for these four cost parameters.  Rather, these studies are intended to serve as "stress analyses" to examine how results would be impacted by a "hypothetical" adjustment in a cost parameter.  The four "stress tests" separately examine the impact of adjustments to the cost model by substantially increasing one of four key cost parameters—two related to cost calculations for the automated announcement systems requirement, and two related to the cost calculus for the new OTRB accessibility requirements.

7.2.1.   Unit Costs for Automated Announcement Systems

The first stress test assesses the impact of substantial increases in unit costs for automated announcement systems.  Specifically, all unit cost values used in the cost model calculate costs for this this requirement (with the exception of hourly or annual wage rates for transit agency employees)—including one-time costs for onboard equipment and backend systems, annual operation and maintenance expenses, and mid-life software upgrades—were inflated by 25%.  The results from this first stress test are presented below in Figure 4.

Figure 4 - Impact of Increase in Unit Costs of Automated Announcement Systems Requirement on Per-Agency Annualized Costs (Stress Test #1)

Figure 4 of 3, line graph with 3 pairs of lines, each with 3 data points.

As demonstrated by the figure above, a 25% increase in unit costs for automated announcement systems would result, not surprisingly, in a concomitant rise in overall costs for this requirement under each L-M-H scenario.  This inflationary effect on overall results, however, does not fall equally, in a relative sense, across the three cost scenarios.  Rather, the low scenario experiences the smallest differential as between results from the stress test and "main" analysis, while the high scenario exhibits the largest differential.  This stress test demonstrates that, because initial costs for deployment of automated announcement represent the largest component of their total (lifecycle) costs, the largest transit agencies (Tier III) would be most affected by increases in unit costs for automated announcement systems.

7.2.2.   Number of Large Transit Agencies Likely to Incur Costs under Automated Announcement Systems Requirement

The second stress test evaluates the impact of a hypothetical, significant increase in the number of large transit agencies at "Year 1" that do not already have automated announcement systems (or firm plans for such systems) and, thereby, incur compliance costs under the automated announcement system requirement.  In this test, the number of affected transit agencies was inflated by 25%.   The net effect of this increase is, with respect to the number of large transit agencies that incur compliance costs under the announcement systems requirement, to add two additional agencies per agency category (i.e., Tiers I, II & III) relative to the main analysis.[68]

The impact on overall costs from this second stress test are shown below in Table 15, which presents the increase in annualized costs of the final rule from the stress test relative to the main analysis.

Table 15 - Impact of Increase in Number of Large Transit Agencies Expected to Incur Compliance Costs under Automated Announcement Systems Requirement on Annualized Costs of Final Rule

Discount Rate

Low Estimate   ($millions)

Primary  Estimate ($millions)

High Estimate   ($millions)

3%

$0.6

$1.1

$1.8

7%

$0.5

$1.0

$1.6

In sum, this stress test shows that increasing the number of large transit agencies incurring compliance costs under the requirement for automated announcement systems raises annualized costs by about $500,000 under each L-M-H scenario at both 3% and 7% discount rates.

7.2.3.   Percentage of OTRBs Operating in Fixed Route Service

Turning to the OTRB-related requirements, the third stress test examines the impact of a significant increase in the percentage of OTRBs assumed to be operating in fixed route service.  This proportional change affects the number of OTRBs potentially incurring costs under the requirements for public address systems, stop request systems, and priority seat signage since these requirements are limited to large vehicles in fixed-route service.  For this stress test, 50% of the total OTRB fleet was assumed to be operating in fixed route service and thereby subject to these three requirements, which represents a 20% relative to the "regular" cost model.  The results from this third stress test are provided in Table 16 below.

Table 16 - Impact of Increase in Assumed Proportion of OTRBs Used in Fixed Route Service on Per-Vehicle Annualized Costs
 

Low Scenario

Med Scenario

High Scenario

3% Discount Rate

$49

$97

$159

7% Discount Rate

$43

$84

$137

As this table demonstrates, annualized costs per vehicle are only modestly sensitive to a substantial increase in the proportion of the total OTRB fleet assumed to be operating in fixed-route service.  Under the high scenario, for example, annualized costs under the stress test rise by less than $160 per vehicle.  This is likely due to two considerations.  First, the three affected requirements (i.e., public address systems, stop request systems, and priority seating signage) are not typically high-cost items, so that even a several-fold increase in the number of affected vehicles does not have a significant impact on costs overall.  Second, even though this stress test increases the number of OTRBs incurring compliance costs under these requirements, this still represents only a portion of the total OTRB fleet nationally, thereby muting the impact of such a change on per vehicle annualized costs.

7.2.4.   Likelihoods of Changes that Incur OTRB Compliance Costs

The fourth—and final—stress test explores the impact of a hypothetical across-the-board increase in the likelihoods that OTRBs will incur compliance costs related to the new OTRB accessibility requirements.  Specifically, this stress test assumes a 50% greater likelihood that an OTRB would not, based on current industry practice or assumed mode of operation, have the accessibility features required by the final rule and, thereby, incur compliance costs.  Only costs related to the requirements for priority seating signs, exterior destination/route signs, public address systems, and stop request systems are affected by this hypothetical increase in likelihoods.  (The cost model already conservatively assumes that all OTRBs will incur compliance costs to identify wheelchair spaces and accessible doorways with the International Symbol of Accessibility (i.e., 100% likelihood).  See Appendix D.)  The results from the fourth stress test are provided in Table 17 below.

Table 17 - Impact of Increase in Likelihoods that OTRBs Will Incur Compliance Costs under New Accessibility Requirements on Per-Vehicle Annualized Costs
 

Low Scenario

Primary Scenario

High Scenario

3% Discount Rate

$693

$833

$920

7% Discount Rate

$603

$720

$792

As this table shows, an across-the-board 50% increase in likelihoods has a sizeable impact on costs, with overall per-vehicle annualized costs rising about $700 (low scenario/3% discount rate) to just under $1,000 (high scenario/7% discount rate) depending on the scenario and discount rate.  This increase in likelihoods, moreover, had significantly greater cost impact on per-vehicle annualized costs as compared to third stress test, which evaluated the impact of a higher proportion of OTRBs operating in fixed route service.  This is largely due to the fact that this fourth stress test explores the impact of increasing a cost factor (i.e., likelihood of incurring costs) that applies to all OTRBs, whereas the third stress test involves one cost factor (i.e., type of service) that affects only a portion of the total U.S. fleet of OTRBs.  Nevertheless, this fourth stress test serves to underscore the significant role likelihoods play in the calculation of costs for OTRB-related accessibility requirements.


   8.   Alternative Regulatory Approaches: Large Transit Agencies and the VOMS 100 Threshold

While other sections of this regulatory assessment evaluate the likely incremental costs and benefits of new or revised accessibility requirements in the final rule, this section aims to explore one specific requirement from a slightly different perspective – namely,  some of the primary quantitative factors supporting promulgation of a VOMS 100 threshold for large transit agencies (which are the only transit agencies subject to the automated announcement systems requirement) in lieu of other potential VOMS thresholds.  As discussed more fully in the preamble to the final rule, establishment of a 100-bus VOMS threshold for large transit agencies, in the Access Board's view, strikes a reasonable balance between competing interests (e.g., improved communication accessibility versus not overburdening smaller transit agencies).  See Preamble to Final Rule – Americans with Disabilities Act Transportation Vehicle Guidelines, Section III (Major Issues – Automated Stop Announcements).  This section explores some of the quantitative considerations underlying the agency's establishment of a VOMS 100 threshold for large transit agencies, as opposed to other potential numeric thresholds.

As an initial matter, it bears noting that the scope of the automated announcement requirement has narrowed since it was first proposed by the Access Board in 2007.  As discussed in the preamble to the final rule, under the Board's 2007 draft revisions to the existing vehicle accessibility guidelines, all transit agencies - regardless of size - would have been required to outfit their large, fixed-route buses with automated stop and route announcement systems.  Id. at Sections II (Regulatory History) & III (Major Issues – Automated Stop Announcements).  Several commenters responded by urging the agency to add a "small fleet exemption" to the automated announcement systems requirement because, in their view, smaller agencies often lack the financial resources or technical knowledge needed to acquire and implement such systems.  Id. at Section II (Regulatory History).  To address these concerns, when the Access Board published a second set of draft revisions to the existing vehicle guidelines the following year (2008), application of the automated announcement systems requirement was limited to larger transit agencies that operated 100 or more buses in annual maximum service (VOMS).  Id.  In establishing a VOMS 100 threshold for transit agencies subject to the automated announcement systems requirement, the Access Board's primary aims were to limit coverage to larger transit entities that were most likely to (i) have the financial and technological resources to deploy automated announcement system functionality, and (ii) serve a significant population of persons with disabilities.  Id. at Sections II (Regulatory History) & III (Major Issues – Automated Stop Announcements).   The proposal in the 2008 draft revised vehicle accessibility guidelines for inclusion of a VOMS 100 threshold in the automated announcement systems requirement received no negative comments.  Id. at Section II (Regulatory History).  The VOMS 100 threshold was thus carried forward with only minor (non-substantive) changes to the 2010 NPRM (where it also received no negative comments), and, subsequently, to the final rule.  Id.

Inclusion of a VOMS 100 threshold in the final rule, while not solely data-driven, was nonetheless backed by several quantitative considerations that pointed to this numeric threshold as an appropriate and reasonable metric by which to classify large transit agencies.  Comparison between and among transit agencies of various sizes was facilitated by data from the National Transportation Database (NTD), which provides a wealth of information on public transit entities operating in urbanized areas (UZAs)[69], including geographic, modal, operational, and financial information.[70]  Though the NTD provides a significant amount of data, it does not, however, capture information specific to persons with disabilities, such as transit ridership or population within particular geographic areas.  Consequently, to develop per-agency estimates of bus ridership by disabled passengers and the population of persons with disabilities within particular service areas, the Access Board looked to two other federal data sources for UZA-based statistics on individuals with disabilities (Census Bureau) and survey data on bus ridership by persons with disabilities (DOT/TCRP), which, when combined with NTD data, produced estimated population and ridership figures.  See FRIA, App. J, p. J-28 (summary key describing data sources and methodologies used to calculate estimated service area population and bus ridership figures presented in Appendix J).

Taken together, these data enabled the Access Board to "build" a database with information on urban transit agencies of all sizes that operate fixed-route buses in the United States and its territories.  In sum, this dataset permitted the Board to not only paint a quantitative portrait of each of the 681 urban transit agencies operating one or more bus modes according to 2014 NTD data, but also evaluate how drawing different numeric lines for the VOMS threshold might impact transit agencies of various sizes.  A complete list of all 681 urban transit agencies that reported operation of one or more fixed-route buses in annual maximum service in 2014, along with some of their key characteristics, is provided in Appendix J.  See also Tables 18 & 19, infra.  Information presented in Appendix J includes data taken directly from 2014 NTD annual data (e.g., primary UZA, bus VOMS, total federal capital funds), as well as estimated figures related to persons with disabilities (i.e., population of persons with disabilities per service area, number of unlinked passenger trips by persons with disabilities for all fixed-route bus modes).  See App. J, p. J-28 (key summarizing data sources and methodologies for data presented in Appendix J).

Based on this dataset, the Access Board conducted comparative analyses of alternate thresholds for large transit agencies that potentially could have been used (from a quantitative perspective) in the final rule, with particular emphasis on 50- and 250-bus VOMS levels as potential alternate regulatory approaches.  The 50- and 250- bus VOMS levels were selected for analysis because they (i) represent VOMS levels above and below the VOMS 100 threshold used in the final rule, and (ii) replicate break-points in the VOMS-level groups used by FTA to report NTD annual data.[71]

Summarized below are the results from comparative analysis of these three VOMS thresholds – VOMS 50, VOMS 100 and VOMS 250 – from several perspectives, including covered transit agencies' projected service area populations of persons with disabilities, bus ridership by disabled passengers, and availability of federal funds for ADA-related capital expenditures (such as deployment of automated announcement systems).  All of the results discussed below are based directly on, or are derived from, the dataset presented in Appendix J – namely, the 681 urban transit agencies reporting one or more buses operated in annual maximum service based on 2014 NTD annual data.

First, with respect to service area populations and bus ridership by persons with disabilities, estimates for the VOMS 100 threshold fall between those for the alternative VOMS 50 and VOMS 250 thresholds.  Estimated service area population and bus ridership by persons with disabilities (denoted using "PWD" in the table below) for each of the three studied VOMS levels are as follows:

Table 18:  Comparison of Estimated Service Area Populations and Bus Ridership by Persons with Disabilities Using Three Different VOMS Thresholds (Based on 2014 NTD Annual Data)

VOMS Threshold
(all Bus Modes)

# Transit Agencies
(per VOMS Threshold)

Service Area Population - PWD
(Estimated)*

% Total SA
Pop./PWD

Unlinked Passenger Trips - PWD
(Estimated)*

% Total
UPT/PWD

All Transit Agencies
(Totals) =

681

44,404,008

100.0%

258,796,035

100.0%

VOMS 250

47

14,388,634

32.4%

192,902,910

74.5%

VOMS 100

99

21,400,372

48.2%

221,355,379

85.5%

 VOMS 50

170

27,971,416

63.0%

237,504,055

91.8%

On close review, however, the data in Table 18 provide some illuminating results.  Notably, the VOMS 100 threshold encompasses service areas with a total population of persons with disabilities that is about 49% greater than the total population served by an alternate VOMS 250 threshold (i.e., 21.4 million vs.14.4 million).  Additionally, in terms of projected bus ridership by persons with disabilities, the VOMS 100 threshold is expected to generate about 15% more annual trips by passengers with disabilities on covered buses than would a VOMS 250 threshold (i.e., 221.4 million vs. 192.9 million).  Conversely, an alternate VOMS 50 threshold – because it covers significantly more transit agencies – would be expected to have higher service areas populations and bus ridership levels by passengers with disabilities than the VOMS 100 threshold; however, the relative differences between these two thresholds in service area population and bus ridership would be smaller than the VOMS 100/VOMS 250 differential.  Taken together, these results lead to the conclusion that the VOMS 100 threshold is superior to an alternative, higher (VOMS 250) threshold in terms of maximizing potential beneficiaries (i.e., individuals with disabilities who live in areas served by covered transit agencies and disabled bus passengers), while a lower VOMS threshold (VOMS 50) would produce only marginal increases in total service area population and bus ridership by individuals with disabilities.

Second, in terms of geographical coverage, each of the three studied VOMS thresholds would cover transit agencies nationwide, though such coverage would also vary in distinctive ways.  An alternate VOMS 250 threshold would predominantly cover only transit agencies situated in America's largest metropolitan areas with several million residents – such as New York, Los Angeles, Miami, Philadelphia, Boston, Chicago, Dallas, and Phoenix.  See Appendix J, pp. J-1 to J-3.  The VOMS 100 threshold, in turn, encompasses transit agencies located in both large and medium-sized UZAs nationwide.  See id. at pp. J-1 to J-6.  Lastly, the alternate VOMS 50 threshold would embrace the widest size range of UZAs, from the largest metro areas to relatively smaller urban areas with only several thousand residents.  See id. at pp. J-1 to J-9.

Based on this geographical data, the VOMS 100 threshold can be viewed as striking a middle ground in terms of scope of covered urban areas.  First, relative to an alternate VOMS 250 threshold, the VOMS 100 threshold covers transit agencies across a significantly broader range of urban areas, from both geographical and demographic perspectives.  For example, based on 2014 NTD data, a VOMS 100 threshold encompasses transit agencies in 64 different UZAs across the country, whereas a VOMS 250 threshold would cover transit agencies only in 33 different UZAs.  See id. at pp. J-1 to J-6.  Noticeably absent from coverage under a VOMS 250 threshold would be large and medium-sized UZAs throughout the country, including: Detroit, MI; Virginia Beach, VA; Rochester, NY; Hartford, CT; Tucson, AZ; Tampa-St. Petersburg, FL; Louisville/Jefferson County, KY-IN; Riverside-San Bernardino, CA; Kansas City, MO-KS; Indianapolis, IN; Providence, RI-MA; Memphis, TN-MS-AR; and Salt Lake City-West Valley City, UT.  Id.  A VOMS 250 threshold would thus leave millions of persons with disabilities in metro areas nationwide potentially without access to automatic announcement-equipped fixed-route transit buses.  Second, unlike the alternate VOMS 50 threshold, the VOMS 100 threshold would not extend coverage to transit agencies located in relatively smaller UZAs, such as: Lafayette, IN; Duluth, MN-WI; Burlington, VT; State College, PA; Ames, IA; and, Olympia-Lacey, WA.  See id. at pp. J-1 to J-9.

Lastly, it is important to assess the availability of federal funds for transit agencies' capital expenditures across the three studied VOMS thresholds given that deployment of automated announcement systems (or ITS/AVL systems) constitute capital expenses.[72]  Funding support for capital expenses by urban transit agencies comes largely from the federal government.  For example, in 2014, federal funds (totaling $7.8 billion) accounted for 42% of all capital expenses by urban reporters.[73]  Consequently, nearly all urban transit agencies receive federal monies for capital expenses, whether under DOT/FTA-administered formula grant programs, competitive grant programs, or both.  See, e.g., App. J, pp. J-1 to J-28.[74]  Indeed, across the cumulative 171 urban transit agencies that would be covered under one of more of the three studied VOMS thresholds, about 95% reported using federal funds for capital expenditures in 2014.  Id.  Generally, while federal grants for capital expenses may be used on a variety of capital projects (such as replacing existing revenue vehicles, constructing subway facilities, purchasing communications systems, or building new passenger stations), there often are federal match requirements.  For example, under the Urbanized Area Formula Grant program (49 U.S.C. § 5307) – which is the single largest federal capital grant program for public transit – the federal share cannot exceed 80% of the net expenditures for capital projects; however, for ADA-related capital expenditures, the federal share may be up to 90% of net project costs.[75]

To explore relative differences in the projected availability of federal funds for ADA-related bus transit projects – such as deployment of automated announcement systems or upgrading existing ITS/AVL, it was necessary to refine the per-agency data on federal capital funds listed in Appendix J.  See App. J (column heading "Total Federal Capital Funds").  That is, because NTD data present only summary totals for monies expended under federal capital grant programs, several additional assumptions (and calculations) were needed to estimate how much of these capital funds might reasonably be considered available for ADA-related bus projects.  First, to apportion total federal capital funds among different modes of service on a per-agency basis, it was assumed that each transit agency would allocate their respective capital expenditures on bus-related projects in an amount equal to their buses' pro rata share of total vehicle inventory (i.e., ratio of Bus VOMS:Total VOMS).  Second, because the Urbanized Area Grant program makes up the vast bulk of federal capital funds, it was further assumed that up to 90% of these federal funds could be used on ADA-related capital projects.  These two assumptions were then applied on a per-agency basis to 2014 NTD data on federal capital funds, with the net result being an estimated figure representing the amount of federal capital funds available on a per-agency basis to potentially offset deployment costs for automated announcement systems (or other ADA-related capital expenses).[76]

 Presented below in Table 19 are the resulting estimates of federal capital funds available to transit agencies of various size groupings for ADA-related bus projects.  The results in this table are broken down according to seven size-based categories of transit agencies (rather than by the three studied VOMS thresholds) to permit a more nuanced analysis of the data.  The seven transit agency size categories mirror the VOMS-level groups used by FTA to report NTD annual data.  See discussion, supra, p. 49 & n. 71.

Table 19:  Estimated Federal Capital Funds Available for ADA-Related Bus Transit Projects by NTD Transit Agency Size Category (Based on 2014 NTD Data)
Transit Agency Size Category - Bus VOMS
(by NTD Group)
Number of Transit AgenciesFederal Capital Funds Available
(by NTD Group) – ADA-Related Bus Projects
>(Estimated)*
($1000s)
Federal Capital Funds Available
(per Transit Agency) – ADA-Related Bus Projects
(Estimated)*
($1000s)
Federal Capital Funds Available (per Bus)
– ADA - Related Bus Projects (Estimated)*

1,000 & Over

9

1,974,898.6

219,433.2

60,886.7

250-499

28

810,428.6

28,943.9

51,627.3

100-249

52

659,211.9

12,677.2

49,736.5

50-99

71

202,521.3

2,852.4

24,147.3

25-49

118

311,425.5

2,639.2

43,882.7

10-24

181

138,808.0

766.9

25,150.9

Under 10

212

133,994.6

632.1

31,909.4

 Total Agencies/Fed. Capital

Funds Avail. (median) =

681

485,318.7

(median)

7,764.8

(median)

46,809.6

(median)

The foregoing data illuminates two important points.  First, transit agencies with bus VOMS at or near (but not under) the VOMS 100 threshold appear as well-positioned as larger agencies to fund deployment of automated announcement systems using federal capital grant monies.  Notably, estimated federal capital funds available to transit agencies in the 100-249 size category for ADA-related bus projects are – on a per-bus basis – nearly equal to the funds available to the next largest size category of transit agencies (250- 499 buses).  This finding provides implicit support for one of the central assumptions underlying the Access Board's promulgation of the VOMS 100 threshold – namely, that covered transit agencies would have sufficient financial resources (including federal capital funds) to offset the costs of deploying automated announcement systems (or upgrading existing systems) on their fixed-route transit buses to the extent they had not already deployed such systems.  Moreover, all of the transit agencies in the three size categories at or above the VOMS 100 threshold (i.e., 1000 & Over, 250-499, and 100-249) have estimated totals of federal capital funds available for ADA-related bus projects that are above the median per-group, per-agency, and per-bus figures.

Second, for transit agencies below the VOMS 100 threshold, there is a distinct and sizeable drop-off in total estimated federal capital funds available for ADA-related bus projects s.  For example, transit agencies in the size category immediately below the VOMS 100 threshold (i.e., 50-99 buses) have, on a per-bus basis, only about half the federal capital funds available for such projects as do agencies in the next highest (100-249) size category.  Additionally, transit agencies in each of the three size categories below the VOMS 100 threshold (i.e., 50-99, 25-49, and Under 10), have total estimated federal capital funds available for ADA-related bus projects that fall below the median per-group, per-agency, and per-bus figures.

Collectively, these two considerations drawn from the federal capital funding data presented in Table 19 above underscore both the propriety and reasonableness of the Access Board's promulgation of a VOMS 100 threshold for large transit agencies subject to the automated announcement systems requirement.


   9.   Small Business Analysis

As noted above, the Regulatory Flexibility Act ("RFA") generally requires federal agencies to assess the economic impact of regulatory action on small entities in terms of significance and proportionality as compared to other entities in the same industry.[77]  Consistent with this requirement, the Final RA includes a separate "threshold" small business assessment that evaluates the economic impact of the final rule on "small businesses" in industry sectors that include OTRB-provided transportation, charter, or sightseeing services.  The results of this small business "threshold" assessment shows that, while the final rule will undoubtedly affect a substantial number of "small business"-sized OTRB firms, its economic impact will be neither significant nor disproportionate relative to other firms.

As noted previously, see supra Section 4.3, approximately 2,600 firms—or about 95% of firms—in the four industry sectors most closely aligned with OTRB-provided transportation and other services qualify as "small businesses" (or firms) based on SBA small business size standards.  Yet, while the final rule is thus expected to have widespread impact in terms of the number of affected small businesses, compliance costs for small firms that potentially operate OTRBs are not expected to be weighty.  This conclusion is based on an assessment of the economic (cost) impact of the final rule on small businesses in terms of annualized per-facility costs, annualized per-facility costs as a percentage of annual receipts ("sales receipt test"), and annualized per-facility costs as a percentage of payroll costs ("payroll cost test").[78]  A detailed discussion of the sources for, and methodology for compilation of, this small business data is provided in Appendix G.

None of these analyses demonstrate that the final rule will impose economically substantial costs on small businesses in the four industry sectors most closely aligned with provision of OTRB-related services.  Annualized costs for small OTRB firms are only expected to be about $900 - $1,000 per vehicle under the primary cost scenario.  See discussion supra Section 7.1.3 & Tbl. 13.  Nor would such costs be disproportionately borne by small businesses.  Table 18, below, demonstrates that costs for small OTRB firms are less than 10% of annual costs for other (non-small) firms in the same industry sectors.

Table 20 - Comparative Annual Per-Firm Costs of New OTRB Accessibility Requirements

Total Costs (Years 1 - 12)

 Average Annual Costs Per Firm (Years 1 - 12)

Other Firms

Small Firms

Other Firms

Small Firms

Cost Per Firm Ratio
(Small Firms/Other Firms)

$4,409,689

$6,089,564

$2,466

$151

0.061

Annual costs for small OTRB firms, moreover, represent only a fraction of these firms' collective annual sales receipts and payrolls.  Annual per-firm costs relative to sales receipts and payroll are presented in Tables 21 and 22 below.  As depicted in these tables, both the "payroll cost test" and the "sales receipt test" demonstrate that annual compliance costs for the new OTRB requirements are expected to be less than 1% of annual payroll and sales receipts respectively.

Table 21 – ;Comparative Ratios of Annual Per-Firm Costs to Payroll

Average Annual Cost Per Firm

 Ratio of Average Annual Per-Firm Costs to Payroll

Other Firms  

Small Firms 

Other Firms 

Small Firms

Cost:Payroll Ratio  
(Small Firms/Others Firms)

$2,466

$151

0.016%

0.040%

2.47

Table 22 – Comparative Ratios of Annual Per-Firm Costs to Sales Receipts

Average Annual Cost Per Firm

Ratio of Average Annual Per-Firm Costs to Sales Receipts

Other Firms

Small Firms

Other Firms

Small Firms

Cost: Sales Receipt Ratio
(Small Firms/Other Firms)

$2,466

$151

0.007%

0.013%

1.68

Comparative analysis of per firm annual cost-to-payroll and annual cost-to-sales receipt ratios for small OTRB firms versus other (larger) firms in the same industry sectors, moreover, shows that small firms will experience only modestly higher ratios.  (The higher the ratio, the higher the cost burden relative to sales or payroll for small firms in comparison to larger firms.)  The cost-to-payroll ratio for small OTRB firms is 2.47, while the cost-to-sales receipt ratio is slightly lower, at 1.68.  Such ratios demonstrate that compliance costs under the final rule are distributed fairly equally amongst firms of all sizes in these industry sectors relative to their respective differences in sales receipts and payroll costs.

 


Data Tables for Figures

Data for Figure 1
Nominal Dollars
 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10Year 11Year 12
Low Scenario $4,269,309 $2,768,497 $2,870,293 $2,787,898 $2,785,039 $3,051,018 $2,969,299 $2,808,569 $2,909,601 $2,822,834 $2,821,073 $2,922,822
Primary Scenario $10,929,430 $4,839,365 $5,232,014 $4,923,332 $4,928,772 $5,390,321 $5,123,423 $4,951,800 $5,229,843 $4,956,592 $4,962,209 $5,240,340
High Scenario $18,170,815 $7,624,009 $8,044,432 $7,756,070 $7,780,287 $8,398,979 $8,110,110 $7,940,940 $8,356,064 $8,061,203 $8,086,197 $8,502,421
Data for Figure 2
Requirement CategoryTotal Cost
(Nominal Dollars)
Total =  $66,707,440
Announcement Systems - Initial Costs $41,949,479
AnnouncementSystems - Ongoing (O&M) Costs $11,124,485
Wheelchair Space ID (ISA Decals) $393,552
Exerior Destination/Route Signage $11,808,000
Public Address System $369,000
Stop Request System $795,600
OTRBs - Ongoing (O&M) Costs $267,324
Data for Figure 3
 Identification of Accessible Seating and Doorways (Signs/ISA Decals)Exterior Destination/Route SignagePublic Address SystemsStop Request SystemsO&M CostsTotal Cost
(Nominal Dollars)
Totals =  $1,576,361 $11,808,000 $369,000 $795,600 $290,976 $14,839,937
Year 1 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 2 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 3 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 4 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 5 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 6 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 7 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 8 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 9 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 10 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 11 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Year 12 $131,363 $984,000 $30,750 $66,300 $24,248 $1,236,661
Data for Figure 4
 Low
(Stress Test #1)
Primary
(Stress Test #1)
High
(Stress Test #1)
Low
(Main Analysis)
Primary
(Main Analysis)
High
(Main Analysis)
Large Transit Agency - Tier I $55,269 $101,031 $163,159 $44,208 $80,659 $129,305
Large Transit Agency - Tier II $95,840 $194,063 $313,051 $76,678 $154,985 $248,313
Large Transit Agency - Tier III $161,811 $331,867 $542,251 $129,444 $264,968 $429,715

End Notes

[1] Notice of Proposed Rulemaking, 75 Fed. Reg. 43,748 (July 26, 2010) [hereinafter, "NPRM"]; see also 36 C.F.R. pt. 1192, subpts. B & G (existing regulations for buses, vans, and over-the-road buses).   Prior to the publication of the NPRM, the Access Board also posted on its website—and accepted comments on—draft revisions to the existing requirements for buses, vans, and OTRBs.  See Availability of Draft Revisions to Guidelines, 72 Fed. Reg. 18,179 (Apr. 11, 2007); Availability of Draft Revisions to Guidelines, 73 Fed. Reg. 69,652 (Nov. 19, 2008).

[2] See id. at 43,749.

[3] Id. at 43,753-54 (discussing proposed T203.13 and T704).  The final rule increased the minimum length threshold for "large vehicles" from 22 feet to 25 feet based on comments to the NPRM observing that the exterior length of vans and small buses had increased in recent years to accommodate safety bumpers and frontal crash protection features, without a concomitant increase in interior passenger space or square footage.  See Preamble to Final Rule – Americans with Disabilities Act Transportation Vehicle Guidelines, Section IV (Summary of Significant Comments on Other Aspects of the Proposed Rule) – T103 Definitions (discussing definitions of "large vehicle" and "small vehicle").  This slight modification to the definition of "large vehicle" in the final rule is not expected to have any material cost impact.

[4] Access Board, Cost Estimates for Automated Stop and Route Announcements (July 2010), available at: http://www.regulations.gov/#!documentDetail;D=ATBCB-2010-0004-0003 (last accessed Jan. 4, 2016).

[5] Subsequently, in 2012, the comment period was reopened for several months to solicit additional public input on regulatory requirements for bus ramps.  See Notice of Public Information Meeting and Reopening of Comment Period, 77 Fed. Reg. 50,068 (Aug. 20, 2012).

[6]  See, e.g., Transportation Research Board, TCRP Report 163, Strategy Guide to Enable and Promote Use of Fixed-Route Transit by People with Disabilities 35-36 (2013) (noting importance of high-level management support for effective onboard stop and route announcement programs, including comprehensive driver training, proactive monitoring, and discipline/incentives programs).

[7] Based on ADA compliance reviews by DOT's Federal Transit Administration, operator-based stop and route announcements are a frequent source of rider complaints.  DOT/FTA compliance review reports are available at: http://www.fta.dot.gov/civilrights/12875_3899.html.

[8] See id.  For example, in a compliance review of the Springfield Mass Transit District, the FTA observers found that stops were announced by vehicle operators and audible on only 38% of route segments, and, on 32% of route segments, there were no stop announcements made by vehicle operators.  See ADA Fixed Service Review -Springfield Mass Transit District, Review of Stop Announcement and Route Identification Efforts 13-14 (July 6, 2012), available at: http://www.fta.dot.gov/documents/SMTD_Final_Report.pdf (last visited: Jan. 19, 2016).

[9] See, e.g., Tandy v. City of Wichita, 380 F. 3d 1277 (10 Cir. 2004); Stewart v. New York Transit Auth., 2006 U.S. District LEXIS 4279 (Feb. 6, 2006); Martin v. Metropolitan Atlanta Rapid Transit Authority, 225 F. Supp. 2d 1362 (N.D. Ga. 2002); Neff v. VIA Metropolitan Transit Authority, 178 F.R.D. 185 (W.D. Tex. 1998); see also Daniels-Finegold v. Massachusetts Bay Transportation Authority, C.A. No. 02 CV 11504 MEL (U.S. Dist. Ct. Mass. filed June 15, 2006) (approving class action settlement and entering final judgement in ADA litigation alleging system-wide problems in provision of accessible public transportation by defendant transit agency, including failure to announce stops and routes).

[10] See, e.g., National Council on Disability, Transportation Update: Where We've Gone and What We've Learned 38-39 (May 4, 2015), available at: http://www.ncd.gov/publications/2015/05042015; National Council on Disability, Current State of Transportation for People with Disabilities in the United States (June 13, 2005), available at: http://www.ncd.gov/policy/current-state-transportation-people-disabilities-united-states.

[11] DOT, FHWA-JPO-11-052, Intelligent Transportation Systems (ITS) Standards Program Strategic Plan for 2011–2014 4, 7 (April 2011).  DOT's ITS Joint Program Office, on its FAQ web page, describes ITS as follows: "ITS improves transportation safety and mobility . . . through the integration of advanced communications technologies into the transportation infrastructure and in vehicles. [ITS] encompass a broad range of wireless and wire line communications-based information and electronics technologies." DOT/ITS Joint Program Office, About ITS – Frequently Asked Questions, http://www.its.dot.gov/faqs.htm (last visited January 4, 2016).

[12] For good descriptions of typical AVL/CAD system architecture and features when deployed by bus transit systems, see DOT/FTA, Transportation Research Board, TCRP Synthesis 73 AVL Systems for Bus Transit: Update 1-8 (2008); Advanced Public Transportation Systems: The State of the Art Update 2006, Chaps. 2, 3 & 5 (March 2006).  While AVL systems now predominately rely on GPS-based methods of determining vehicle position, some systems still use signals from signposts or dead-reckoning (i.e., calculation from a known position, odometers, compass readings), either alone or as a complement to a GPS-based system.  TCRP Synthesis 73 at 6-7, 92-93; David P. Racca, Costs and Benefits of Advanced Public Transportation Systems at Dart First State 2-3 (July 2004).

[13] DOT, Deployment of Intelligent Transportation Systems: A Summary of the 2013 National Survey Results xiv, 26-27 (Aug. 2014).  The data also show that the proportion of transit agencies deploying AVL on fixed route buses continued to increase in 2013, and at an accelerated rate between 2010 and 2013.  Id. at 27.

[14] See, e.g., id.; DOT/FTA, APTS State of the Art Update 2006, supra note 12, at chaps. 3 & 4.

[15] Historical data on ASA deployment is based on the Appendix to APTA's 2015 Public Transportation Fact Book, which provides data on vehicle amenities by mode of travel from 2001 through 2014.  See 2015 Public Transportation Fact Book, Appendix A: Historical Tables, Table 30 (June 2015), available at: https://www.apta.com/resources/statistics/Documents/FactBook/2015-APTA-Fact-Book-Appendix-A.pdf.   Data on ASA deployments in 2015 is derived from a sample of vehicle amenity data in the 2015 APTA Public Transportation Database, which is available for purchase from APTA.

[16] See, e.g., National Council on Disability, Transportation Update: Where We've Gone and What We've Learned 42-43 (May 2015); National Council on Disability, The Current State of Transportation for People with Disabilities in the United States 26-30 (June 2005).

[17] For a discussion of suggested maintenance and training best practices for successful implementation of automated (or manual) stop and route announcement programs, see Easter Seals Project ACTION, Accessible Community Transportation in Our Nation: Resource Guide to Effective Approaches for Increasing Stop Announcements and Route Identification by Transit Operators 40-49, 65-68 (June 2009).

[18] See NCD, Transportation Update 2015, supra n. 10, at 21, 38-39; see also DOT/FTA, ADA Compliance Review Final Reports – Fixed Route Operations (2000 - 2015), available at: http://www.fta.dot.gov/civilrights/12875_3899.html (last visited Jan. 19, 2016).  For example, when reviewing the King County Metro Transit, FTA observers found that its automated announcement system properly announced about 90% of programmed stops (though observers also took issue with KCMT's selection of programmed stops).  See FTA, King County Metro Transit – FTA ADA Stop Announcement and Route Identification Review Report 14-15 (Aug. 2015).  Perhaps the best window into the value of automated announcement systems is provided by FTA compliance reviews conducted when transit agencies are in the midst of transitioning to automated announcement systems, since this provides a direct comparison of automated stop announcements versus vehicle operator-based announcements.  In such reviews, within the same agency, vehicles equipped with automated announcement far out-performed vehicles without such equipment, which instead had to rely on vehicle operators to announce stops and provide route identification information.  See, e.g., FTA, Toledo Area Regional Transit Authority - Review of Route Identification and Stop Announcements 25 & tbl. 4.1 (Nov. 28, 2011) (TARTA "Talking Bus" system properly announced the majority of stops on 45% of route segments, whereas, on vehicles without this system, operator performance was "poor," with 73% of route segments having no stop announcements); FTA, Los Angeles County Metropolitan Transit Authority - Review of Route Identification and Stop Announcements 24 (Sept. 30, 2010) (finding that, on transit buses equipped with automated announcement systems, all or most of the stops were properly announced on 89% of observed route segments; on buses operated by contractors without announcement system equipment, compliance was characterized as "low" with only 13% of route segments having similar stop announcement performance and 56% of route segments having no announcements).

[19] See, e.g., Docket ## ATBCB-2010-004-0052 (comment submitted by Lift-U observing that "the majority of low floor bus manufacturers now offer a 1:6 ramp slope to the roadway"), -0078 (comment submitted by Ricon Corp.) & -0088 (comments by representatives from ARBOC Technologies, Dallas Smith Corp., and Lift-U at public information meeting).  Online research by Access Board staff also found that, as of 2016, all major manufacturers of large, heavy-duty transit buses offer low floor bus models that accept drop-in modules for 1:6 ramps; most manufacturers of smaller cutaway buses also offer low floor models that can be equipped with 1:6 ramps.

[20] See, e.g., Docket # ATBCB-2010-004-0052 (Lift-U comment noting that "there is relatively no change to the purchase price or maintenance costs per bus for [the company's] 1:6 ramp models").  In 2016, Access Board staff contacted several manufacturers who noted that, for heavy-duty low floor transit buses, 1:6 ramps are now generally less expensive than steeper (1:4) ramps, which are considered non-production, special order items.  Current costs for 1:6 ramps are about equal to costs for 1:4 ramps when these latter types of ramps were still in regular production.

[21] See, e.g., Docket ## ATBCB-2010-004-0082 (comment by Lift-U noting that, as of late 2012, there were about 6,500 1:6 ramps in service on low floor transit buses operated by over 400 transit agencies) & -0088 (statement by Lift-U representative at public information meeting).

[22] See APTA Standard Bus Procurement Guidelines, § TS 81.3 (May 2013), available at: http://www.apta.com/resources/standards/Documents/APTA%20Bus%20Procurement%20Guidelines.docx.

[23] Under the final rule, which incorporates the definition of certain terms from existing DOT regulations, "buses" are defined as "self-propelled vehicles, generally rubber-tired, intended for use on city streets, highways, and busways . . . used by public entities to provide designated public transportation service and by private entities to provide transportation service including, but not limited to, specified public transportation services."  49 C.F.R. § 37.3; see also T103.2 (incorporating DOT definitions of terms not otherwise defined in final rule).  OTRBs, in turn, are a particular type of bus "characterized by an elevated passenger deck located over a baggage compartment."  49 C.F.R. § 37.3.  OTRBs rarely (if ever) fall below 25-feet in length.  Therefore, for purposes of evaluating the economic impact of the final rule, all OTRBs are deemed to be "large vehicles."

[24] This 12-year service-life assumption is based on the service-life for large, heavy-duty buses set forth in FTA regulations that govern bus procurements using federal funds.  See 49 C.F.R. § 665.11(e)(1).  This 12-year service life assumption was also used in the Preliminary RA.  See Preliminary RA at 13.

[25] See 5 U.S.C. § 604; Exec. Order 13,272, 67 Fed. Reg. 53,461 (Aug. 16, 2002); see also Small Business Administration, A Guide for Government Agencies: How to Comply with the Regulatory Flexibility Act (May 2012), available at: https://www.sba.gov/sites/default/files/rfaguide_0512_0.pdf.

[26] See 5 U.S.C. §§ 601(3) - (6).

[27] See Federal Transit Administration, 2013 National Transportation Database – Agency Information, http://www.ntdprogram.gov/ntdprogram/datbase/2013_database/NTDdatabase.htm (last visited Jan. 11, 2016).  Public transportation agencies that receive or benefit from federal formula grant programs for mass transportation in urbanized areas (49 U.S.C. § 5307) or rural areas (49 U.S.C. § 5311) are required to report specified financial and service data annually to the NTD.  See, e.g., FTA, NTD Policy Manual – 2014 Reporting Year 2-4 (Feb. 2015).  The online NTD reporting requirements (absent a waiver from DOT) differ substantially for urbanized area and rural reporters, with the rural reporting module having a simpler format with fewer data fields for sub-recipient rural and tribal transit agencies.  Id. at 10-16.

[28] See American Bus Assoc., Motorcoach Census 2013 10-11 (Feb. 2014).

[29] See U.S Census Bureau, 2012 NAICS Definitions (undated), available at: http://www.census.gov/eos/www/naics/2012NAICS/2012_Definition_File.pdf (last visited: Jan. 11, 2016).

[30] See SBA, Table of Small Business Size Standards Matched to North American Industry Classification System Codes 26-27 (Feb. 26, 2016), available at: https://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf (last visited Apr. 1, 2016).  The term "annual receipts," as used in SBA's small business size standards, consists of "total income" plus "cost of goods sold" as these latter two terms are defined in, and reported on, Internal Revenue Service tax forms.  See 13 C.F.R. § 121.104.

[31] See, e.g., FTA, NTD Policy Manual – 2014 Reporting Year 2-4 (Feb. 2015).

[32] Annual NTD databases, including the 2014 database, are available for download from the NTD program website.  See DOT/FTA, NTD Data, http://www.ntdprogram.gov/ntdprogram/data.htm (last visited: Jan. 19, 2016).

[33] This figure, which is drawn from Access Board research from publicly available information and information provided by several transit agencies, also finds implicit support in data from the 2015 APTA Vehicle Database on the current state of deployments of automated stop announcement systems.  According to this database, about 70% of existing fixed-route buses have stop announcement equipment installed.  See APTA, 2015 APTA Vehicle Database – Equipment Data (2015) (based on transit agencies reporting new data in 2014 or 2015).  Based on 2014 NTD data, this equates to about 27,500 buses across the total VOMS for all large transit agencies (i.e., 39,886 x .70).  See Appendix A at A-4.   The APTA database, however, reflects only existing installations of automated announcement system equipment; it does not capture transit agencies' ongoing fleet roll-outs for, or planned procurements of, automated announcement systems.  When these near-term projected announcement system deployments are taken into account, the figure used in this analysis dovetails with reported existing deployments in the 2015 APTA Vehicle Database.

[34] The American Bus Association Foundation has published a Motorcoach Census annually since 2010.  The 2014 Motorcoach Census is available at http://www.buses.org/assets/images/uploads/general/Report%20-%20Census2013data.pdf.  The Motorcoach Census for prior years (i.e., 2010 – 13) is also available on the ABA's website at http://www.buses.org/aba-foundation/research-summary/size-and-scope.

[35] Id. at 9.

[36] Id. at 20.

[37] See, e.g., ABA, 2014 Motorcoach Census at 12 (noting that about 34% of motorcoach service mileage in calendar year 2013 attributed to "scheduled service," and 6% to "commuter" service); Kathryn J. Ready, The Impact of Consolidation and Strategic Considerations in the Motorcoach Industry, 1 Intl. Bus. & Econ. Research J. 89, 90 (2011) (estimating about 25% of OTRBs used in fixed-route operations); KFG Group, Cost of Meeting Accessibility Requirements for Over-the-Road Buses 3-8, 3-12 (April 2000) (estimating, as part of economic analysis of then-new 1998 DOT final accessibility regulations applicable to OTRBs, that 29% to 33% of OTRBs were primarily used in fixed-route service).

[38] Preliminary RA at 1.

[39] Id. at Table 6 (cost factors).

[40] Id.

[41] Compare DOT, FHWA-JPO-14-146, Deployment of Intelligent Transportation Systems: A Summary of the 2013 National Survey Results xiv, 27 (Aug. 2014) with DOT, FHWA-JPO-11-132, Deployment of Intelligent Transportation Systems: A Summary of the 2010 National Survey Results 31-32 (Aug. 2011).

[42] See Preliminary RA at Tbl. 6 (cost factors); see also Appendix B.

[43] The BLS CPI Inflation calculator is available at http://www.bls.gov/data/inflation_calculator.htm.

[44] Size-dependent cost components are those elements that are expected to vary based on agency size and which do not automatically adjust for scale.  For example, costs that are calculated on a per-item basis, such as onboard bus equipment (assessed per bus), GPS receivers (per bus), WLAN systems (per garage), "automatically" adjust for the size of the transit agency because they necessarily depend on the number of buses to be equipped or garages in which networking equipment will be housed.

[45] See Preliminary RA at 10.

[46] See Appendix B, which details the estimated training needs of vehicle operators and mechanics.  In sum, it is assumed that all vehicle operators will receive one hour of training on their transit agencies' respective automated announcement systems, while 10% of agencies' mechanics will receive an equivalent amount of training on repair and maintenance of such announcement systems.  This mirrors the assumptions used in the Preliminary RA.  See Preliminary RA at 12.

[47] The BLS provides an online tool, called the "Occupational Employment Statistics Query System," through which generates custom tables with OES wage data based on user-provided specifications.  See BLS, OES Query System, http://data.bls.gov/oes/ (last visited: Jan. 19, 2016).  The following Standard Occupation Classifications (SOC) codes were used to generate the OES wage data for vehicle operators and mechanics: 53-3021 (Bus Drivers, Transit and Intercity) and 49-3031 (Bus and Truck Mechanics and Diesel Engine Specialists).

[48] See Preliminary RA at 12 & App. C.  The Preliminary RA used the same average OES wage rates for both "low" and "high" scenarios.

[49] See Appendix B, which details the assumed labor hours respectively needed by IT/GIS Specialist and IT Manager under each scenario.  In sum, the "low" scenario assumes that the transit agency has up-to-call sheets that can be readily entered into an announcement database (thereby calling for less work by IT professionals) and minimal system testing is required.  The "primary" and "high" scenarios, on the other hand, assume more time is needed by IT professionals because, for example, more intensive system testing is required and the transfer of data from the scheduling database (i.e., HASTUS) to the announcement database does not go smoothly due to mismatching database schema.  Id.

[50] Specifically, for the IT/GIS Specialist position, wage date was obtained from BLS National Industry-Specific Occupational Wage Estimates for SOC 151140 (Database Administer) in NAICS Sector 999300 (Federal, State, and Local Government).  See BLS, May 2014 National Industry-Specific Occupational Employment and Wage Estimates - NAICS 999300, available at: http://www.bls.gov/oes/current/naics4_999300.htm. For the IT Manager, because OES wage data has no specific classification this position, wage rates were assumed to be 1.4 times the wage of an IT/GIS Specialist.  This replicates the wage ratio for these two IT positions in the Preliminary RA.  See Preliminary RA, App. C.

[51] See Preliminary RA at App. C.

[52] See Preliminary RA at App. C.  The Preliminary RA used the same average annual wage rates for both "low" and "high" scenarios.

[53] Because the Preliminary RA did not evaluate costs related to compliance with OTRB accessibility requirements in the proposed rule, the OTRB-related cost methodology and assumptions in the Final RA are necessarily new to this assessment.  That said, this methodology is generally consistent with the approach taken in the Preliminary RA for estimating costs for automated announcement systems.

[54] See discussion in Appendix D.

[55] See, e.g., Exec. Order No. 13,563, Improving Regulation and Regulatory Review § 1(c), 76 Fed. Reg. 3821 (Jan. 21, 2011) (counselling that, where permitted by law, agencies should "consider (and discuss qualitatively) values that are difficult or impossible to quantify, including equity, human dignity, fairness, and distributive impacts"); Exec. Order No. 12,866, Regulatory Planning and Review § 1(a), 58 Fed. Reg. 51,735 (Oct. 4, 1993) (same); see also Office of Mgmt. & Budget, Circular A-4, Regulatory Analysis 26-27 (Sept. 17, 2003) (acknowledging that "some important [regulatory] benefits . . . may be inherently too difficult to quantify or monetize given current data and methods").

[56] Indeed, some transportation-related research studies suggest that there is latent demand among persons with disabilities to use fixed-route transit bus service, or use it more frequently.  See TRB, TCRP Report 163, supra note 6, at 12-14 (finding, based on national survey of persons with disabilities, that majorities of individuals who currently use fixed-route transit only or who use both fixed-route transit and paratransit services wished to use fixed-route transit service more frequently; also finding, based on same survey, that nearly 40% of non-users of public transit wished to start using fixed-transit service).  While survey respondents cited various barriers to greater use of fixed-route service, about one-half noted "problems with stop announcements" as a "very important" or "important" factor in their decision to use fixed-route transit services.  Id. at 16.

[57] Benefits likely to accrue from the final rule's specification of a 1:6 maximum running slope for non-rail vehicle ramps are not discussed in this section.  To be sure, both commenters and published studies attest that a 1:6 maximum ramp slope makes ramps safer and more usable for most passengers who use wheeled mobility devices relative to existing transportation vehicle guidelines.  See, e.g., Karen L. Frost, et al., Ramp-Related Incidents Involving Wheeled Mobility Device Users During Transit Bus Boarding/Alighting, 96 J. Physical Med. & Rehabilitation 928 - 33 (2015); see also Preamble to Final Rule – Americans with Disabilities Act Transportation Vehicle Guidelines, Section III (Major Issues – Running Slope of Ramps Deployed to Roadways or Curb-Height Bus Stops) (discussing comments related to Access Board's proposal to specify 1:6 as the maximum slope of ramps in non-rail vehicles).  However, since it is believed that a 1:6 maximum ramp slope will not have a significant incremental cost impact, we do not monetize costs related to this revised requirement in the final regulatory assessment.  See discussion supra Section 3.4 (Final Rule – New or Revised Requirements with Cost Impacts).  In this light, discussion herein of qualitative benefits relating to this requirement would also be misplaced.

[58] See, e.g., NCD, Current State of Transportation 2005, supra note 10, at 13-14, 26; Arizona State Univ., Morrison Institute for Public Policy, Stuck at Home: By-Passing Transportation Roadblocks to Community Mobility and Independence 3 (2013).

[59] For example, a transit bus rider with mobility-related disabilities, recounted her difficulties when vehicle operators failed to announce stops, or when such announcements were unintelligible:

I am living with MS [multiple sclerosis] and other congenital deformities …. It was really bad when stops were not being announced on our buses. Even when they were announced, depending on where you sat, it may be hard to hear the stop called out. I was taking night classes and had to get off at an unusual stop. I would miss the stop because I couldn't see it and the stop was not announced. So I had to get off at a later stop, which meant crossing one of the busiest intersections. For me, the less walking the better. By the time I got to class, I was late, angry, and [fatigued].

NCD, Current State of Transportation 2005, supra note 10, at 26.

[60] See Centers for Disease Control and Prevention, Morbidity and Mortality Weekly Report, "Prevalence of Disability and Disability Type among Adults – United States, 2013" (July 2015) (compiling data from the CDC's "Behavioral Risk Factor Surveillance System"); U.S. Census Bureau, American Community Survey, 2014 Data Release (2015), available at: https://www.census.gov/programs-surveys/acs/; U.S. Census Bureau, Americans with Disabilities: 2010 (July 2012) (compiling data from the Census Bureau's "Survey of Income and Program Participation").

[61] See TRB, TCRP Report 163, supra note 6, at 8-9 & tbl. 2-2 (calculated average from data provided in Table 2-2).

[62] Dept. of Transportation, Bureau of Transportation Statistics, 2002 National Transportation Availability and Use Survey, Tbl. 18 (2002), available at: http://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/files/publications/freedom_to_travel/html/table_18.html.

[63] Id.; see also NCD, Transportation Update 2015, supra note 10, at 22-24; TRB, TCRP Report 163, supra note 6, at 9 & tbl. 2-2; ASU, Stuck at Home, supra note 57, at 2 (noting that public transit ridership by persons with disabilities in Maricopa Country had increased in the past ten years, but still represented only .04% of total ridership); NCD, Current State of Transportation 2005, supra note 10, at 24.

[64] See, e.g., Transportation Research Board, TCRP Synthesis 73 – AVL System for Bus Transit: Update 3, 64-66 (2008); Delaware Center for Transportation, University of Delaware, Costs and Benefits of Advanced Public Transportation Systems at Dart First State 23-32 (July 2004).

[65] Specifically, despite extensive research, the Access Board found no published reports, statistics, or other quantitative metrics relating to the number of passengers with disabilities who use OTRBs operated by charter buses, long distance bus companies, or other private firms offering OTRBB-related transportation services.

[66] See, e.g., TRB, TCRP Report 163, supra note 6, at Chapter 2.2; see also National Council on Disability, Transportation Update: Where We've Gone and What We've Learned 39 (2015) (discussing the importance of effective stop announcements to persons with disabilities, and noting that "lack of an effective stop announcement and route identification program can force riders onto ADA paratransit").

[67] In addition, as noted below, Appendices E and F present detailed breakdowns of annual compliance costs under each scenario for the automated announcement systems requirement (applicable only to large transit agencies) and for the new OTRB accessibility requirements.

[68] For example, under the main analysis, nine Tier I transit agencies are assumed to incur compliance costs under the automated announcement systems requirement, whereas, under the stress test, eleven such agencies (9 x .25) incur such compliance costs.

[69] The Census Bureau, which has responsibility for designating UZAs, considers any densely populated area with 50,000 or more inhabitants to be an urbanized area.  See, e.g., FTA, 2014 Reporting Year – NTD National Transit Summary & Trends 4 (Feb. 2015) (discussing UZAs in context of NTD data) (hereafter, "2014 National Transit Summary & Trends"), available at: https://www.transit.dot.gov/ntd/2014-ntst-storylines.  UZA designations are based on decennial census data.  According to 2010 Census data, there are just under 500 UZAs collectively in the United States and its territories.  Id.

[70]  For example, for urban transit providers, NTD data includes: number, type, and age of transit vehicles operated by mode of service; service area population; primary UZA designation; capital and operating expenses; revenue and funding sources; number of passenger trips (and miles) by mode of service; employee work hours and counts; and statistics on transit stations and maintenance facilities.  See, e.g., FTA, 2014 Reporting Year – NTD Policy Manual (Feb. 2015), available at: https://www.transit.dot.gov/ntd/2014-ntd-policy-manual.

[71] See, e.g., FTA, 2014 NTD Annual Summary – Tables 3 (Federal Government Sources for Transit Operating Funds Applied) & 7 (Transit Capital Funds Applied – Summary and Federal Sources), available at: https://https://www.transit.dot.gov/ntd/ntd-data.  The eight VOMS-level groups used by FTA in its annual NTD data summary tables are: "1000 & Over," "500 – 999," "250 – 499," "100 – 249," "50 – 99," "25 – 49," "10 – 24," and "Under 10."  Id.

[72] For an illustrative list of the types of capital expenditures by urban reporting agencies, see FTA, 2014 Reporting Year – NTD National Transit Summary & Trends: Appendix 19-21 (Feb. 2015) (hereafter, "2014 National Transit Appendix"), available at: https://www.transit.dot.gov/ntd/2014-ntst-appendix.

[73] See 2014 National Transit Summary & Trends, supra, note 69, at 14; 2014 National Transit Appendix, supra, note 72, at 23-24.

[74] FTA's website provides a comprehensive and searchable inventory of all DOT- and FTA-administered transit grant programs.  See FTA, Grant Programs, https://www.transit.dot.gov/funding/grants/grant-programs (last accessed Nov. 7, 2016).

[75] See FTA, Urbanized Area Formula Grants – 5307, https://www.transit.dot.gov/funding/grants/urbanized-area-formula-grants-5307 (last accessed Nov. 7, 2016).

[76] Specifically, for each transit agency, the estimated amount of federal capital funds available for ADA-related bus projects was calculated according to the following formula: (Total Federal Capital Funds per 2014 NTD annual data) x (# bus VOMS/# total VOMS) x (.90).

[77] See RFA § 605(b); see also Presidential Memorandum, "Regulatory Flexibility, Small Business, and Job Creation," 76 Fed. Reg. 3,827 (Jan. 21, 2011).

[78] See, e.g., Small Business Administration/Office of Advocacy, A Guide for Government Agencies: How to Comply with the Regulatory Flexibility Act 17-19 (June 2010) (noting lack of single standard for determining "significant economic impact" under RFA but endorsing, among other measures, use of "sales test"); Small Business Administration/Office of Advocacy, The Small Business Advocate 5 (Aug.-Sept. 2004) (suggesting that regulatory action may lack economic significance if cost of proposed requirements fell below 1 percent of gross revenues or 5 percent of labor costs of small entities in affected industry).


Appendix A: Large Transit Agencies Over VOMS 100 Threshold for Fixed-Route Bus Modes (2014 NTD Data)

The table below presents data compiled from the 2014 National Transit Database (NTD) for transit agencies reporting operation of 100 or more vehicles in annual maximum service  in fixed route bus service (Bus VOMS).  The 2014 NTD provides data on four fixed-route bus modes, which are coded as follows:  traditional transit bus fixed route service (MB); bus rapid transit (RB); commuter bus (CB); and trolley bus (TB).  (Note: According to the 2014 NTD Policy Manual, the "TB" mode includes only fixed route service using rubber-tired buses powered by electric current from overhead wires using trolley poles; replica or historic trolleys powered by onboard motors are not included in this mode.)  With respect to "Type of Service," "DO" refers to direct operation by the reporting transit agency, while "PT" connotes fixed-route bus service provided to a public transit agency or governmental unit under a written contract with a public or private third-party transportation provider.

Table A - 1: Large Transit Agencies over VOMS 100 Threshold Based on 2014 NTD Data for Fixed-Route Bus Modes (Sorted by VOMS Size)

NTD ID #

Reporting Transit Agency

Mode of Service - Fixed-Route Buses (MOS)

Type of Service (TOS)

Vehicles Operated at Maximum Service - Fixed-Route Bus Modes
(Bus VOMS)

20008

MTA New York City Transit

CB, MB, RB

DO

3,819

20080

New Jersey Transit Corporation

MB

DO, PT

2,047

90154

Los Angeles County Metropolitan Transportation Authority dba: Metro

MB, RB

DO, PT

1,904

50066

Chicago Transit Authority

MB

DO

1,568

30030

Washington Metropolitan Area Transit Authority

MB

DO, PT

1,342

30019

Southeastern Pennsylvania Transportation Authority

MB, TB

DO, PT

1,212

20188

MTA Bus Company

MB

DO

1,089

00001

King County Department of Transportation - Metro Transit Division

CB, MB, TB

DO, PT

1,080

60008

Metropolitan Transit Authority of Harris County, Texas

CB, MB

DO, PT

1,054

80006

Denver Regional Transportation District

MB

DO, PT

834

10003

Massachusetts Bay Transportation Authority

MB, RB, TB

DO, PT

817

30034

Maryland Transit Administration

CB, MB

DO, PT

803

50027

Metro Transit

MB

DO

769

40034

Miami-Dade Transit

MB

DO, PT

679

50113

Pace - Suburban Bus Division

MB

DO, PT

628

90015

San Francisco Municipal Railway

MB, TB

DO

616

30022

Port Authority of Allegheny County

MB

DO

567

60056

Dallas Area Rapid Transit

MB

DO

544

00008

Tri-County Metropolitan Transportation District of Oregon

MB

DO

516

90036

Orange County Transportation Authority

CB, MB

DO, PT

489

90014

 Alameda-Contra Costa Transit District

CB, MB

DO, PT

472

90026

San Diego Metropolitan Transit System

CB, MB

DO, PT

459

40022

Metropolitan Atlanta Rapid Transit Authority

MB

DO

450

90032

City of Phoenix Public Transit Department dba Valley Metro

MB

PT

447

90002

City and County of Honolulu Department of Transportation Services

MB

PT

431

80001

Utah Transit Authority

CB, MB

DO, PT

426

90013

Santa Clara Valley Transportation Authority

MB

DO, PT

381

50015

The Greater Cleveland Regional Transit Authority

MB, RB

DO

366

60011

VIA Metropolitan Transit

MB

DO

360

60048

Capital Metropolitan Transportation Authority

CB, MB

PT

339

90045

Regional Transportation Commission of Southern Nevada

MB, RB

PT

336

50008

Milwaukee County Transit System

MB

DO

334

70006

Bi-State Development Agency of the Missouri-Illinois Metropolitan District, d.b.a.(St. Louis) Metro

MB

DO

314

50154

Metropolitan Council

CB, MB

PT

307

50012

Southwest Ohio Regional Transit Authority

MB

DO

297

90136

Regional Public Transportation Authority, dba: Valley Metro

MB

PT

285

30051

Ride-On Montgomery County Transit

MB

DO

282

90009

San Mateo County Transit District

MB

DO, PT

278

90146

Foothill Transit

MB

PT

278

20076

Westchester County Bee-Line System

MB

PT

276

50016

Central Ohio Transit Authority

MB

DO

275

20004

Niagara Frontier Transportation Authority

MB

DO

269

40008

Charlotte Area Transit System

CB

DO

268

40029

Broward County Transit Division

MB

DO, PT

265

40035

Central Florida Regional Transportation Authority

CB, MB, RB

DO, PT

262

20206

Nassau Inter County Express

MB

PT

252

90147

City of Los Angeles Department of Transportation

CB, MB

PT

252

30083

Transportation District Commission of Hampton Roads

MB

DO

233

00040

Central Puget Sound Regional Transit Authority

CB

DO, PT

231

50119

City of Detroit Department of Transportation

MB

DO

229

20122

Academy Lines, Inc.

CB

DO

225

20113

Regional Transit Service, Inc. and Lift Line, Inc.

MB

DO

221

10045

Connecticut Department of Transportation - CTTransit New Britain -Dattco

CB, MB

DO, PT

213

90033

City of Tucson

MB

DO

211

30068

Fairfax Connector Bus System

MB

PT

208

50031

Suburban Mobility Authority for Regional Transportation

MB

DO, PT

205

10001

Rhode Island Public Transit Authority

MB

DO

191

00029

Snohomish County Public Transportation Benefit Area Corporation

CB, MB

DO, PT

189

30075

Delaware Transit Corporation

MB

DO, PT

188

90166

LACMTA - Small Operators

MB

PT

188

90023

Long Beach Transit

MB

DO

185

40027

Pinellas Suncoast Transit Authority

CB, MB

DO, PT

182

20002

Capital District Transportation Authority

CB, MB

DO, PT

180

50005

Metro Transit System

MB

DO

179

70005

Kansas City Area Transportation Authority

MB, RB

DO

179

40018

Transit Authority of River City

MB

DO, PT

177

40041

Hillsborough Area Regional Transit Authority

MB

DO

162

20126

Hudson Transit Lines, Inc.

CB

DO

161

90019

Sacramento Regional Transit District

MB

DO

160

90016

Golden Gate Bridge, Highway and Transportation District

MB

DO

159

40040

Jacksonville Transportation Authority

MB

DO

158

90008

Santa Monica's Big Blue Bus

MB

DO

152

90031

Riverside Transit Agency

CB, MB

DO, PT

149

90029

Omnitrans

MB

DO, PT

144

10008

Pioneer Valley Transit Authority

MB

PT

141

40004

Metropolitan Transit Authority

MB

DO

137

90030

North County Transit District

MB

PT

137

50033

Interurban Transit Partnership

MB, RB

DO

135

50050

Indianapolis and Marion County Public Transportation

MB

DO

133

60019

City of Albuquerque Transit Department

MB

DO

131

20072

Suffolk County Department of Public Works - Transportation Division

MB

PT

130

40037

Board of County Commissioners, Palm Beach County, PalmTran, Inc.

MB

DO

130

60007

Fort Worth Transportation Authority

MB

DO, PT

130

30006

Greater Richmond Transit Company

MB

DO

124

60006

Mass Transit Department - City of El Paso

MB

DO

124

20018

CNY Centro, Inc.

MB

DO

121

00003

Pierce County Transportation Benefit Area Authority

MB

DO

120

50017

Greater Dayton Regional Transit Authority

MB, TB

DO

120

30070

Potomac and Rappahannock Transportation Commission

CB, MB

PT

119

40003

Memphis Area Transit Authority

MB

DO

119

00002

Spokane Transit Authority

MB

DO

112

50010

METRO Regional Transit Authority

CB, MB

DO

112

50211

Rides Mass Transit District

MB

DO

112

20128

Suburban Transit Corporation

CB

DO

110

40086

Metropolitan Bus Authority

MB

DO

109

70010

Des Moines Area Regional Transit Authority

MB

DO

108

70002

Transit Authority of Omaha

MB

DO

107

40030

Gainesville Regional Transit System

MB

DO

104

40135

Georgia Regional Transportation Authority

CB

PT

101

Bus VOMS Total (all large transit agencies) =

39,423

 

Appendix B – Unit Costs: Automated Announcement Systems

Unit costs for this final regulatory assessment were developed for the new requirement for automated announcement systems to represent the likely low, medium, and high costs of compliance experienced by large transit agencies.  Unit costs for the automated announcement systems requirement are assessed with respect to: initial (one-time) costs for onboard equipment (App. B-1); initial (one-time) costs for backend systems (App. B-2); initial training for transit agency personnel (App. B-3); annual operation and maintenance expenses (App. B-4); and, mid-life software upgrades for onboard equipment and backend systems (App. B-5).  These unit costs are based largely on cost estimates used in the Cost Estimates for Automated Stop Announcements (July 2010) (hereafter, "2010 Preliminary RA"), which was prepared with the assistance of the Volpe National Transportation Center and published in conjunction with the Access Board's 2010 Notice of Proposed Rulemaking.  Some adjustments were nonetheless made to unit cost estimates used in the Preliminary RA to update costs (i.e., reflect passage of time) and to incorporate revisions to the cost model (e.g., introduction of low, medium, and high cost scenarios).  These updates and adjustments are discussed in greater detail in the body of this final report.  See supra Section 5.2.


Appendix B-1: Initial (One-Time) Costs for Onboard Bus Equipment

Cost Element(s)

Value(s)

Unit Cost Assumptions

Source(s)

Onboard Equipment (per bus):

Onboard Processor
Next Stop Annunciator
Cables & Brackets

Low: $2,558
Medium: $5,442
High: $5,986

Low: Assumes transit agency already deploys AVL technology and equips its buses with onboard processors, which can be mobile data terminals.  Additional cost only for next stop annunciators with automated voice announcement software.
Medium: Assumes transit agency has no existing ITS system in place.  Unit cost represents onboard processor with automated voice announcement software, along with related installation hardware, for each bus.
High:  Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs onboard processor and annunciator), but with 10% higher costs.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost estimates (as updated by BLS/CPI inflation calculator).

GPS Receiver

Low: n/a
Medium: $893
High: $982

Low: Assumes transit agency already deploys AVL technology and equips its buses with GPS receivers.  No new GPS receivers needed.
Medium: Assumes transit agency has no existing ITS system in place.  GPS receivers needed for each bus.
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs GPS receivers), but with 10% higher costs.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost estimates (as updated by BLS/CPI inflation calculator).

WLAN Adapter & Antenna

Low:  n/a
Medium: $637
High: $701

Low: Assumes transit agency already deploys AVL technology and equips its buses with systems to communicate data.  No new WLAN equipment needed.
Medium: Assumes transit agency has no existing ITS system in place.  WLAN adapter and receiver needed for each bus.
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs WLAN equipment), but with 10% higher costs.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost estimates (as updated by BLS/CPI inflation calculator).

Interior LED Sign

Low:  n/a
Medium: $708
High: $779

Low: Assumes transit agency already equips buses with interior display signs for other informational purposes (e.g., to announce "Stop Requested" or "Please Exit Using Rear Door").  No new LED signs needed.
Medium: Assumes transit agency neither has existing ITS system nor equips its buses with LED signs for other purposes.  Interior LED sign needed on each bus for stop announcements.
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, no existing onboard LED signs), but with 10% higher costs.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost estimates (as updated by BLS/CPI inflation calculator).

External Speakers

Low: $54
Medium: $54
High: $59

Existing guidelines require buses to be equipped with public address systems and internal speakers.  So only new cost -- under all three cost scenarios -- is equipping each bus with an external speaker for route announcements.  Low and medium costs represent unit cost estimate from PRIA ($50), as updated by BLS/CPI inflation calculator.  High cost is based on medium cost plus 10% upward adjustment.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost estimates (as updated by BLS/CPI inflation calculator).

 

Appendix B-2: Initial (One-Time) Costs for Backend System

As discussed in the text of this final report, see supra Section 5.2.1, compliance costs for certain components of backend systems for automated announcement systems are expected to vary based on the size of a given large transit agency's fixed-route operations, with relatively smaller (i.e., Tier I) agencies incurring somewhat lower compliance costs and relatively larger (i.e., Tier III) agencies incurring higher costs.  These cost components are: Software & Hardware; Stop Database Setup/Consolidation; Announcement Database Setup; and, System Testing.  (These four cost components are also identified with an asterisk in the unit cost table below.)

Because unit costs for these four components are not inherently "scaled" for size—by, for example, being based per route or per bus—the unit costs for these components in the final regulatory assessment are proportionally scaled to adjust costs to better reflect the relative sizes of the three size-based tiers used to model compliance costs for large transit agencies.  Costs listed here are unit costs used for a large transit agency in Tier II, which equates to assumed characteristics of the "sample" transit agency used in the 2010 Preliminary RA.  Estimated unit costs for Tier I transit agencies are scaled by .75 to reflect their relatively smaller size, while costs for Tier III transit agencies are scaled by 1.25 to account for their larger size.

Cost Element(s)

Value(s)

Unit Cost Assumptions

Source(s)

Backend System:

*Software & Hardware

Low: $48,979
Medium: $54,421
High: $59,863

Backend hardware and software costs assumed to include: global information system (GIS) software, announcement database software, recording and editing software, and computers and related hardware.  Medium cost represents unit cost estimate used in the PRIA, as updated by BLS/CPI inflation calculator. Low and high costs are based on the medium cost estimate, but with respective 10% downward and upward cost adjustment.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).

WLAN System (per garage)

Low:  n/a
Medium: $47,564
High: $52,320

Low: Assumes transit agency already deploys AVL technology and has established backend systems to communicate data.  No new WLAN equipment needed.
Medium: Assumes transit agency has no existing ITS system in place.  WLAN system needed for each garage to communicate data.  Unit cost for WLAN system includes: 7 WLAN access points per garage, Cat6 or fiber wiring, and WLAN firewall equipment.
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs WLAN equipment), but with 10% higher costs.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost estimates (as updated by BLS/CPI inflation calculator).

*Stop Database Setup/Consolidation

Low: n/a
Medium: $2,177
High: $2,395

Low:  Assumes transit agency already deploys AVL technology and has established stop database and geocoded locations for stops.  No new Stop Database costs.
Medium: Assumes transit agency has no existing ITS system in place, and a stop database needs to be setup or consolidated from any existing stop database that is used for other purposes.  Unit cost represents cost to set-up new database or consolidate existing stop database.
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs stop database setup/consolidation), but with 10% higher costs.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).

Geocoding Costs (per route)

Low:  n/a
Medium: $1,088
High: $1,197

Low: Assumes transit agency already deploys AVL technology and has established stop database and geocoded locations for stops.  No new Stop Database costs.
Medium: Assumes transit agency has no existing ITS system in place, and needs to establish a stop database with geocoded stop locations.  Unit costs represent the estimated cost to geocode all stop locations on a per-route basis.
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs to geocode all stop locations), but with 10% higher costs.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).

*Announcement Database Setup

Low: $28,485
Medium: $84,612
High: $106,542

Low: Assumes transit agency has up-to-date operator call sheets that can be readily entered into the announcement database.  Announcement database set-up costs estimated to include full-time work by an IT/GIS specialist, as well as quarter-time oversight by an IT project manager, for a 3-month period.  (Wage rates for IT/GIS specialist and IT project manager based on low cost scenario wages listed below in Appendix B - 3.)  
Medium:  Assumes transit agency reevaluates what stops to announce, and incurs additional labor costs in transferring data from the scheduling database (e.g., HASTUS) to the announcement database because the database schemas do not match exactly.  Announcement database set-up costs estimated to include full-time work by an IT/GIS specialist, as well as quarter-time oversight by an IT project manager, for a 7-month period.   (Wage rates for IT/GIS specialist and IT project manager based on medium cost scenario wages listed below in Appendix B - 3.)
High: Same underlying assumptions as medium scenario (i.e., transit agency has no existing ITS system, needs to geocode stop locations), but using high cost scenario wages for IT/GIS specialist and IT project manager from App. B - 3, below.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost assumptions.
All cost scenarios: Wage rates for IT/GIS specialist and IT project manager, App. B - 3.

Recording/Editing Announcements

Low: $490
Medium: $544
High: $598

Stop and route announcements must be recorded and edited, and these recordings must be entered in the announcement database.  Medium cost represents unit cost estimate used in the PRIA, as updated by BLS/CPI inflation calculator.  Low and high costs based on medium cost estimate, but with respective 10% downward and upward cost adjustment.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).

*System Testing

Low: $1,614
Medium: $6,168
High: $7,766

Low: Assumed that stops to be announced are few or highly separated, and minimal system testing is required to ensure that the geofences do not overlap or conflict.  System testing estimated to include 40 hours of work by an IT/GIS specialist.   (Wage rate for IT/GIS specialist based on low cost scenario wages listed below in Appendix B - 3.)
Medium: Assumed that a high density network of stops will be announced, and every route needs to be tested to ensure that geofences do not overlap or conflict.  System testing estimated to include 120 hours of work by an IT/GIS specialist.   (Wage rate for IT/GIS specialist based on medium cost scenario wages listed below in Appendix B - 3.)
High: Same underlying assumptions as medium scenario (i.e., stop database needs extensive testing), but using high cost scenario wages for IT/GIS specialist from App. B - 3, below.

Low/Medium cost scenarios: 2010 Preliminary RA/Volpe Center cost assumptions.
All cost scenarios: Wage rates for IT/GIS specialist, App. B - 3.

 

*(Note: Cost scaling used to adjust assumed backend costs based on transit agency size and relative backend system needs.  Costs listed are unit costs used for a large transit agency in Tier II.  Estimated unit costs used in this final regulatory assessment for Tier I transit agencies are scaled by .75 to reflect their relatively smaller size, while costs for Tier III transit agencies are scaled by 1.25 to account for their larger size.)


Appendix B-3: Training Cost Assumptions/Labor Costs

Cost Element(s)

Value(s)

Unit Cost Assumptions

Source(s)

Labor/Training Costs

Vehicle Operators

(hourly wages)

Low: $19.55
Medium: $27.03
High: $35.94

Training Cost Assumptions:  Assumed that all vehicle operators receive a one-hour training on using automated announcements.  Also assumed that subsequent refresher training can be incorporated into transit agency's ongoing training program at minimal or no cost.

Labor Costs:  Estimated hourly wage rates for vehicle operators derived from May 2014 Occupation Employment Statistics (OES) published by the Bureau of Labor Statistics.  The medium scenario is based on the median national hourly wage, while the low and high scenarios respectively use hourly wages at the 25th and 75th percentiles nationally.  Under each scenario, OES hourly wages are then multiplied by 1.5 to adjust for benefits.

Training/Labor classification assumptions: 2010 Preliminary RA/Volpe Center.
Wage rates: Bureau of Labor Statistics, Occupational Employment and Wages (May2014), Standard Occupation Classification (SOC) 53-3021 (Bus Drivers, Transit & Inter-City).

Mechanics

(hourly wages)

Low: $25.04
Medium: $31.47
High: $39.47

Training Cost Assumptions: Assumed that 10% of each transit agency's mechanics receive a one-hour training on repairing automated announcement equipment.  Also assumed that subsequent refresher training can be incorporated into transit agency's ongoing training program at minimal or no cost.

Labor Costs: Estimated hourly wage rates for bus mechanics derived from May 2014 Occupation Employment Statistics (OES) published by the Bureau of Labor Statistics.  The medium scenario is based on the median national hourly wage, while the low and high scenarios respectively use hourly wages at the 25th and 75th percentiles nationally.  Under each scenario, OES hourly wages are then multiplied by 1.5 to adjust for benefits.

Training/Labor classification assumptions: 2010 Preliminary RA/Volpe Center.
Wage rates: Bureau of Labor Statistics, Occupational Employment and Wages (May2014), SOC 49-3031 (Bus & Truck Mechanics).

IT/GIS Specialist

(annual wages)

Low: $83,955 Medium: $106,890
High: $134,595

Training Costs: n/a

Labor Costs: Estimated annual wage rates for an IT/GIS specialist derived from May 2014 National Industry-Specific Occupational Wage Estimates tables (OES) published by the Bureau of Labor Statistics.  The medium scenario is based on the median national annual wage, while the low and high scenarios respectively use annual wages at the 25th and 75th percentiles nationally.  Under each scenario, OES annual wages are then multiplied by 1.5 to adjust for benefits.

Labor classification assumptions: 2010 Preliminary RA/Volpe Center.
Wage rates: Bureau of Labor Statistics, Occupational Employment and Wages (May2014), NAICS 999300 (Local Govt., excluding schools and hospitals), SOC 15-1140 (Database and Systems Administrators).

IT Project Manager

(annual wages)

Low: $119,938
Medium: $152,703
High: $192,22

Training Costs: n/a

Labor Costs: Because the May 2014 National Industry-Specific Occupational Wage Estimates tables (OES) published by the Bureau of Labor Statistics do not contain an "IT project manager" job classification, annual wage rates for an IT project manager were developed, under each cost scenario (i.e., low, medium, and high), by multiplying the annual wages for an IT/GIS specialist (listed above) by 1.4286.  This latter figure replicates the ratio of annual wages for IT project manager and IT/GIS specialist reflected in PRIA labor cost estimates.  See PRIA, App. C.

Labor classification assumptions: 2010 Preliminary RA/Volpe Center.
Wage rates: Bureau of Labor Statistics, Occupational Employment and Wages (May2014), NAICS 999300 (Local Govt., excluding schools and hospitals), SOC 15-1140 (Database and Systems Administrators).

 

Appendix B-4: Annual Costs – Operation & Maintenance

Cost Element(s)

Value(s)

Unit Cost Assumptions

Source(s)

       

Bus Equipment

Spare Parts
(as % total bus equip. costs)

Low: 4%
Medium: 5%
High: 6%

Assumed that, for any transit agency in any given year, the annual cost for spare parts to repair or replace onboard equipment is equal to a fixed percentage of the total cost for onboard equipment installed on buses that year.  The medium scenario assumes spare parts represent 5% of total bus equipment costs, while the low and high scenarios assume spare parts costs of 3% and 6% respectively.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate.

Repair Costs
(per bus)

Low: $7.81
Medium: $9.82
High: $12.31

Based on information provided by transit agencies, the PRIA assumed that the average weekly equipment failure rate per bus was 0.3%, and that average repair time for each equipment failure was 2 hours.  The FRIA retains these repair cost assumptions, but applies them using updated hourly wage rates for bus mechanics (see App. B - 3).  Based on these assumptions, the medium per-bus cost for equipment repair is estimated to be $ 9.82 annually [.003 average weekly equipment failure rate per bus x 52 weeks x 2 hours per repair x $31.47 bus mechanics hourly wage].  Low and high costs for bus equipment repair are estimated in similar fashion, though using instead the low and high hourly wage rates for bus mechanics respectively (see App. B - 3).

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate.

Backend System

Database Updates & Maintenance
(Hardware & Software)

Low: $27,957
Medium: $35,594
High: $44,820

Assumed that performing operations and maintenance tasks on the backend system involves work by an IT/GIS specialist 1 month per quarter, or 4 months per year.  The Medium cost scenario uses medium wage rate for IT/GIS specialist (see App. B - 3.), while low and high scenarios respectively use low and high wage rates for IT/GIS specialist (see App. B - 3).

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).


Appendix B-5:  Mid-life Software Upgrade Costs

Cost Element(s)

Value(s)

Unit Cost Assumptions

Source(s)

Mid-Life Software Upgrade

Onboard Bus Equipment
(per bus)

Low: $142
Medium: $158
High: $174

Assumed that each transit agency's onboard bus equipment (e.g., onboard processor, mobile data terminal) requires one mid-life software upgrade during the 12-year regulatory horizon.  Upgrade costs are assumed to be apportioned equally between years 5 and 6.  The medium cost represents the unit cost estimate used in the PRIA ($145 per bus), as updated by BLS/CPI inflation calculator.  The low and high costs are based on the medium cost estimate, but with 10% downward and upward adjustment respectively.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).

Backend System
(per system/agency)

Low: $1,390
Medium: $1,544
High: $1,698

Assumed that the backend system (e.g., onboard processor, mobile data terminal) for each transit agency's automated announcement system requires one mid-life software upgrade during the 12-year regulatory horizon.  Upgrade costs are assumed to be apportioned equally between years 5 and 6.  The medium cost represents the unit cost estimate used in the PRIA ($145 per bus), as updated by BLS/CPI inflation calculator.  The low and high costs are based on the medium cost estimate, but with 10% downward and upward adjustment respectively.

Medium cost scenario: 2010 Preliminary RA/Volpe Center cost estimate (as updated by BLS/CPI inflation calculator).


Appendix C – Unit Costs: New Accessibility Requirements for OTRBs

Unit Costs for New OTRB Accessibility Requirements (Per Bus)

 

Low

Medium

High

Identification of Wheelchair Spaces and Accessible Doorways*

(ISA Signs/Decals)

$9

$18

$30

Priority Seating Signs*

$30

$70

$110

Exterior Destination/Route Signage

$640

$800

$960

Public Address System

$600

$750

$900

Stop Request System

$240

$300

$360

(*Note: Each OTRB is assumed to have two wheelchair spaces and one accessible doorway for which ISA identification is required.  Accordingly, the per-vehicle unit costs listed above reflect costs for three ISA signs or decals.  For priority seating, each OTRB operated in fixed-route service is required to designate two priority seats.  Per-vehicle unit costs for signage at priority seating thus reflect costs for two signs.)

OTRBs – Operation & Maintenance Costs

 

Low

Medium

High

Annual Operation & Maintenance Costs
(as % of total annual bus equipment costs)

1.0%

2.0%

3.0%

OTRBs – Projected Growth Rates (U.S. Domestic Fleet)

 

Low

Medium

High

Annual Growth Rate

-1.0%

0.0%

1.0%


Appendix D – OTRB Accessibility Requirements: Likelihood of Incurring Costs

The table below provides the assumed values used in the cost model regarding the likelihood that a typical over-the-road bus (OTRB) will both have a covered element (such as an exterior destination sign) and incur compliance costs under the final rule.  All percentages represent likelihoods relative to the entire U.S. fleet of OTRBs.  For requirements applicable to fixed-route service only, it is assumed that 30% of OTRBs are used in such service.  Also provided below are the sources used to develop estimated likelihood values.

 

Low Scenario

Primary Scenario

High Scenario

Discussion/Source(s)

Identification of Accessible Seating and Doorways

100%

100%

100%

Condition for Change: Required wheelchair spaces and doorways with accessible means of boarding and alighting must be identified by the International Symbol of Accessibility (ISA) on all OTRBs (since all OTRBs are large vehicles).  Compliance costs assumed when wheelchair spaces and accessible doorways on a new OTRB are not expected, based on current industry practice or assumed mode of operation, to have the requisite ISA sign or decal absent a requirement in the final rule.  OTRBs are not currently required to identify wheelchair spaces or doorways.  Since scant information is available on current industry practices, conservatively assumed that OTRBs do not typically provide such identification.
Source(s): Access Board subject matter expert.

Priority Seating Signs

27%

28.5%

30%

Condition for Change: Requirement only applies to OTRBs used in fixed-route service.  Priority seats must be identified by sign informing passengers that such seats are for use by persons with disabilities.  Compliance costs assumed when priority seating is not expected, based on current industry practice or assumed mode of operation, to have the requisite signage absent a requirement in the final rule.  OTRBs are not currently required to provide priority seats.  Some OTRBs operating as commuter buses do nonetheless provide both priority seating and signage for such seats.  However, since scant information is available on current industry practices, so it is conservatively assumed that OTRBs used in fixed-route service do not typically provide signs for priority seating.  Assumed that following proportions of OTRBs in fixed route service will incur compliance costs for priority seating signs: 90% (low), 95% (medium), and 100% (high). 
Source(s): Access Board subject matter expert.  Visual "survey" of OTRBs operating in fixed-route services in the Washington, D.C. metro area (Access Board staff - 2015).

Exterior Destination/ Route Signage

35.0%

45.0%

55.0%

Condition for Change: Where destination or route signs are provided on the exterior of an OTRB, such signage must be located on both the front and boarding side of the vehicle.  Compliance costs assumed when a new OTRB is expected, based on current industry practice or assumed mode of operation, to provide exterior signage, but only in one location (typically, the front of the vehicle) absent a requirement in the final rule.  Nearly all OTRBs used in fixed-route service as commuter buses currently provide compliant exterior destination/route signage in both locations.  OTRBs used in other types of fixed-route service (such as inter-city transportation) typically provide exterior signage only on the front of the vehicle.  Provision of exterior destination/route signage by OTRBs used in charter or sightseeing service varies, but, if such signage is provided, it generally is located only on the front of the vehicle.
  
Source(s): Information provided by OTRB manufacturers and transit agencies; Visual "survey" of OTRBs operating in fixed-route and charter services in the Washington, D.C. metro area (Access Board staff - 2015).

Public Address System

0.6%

1.5%

2.4%

Condition for Change: Requirement only applies to OTRBs used in fixed-route service.  Public address systems must provide electronic amplification systems capable of broadcasting onboard announcements to passengers.  Compliance costs assumed when a new OTRB operating in fixed route service is not expected, based on current industry practice, to have a PA system installed on the vehicle absent a requirement in the final rule.  Nearly all new OTRBs are currently built with OEM-installed public address systems, either as standard equipment or through customer-requested specification.  Assumed that following proportions of OTRBs in fixed route service will incur compliance costs for public address systems: 2% (low), 5% (medium), and 8% (high). 
Source(s): Access Board subject matter expert. 

Source(s): Information provided by OTRB manufacturers; APTA 2015 Vehicle Database.

Stop Request System

7.7%

8.1%

8.6%

Condition for Change: Requirement only applies to OTRBs used in fixed route service that stop on passenger request.  Mechanisms for requesting stops must be located within reach of each required wheelchair space and priority seat on the vehicle.  Compliance costs assumed when a new OTRB is used in fixed route service and stops on passenger request, but is not expected, based on current industry practice, to have the requisite stop request mechanisms installed onboard absent a requirement in the final rule.  Assumed that, of OTRBs operating in fixed-route service, one-third stop on passenger request.  Also assumed that the following proportions of OTRBs in fixed route service that stop on passenger request will incur compliance costs for stop request systems: 85% (low), 90% (medium), and 95% (high).  
Source(s): Information provided by OTRB manufacturers; Access Board subject matter experts.


Appendix E-1: Annual Costs for Automated Announcement Systems under Primary Scenario by Transit Agency Category (Tiers I, II & III)

Automated Stop Announcement Costs for Large Transit Agency - Tier I (Primary Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$52,623

$169,193

$6,889

$2,784

$6,674

$0

$238,164

$238,164

$238,164

Year 2

$52,623

$0

$350

$2,905

$26,696

$0

$82,573

$80,096

$76,793

Year 3

$52,623

$0

$350

$3,023

$26,696

$0

$82,691

$77,729

$71,941

Year 4

$52,623

$0

$350

$3,140

$26,696

$0

$82,809

$76,184

$67,903

Year 5

$52,623

$0

$350

$3,258

$26,696

$0

$82,927

$73,805

$63,024

Year 6

$52,623

$0

$350

$3,386

$26,696

$4,528

$87,583

$75,321

$62,184

Year 7

$52,623

$0

$350

$3,514

$26,696

$4,528

$87,710

$73,677

$58,766

Year 8

$52,623

$0

$350

$3,641

$26,696

$0

$83,310

$67,481

$51,652

Year 9

$52,623

$0

$350

$3,779

$26,696

$0

$83,447

$65,923

$48,399

Year 10

$52,623

$0

$350

$3,916

$26,696

$0

$83,585

$64,360

$45,136

Year 11

$52,623

$0

$350

$4,054

$26,696

$0

$83,722

$61,954

$42,698

Year 12

$52,623

$0

$350

$4,201

$26,696

$0

$83,869

$60,386

$40,257

Total

$631,480

$169,193

$10,734

$41,600

$300,324

$9,057

$1,162,389

$1,015,080

$866,917

Annualized

 

$87,502

$80,659

Automated Stop Announcement Costs for Large Transit Agency - Tier II (Primary Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$117,255

$304,912

$14,446

$6,175

$8,899

$0

$451,686

$451,686

$451,686

Year 2

$117,255

$0

$729

$6,401

$35,594

$0

$159,978

$155,179

$148,780

Year 3

$117,255

$0

$729

$6,627

$35,594

$0

$160,204

$150,592

$139,378

Year 4

$117,255

$0

$729

$6,852

$35,594

$0

$160,430

$147,596

$131,553

Year 5

$117,255

$0

$729

$7,078

$35,594

$0

$160,656

$142,984

$122,099

Year 6

$117,255

$0

$729

$7,304

$35,594

$7,811

$168,693

$145,076

$119,772

Year 7

$117,255

$0

$729

$7,530

$35,594

$7,811

$168,919

$141,892

$113,176

Year 8

$117,255

$0

$729

$7,756

$35,594

$0

$161,334

$130,680

$100,027

Year 9

$117,255

$0

$729

$7,982

$35,594

$0

$161,559

$127,632

$93,704

Year 10

$117,255

$0

$729

$8,208

$35,594

$0

$161,785

$124,575

$87,364

Year 11

$117,255

$0

$729

$8,433

$35,594

$0

$162,011

$119,888

$82,626

Year 12

$117,255

$0

$729

$8,659

$35,594

$0

$162,237

$116,811

$77,874

Total

$1,407,056

$304,912

$22,466

$89,004

$400,433

$15,623

$2,239,494

$1,954,590

$1,668,038

Annualized

 

$168,392

$154,985

Automated Stop Announcement Costs for Large Transit Agency - Tier III (Primary Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$227,612

$427,068

$28,059

$11,813

$11,123

$0

$705,674

$705,674

$705,674

Year 2

$227,612

$0

$1,396

$12,245

$44,493

$0

$285,745

$277,172

$265,743

Year 3

$227,612

$0

$1,396

$12,677

$44,493

$0

$286,177

$269,006

$248,974

Year 4

$227,612

$0

$1,396

$13,109

$44,493

$0

$286,609

$263,680

$235,019

Year 5

$227,612

$0

$1,396

$13,541

$44,493

$0

$287,041

$255,467

$218,151

Year 6

$227,612

$0

$1,396

$13,973

$44,493

$13,710

$301,183

$259,018

$213,840

Year 7

$227,612

$0

$1,396

$14,405

$44,493

$13,710

$301,615

$253,357

$202,082

Year 8

$227,612

$0

$1,396

$14,837

$44,493

$0

$288,337

$233,553

$178,769

Year 9

$227,612

$0

$1,396

$15,269

$44,493

$0

$288,769

$228,128

$167,486

Year 10

$227,612

$0

$1,396

$15,701

$44,493

$0

$289,201

$222,685

$156,169

Year 11

$227,612

$0

$1,396

$16,133

$44,493

$0

$289,634

$214,329

$147,713

Year 12

$227,612

$0

$1,396

$16,566

$44,493

$0

$290,066

$208,847

$139,231

Total

$2,731,344

$427,068

$43,410

$170,269

$500,541

$27,420

$3,900,052

$3,390,916

$2,878,852

Annualized

 

$290,974

$264,968


Appendix E-2: Annual Costs for Automated Announcement Systems under Low Scenario by Transit Agency Category (Tiers I, II & III)

Automated Stop Announcement Costs for Large Transit Agency - Tier I (Low Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$28,152

$59,799

$4,996

$1,235

$5,242

$0

$99,423

$99,423

$99,423

Year 2

$28,152

$0

$252

$1,321

$20,968

$0

$50,692

$49,171

$47,144

Year 3

$28,152

$0

$252

$1,415

$20,968

$0

$50,786

$47,739

$44,184

Year 4

$28,152

$0

$252

$1,509

$20,968

$0

$50,880

$46,809

$41,721

Year 5

$28,152

$0

$252

$1,602

$20,968

$0

$50,973

$45,366

$38,740

Year 6

$28,152

$0

$252

$1,704

$20,968

$4,072

$55,147

$47,426

$39,154

Year 7

$28,152

$0

$252

$1,805

$20,968

$4,072

$55,249

$46,409

$37,017

Year 8

$28,152

$0

$252

$1,907

$20,968

$0

$51,278

$41,535

$31,792

Year 9

$28,152

$0

$252

$2,016

$20,968

$0

$51,387

$40,596

$29,805

Year 10

$28,152

$0

$252

$2,126

$20,968

$0

$51,497

$39,652

$27,808

Year 11

$28,152

$0

$252

$2,235

$20,968

$0

$51,606

$38,188

$26,319

Year 12

$28,152

$0

$252

$2,352

$20,968

$0

$51,723

$37,241

$24,827

Total

$337,819

$59,799

$7,764

$21,227

$235,887

$8,144

$670,640

$579,556

$487,933

Annualized

 

$49,413

$44,208

Automated Stop Announcement Costs for Large Transit Agency - Tier II (Low Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$59,205

$79,568

$10,476

$2,583

$6,989

$0

$158,822

$158,822

$158,822

Year 2

$59,205

$0

$525

$2,762

$27,957

$0

$90,450

$87,736

$84,118

Year 3

$59,205

$0

$525

$2,942

$27,957

$0

$90,629

$85,192

$78,847

Year 4

$59,205

$0

$525

$3,122

$27,957

$0

$90,809

$83,544

$74,463

Year 5

$59,205

$0

$525

$3,301

$27,957

$0

$90,989

$80,980

$69,151

Year 6

$59,205

$0

$525

$3,481

$27,957

$7,023

$98,191

$84,444

$69,715

Year 7

$59,205

$0

$525

$3,660

$27,957

$7,023

$98,370

$82,631

$65,908

Year 8

$59,205

$0

$525

$3,840

$27,957

$0

$91,527

$74,137

$56,747

Year 9

$59,205

$0

$525

$4,020

$27,957

$0

$91,707

$72,449

$53,190

Year 10

$59,205

$0

$525

$4,199

$27,957

$0

$91,887

$70,753

$49,619

Year 11

$59,205

$0

$525

$4,379

$27,957

$0

$92,066

$68,129

$46,954

Year 12

$59,205

$0

$525

$4,559

$27,957

$0

$92,246

$66,417

$44,278

Total

$710,464

$79,568

$16,251

$42,848

$314,516

$14,045

$1,177,693

$1,015,233

$851,813

Annualized

 

$86,332

$76,678

Automated Stop Announcement Costs for Large Transit Agency - Tier III (Low Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$114,928

$99,338

$20,349

$4,941

$8,737

$0

$248,292

$248,292

$248,292

Year 2

$114,928

$0

$1,017

$5,284

$34,946

$0

$156,176

$151,491

$145,244

Year 3

$114,928

$0

$1,017

$5,628

$34,946

$0

$156,520

$147,128

$136,172

Year 4

$114,928

$0

$1,017

$5,972

$34,946

$0

$156,863

$144,314

$128,628

Year 5

$114,928

$0

$1,017

$6,315

$34,946

$0

$157,207

$139,914

$119,477

Year 6

$114,928

$0

$1,017

$6,659

$34,946

$12,324

$169,874

$146,092

$120,611

Year 7

$114,928

$0

$1,017

$7,003

$34,946

$12,324

$170,218

$142,983

$114,046

Year 8

$114,928

$0

$1,017

$7,346

$34,946

$0

$158,238

$128,173

$98,107

Year 9

$114,928

$0

$1,017

$7,690

$34,946

$0

$158,581

$125,279

$91,977

Year 10

$114,928

$0

$1,017

$8,034

$34,946

$0

$158,925

$122,372

$85,820

Year 11

$114,928

$0

$1,017

$8,377

$34,946

$0

$159,269

$117,859

$81,227

Year 12

$114,928

$0

$1,017

$8,721

$34,946

$0

$159,612

$114,921

$76,614

Total

$1,379,136

$99,338

$31,539

$81,969

$393,145

$24,648

$2,009,775

$1,728,818

$1,446,215

Annualized

 

$146,677

$129,444


Appendix E-3: Annual Costs for Automated Announcement Systems under High Scenario by Transit Agency Category (Tiers I, II & III)

Automated Stop Announcement Costs for Large Transit Agency - Tier I (High Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$91,687

$277,164

$4,996

$5,750

$8,404

$0

$388,000

$388,000

$388,000

Year 2

$91,687

$0

$252

$5,885

$33,615

$0

$131,439

$127,495

$122,238

Year 3

$91,687

$0

$252

$6,439

$33,615

$0

$131,992

$124,073

$114,833

Year 4

$91,687

$0

$252

$6,587

$33,615

$0

$132,140

$121,569

$108,355

Year 5

$91,687

$0

$252

$6,735

$33,615

$0

$132,288

$117,736

$100,539

Year 6

$91,687

$0

$252

$6,895

$33,615

$4,985

$137,432

$118,192

$97,577

Year 7

$91,687

$0

$252

$7,055

$33,615

$4,985

$137,592

$115,578

$92,187

Year 8

$91,687

$0

$252

$7,215

$33,615

$0

$132,768

$107,542

$82,316

Year 9

$91,687

$0

$252

$7,387

$33,615

$0

$132,940

$105,023

$77,105

Year 10

$91,687

$0

$252

$7,559

$33,615

$0

$133,113

$102,497

$71,881

Year 11

$91,687

$0

$252

$7,732

$33,615

$0

$133,285

$98,631

$67,975

Year 12

$91,687

$0

$252

$7,916

$33,615

$0

$133,470

$96,098

$64,065

Total

$1,100,239

$277,164

$7,764

$83,154

$378,169

$9,969

$1,856,459

$1,622,433

$1,387,072

Annualized

 

$139,970

$129,305

Automated Stop Announcement Costs for Large Transit Agency - Tier II (High Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$192,825

$522,554

$19,178

$12,023

$11,205

$0

$757,785

$757,785

$757,785

Year 2

$192,825

$0

$961

$12,306

$44,820

$0

$250,912

$243,385

$233,348

Year 3

$192,825

$0

$961

$12,589

$44,820

$0

$251,195

$236,123

$218,540

Year 4

$192,825

$0

$961

$12,872

$44,820

$0

$251,478

$231,360

$206,212

Year 5

$192,825

$0

$961

$13,155

$44,820

$0

$251,761

$224,068

$191,339

Year 6

$192,825

$0

$961

$13,438

$44,820

$8,600

$260,645

$224,154

$185,058

Year 7

$192,825

$0

$961

$13,722

$44,820

$8,600

$260,928

$219,179

$174,822

Year 8

$192,825

$0

$961

$14,005

$44,820

$0

$252,611

$204,615

$156,619

Year 9

$192,825

$0

$961

$14,288

$44,820

$0

$252,894

$199,786

$146,678

Year 10

$192,825

$0

$961

$14,571

$44,820

$0

$253,177

$194,946

$136,716

Year 11

$192,825

$0

$961

$14,854

$44,820

$0

$253,460

$187,561

$129,265

Year 12

$192,825

$0

$961

$15,137

$44,820

$0

$253,743

$182,695

$121,797

Total

$2,313,904

$522,554

$29,747

$162,960

$504,225

$17,200

$3,550,590

$3,105,658

$2,658,178

Annualized

 

$268,167

$248,313

Automated Stop Announcement Costs for Large Transit Agency - Tier III (High Scenario)

Regulatory Year

One-Time Costs

Training

O&M Costs

Mid-Life Software Upgrade

Total Cost

Present Value
(3%)

Present Value
(7%)

Bus Equipment

Backend System

Bus Equipment

Backend System

Year 1

$374,308

$746,747

$37,251

$23,000

$14,006

$0

$1,195,312

$1,195,312

$1,195,312

Year 2

$374,308

$0

$1,863

$23,542

$56,025

$0

$455,737

$442,065

$423,836

Year 3

$374,308

$0

$1,863

$24,083

$56,025

$0

$456,279

$428,902

$396,963

Year 4

$374,308

$0

$1,863

$24,625

$56,025

$0

$456,821

$420,275

$374,593

Year 5

$374,308

$0

$1,863

$25,167

$56,025

$0

$457,362

$407,052

$347,595

Year 6

$374,308

$0

$1,863

$25,708

$56,025

$15,096

$473,000

$406,780

$335,830

Year 7

$374,308

$0

$1,863

$26,250

$56,025

$15,096

$473,542

$397,775

$317,273

Year 8

$374,308

$0

$1,863

$26,792

$56,025

$0

$458,987

$371,780

$284,572

Year 9

$374,308

$0

$1,863

$27,333

$56,025

$0

$459,529

$363,028

$266,527

Year 10

$374,308

$0

$1,863

$27,875

$56,025

$0

$460,071

$354,254

$248,438

Year 11

$374,308

$0

$1,863

$28,417

$56,025

$0

$460,612

$340,853

$234,912

Year 12

$374,308

$0

$1,863

$28,958

$56,025

$0

$461,154

$332,031

$221,354

Total

$4,491,696

$746,747

$57,740

$311,750

$630,281

$30,192

$6,268,405

$5,460,107

$4,647,204

Annualized

 

$469,435

$429,715


Appendix F-1: Annual Costs for Over-the-Road Buses (OTRBs) under Primary Scenario

Annual Costs for Over-the-Road Buses (Primary Scenario)

 

Identification of Accessible Seating and Doorways  (Signs/ISA Decals)

Exterior Destination/Route Sign

Public Address System

Stop Request System

O&M Costs

Total Cost

Present Value (3%)

Present Value
(7%)

Year 1

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,236,661

$1,236,661

Year 2

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,199,562

$1,150,095

Year 3

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,162,462

$1,075,895

Year 4

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,137,729

$1,014,062

Year 5

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,100,629

$939,863

Year 6

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,063,529

$878,030

Year 7

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,038,796

$828,563

Year 8

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$1,001,696

$766,730

Year 9

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$976,963

$717,264

Year 10

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$952,229

$667,797

Year 11

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$915,129

$630,697

Year 12

$131,363

$984,000

$30,750

$66,300

$24,248

$1,236,661

$890,396

$593,597

Total

$1,576,361

$11,808,000

$369,000

$795,600

$290,976

$14,839,937

$12,675,780

$10,499,256

Annualized

 

$1,067,352

$921,905

 (Note: Annual compliance costs for OTRBs appear to be constant in table above due to three inter-related factors: (i) annual per-requirement and total costs are expressed in nominal dollars; (ii) the primary (medium) scenario assumes a 0% growth rate for the U.S. OTRB fleet over the regulatory timeframe; and (iii) OTRBs are assumed to incur compliance costs at a constant rate across all regulatory years.)


Appendix F-2: Annual Costs for Over-the-Road Buses (OTRBs) under Low Scenario

Annual Costs for Over-the-Road Buses (Low Scenario)

Regulatory Year

Identification of Accessible Seating and Doorways  (Signs/ISA Decals)

Exterior Destination/Route Sign

Public Address System

Stop Request System

O&M Costs

Total Cost

Present Value (3%)

Present Value (7%)

Year 1

$66,447

$594,560

$9,600

$48,720

$7,193

$726,520

$726,520

$726,520

Year 2

$66,193

$588,160

$9,600

$48,240

$7,122

$719,315

$697,736

$668,963

Year 3

$65,939

$582,400

$9,600

$47,760

$7,057

$712,756

$669,991

$620,098

Year 4

$65,685

$576,640

$9,000

$47,280

$6,986

$705,591

$649,144

$578,585

Year 5

$65,432

$570,240

$9,000

$46,800

$6,915

$698,387

$621,564

$530,774

Year 6

$65,142

$564,480

$9,000

$46,320

$6,849

$691,791

$594,940

$491,171

Year 7

$64,888

$558,720

$9,000

$45,840

$6,784

$685,232

$575,595

$459,105

Year 8

$64,670

$553,600

$9,000

$45,360

$6,726

$679,356

$550,279

$421,201

Year 9

$64,453

$547,840

$9,000

$44,880

$6,662

$672,835

$531,539

$390,244

Year 10

$64,199

$542,720

$9,000

$44,400

$6,603

$666,922

$513,530

$360,138

Year 11

$63,981

$537,600

$8,400

$44,160

$6,541

$660,682

$488,905

$336,948

Year 12

$63,764

$532,480

$8,400

$43,680

$6,483

$654,807

$471,461

$314,307

Total

$780,792

$6,749,440

$108,600

$553,440

$81,921

$8,274,193

$7,091,203

$5,898,054

Annualized

 

$599,068

$521,565


Appendix F-3: Annual Costs for Over-the-Road Buses (OTRBs) under High Scenario

Annual Costs for Over-the-Road Buses (High Scenario)

Regulatory Year

Identification of Accessible Seating and Doorways  (Signs/ISA Decals)

Exterior Destination/Route Sign

Public Address System

Stop Request System

O&M Costs

Total Cost

Present Value (3%)

Present Value (7%)

Year 1

$213,604

$1,487,040

$61,200

$86,760

$55,458

$1,904,062

$1,904,062

$1,904,062

Year 2

$214,563

$1,501,440

$61,200

$87,480

$55,940

$1,920,623

$1,863,004

$1,786,179

Year 3

$215,642

$1,501,440

$62,100

$88,560

$56,032

$1,923,774

$1,808,347

$1,673,683

Year 4

$216,721

$1,501,440

$63,000

$89,280

$56,113

$1,926,554

$1,772,429

$1,579,774

Year 5

$217,799

$1,501,440

$63,000

$90,360

$56,178

$1,928,777

$1,716,612

$1,465,871

Year 6

$218,878

$1,501,440

$63,900

$91,080

$56,259

$1,931,557

$1,661,139

$1,371,406

Year 7

$219,957

$1,501,440

$64,800

$92,160

$56,351

$1,934,708

$1,625,155

$1,296,254

Year 8

$221,036

$1,501,440

$65,700

$92,880

$56,432

$1,937,488

$1,569,365

$1,201,242

Year 9

$222,115

$1,501,440

$65,700

$93,960

$56,496

$1,939,711

$1,532,371

$1,125,032

Year 10

$224,628

$1,501,440

$66,600

$95,040

$56,588

$1,944,296

$1,497,108

$1,049,920

Year 11

$224,272

$1,501,440

$67,500

$95,760

$56,669

$1,945,641

$1,439,775

$992,277

Year 12

$225,351

$1,501,440

$67,500

$96,840

$56,734

$1,947,865

$1,402,463

$934,975

Total

$2,634,566

$18,002,880

$772,200

$1,100,160

$675,250

$23,185,056

$19,791,830

$16,380,676

Annualized

 

$1,665,537

$1,436,368


Appendix G: Small Business Data

 

Total Firms

Small Firms

Other Firms

Total Receipts ($1,000s)

Receipts:
Small Firms ($1,000s)

Receipts:
Other Firms  (%1,000s)

Avg. Receipts Per Firm:
Small Firms
($1,000s)

Avg. Receipts Per Firm:
Other Firms
($1,000s)

Total Payroll ($1,000s)

Payroll:
Small Firms ($1,000s)

Payroll:
Other Firms  ($1,000s)

Avg Payroll  Per Firm:
Small Firms ($1,000s)

Avg Payroll  Per Firm:
Other Firms ($1,000s)

NAICS 485113

625

584

41

$3,073,522

$595,653

$2,477,869

$1,019.95

$60,435.83

$1,672,480

$264,503

$1,407,977

$453

$34,341

NAICS 485210

397

369

28

$1,232,040

$407,549

$824,491

$1,104.47

$29,446.11

$546,609

$125,217

$421,392

$339

$15,050

NAICS 485510

1,265

1,211

54

$2,906,334

$1,866,746

$1,039,588

$1,541.49

$19,251.63

$850,744

$524,334

$326,410

$433

$6,045

NAICS 487110

543

517

26

$929,919

$356,455

$573,464

$689.47

$22,056.31

$236,284

$105,179

$131,105

$203

$5,043

                           

Totals  =

2,830

2,681

149

$8,141,815

$3,226,403

$4,915,412

$1,203

$32,989

$3,306,117

$1,019,233

$2,286,884

$380

$15,348

Source: U.S. Census Bureau, Statistics of U.S. Businesses (SUSB) Main, Data Tables by Enterprise Receipt Size, United States (all industries) (Number of Firms, Estimated Receipts, and Annual Payroll by Enterprise Receipt Sizes for the United States, NAICS Sectors: 2012), available at: http://www.census.gov/econ/susb.

Data Compilation Methodology: The SUSB "Tables by Enterprise Receipt Size" data are broken down by 6-digit NAICS codes, and, within each NAICS code, by 17 bands relating to "Enterprise Receipt Size," ranging from "< 100,000" on the low end to "$100 million+" on the high end.  Based on the SBA-defined "small business" size standard for the four OTRB-related NAICS codes studied in this analysis (i.e., 485113, 485210, 485510, and 487110), data were compiled for all small and non-small firms within each of the four OTRB-related NAICS codes.  Specifically, data were derived for the following areas: number of small and "other" (non-small) firms; annual and average per-firm sales receipts for small and non-small firms; and annual and average per-firm payrolls for small and non-small firms.  Totals within each NAICS code for these areas (see rows 2 -5 in chart above) were then summed across all NAICS codes to derive summary statistics across all OTRB-related NAICS codes.  These summary statistics are presented in the "Total" line at the bottom of the chart above.

2012 NAICS Codes – OTRB-Related Codes

NAICS 485113 - Bus and Other Motor Vehicle Transit Systems

NAICS 485210 - Interurban and Rural Bus Transportation

NAICS 485510 - Charter Bus Industry

NAICS 487110 - Scenic and Sightseeing Transportation, Land



Appendix H: Federal Statistics on Prevalence of Certain Categories of Functional Disabilities, U.S. Non-Institutionalized Population

As noted below, federal agencies' respective disability-related statistical data sets do not fully align in terms of methodologies, statistical categories employed, or age ranges for surveyed populations.  Unless otherwise noted, functional disability categories in tables below are taken directly from the respective federal agency data sources.  Other notes, if any, concerning derivation of tabular data below are also provided below.

Census Bureau –SIPP Data (2010)

 Functional Disability Category

Total Population

Percent of U.S. Population
(Non-Institutionalized, = 15 yrs.)

Difficulty Seeing

8,077,000

3.3%

Difficulty Hearing*

13,131,000

5.4%

Cognitive/Intellectual Disability**

2,183,000

0.9%

Ambulatory Disability***

28,339,000

11.7%

(Source: U.S. Census Bureau, Survey of Income and Program Participation, as cited in Americans with Disabilities: 2010 (July 2012).)

(Notes: *"Difficulty hearing" category includes data compiled from separate entries for "Difficulty hearing" and "Used a hearing aid."  ** "Cognitive Disability" includes data compiled from separate entries for "Intellectual disability" and "Other developmental disability.  *** SIPP does not provide a functional disability category for "Ambulatory Disability."  Data for this category represents combination of data from separate entries for "Difficulty walking (Severe)," "Used a wheelchair," and "Used a cane/crutches/walker.")

Census Bureau – American Community Survey Data (2014)

  Functional Disability Category

Total Population

Percent of U.S. Population*
(Non-Institutionalized, = 18 yrs.)

Vision Difficulty

6,802,400

2.8%

 Hearing Difficulty

10,799,456

4.5%

Cognitive Difficulty

12,769,520

5.3%

Ambulatory Difficulty

20,576,265

8.6%

(Source: U.S. Census Bureau, 2014 American Community Survey 1-Year Estimates.)

(Note: *The 2014 ACS data set provides population totals only for each functional disability category.  Figures in this "Percent of U.S. Population" column calculated based on each category's respective proportion of the total civilian non-institutionalized population 18 years and older identified in the ACS data (313,890,422).)

CDC – MMWR Data (2013)

  Functional Disability Category

Total Population

Percent of US Population
(Non-Institutionalized, = 18 yrs.)

Vision

11,148,032

4.6%

Hearing*

n/a

n/a

Cognitive

25,688,944

10.6%

Mobility

31,505,309

13.0%

(Source: Centers for Disease Control and Prevention, Behavioral Risk Factor Surveillance System, as cited in Morbidity and Mortality Weekly Report, "Prevalence of Disability and Disability Type among Adults – United States, 2013 (July 2015))

(Note: The MMWR data set does not provide statistics concerning hearing-related disabilities.)


Appendix I: Data Sources and Methodology for Threshold Analyses of Automated Announcement Systems

While the calculations used in the two threshold analyses presented in Section 6.2 are not complex, each analysis relies on data from multiple sources which, in several instances, must be estimated for purposes of use here as input values.  The data sources and basic methodology underlying each of these threshold analyses are presented below.  The formulae and discussion below use the following abbreviations: ASA (automated stop announcements); FR (fixed-route); PWD (persons with disabilities); UPT (unlinked passenger trips); and VOMS (vehicles operated in maximum service).

1.   First Threshold Analysis: Value of Benefits to Persons with Disabilities of Automated Announcement Systems on Fixed-Route Buses on Per Trip Basis

The first threshold analysis is based on the following formula:

 (Annualized ASA costs)/(# of PWD trips annually on ASA-equipped FR buses)

where the annual number of trips by persons with disabilities on ASA-equipped fixed-route buses is further estimated to be equal to:

 (# FR buses equipped annually with ASA) x (Average annual UPT per FR bus) x (PWD % of total FR bus riders) x (PWD ridership premium)

Input values, sources, and any related discussions are provided in the table below.

Input

Value

Source/Discussion

Annualized ASA costs

$3,612,015

FRIA model

Number of buses equipped annually with ASA

559

Total number of ASA-equipped buses (All Tiers/All Years)/12

Average annual UPT per fixed-route bus

114,774

Estimated value based on 2014 NTD annual data for all large transit entities (see list in Appendix A). Value derived by dividing Total annual UPT for all bus modes by total annual VOMS for all bus modes.

Percentage of persons with disabilities of total fixed-route transit ridership

4.90%

Estimated value based on average ridership by persons with disabilities on all fixed-route transit modes as presented in Transp. Research Board, TCRP Report 163, Strategy Guide to Enable and Promote Use of Fixed-Route Transit by People with Disabilities, Table2-2 (2013).  See FRIA, pp. 35-36 & n. 61.

Persons with Disabilities ridership premium

1.3

Estimated value based on transportation use survey conducted in 2002 by DOT's Bureau of Transportation Statistics.  See FRIA, pp. 35-36 & n. 62.  Survey found that, on average, persons with disabilities rode fixed-route transit buses 1.3 more times per week than bus passengers without disabilities.

2.   Second Threshold Analysis: Value of Switching Ridership from Paratransit to Fixed-Route Bus Transit

The second threshold analysis is based on the following formula:

 (Annualized ASA costs)/(Annual paratransit costs per person)

where annual per-person paratransit costs are further estimated to be equal to:

(Paratransit costs per trip [operating costs only]) x (Estimated # of paratransit trips annually per person)

Input values, sources, and any related discussions are provided in the table below.

Input

Value

Source/Discussion

Annualized ASA costs

$3,612,015

FRIA model

Paratransit operating costs (per trip)

$40.00

Rounded average per trip paratransit operating costs of Top 20 largest paratransit providers in the United States, based on 2013 annual NTD data.  See Greg Sullivan, "What if 'The Ride' operated like the best big paratransit systems in the US?" (Apr. 7, 2015), http://pioneerinstitute.org/better_government/what-if-the-ride-operated-like-the-best-big-paratransit-systems-in-the-us/.

Estimated number of paratransit trips annually (per person)

400

Assumes 8 trips weekly for 50 weeks (with two weeks of vacation annually).


Appendix J: Key Characteristics of Transit Agencies Reporting Bus Modes of Service (2014 NTD Annual Data)

The table below presents data compiled from the 2014 National Transit Database (NTD) for all transit agencies reporting operation of one or more buses in annual maximum service for any fixed-route bus mode of service (Bus VOMS).  In addition, for each reporting transit agency, the following estimated figures are provided: (i) population of persons with disabilities (PWD) in its respective service area; and (ii) total number of unlinked passenger trips (UPT) by persons with disabilities across all of its respective fixed-route bus modes.

Based on the 2014 NTD, a total of 681 transit agencies had one or more bus operating in fixed-route bus modes.  Data for each of these transit agencies is presented below in descending size order of Bus VOMS.  A key at the end of this table identifies the data source(s) and methodologies used to compile or estimate, as appropriate, the tabular data.

NTD ID

Reporting Transit Agency

State

Primary UZA

Bus VOMS

Bus VOMS Category
(by NTD Group)

Total Federal Capital Funds
($1000s)

Service Area Population -PWD (Estimated)*

Unlinked Passenger Trips - PWD
(Estimated)*

20008

MTA New York City Transit

NY

New York-Newark, NY-NJ-CT

3,819

1,000 & Over

1,118,254.3

857,599

38,990,185

20080

New Jersey Transit Corporation

NJ

New York-Newark, NY-NJ-CT

2,047

1,000 & Over

178,547.6

1,853,481

7,900,236

90154

Los Angeles County Metropolitan Transportation Authority dba: Metro

CA

Los Angeles-Long Beach-Anaheim, CA

1,904

1,000 & Over

157,748.4

828,174

17,718,456

50066

Chicago Transit Authority

IL

Chicago, IL-IN

1,568

1,000 & Over

225,322.5

339,170

13,529,721

30030

Washington Metropolitan Area Transit Authority

DC

Washington, DC-VA-MD

1,342

1,000 & Over

222,981.9

297,565

6,843,747

30019

Southeastern Pennsylvania Transportation Authority

PA

Philadelphia, PA-NJ-DE-MD

1,212

1,000 & Over

145,288.8

413,412

9,014,144

20188

MTA Bus Company

NY

New York-Newark, NY-NJ-CT

1,089

1,000 & Over

17,697.4

778,347

6,153,481

00001

King County Department of Transportation - Metro Transit Division

WA

Seattle, WA

1,080

1,000 & Over

20,146.5

201,725

5,885,339

60008

Metropolitan Transit Authority of Harris County, Texas

TX

Houston, TX

1,054

1,000 & Over

108,344.2

369,840

3,349,833

80006

Denver Regional Transportation District

CO

Denver-Aurora, CO

834

500-999

251,184.9

276,096

3,756,236

10003

Massachusetts Bay Transportation Authority

MA

Boston, MA-NH-RI

817

500-999

330,655.9

447,369

5,861,165

30034

Maryland Transit Administration

MD

Baltimore, MD

803

500-999

162,606.8

251,218

3,910,065

50027

Metro Transit

MN

Minneapolis-St. Paul, MN-WI

769

500-999

179,485.1

184,321

3,322,901

40034

Miami-Dade Transit

FL

Miami, FL

679

500-999

12,683.2

279,601

3,790,490

50113

Pace - Suburban Bus Division

IL

Chicago, IL-IN

628

500-999

36,065.0

557,394

1,552,594

90015

San Francisco Municipal Railway

CA

San Francisco-Oakland, CA

616

500-999

298,524.1

82,825

8,021,005

30022

Port Authority of Allegheny County

PA

Pittsburgh, PA

567

500-999

41,947.9

189,643

2,616,695

60056

Dallas Area Rapid Transit

TX

Dallas-Fort Worth-Arlington, TX

544

500-999

152,940.4

217,144

1,831,769

00008

Tri-County Metropolitan Transportation District of Oregon

OR

Portland, OR-WA

516

500-999

105,312.2

191,213

2,927,742

90036

Orange County Transportation Authority

CA

Los Angeles-Long Beach-Anaheim, CA

489

250-499

19,734.1

292,008

2,396,336

90014

 Alameda-Contra Costa Transit District

CA

San Francisco-Oakland, CA

472

250-499

34,991.9

141,102

2,746,869

90026

San Diego Metropolitan Transit System

CA

San Diego, CA

459

250-499

46,115.9

208,566

2,529,875

40022

Metropolitan Atlanta Rapid Transit Authority

GA

Atlanta, GA

450

250-499

63,878.1

162,973

2,929,109

90032

City of Phoenix Public Transit Department dba Valley Metro

AZ

Phoenix-Mesa, AZ

447

250-499

60,995.9

184,851

1,984,637

90002

City and County of Honolulu Department of Transportation Services

HI

Urban Honolulu, HI

431

250-499

117,495.8

108,666

3,247,987

80001

Utah Transit Authority

UT

Salt Lake City-West Valley City, UT

426

250-499

8,025.6

169,515

988,094

90013

Santa Clara Valley Transportation Authority

CA

San Jose, CA

381

250-499

142,514.2

142,947

1,610,074

50015

The Greater Cleveland Regional Transit Authority

OH

Cleveland, OH

366

250-499

43,676.5

190,639

1,936,057

60011

VIA Metropolitan Transit

TX

San Antonio, TX

360

250-499

14,936.3

244,641

2,084,336

60048

Capital Metropolitan Transportation Authority

TX

Austin, TX

339

250-499

14,331.1

89,640

1,594,839

90045

Regional Transportation Commission of Southern Nevada

NV

Las Vegas-Henderson, NV

336

250-499

17,376.1

253,091

2,926,772

50008

Milwaukee County Transit System

WI

Milwaukee, WI

334

250-499

16,261.2

115,624

2,009,699

70006

Bi-State Development Agency of the Missouri-Illinois Metropolitan District, d.b.a.(St. Louis) Metro

MO

St. Louis, MO-IL

314

250-499

48,465.8

186,340

1,474,239

50154

Metropolitan Council

MN

Minneapolis-St. Paul, MN-WI

307

250-499

7,987.4

284,971

514,419

50012

Southwest Ohio Regional Transit Authority

OH

Cincinnati, OH-KY-IN

297

250-499

2,538.5

103,127

804,881

90136

Regional Public Transportation Authority, dba: Valley Metro

AZ

Phoenix-Mesa, AZ

285

250-499

16,273.7

402,832

873,789

30051

Ride-On Montgomery County Transit

MD

Washington, DC-VA-MD

282

250-499

10,907.7

77,680

1,293,187

90009

San Mateo County Transit District

CA

San Francisco-Oakland, CA

278

250-499

16,739.0

72,973

649,164

90146

Foothill Transit

CA

Los Angeles-Long Beach-Anaheim, CA

278

250-499

44,339.6

145,520

711,586

20076

Westchester County Bee-Line System

NY

New York-Newark, NY-NJ-CT

276

250-499

682.6

95,860

1,539,282

50016

Central Ohio Transit Authority

OH

Columbus, OH

275

250-499

22,926.5

113,548

933,028

20004

Niagara Frontier Transportation Authority

NY

Buffalo, NY

269

250-499

5,992.6

165,503

1,058,517

40008

Charlotte Area Transit System

NC

Charlotte, NC-SC

268

250-499

57,769.0

104,400

1,170,472

40029

Broward County Transit Division

FL

Miami, FL

265

250-499

21,047.9

205,951

1,867,808

40035

Central Florida Regional Transportation Authority

FL

Orlando, FL

262

250-499

27,585.9

207,740

1,422,657

20206

Nassau Inter County Express

NY

New York-Newark, NY-NJ-CT

252

250-499

6,107.3

135,293

1,390,810

90147

City of Los Angeles Department of Transportation

CA

Los Angeles-Long Beach-Anaheim, CA

252

250-499

10,780.1

1,166,496

1,238,583

30083

Transportation District Commission of Hampton Roads

VA

Virginia Beach, VA

233

100-249

4,712.3

130,449

736,319

00040

Central Puget Sound Regional Transit Authority

WA

Seattle, WA

231

100-249

191,187.9

287,351

865,822

50119

City of Detroit Department of Transportation

MI

Detroit, MI

229

100-249

8,906.6

103,498

1,230,699

20122

Academy Lines, Inc.

NJ

New York-Newark, NY-NJ-CT

225

100-249

0.0

549,743

189,815

20113

Regional Transit Service, Inc. and Lift Line, Inc.

NY

Rochester, NY

221

100-249

42,515.2

72,217

842,551

10045

Connecticut Department of Transportation - CTTransit New Britain -Dattco.

CT

Hartford, CT

213

100-249

0.0

9,021

735,102

90033

City of Tucson

AZ

Tucson, AZ

211

100-249

14,145.2

80,512

965,959

30068

Fairfax Connector Bus System

VA

Washington, DC-VA-MD

208

100-249

0.0

84,515

522,096

50031

Suburban Mobility Authority for Regional Transportation

MI

Detroit, MI

205

100-249

7,688.0

541,443

453,181

10001

Rhode Island Public Transit Authority

RI

Providence, RI-MA

191

100-249

5,199.7

149,910

969,222

00029

Snohomish County Public Transportation Benefit Area Corporation

WA

Seattle, WA

189

100-249

2,848.0

70,598

425,944

30075

Delaware Transit Corporation

DE

Philadelphia, PA-NJ-DE-MD

188

100-249

25,921.4

113,867

486,760

90166

LACMTA - Small Operators

CA

Los Angeles-Long Beach-Anaheim, CA

188

100-249

4,243.6

341,296

519,988

90023

Long Beach Transit

CA

Los Angeles-Long Beach-Anaheim, CA

185

100-249

3,769.5

76,800

1,395,547

40027

Pinellas Suncoast Transit Authority

FL

Tampa-St. Petersburg, FL

182

100-249

1,052.9

113,151

695,032

20002

Capital District Transportation Authority

NY

Albany-Schenectady, NY

180

100-249

8,332.4

98,042

788,928

50005

Metro Transit System

WI

Madison, WI

179

100-249

9,427.5

24,042

745,974

70005

Kansas City Area Transportation Authority

MO

Kansas City, MO-KS

179

100-249

13,350.7

94,300

776,721

40018

Transit Authority of River City

KY

Louisville/Jefferson County, KY-IN

177

100-249

19,606.6

116,999

711,372

40041

Hillsborough Area Regional Transit Authority

FL

Tampa-St. Petersburg, FL

162

100-249

6,142.9

116,455

737,795

20126

Hudson Transit Lines, Inc.

NJ

New York-Newark, NY-NJ-CT

161

100-249

0.0

549,743

224,290

90019

Sacramento Regional Transit District

CA

Sacramento, CA

160

100-249

47,549.8

132,580

669,226

90016

Golden Gate Bridge, Highway and Transportation District

CA

San Francisco-Oakland, CA

159

100-249

16,217.0

86,031

312,854

40040

Jacksonville Transportation Authority

FL

Jacksonville, FL

158

100-249

15,485.7

131,997

540,853

90008

Santa Monica's Big Blue Bus

CA

Los Angeles-Long Beach-Anaheim, CA

152

100-249

17,172.7

44,017

922,057

90031

Riverside Transit Agency

CA

Riverside-San Bernardino, CA

149

100-249

10,244.7

168,335

448,931

90029

Omnitrans

CA

Riverside-San Bernardino, CA

144

100-249

45,103.2

146,916

740,837

10008

Pioneer Valley Transit Authority

MA

Springfield, MA-CT

141

100-249

9,703.0

81,628

559,801

40004

Metropolitan Transit Authority

TN

Nashville-Davidson, TN

137

100-249

2,118.1

70,188

451,454

90030

North County Transit District

CA

San Diego, CA

137

100-249

10,290.4

79,845

398,631

50033

Interurban Transit Partnership

MI

Grand Rapids, MI

135

100-249

14,949.7

57,929

591,198

50050

Indianapolis and Marion County Public Transportation

IN

Indianapolis, IN

133

100-249

3,369.9

116,035

504,338

60019

City of Albuquerque Transit Department

NM

Albuquerque, NM

131

100-249

18,808.7

87,997

637,443

20072

Suffolk County Department of Public Works - Transportation Division

NY

New York-Newark, NY-NJ-CT

130

100-249

2,513.2

151,800

276,961

40037

Board of County Commissioners, Palm Beach County, PalmTran, Inc.

FL

Miami, FL

130

100-249

7,807.1

142,104

559,913

60007

Fort Worth Transportation Authority

TX

Dallas-Fort Worth-Arlington, TX

130

100-249

11,414.8

76,724

372,523

30006

Greater Richmond Transit Company

VA

Richmond, VA

124

100-249

21,301.3

52,600

415,358

60006

Mass Transit Department - City of El Paso

TX

El Paso, TX-NM

124

100-249

29,863.8

114,038

599,121

20018

CNY Centro, Inc.

NY

Syracuse, NY

121

100-249

3,246.0

64,916

454,728

00003

Pierce County Transportation Benefit Area Authority

WA

Seattle, WA

120

100-249

7,105.5

55,707

501,331

50017

Greater Dayton Regional Transit Authority

OH

Dayton, OH

120

100-249

7,123.4

77,710

514,510

30070

Potomac and Rappahannock Transportation Commission

VA

Washington, DC-VA-MD

119

100-249

7,398.7

36,328

155,530

40003

Memphis Area Transit Authority

TN

Memphis, TN-MS-AR

119

100-249

12,542.0

96,658

392,387

00002

Spokane Transit Authority

WA

Spokane, WA

112

100-249

4,538.0

66,711

554,897

50010

METRO Regional Transit Authority

OH

Akron, OH

112

100-249

9,054.5

67,728

254,988

50211

Rides Mass Transit District

IL

Carbondale, IL

112

100-249

1,034.3

34,382

31,166

20128

Suburban Transit Corporation

NJ

New York-Newark, NY-NJ-CT

110

100-249

0.0

549,743

136,872

40086

Metropolitan Bus Authority

PR

San Juan, PR

109

100-249

153.4

254,225

413,295

70010

Des Moines Area Regional Transit Authority

IA

Des Moines, IA

108

100-249

680.1

39,366

211,171

70002

Transit Authority of Omaha

NE

Omaha, NE-IA

107

100-249

5,555.7

58,440

198,137

40030

Gainesville Regional Transit System

FL

Gainesville, FL

104

100-249

20,949.3

15,040

529,907

40135

Georgia Regional Transportation Authority

GA

Atlanta, GA

101

100-249

113.1

130,068

82,934

10055

Connecticut Department of Transportation - CTTRANSIT New Haven Division

CT

New Haven, CT

97

50-99

2,007.5

57,913

466,808

50060

Champaign-Urbana Mass Transit District

IL

Champaign, IL

95

50-99

0.0

11,601

643,723

00024

Clark County Public Transportation Benefit Area Authority

WA

Portland, OR-WA

94

50-99

4,733.2

46,669

297,006

50032

Mass Transportation Authority

MI

Flint, MI

92

50-99

844.2

66,945

252,279

90078

Central Contra Costa Transit Authority

CA

Concord, CA

89

50-99

2,632.5

47,472

163,099

90020

Santa Barbara Metropolitan Transit District

CA

Santa Barbara, CA

87

50-99

131.8

28,161

373,568

00007

Lane Transit District

OR

Eugene, OR

86

50-99

9,399.1

47,303

549,246

00020

Kitsap Transit

WA

Bremerton, WA

86

50-99

2,399.7

41,693

138,099

20149

Rockland Coaches, Inc.

NJ

New York-Newark, NY-NJ-CT

84

50-99

0.0

549,743

128,097

30081

Loudoun County Commuter Bus Service - Office of Transportation Services

VA

Washington, DC-VA-MD

84

50-99

0.0

26,283

86,090

60032

New Orleans Regional Transit Authority

LA

New Orleans, LA

83

50-99

5,354.1

46,895

554,773

90006

Santa Cruz Metropolitan Transit District

CA

Santa Cruz, CA

83

50-99

3,615.7

21,127

270,150

40019

Transit Authority of Northern Kentucky

KY

Cincinnati, OH-KY-IN

82

50-99

5,523.1

33,996

171,127

50022

Toledo Area Regional Transit Authority

OH

Toledo, OH-MI

82

50-99

243.0

58,313

141,695

40110

Charleston Area Regional Transportation Authority

SC

Charleston-North Charleston, SC

81

50-99

1,874.1

58,123

237,354

90012

San Joaquin Regional Transit District

CA

Stockton, CA

81

50-99

23,551.2

90,448

216,091

50036

Capital Area Transportation Authority

MI

Lansing, MI

80

50-99

7,788.8

37,675

542,407

90027

Fresno Area Express

CA

Fresno, CA

80

50-99

5,052.2

71,670

590,893

20217

Hampton Jitney, Inc.

NY

New York-Newark, NY-NJ-CT

78

50-99

0.0

1,000,789

40,976

30085

Prince George's County Transit

MD

Washington, DC-VA-MD

75

50-99

0.0

69,040

186,518

90062

Monterey-Salinas Transit

CA

Seaside-Monterey, CA

75

50-99

1,148.5

56,525

199,452

70041

Ames Transit Agency dba CyRide

IA

Atlanta, GA

74

50-99

1,182.0

3,718

323,852

40078

Cobb County Department of Transportation Authority

GA

St. Louis, MO-IL

74

50-99

2,054.8

66,055

171,379

50146

Madison County Transit District

IL

Ames, IA

74

50-99

1,818.4

28,108

129,532

40051

Chapel Hill Transit

NC

Durham, NC

73

50-99

141.2

7,781

338,296

50040

Ann Arbor Area Transportation Authority

MI

Ann Arbor, MI

73

50-99

3,766.0

19,337

317,969

30010

Lehigh and Northampton Transportation Authority

PA

Allentown, PA-NJ

70

50-99

8,062.1

53,682

245,919

60059

Brazos Transit District

TX

College Station-Bryan, TX

70

50-99

0.0

11,395

60,831

40108

Research Triangle Regional Public Transportation Authority

NC

Durham, NC

68

50-99

86.0

136,074

89,320

90171

Santa Clarita Transit

CA

Santa Clarita, CA

67

50-99

10,461.8

14,202

168,068

30014

Cumberland Dauphin-Harrisburg Transit Authority

PA

Harrisburg, PA

65

50-99

5,442.8

62,938

130,733

40007

Capital Area Transit

NC

Raleigh, NC

65

50-99

590.1

28,862

303,148

40042

Birmingham-Jefferson County Transit Authority

AL

Birmingham, AL

65

50-99

3,198.8

62,841

158,153

40179

Broward County Community Bus Service

FL

Miami, FL

65

50-99

0.0

205,951

131,916

90004

Golden Empire Transit District

CA

Bakersfield, CA

65

50-99

3,864.6

56,401

296,264

90041

Montebello Bus Lines

CA

Los Angeles-Long Beach-Anaheim, CA

65

50-99

1,411.8

30,247

388,814

90121

Antelope Valley Transit Authority

CA

Lancaster-Palmdale, CA

65

50-99

2,444.2

35,603

176,711

60051

Corpus Christi Regional Transportation Authority

TX

Corpus Christi, TX

64

50-99

4,492.6

48,845

276,883

30013

Erie Metropolitan Transit Authority

PA

Erie, PA

63

50-99

5,683.8

29,620

157,273

30071

City of Alexandria

VA

Washington, DC-VA-MD

60

50-99

4,070.5

11,197

207,700

60010

City Transit Management Company, Inc.

TX

Lubbock, TX

60

50-99

302.3

33,230

194,464

00019

Intercity Transit

WA

Olympia-Lacey, WA

59

50-99

5,154.5

20,491

219,046

20163

Lakeland Bus Lines, Inc.

NJ

New York-Newark, NY-NJ-CT

59

50-99

0.0

549,743

76,891

40002

Knoxville Area Transit

TN

Knoxville, TN

59

50-99

4,254.3

27,857

136,271

40138

Gwinnett County Board of Commissioners

GA

Atlanta, GA

59

50-99

993.6

77,311

82,864

30054

Centre Area Transportation Authority

PA

State College, PA

58

50-99

1,630.7

9,791

360,279

40036

City of Tallahassee

FL

Tallahassee, FL

58

50-99

3,452.2

17,692

208,756

60022

Capital Area Transit System

LA

Baton Rouge, LA

58

50-99

5,446.9

50,122

190,059

20161

DeCamp Bus Lines

NJ

New York-Newark, NY-NJ-CT

57

50-99

0.0

550

91,820

60018

Metropolitan Tulsa Transit Authority

OK

Tulsa, OK

57

50-99

2,370.1

52,000

153,473

90001

Regional Transportation Commission of Washoe County

NV

Reno, NV-CA

57

50-99

4,174.7

39,004

400,101

30027

York County Transportation Authority

PA

York, PA

55

50-99

2,008.4

54,209

82,525

90211

Anaheim Transportation Network

CA

Los Angeles-Long Beach-Anaheim, CA

55

50-99

496.3

33,600

441,516

00025

Salem Area Mass Transit District

OR

Salem, OR

54

50-99

1,191.7

37,388

162,810

10066

Chittenden County Transportation Authority

VT

Burlington, VT

54

50-99

1,764.7

13,580

124,250

40017

Lexington Transit Authority

KY

Lexington-Fayette, KY

54

50-99

742.6

33,426

232,984

40032

County of Volusia, dba: VOTRAN

FL

Palm Coast-Daytona Beach-Port Orange, FL

54

50-99

4,686.4

86,059

182,736

20169

Trans-Bridge Lines, Inc.

PA

New York-Newark, NY-NJ-CT

53

50-99

0.0

549,743

59,968

30012

Cambria County Transit Authority

PA

Johnstown, PA

53

50-99

12,996.7

15,297

56,609

40046

Sarasota County Area Transit

FL

Sarasota-Bradenton, FL

53

50-99

5,899.1

59,061

140,846

10006

Southeastern Regional Transit Authority

MA

New Bedford, MA

52

50-99

3,382.4

28,383

115,663

20084

Transport of Rockland

NY

New York-Newark, NY-NJ-CT

52

50-99

1,146.6

32,710

144,463

20166

Orange-Newark-Elizabeth, Inc.

NJ

New York-Newark, NY-NJ-CT

52

50-99

0.0

549,743

477,868

40025

Chatham Area Transit Authority

GA

Savannah, GA

52

50-99

3,757.1

32,876

176,017

00018

Ben Franklin Transit

WA

Kennewick-Pasco, WA

51

50-99

4,707.4

27,577

138,382

50025

Duluth Transit Authority

MN

Duluth, MN-WI

51

50-99

5,509.6

17,368

152,258

70001

StarTran

NE

Lincoln, NE

51

50-99

2,247.1

27,683

119,389

90079

SunLine Transit Agency

CA

Indio-Cathedral City, CA

51

50-99

5,874.8

55,921

229,530

20132

New Jersey Transit Corporation-45

NJ

New York-Newark, NY-NJ-CT

50

50-99

0.0

549,743

277,430

50051

Greater Lafayette Public Transportation Corporation

IN

Lafayette, IN

50

50-99

1,853.5

15,314

257,110

60017

Central Oklahoma Transportation and Parking Authority

OK

Oklahoma City, OK

50

50-99

3,909.7

92,331

140,086

20190

Port Imperial Ferry Corporation dba NY Waterway

NJ

New York-Newark, NY-NJ-CT

49

25-49

0.0

369,504

148,215

40028

Lee County Transit

FL

Cape Coral, FL

49

25-49

19,333.2

65,882

193,211

60033

Central Arkansas Transit Authority

AR

Little Rock, AR

49

25-49

961.1

24,744

134,309

90144

Livermore / Amador Valley Transit Authority

CA

Concord, CA

49

25-49

403.5

18,151

80,955

10057

Norwalk Transit District

CT

Bridgeport-Stamford, CT-NY

48

25-49

1,124.6

9,892

94,524

50059

Springfield Mass Transit District

IL

Springfield, IL

48

25-49

6,348.7

17,627

89,519

90010

Torrance Transit System

CA

Los Angeles-Long Beach-Anaheim, CA

48

25-49

954.2

58,257

196,021

30001

Kanawha Valley Regional Transportation Authority

WV

Charleston, WV

47

25-49

3,309.2

37,694

132,988

50003

Kenosha Transit

WI

Kenosha, WI-IL

46

25-49

0.0

16,997

61,635

50029

Bay Metropolitan Transit Authority

MI

Bay City, MI

46

25-49

0.0

19,367

24,318

70035

Johnson County Kansas, aka: Johnson County Transit

KS

Kansas City, MO-KS

46

25-49

1,025.3

49,251

25,083

90007

Modesto Area Express

CA

Modesto, CA

46

25-49

1,328.6

34,491

177,913

90162

The Eastern Contra Costa Transit Authority

CA

Antioch, CA

46

25-49

134.3

40,392

138,781

10064

Greater Attleboro-Taunton Regional Transit Authority

MA

Providence, RI-MA

45

25-49

3,927.9

14,039

45,961

40087

Durham Area Transit Authority

NC

Durham, NC

45

25-49

495.5

23,282

309,412

50056

Greater Peoria Mass Transit District

IL

Peoria, IL

45

25-49

366.6

26,237

163,210

90035

Gold Coast Transit

CA

Oxnard, CA

45

25-49

876.4

40,766

187,070

00012

Municipality of Anchorage - Public Transportation Department

AK

Anchorage, AK

44

25-49

1,938.5

26,467

189,200

00021

Whatcom Transportation Authority

WA

Bellingham, WA

44

25-49

1,872.6

31,527

290,061

10004

Brockton Area Transit Authority

MA

Boston, MA-NH-RI

44

25-49

3,879.7

27,247

139,752

30024

Berks Area Regional Transportation Authority

PA

Reading, PA

44

25-49

1,084.5

61,716

158,083

40001

Chattanooga Area Regional Transportation Authority

TN

Chattanooga, TN-GA

44

25-49

6,706.1

21,965

128,509

90205

City of Elk Grove

CA

Sacramento, CA

44

25-49

0.0

20,568

50,343

20145

Tompkins Consolidated Area Transit

NY

Boston, MA-NH-RI

43

25-49

3,119.8

7,046

210,545

10005

Lowell Regional Transit Authority

MA

Boston, MA-NH-RI

43

25-49

1,827.4

36,186

73,313

10013

Merrimack Valley Regional Transit Authority

MA

Worcester, MA-CT

43

25-49

17,729.1

32,778

102,287

10014

Worcester Regional Transit Authority

MA

Bridgeport-Stamford, CT-NY

43

25-49

1,234.3

59,437

183,047

10050

Greater Bridgeport Transit Authority

CT

Ithaca, NY

43

25-49

166.4

26,484

298,055

40180

University of Georgia Transit System

GA

Athens-Clarke County, GA

43

25-49

1,319.1

4,532

521,362

50057

Rock Island County Metropolitan Mass Transit District

IL

Davenport, IA-IL

43

25-49

6,938.7

13,242

171,543

90039

Culver City Municipal Bus Lines

CA

Los Angeles-Long Beach-Anaheim, CA

43

25-49

2,845.1

32,805

296,371

90042

City of Gardena Transportation Department

CA

Los Angeles-Long Beach-Anaheim, CA

43

25-49

84.7

44,541

180,768

10056

Connecticut Department of Transportation - CTTRANSIT Stamford Division

CT

Bridgeport-Stamford, CT-NY

42

25-49

86.3

25,601

173,319

30102

Martz Trailways

PA

New York-Newark, NY-NJ-CT

42

25-49

0.0

82,203

47,762

80011

Transfort

CO

Fort Collins, CO

42

25-49

17,309.7

13,535

127,970

40093

Greensboro Transit Authority

NC

Greensboro, NC

41

25-49

112.1

27,776

217,065

60101

Denton County Transportation Authority

TX

Denton-Lewisville, TX

41

25-49

4,116.7

19,468

109,105

90089

Sonoma County Transit

CA

Santa Rosa, CA

41

25-49

3,506.5

56,012

64,490

90090

Yolo County Transportation District

CA

Sacramento, CA

41

25-49

80.4

67,697

83,281

90148

Victor Valley Transit Authority

CA

Victorville-Hesperia, CA

41

25-49

2,314.0

40,199

88,985

00011

Valley Regional Transit

ID

Boise City, ID

40

25-49

4,714.1

34,619

69,014

30076

Williamsburg Area Transit Authority

VA

Williamsburg, VA

40

25-49

585.5

7,638

121,710

20003

Broome County Department of Public Transportation

NY

Binghamton, NY-PA

39

25-49

2,955.5

30,692

115,450

30080

Arlington Transit - Arlington County

VA

Washington, DC-VA-MD

39

25-49

1,309.5

16,800

139,014

50158

University of Michigan Parking and Transportation Services

MI

Ann Arbor, MI

39

25-49

0.0

5,824

357,621

70015

Wichita Transit

KS

Wichita, KS

38

25-49

3,848.1

45,122

91,350

70048

City of Lawrence

KS

Lawrence, KS

38

25-49

8.6

7,187

148,261

10105

Cape Cod Regional Transit Authority

MA

Barnstable Town, MA

37

25-49

1,383.7

29,178

32,933

50092

City of Rochester Public Transportation

MN

Rochester, MN

37

25-49

1,629.6

10,840

81,728

40012

Winston-Salem Transit Authority - Trans-Aid of Forsyth County

NC

Winston-Salem, NC

36

25-49

3,113.2

24,146

160,424

50052

South Bend Public Transportation Corporation

IN

South Bend, IN-MI

36

25-49

7,500.5

21,917

104,250

60024

Shreveport Area Transit System

LA

Shreveport, LA

36

25-49

629.2

40,732

154,917

90092

City of Fairfield - Fairfield and Suisun Transit

CA

Fairfield, CA

36

25-49

242.3

16,309

52,381

90142

Unitrans - City of Davis/ASUCD

CA

Davis, CA

36

25-49

1,841.1

3,558

193,014

90159

Western Contra Costa Transit Authority

CA

San Francisco-Oakland, CA

36

25-49

6,372.6

6,428

64,284

30007

Greater Roanoke Transit Company

VA

Roanoke, VA

35

25-49

2,571.5

14,458

115,770

50011

Stark Area Regional Transit Authority

OH

Canton, OH

35

25-49

3,759.0

54,763

130,430

50024

Western Reserve Transit Authority

OH

Youngstown, OH-PA

35

25-49

1,725.3

37,973

76,562

60009

Laredo Transit Management, Inc.

TX

Laredo, TX

35

25-49

15.1

29,747

156,022

90193

Chula Vista Transit

CA

San Diego, CA

35

25-49

0.0

22,928

153,913

10128

Connecticut Department of Transportation- CTTransit Waterbury- NET

CT

Waterbury, CT

34

25-49

287.0

24,122

135,928

30018

Red Rose Transit Authority

PA

Lancaster, PA

33

25-49

976.8

56,824

92,504

30091

Blacksburg Transit

VA

Blacksburg, VA

33

25-49

5,014.6

5,857

179,014

80005

Mountain Metropolitan Transit

CO

Colorado Springs, CO

33

25-49

1,928.5

65,384

143,817

90091

City of Visalia - Visalia City Coach

CA

Visalia, CA

33

25-49

727.3

15,970

83,700

00005

Everett Transit

WA

Seattle, WA

32

25-49

0.0

10,464

96,585

20135

Monsey New Square Trails Corporation

NY

New York-Newark, NY-NJ-CT

32

25-49

0.0

28,944

31,292

30025

County of Lackawanna Transit System

PA

Scranton, PA

32

25-49

1,692.9

66,381

56,258

40031

Lakeland Area Mass Transit District

FL

Lakeland, FL

32

25-49

1,026.5

20,880

74,056

50001

City of Appleton - Valley Transit

WI

Appleton, WI

32

25-49

22.7

23,345

54,621

50006

Belle Urban System - Racine

WI

Racine, WI

32

25-49

0.0

15,021

70,864

50096

City of Waukesha Transit Commission

WI

Milwaukee, WI

32

25-49

77.1

17,280

55,364

30015

Luzerne County Transportation Authority

PA

Scranton, PA

31

25-49

131.3

35,235

58,204

30044

Westmoreland County Transit Authority

PA

Pittsburgh, PA

31

25-49

3,150.1

39,673

26,836

30094

City of Harrisonburg Department of Public Transportation

VA

Harrisonburg, VA

31

25-49

4,601.3

5,248

135,904

40038

Escambia County Area Transit

FL

Pensacola, FL-AL

31

25-49

1,346.9

48,872

74,316

50028

St. Cloud Metropolitan Transit Commission

MN

St. Cloud, MN

31

25-49

4,173.3

12,156

108,099

90088

Napa County Transportation and Planning Agency

CA

Napa, CA

31

25-49

2,151.7

15,318

37,395

90232

Solano County Transit

CA

Vallejo, CA

31

25-49

398.1

27,861

70,469

50044

Fort Wayne Public Transportation Corporation

IN

Fort Wayne, IN

30

25-49

730.3

36,782

97,855

90134

Peninsula Corridor Joint Powers Board dba: Caltrain

CA

San Francisco-Oakland, CA

30

25-49

38,968.2

365,346

46,178

90164

Ventura Intercity Service Transit Authority

CA

Oxnard, CA

30

25-49

0.0

22,194

40,327

40058

City of Rome Transit Department

GA

Rome, GA

29

25-49

716.1

6,147

51,068

40063

Space Coast Area Transit

FL

Palm Bay-Melbourne, FL

29

25-49

3,118.2

78,718

114,028

40147

North Carolina State University Transportation Department

NC

Raleigh, NC

29

25-49

0.0

3,735

142,953

50058

Rockford Mass Transit District

IL

Rockford, IL

29

25-49

289.8

43,045

87,415

50110

Bloomington Public Transportation Corporation

IN

Bloomington, IN

29

25-49

2,386.9

8,121

172,013

60088

Jefferson Parish Department of Transit Administration

LA

New Orleans, LA

29

25-49

371.3

54,739

103,212

90173

Transit Joint Powers Authority for Merced County

CA

Merced, CA

29

25-49

0.0

24,480

40,425

00043

Link Transit

WA

Wenatchee, WA

28

25-49

360.6

13,800

48,381

40141

Central Midlands Transit

SC

Columbia, SC

28

25-49

0.0

29,464

75,223

50021

Portage Area Regional Transportation Authority

OH

Akron, OH

28

25-49

388.6

20,187

69,999

50035

Kalamazoo Metro Transit System

MI

Kalamazoo, MI

28

25-49

1,834.7

29,778

148,346

50039

Saginaw Transit Authority Regional Service

MI

Saginaw, MI

28

25-49

83.5

22,479

47,412

70016

City of Columbia

MO

Columbia, MO

28

25-49

608.7

11,621

107,184

80002

Su Tran LLC dba: Sioux Area Metro

SD

Sioux Falls, SD

28

25-49

30.9

15,552

46,812

10118

MetroWest Regional Transit Authority

MA

Boston, MA-NH-RI

27

25-49

3,714.0

24,738

23,317

30002

The Tri-State Transit Authority

WV

Huntington, WV-KY-OH

27

25-49

1,945.7

41,338

43,507

30008

Greater Lynchburg Transit Company

VA

Lynchburg, VA

27

25-49

6,203.2

9,459

121,932

50054

Muncie Indiana Transit System

IN

Muncie, IN

27

25-49

1,059.5

10,933

90,885

60090

Lower Rio Grande Valley Development Council

TX

McAllen, TX

27

25-49

2,882.4

90,374

19,232

10051

Housatonic Area Regional Transit

CT

Danbury, CT-NY

26

25-49

1,115.0

12,698

41,160

10122

Jalbert Leasing, Inc. dba C&J

NH

Portsmouth, NH-ME

26

25-49

0.0

64,320

32,361

20010

Dutchess County Division of Mass Transportation

NY

Poughkeepsie-Newburgh, NY-NJ

26

25-49

3,242.1

42,240

22,710

20177

Adirondack Transit Lines, Inc,

NY

New York-Newark, NY-NJ-CT

26

25-49

0.0

952,230

29,473

40112

City of San Juan

PR

San Juan, PR

26

25-49

0.0

82,497

61,708

70019

University of Iowa

IA

Iowa City, IA

26

25-49

1,544.2

4,782

230,834

90208

Butte County Association of Governments

CA

Chico, CA

26

25-49

865.5

22,420

66,869

10119

University Of New Hampshire - University Transportation Services

NH

Dover-Rochester, NH-ME

25

25-49

174.8

14,172

60,874

20082

New York City Department of Transportation

NY

New York-Newark, NY-NJ-CT

25

25-49

69,645.0

855,270

27,912

20210

County of Morris

NJ

New York-Newark, NY-NJ-CT

25

25-49

0.0

49,993

2,509

20211

County of Mercer

NJ

Trenton, NJ

25

25-49

0.0

45,149

5,520

30036

Charlottesville Area Transit

VA

Charlottesville, VA

25

25-49

1,906.5

9,262

111,500

40006

Cape Fear Public Transportation Authority

NC

Wilmington, NC

25

25-49

4,276.1

19,660

71,306

40015

City of Jackson, Department of Planning and Development, Transit Services Division

MS

Jackson, MS

25

25-49

2,718.1

20,128

31,120

50002

Green Bay Metro

WI

Green Bay, WI

25

25-49

40.5

20,742

70,031

50117

Laketran

OH

Cleveland, OH

25

25-49

2,104.5

31,034

24,290

60014

City of Brownsville - Brownsville Metro

TX

Brownsville, TX

25

25-49

1,932.4

21,278

85,897

40206

Berkeley Charleston Dorchester RTMA

SC

Charleston-North Charleston, SC

24

10-24

128.3

71,113

5,092

50043

Metropolitan Evansville Transit System

IN

Evansville, IN-KY

24

10-24

901.7

19,305

101,381

50047

Bloomington-Normal Public Transit System

IL

Bloomington-Normal, IL

24

10-24

408.8

12,782

123,576

90061

Yuba-Sutter Transit Authority

CA

Yuba City, CA

24

10-24

3,337.0

19,596

58,982

30026

Williamsport Bureau of Transportation

PA

New York-Newark, NY-NJ-CT

23

10-24

0.0

12,418

64,561

90149

City of Lompoc - Lompoc Transit

CA

Williamsport, PA

23

10-24

5,474.8

6,513

15,196

90206

San Luis Obispo Regional Transit Authority

CA

Mobile, AL

23

10-24

871.9

17,305

50,456

20160

Community Transit, Inc.

NJ

Greensboro, NC

23

10-24

1,414.5

549,743

26,841

40043

The Wave Transit System

AL

Santa Rosa, CA

23

10-24

2,303.8

29,973

58,626

40173

Piedmont Authority for Regional Transportation

NC

Lompoc, CA

23

10-24

0.0

151,589

23,560

90017

City of Santa Rosa

CA

San Luis Obispo, CA

23

10-24

1,904.0

19,081

114,583

90241

County of Maui - Dept. of Transportation

HI

Kahului, HI

23

10-24

1,519.7

16,113

116,742

10016

Greater Portland Transit District

ME

Portland, ME

22

10-24

2,089.0

11,575

72,967

10133

Boston Express Bus, Inc.

NH

Boston, MA-NH-RI

22

10-24

27.8

49,275

28,593

20185

Centro of Oneida, Inc.

NY

Utica, NY

22

10-24

482.8

25,436

60,938

30011

Altoona Metro Transit

PA

Altoona, PA

22

10-24

193.1

12,599

30,873

30089

Monongalia County Urban Mass Transit Authority

WV

Morgantown, WV

22

10-24

1,735.2

10,073

59,356

40047

Athens Transit System

GA

Athens-Clarke County, GA

22

10-24

489.1

12,022

80,468

40077

South Florida Regional Transportation Authority

FL

Miami, FL

22

10-24

21,744.2

616,266

49,052

40125

Municipality of Carolina

PR

San Juan, PR

22

10-24

172.0

38,181

40,023

40130

Macon-Bibb County Transit Authority

GA

Macon, GA

22

10-24

723.4

23,799

49,288

50061

Decatur Public Transit System

IL

Decatur, IL

22

10-24

68.5

12,038

71,539

60077

Santa Fe Trails - City of Santa Fe

NM

Santa Fe, NM

22

10-24

416.3

9,037

52,219

70008

Cedar Rapids Transit

IA

Cedar Rapids, IA

22

10-24

5,742.2

15,889

61,537

70014

Topeka Metropolitan Transit Authority

KS

Topeka, KS

22

10-24

385.0

19,376

59,013

80003

City of Fargo, DBA:  Metropolitan Area Transit

ND

Fargo, ND-MN

22

10-24

145.6

13,549

85,335

90119

Laguna Beach Municipal Transit

CA

Mission Viejo-Lake Forest-San Clemente, CA

22

10-24

0.0

1,750

33,213

00006

Yakima Transit

WA

Yakima, WA

21

10-24

313.5

15,714

56,802

40044

City of Montgomery-Montgomery Area Transit System

AL

Montgomery, AL

21

10-24

8.0

31,482

44,510

40094

Alternativa de Transporte Integrado -ATI

PR

San Juan, PR

21

10-24

0.0

151,495

76,845

40102

Waccamaw Regional Transportation Authority

SC

Myrtle Beach-Socastee, SC-NC

21

10-24

601.8

43,922

22,493

40115

Municipality of Caguas Mobility Office

PR

San Juan, PR

21

10-24

653.4

43,200

11,604

60107

Texoma Area Paratransit System, Inc

TX

Sherman, TX

21

10-24

2,901.4

127,908

8,759

70003

City Utilities of Springfield

MO

Springfield, MO

21

10-24

1,215.7

25,140

86,069

70012

Sioux City Transit System

IA

Sioux City, IA-NE-SD

21

10-24

239.5

13,099

53,639

70018

Iowa City Transit

IA

Iowa City, IA

21

10-24

243.3

4,619

91,867

90234

Marin County Transit District

CA

San Francisco-Oakland, CA

21

10-24

323.0

25,578

34,127

00044

Skagit Transit

WA

Mount Vernon, WA

20

10-24

356.6

13,322

40,951

00057

Central Oregon Intergovernmental Council

OR

Bend, OR

20

10-24

0.0

12,282

24,626

30023

Beaver County Transit Authority

PA

Pittsburgh, PA

20

10-24

3,141.0

22,852

42,796

30079

Fredericksburg Regional Transit

VA

Fredericksburg, VA

20

10-24

1,747.3

11,372

24,280

40026

Manatee County Area Transit

FL

Sarasota-Bradenton, FL

20

10-24

1,905.1

49,071

89,382

40100

Santee Wateree Regional Transportation Authority

SC

Sumter, SC

20

10-24

545.3

55,155

7,907

80004

Billings Metropolitan Transit

MT

Billings, MT

20

10-24

79.3

12,625

30,416

00034

Rogue Valley Transportation District

OR

Medford, OR

19

10-24

1,477.1

22,312

68,524

10061

Montachusett Regional Transit Authority

MA

Leominster-Fitchburg, MA

19

10-24

4,355.0

41,638

36,855

40174

Municipality of Yauco

PR

Yauco, PR

19

10-24

324.4

10,679

5,192

40208

City of Clemson/ Clemson Area Transit

SC

Greenville, SC

19

10-24

540.0

3,764

78,127

60103

Fort Bend County Public Transportation

TX

Houston, TX

19

10-24

603.4

60,018

13,461

90022

Norwalk Transit System

CA

Los Angeles-Long Beach-Anaheim, CA

19

10-24

979.0

61,187

85,244

90087

Santa Maria Area Transit

CA

Santa Maria, CA

19

10-24

2,424.4

11,770

43,734

90196

Placer County Department of Public Works

CA

Sacramento, CA

19

10-24

0.0

45,755

37,279

90233

Yuma County Intergovernmental Public Transportation Authority

AZ

Yuma, AZ-CA

19

10-24

114.4

27,405

22,804

30061

Mid Mon Valley Transit Authority

PA

Norwich-New London, CT-RI

18

10-24

14.4

11,697

16,620

10040

Southeast Area Transit

CT

Boston, MA-NH-RI

18

10-24

0.0

30,479

57,106

10117

Plymouth & Brockton Street Railway Company

MA

New York-Newark, NY-NJ-CT

18

10-24

0.0

76,873

23,697

20197

Meadowlands Transportation Brokerage Corporation, dba Meadowlink

NJ

Monessen-California, PA

18

10-24

1,255.9

223,743

12,248

30103

Martz Group, National Coach Works of Virginia

VA

Washington, DC-VA-MD

18

10-24

0.0

21,167

12,512

40009

Fayetteville Area System of Transit

NC

Fayetteville, NC

18

10-24

1,914.2

22,820

77,635

40074

Pasco County Public Transportation

FL

Tampa-St. Petersburg, FL

18

10-24

2,753.5

63,242

47,033

50088

Shoreline Metro

WI

Sheboygan, WI

18

10-24

65.3

6,425

26,401

50091

Wausau Area Transit System

WI

Wausau, WI

18

10-24

0.0

6,550

32,050

60062

University of Arkansas, Fayetteville

AR

Fayetteville-Springdale-Rogers, AR-MO

18

10-24

0.0

6,609

96,497

70009

Davenport Public Transit

IA

Davenport, IA-IL

18

10-24

0.0

10,965

75,087

80009

Missoula Urban Transportation District

MT

Missoula, MT

18

10-24

128.9

8,980

44,157

90168

Roseville Transit

CA

Sacramento, CA

18

10-24

1,026.3

16,250

18,314

90226

Imperial County Transportation Commission

CA

El Centro-Calexico, CA

18

10-24

0.0

23,216

42,083

90236

Stanislaus County Public Works - Transit

CA

Modesto, CA

18

10-24

0.0

71,542

17,049

60015

Island Transit

TX

New York-Newark, NY-NJ-CT

17

10-24

0.0

6,111

40,767

20165

Olympia Trails Bus Company, Inc.

NJ

Poughkeepsie-Newburgh, NY-NJ

17

10-24

333.8

549,743

29,880

20178

Ulster County Area Transit

NY

Baltimore, MD

17

10-24

5.2

21,800

20,651

30040

Annapolis Department of Transportation

MD

Baltimore, MD

17

10-24

0.0

14,888

36,662

30048

Howard Transit

MD

Gulfport, MS

17

10-24

1,776.9

32,485

52,076

40014

Ms Coast Transportation Authority

MS

Texas Non-UZA

17

10-24

573.2

17,323

40,167

60038

Lafayette Transit System

LA

Lafayette, LA

17

10-24

563.7

17,712

65,760

60102

Concho Valley Transit District

TX

San Angelo, TX

17

10-24

798.2

14,541

10,910

80028

Cache Valley Transit District

UT

Logan, UT

17

10-24

520.5

7,354

95,202

90131

City of Scottsdale - Scottsdale Trolley

AZ

Phoenix-Mesa, AZ

17

10-24

1,981.5

8,880

43,630

30072

Transit Services of Frederick County

MD

Frederick, MD

16

10-24

0.0

7,620

37,731

40005

ART (Asheville Redefines Transit)

NC

Asheville, NC

16

10-24

1,309.5

11,842

70,117

40024

Metra Transit System (Columbus, GA)

GA

Columbus, GA-AL

16

10-24

919.1

35,682

53,889

40053

Greenville Transit Authority

SC

Greenville, SC

16

10-24

1,039.1

33,503

48,807

40054

Johnson City Transit System

TN

Johnson City, TN

16

10-24

208.5

12,942

33,184

40092

Clarksville Transit System

TN

Clarksville, TN-KY

16

10-24

288.4

16,527

34,478

40140

Collier Area Transit

FL

Bonita Springs, FL

16

10-24

816.1

37,235

57,895

40159

Regional Transportation Authority

TN

Nashville-Davidson, TN

16

10-24

992.4

177,309

9,700

50045

Gary Public Transportation Corporation

IN

Chicago, IL-IN

16

10-24

1,345.2

10,172

36,519

50099

Eau Claire Transit

WI

Eau Claire, WI

16

10-24

0.0

8,760

47,644

50157

Butler County Regional Transit Authority

OH

Cincinnati, OH-KY-IN

16

10-24

414.1

40,602

24,718

60097

Midland-Odessa Urban Transit District

TX

Odessa, TX

16

10-24

1,741.6

13,492

18,921

70032

St. Joseph Transit

MO

St. Joseph, MO-KS

16

10-24

15.4

11,623

20,759

90229

El Dorado County Transit Authority

CA

Sacramento, CA

16

10-24

0.0

5,390

16,708

10007

Berkshire Regional Transit Authority

MA

Pittsfield, MA

15

10-24

2,330.1

20,273

28,079

10102

Connecticut Department of Transportation

CT

Hartford, CT

15

10-24

0.0

45,750

11,212

20005

C-TRAN

NY

Elmira, NY

15

10-24

2,333.3

16,183

31,464

20208

County of Burlington

NJ

Philadelphia, PA-NJ-DE-MD

15

10-24

0.0

55,350

6,084

30074

Harford Transit

MD

Aberdeen-Bel Air South-Bel Air North, MD

15

10-24

22.4

23,608

15,370

30088

County Commissioners of Charles County, MD

MD

Waldorf, MD

15

10-24

521.8

14,069

36,085

30096

The Tri-County Council for the Lower Eastern Shore of Maryland

MD

Salisbury, MD-DE

15

10-24

174.3

17,671

15,505

40056

Pee Dee Regional Transportation Authority

SC

Florence, SC

15

10-24

262.9

52,646

11,218

50108

Janesville Transit System

WI

Janesville, WI

15

10-24

6,488.9

9,286

21,718

50159

River Valley Metro Mass Transit District

IL

Kankakee, IL

15

10-24

199.9

8,630

46,426

60026

City of Monroe Transit System

LA

Monroe, LA

15

10-24

971.6

5,900

58,408

60094

The Lawton Area Transit System

OK

Lawton, OK

15

10-24

0.0

15,158

21,558

60096

Cleveland Area Rapid Transit

OK

Norman, OK

15

10-24

101.3

11,130

49,061

90219

Northern Arizona Intergovernmental Public Transportation Authority

AZ

Flagstaff, AZ

15

10-24

3,558.7

6,620

90,020

10096

City of Bangor - BAT Community Connector

ME

Manchester, NH

14

10-24

20.0

8,381

46,747

40188

Virgin Islands Department of Public Works

VI

Dover-Rochester, NH-ME

14

10-24

0.0

13,407

7,462

10002

Manchester Transit Authority

NH

Bangor, ME

14

10-24

0.0

18,545

23,769

10086

Cooperative Alliance for Seacoast Transportation

NH

New York-Newark, NY-NJ-CT

14

10-24

0.0

18,656

22,981

20196

Middlesex County Area Transit

NJ

Wheeling, WV-OH

14

10-24

0.0

81,305

17,207

30035

Ohio Valley Regional Transportation Authority

WV

Hagerstown, MD-WV-PA

14

10-24

36.3

9,876

21,547

30090

Eastern Panhandle Transit Authority

WV

Sebastian-Vero Beach South-Florida Ridge, FL

14

10-24

247.4

25,057

7,382

40104

Indian River County

FL

Virgin Islands, VI

14

10-24

5,755.0

25,003

52,912

50004

LaCrosse Municipal Transit Utility

WI

La Crosse, WI-MN

14

10-24

0.0

7,476

58,445

50030

Battle Creek Transit

MI

Battle Creek, MI

14

10-24

14.5

13,082

26,582

60012

Waco Transit System, Inc.

TX

Waco, TX

14

10-24

9.4

13,365

51,899

60072

Ozark Regional Transit

AR

Fayetteville-Springdale-Rogers, AR-MO

14

10-24

210.4

41,146

13,448

60082

The Gulf Coast Center

TX

Texas City, TX

14

10-24

542.0

67,322

13,705

60091

Hill Country Transit District

TX

Killeen, TX

14

10-24

274.6

54,947

32,046

90200

Kings County Area Public Transit Agency

CA

Hanford, CA

14

10-24

2.1

11,032

37,494

90231

City of Irvine

CA

Los Angeles-Long Beach-Anaheim, CA

14

10-24

0.0

23,294

12,797

50205

Greater Mankato Transit System

MN

Portland, OR-WA

13

10-24

299.7

4,532

36,007

70050

Southeast Missouri State University

MO

Atlantic City, NJ

13

10-24

0.0

1,508

16,293

00046

South Metro Area Regional Transit

OR

Augusta-Richmond County, GA-SC

13

10-24

65.6

2,544

17,478

20200

South Jersey Transportation Authority

NJ

Huntsville, AL

13

10-24

900.9

201,330

5,556

40023

Augusta Richmond County Transit Department

GA

Mankato, MN

13

10-24

0.0

27,876

38,547

40071

City of Huntsville, Alabama - Public Transportation Division

AL

Dubuque, IA-IL

13

10-24

65.8

16,002

27,314

70011

City of Dubuque

IA

Waterloo, IA

13

10-24

692.5

6,960

20,048

70013

Metropolitan Transit Authority of Black Hawk County

IA

Cape Girardeau, MO-IL

13

10-24

233.3

12,476

20,887

80007

Pueblo Transit System

CO

Pueblo, CO

13

10-24

0.0

19,268

49,483

80012

Great Falls Transit District

MT

Great Falls, MT

13

10-24

0.0

11,403

21,366

90093

Redding Area Bus Authority

CA

Redding, CA

13

10-24

1,024.0

22,130

40,568

90161

City of Union City Transit Division

CA

San Francisco-Oakland, CA

13

10-24

0.0

7,062

19,712

00059

Josephine County

OR

Grants Pass, OR

12

10-24

0.0

13,000

9,028

10053

Cape Ann Transportation Authority

MA

Boston, MA-NH-RI

12

10-24

137.5

4,922

9,467

20137

Monroe Bus Corporation

NY

Poughkeepsie-Newburgh, NY-NJ

12

10-24

0.0

42,238

15,748

20158

Tioga County

NY

Binghamton, NY-PA

12

10-24

0.0

8,008

2,670

30003

Mid-Ohio Valley Transit Authority

WV

Parkersburg, WV-OH

12

10-24

927.9

7,046

25,057

30009

Petersburg Area Transit

VA

Richmond, VA

12

10-24

1,788.2

3,855

20,397

30095

County of Lebanon Transit Authority

PA

Lebanon, PA

12

10-24

0.0

18,833

15,129

30108

Cecil County Government - SSCT

MD

Philadelphia, PA-NJ-DE-MD

12

10-24

248.8

12,509

2,175

40011

High Point Transit

NC

High Point, NC

12

10-24

202.4

14,716

42,733

40128

Okaloosa County Board of County Commissioners

FL

Fort Walton Beach-Navarre-Wright, FL

12

10-24

1,320.0

26,868

7,953

50020

Springfield City Area Transit

OH

Springfield, OH

12

10-24

111.0

11,543

12,843

50148

Blue Water Area Transportation Commission

MI

Port Huron, MI

12

10-24

1,723.7

30,488

48,446

50199

Delaware County Transit Board

OH

Columbus, OH

12

10-24

68.9

18,292

2,769

60001

Amarillo City Transit

TX

Amarillo, TX

12

10-24

0.0

21,167

17,922

60016

Beaumont Municipal Transit System

TX

Beaumont, TX

12

10-24

0.0

11,417

26,228

60040

CityLink Transit

TX

Abilene, TX

12

10-24

94.0

17,447

24,711

60049

Las Cruces Area Transit

NM

Las Cruces, NM

12

10-24

1,011.7

11,816

36,027

70047

Unified Government Transit Department

KS

Kansas City, MO-KS

12

10-24

427.8

19,541

7,572

80010

City of Greeley - Transit Services

CO

Greeley, CO

12

10-24

565.2

11,102

26,073

80016

Mesa County

CO

Grand Junction, CO

12

10-24

1,026.4

19,560

44,192

90155

City of Vacaville

CA

Vacaville, CA

12

10-24

1,320.4

10,525

25,049

00047

City of Corvallis

OR

Pocatello, ID

11

10-24

3,318.9

5,751

55,302

00064

Valley Transit

WA

Fairbanks, AK

11

10-24

1,346.8

5,981

38,227

30137

Monroe County Transportation Authority

PA

Corvallis, OR

11

10-24

1,035.9

26,777

11,969

50174

City of Danville/Danville Mass Transit

IL

Walla Walla, WA-OR

11

10-24

0.0

8,159

30,357

00022

City of Pocatello - Pocatello Regional Transit

ID

Hartford, CT

11

10-24

0.0

11,769

14,548

00045

Fairbanks North Star Borough Transit

AK

New York-Newark, NY-NJ-CT

11

10-24

0.0

11,319

25,691

10130

Connecticut Department of Transportation -CTTRANSIT New Britain

CT

Syracuse, NY

11

10-24

5.8

24,835

41,710

20085

Clarkstown Mini-Trans

NY

Syracuse, NY

11

10-24

13.6

30,317

6,110

20116

Centro of Cayuga, Inc.

NY

East Stroudsburg, PA-NJ

11

10-24

2,962.6

8,008

20,194

20172

Centro of Oswego, Inc.

NY

Panama City, FL

11

10-24

1,988.3

12,453

26,817

40185

Bay County Transportation Planning Organization

FL

Aguadilla-Isabela-San Sebastian, PR

11

10-24

253.0

19,040

33,351

40197

Municipality of Lares

PR

San Juan, PR

11

10-24

0.0

7,350

2,240

40201

Municipality of Guaynabo

PR

Jackson, MI

11

10-24

47.6

21,157

27,613

50034

City of Jackson Transportation Authority

MI

Muskegon, MI

11

10-24

1,672.2

25,800

26,910

50037

Muskegon Area Transit System

MI

Danville, IL-IN

11

10-24

396.9

27,206

33,280

60108

Harris County Community Services Department, Office of Transit Services

TX

Houston, TX

11

10-24

53.6

454,879

4,952

30087

Fayette Area Coordinated Transportation

PA

New York-Newark, NY-NJ-CT

10

10-24

80.2

26,775

9,850

90156

City of San Luis Obispo

CA

Philadelphia, PA-NJ-DE-MD

10

10-24

115.5

4,416

55,995

20071

Huntington Area Rapid Transit

NY

Uniontown-Connellsville, PA

10

10-24

390.9

20,548

7,344

20201

County of Cumberland

NJ

Hickory, NC

10

10-24

284.7

19,298

3,327

40172

Western Piedmont Regional Transit Authority

NC

Oshkosh, WI

10

10-24

0.0

58,506

5,597

50009

GO Transit

WI

Houma, LA

10

10-24

708.6

8,789

44,457

60080

Terrebonne Parish Consolidated Government

LA

Victoria, TX

10

10-24

652.2

13,331

8,051

60095

Golden Crescent Regional Planning Commission

TX

San Luis Obispo, CA

10

10-24

0.0

9,333

11,171

90214

City of Redondo Beach - Beach Cities Transit

CA

Los Angeles-Long Beach-Anaheim, CA

10

10-24

0.0

6,454

19,323

30109

St. Mary's Transit System -Dept. of Public Works and Transit

MD

Longview, WA-OR

9

under 10

553.0

5,456

17,367

40049

Gadsden Transportation Services - City of Gadsden

AL

Portland, ME

9

under 10

29.8

10,019

4,178

60131

San Marcos Urban Transit District

TX

New York-Newark, NY-NJ-CT

9

under 10

90,896.4

5,917

6,316

70043

City of Jefferson

MO

Lexington Park-California-Chesapeake Ranch Estates, MD

9

under 10

0.0

5,980

13,268

00016

RiverCities Transit

WA

Owensboro, KY

9

under 10

316.3

11,560

19,244

10114

Biddeford-Saco-Old Orchard Beach Transit Committee Shuttle Bus

ME

Gadsden, AL

9

under 10

480.9

8,211

7,884

20078

Metro-North Commuter Railroad Company, dba: MTA Metro-North Railroad

NY

Jackson, TN

9

under 10

188.1

656,893

17,786

40020

Owensboro Transit System

KY

Raleigh, NC

9

under 10

0.0

8,910

21,886

40057

Jackson Transit Authority

TN

Jacksonville, NC

9

under 10

0.0

10,493

27,907

40143

Town of Cary

NC

Mansfield, OH

9

under 10

0.0

12,765

14,791

40166

City of Jacksonville

NC

Beloit, WI-IL

9

under 10

660.0

11,153

5,547

50090

Richland County Transit

OH

Cincinnati, OH-KY-IN

9

under 10

244.4

10,686

12,832

50109

City of Beloit Transit System

WI

Wichita Falls, TX

9

under 10

837.3

5,345

11,772

50166

Clermont Transportation Connection

OH

San Marcos, TX

9

under 10

0.0

21,716

3,499

60035

Wichita Falls Transit System

TX

Davenport, IA-IL

9

under 10

0.0

15,512

22,207

70007

Bettendorf Transit System

IA

Jefferson City, MO

9

under 10

0.0

3,929

10,655

80014

Rapid Transit System

SD

Rapid City, SD

9

under 10

275.9

8,359

14,094

90175

City of Lodi - Transit Division

CA

Lodi, CA

9

under 10

209.4

7,680

10,413

90198

City of Porterville

CA

Porterville, CA

9

under 10

860.3

7,140

30,656

10098

Western Maine Transportation Services, Inc.

ME

Nashua, NH-MA

8

under 10

11.3

36,099

7,438

30093

City of Hazleton -- Hazleton Public Transit

PA

Lewiston, ME

8

under 10

113.9

8,532

10,658

50171

Fond du Lac Area Transit

WI

Hagerstown, MD-WV-PA

8

under 10

47.8

5,703

7,555

60100

City of Farmington dba: Red Apple Transit

NM

Washington, DC-VA-MD

8

under 10

0.0

4,732

6,614

70053

Flint Hills Area Transportation

KS

Hazleton, PA

8

under 10

0.0

13,135

12,195

10087

Nashua Transit System

NH

Albany, GA

8

under 10

1,038.6

9,389

24,277

30042

Washington County Transit

MD

Port St. Lucie, FL

8

under 10

2,813.9

7,715

21,434

30058

City of Fairfax CUE Bus

VA

Spartanburg, SC

8

under 10

289.1

1,805

40,511

40021

Albany Transit System

GA

Winter Haven, FL

8

under 10

1,751.4

9,754

50,801

40097

Council on Aging of St. Lucie, Inc.

FL

Gainesville, GA

8

under 10

939.0

47,973

9,119

40101

Spartanburg Transit System

SC

Mayaguez, PR

8

under 10

0.0

5,922

23,891

40127

Polk County Transit Services Division - Polk County Board of County Commissioners

FL

Fargo, ND-MN

8

under 10

75.7

29,187

11,276

40144

Hall Area Transit

GA

Terre Haute, IN

8

under 10

165.4

3,655

7,193

40194

Municipality of Mayaguez

PR

Elkhart, IN-MI

8

under 10

117.5

11,359

16,441

50026

City of Moorhead, DBA: Metropolitan Area Transit

MN

Milwaukee, WI

8

under 10

120.1

4,295

23,627

50053

Terre Haute Transit Utility

IN

Fond du Lac, WI

8

under 10

24.0

11,029

20,092

50149

Michiana Area Council of Governments

IN

Chicago, IL-IN

8

under 10

0.0

19,691

23,049

50160

Washington County Transit

WI

Holland, MI

8

under 10

413.2

16,179

5,407

50183

City of Valparaiso

IN

Alexandria, LA

8

under 10

8.7

3,141

9,490

50184

Macatawa Area Express Transportation Authority

MI

McAllen, TX

8

under 10

1,570.3

7,730

19,028

60025

City of Alexandria

LA

Farmington, NM

8

under 10

126.2

10,445

34,715

60099

City of McAllen - McAllen Express Transit

TX

Albuquerque, NM

8

under 10

1,996.3

16,105

36,435

60111

Rio Metro Regional Transit District

NM

Manhattan, KS

8

under 10

252.4

123,629

3,954

80008

Cities Area Transit

ND

Grand Forks, ND-MN

8

under 10

230.2

7,180

16,987

80020

The City of Cheyenne Transit Program

WY

Cheyenne, WY

8

under 10

195.6

7,493

13,319

90043

City of Commerce Municipal Buslines

CA

Los Angeles-Long Beach-Anaheim, CA

8

under 10

231.5

1,239

31,353

90165

Thousand Oaks Transit

CA

Thousand Oaks, CA

8

under 10

186.3

18,841

11,489

90197

City of Tracy

CA

Tracy, CA

8

under 10

0.0

7,055

6,084

90213

City of Petaluma

CA

Petaluma, CA

8

under 10

1,240.9

6,479

17,616

10015

Lewiston-Auburn Transit Committee

ME

Lewiston, ME

7

under 10

18.0

8,842

18,270

30041

Allegany County Transit

MD

Hartford, CT

7

under 10

7,194.2

12,243

8,749

30989

Central Shenandoah Planning District Commission

VA

Portland, ME

7

under 10

861.1

7,190

3,456

10063

Middletown Transit District

CT

Poughkeepsie-Newburgh, NY-NJ

7

under 10

0.0

11,019

18,727

10112

South Portland Bus Service

ME

Cumberland, MD-WV-PA

7

under 10

0.0

3,074

12,672

20148

Newburgh Beacon Bus Corporation

NY

Staunton-Waynesboro, VA

7

under 10

0.0

27,000

6,192

40045

Tuscaloosa County Parking and Transit Authority

AL

Tuscaloosa, AL

7

under 10

258.0

14,331

14,904

40096

Tar River Transit

NC

Rocky Mount, NC

7

under 10

856.2

9,637

15,384

40155

St Johns County, Florida, Board of County Commissioners

FL

St. Augustine, FL

7

under 10

443.2

27,807

12,711

40158

Lake County Board of County Commissioners

FL

Leesburg-Eustis-Tavares, FL

7

under 10

431.8

17,744

15,600

40167

Concord Kannapolis Area Transit

NC

Concord, NC

7

under 10

4,595.2

11,025

23,031

40177

Buckhead Community Improvement District

GA

Atlanta, GA

7

under 10

0.0

16,416

5,658

40191

Transit Authority of Central Kentucky

KY

Elizabethtown-Radcliff, KY

7

under 10

195.8

28,707

1,701

40234

Autonomous Municipality of Ponce

PR

Ponce, PR

7

under 10

0.0

11,470

50,278

50041

City of Anderson Transportation System

IN

Anderson, IN

7

under 10

776.6

9,848

10,663

50093

Lima Allen County Regional Transit Authority

OH

Lima, OH

7

under 10

1,029.0

16,232

14,318

70030

Coralville Transit System

IA

Iowa City, IA

7

under 10

470.4

1,288

28,886

80013

City of Casper

WY

Casper, WY

7

under 10

55.7

7,656

8,121

80019

Bis-Man Transit Board

ND

Bismarck, ND

7

under 10

798.0

10,609

6,792

90244

City of Tulare

CA

Visalia, CA

7

10-24

0.0

7,617

21,582

10107

Milford Transit District

CT

Bridgeport-Stamford, CT-NY

6

under 10

195.8

4,641

20,055

20009

City of Poughkeepsie

NY

Poughkeepsie-Newburgh, NY-NJ

6

under 10

151.8

3,461

17,861

20096

Putnam County Transit

NY

New York-Newark, NY-NJ-CT

6

under 10

0.0

7,099

6,126

20175

Private Transportation Corporation

NY

New York-Newark, NY-NJ-CT

6

under 10

0.0

248,998

31,050

20179

Hendrick Hudson Bus Lines, Inc.

NY

Poughkeepsie-Newburgh, NY-NJ

6

under 10

0.0

29,901

2,172

30101

City of Washington

PA

Pittsburgh, PA

6

under 10

1,547.7

8,259

2,985

40010

City of Gastonia

NC

Gastonia, NC-SC

6

under 10

0.0

13,690

13,873

40016

Ashland Bus System

KY

Huntington, WV-KY-OH

6

under 10

0.0

4,802

6,260

40080

Kingsport Area Transit System

TN

Kingsport, TN-VA

6

under 10

6.4

8,966

8,318

40095

Greenville Area Transit

NC

Greenville, NC

6

under 10

112.4

9,132

26,704

40120

City of Ocala, Florida

FL

Ocala, FL

6

under 10

95.9

11,444

21,367

40137

Municipality of Bayamon

PR

San Juan, PR

6

under 10

842.3

14,192

9,071

40150

Municipality of Barceloneta

PR

Florida-Imbary-Barceloneta, PR

6

under 10

484.4

5,881

5,471

40184

The City of Bowling Green/Community Action of Southern Kentucky

KY

Bowling Green, KY

6

under 10

22.2

6,750

5,195

40186

City of Murfreesboro

TN

Murfreesboro, TN

6

under 10

460.5

11,724

13,002

40195

Municipality of San Lorenzo

PR

San Juan, PR

6

under 10

48.6

7,020

4,145

50142

Steel Valley Regional Transit Authority

OH

Weirton-Steubenville, WV-OH-PA

6

under 10

12.7

3,848

7,406

60086

Fort Smith Transit

AR

Fort Smith, AR-OK

6

under 10

57.2

14,311

11,845

60093

Texarkana Urban Transit District

TX

Texarkana-Texarkana, TX-AR

6

under 10

0.0

12,544

15,432

60104

Jonesboro Economical Transportation System

AR

Jonesboro, AR

6

under 10

56.3

8,030

4,238

60118

City of Edmond

OK

Oklahoma City, OK

6

under 10

0.0

11,560

13,162

80107

The University of Montana - ASUM Transportation

MT

Missoula, MT

6

under 10

0.0

10,240

19,388

90050

Simi Valley Transit

CA

Simi Valley, CA

6

under 10

910.8

13,147

18,754

90199

City of Madera

CA

Madera, CA

6

under 10

592.6

7,502

7,042

40132

Goldsboro-Wayne Transportation Authority

NC

New York-Newark, NY-NJ-CT

5

under 10

2,380.0

5,917

10,882

90239

City of Sierra Vista

AZ

Glens Falls, NY

5

under 10

230.2

7,452

7,916

20006

City of Long Beach

NY

New York-Newark, NY-NJ-CT

5

under 10

0.0

3,535

19,209

20120

Greater Glens Falls Transit System

NY

Youngstown, OH-PA

5

under 10

130.2

10,507

16,616

20202

Essex County Division of Training and Employment

NJ

Pottstown, PA

5

under 10

0.0

79,181

5,431

30055

Shenango Valley Shuttle Service

PA

Parkersburg, WV-OH

5

under 10

0.0

18,545

5,385

30077

Borough of Pottstown - Pottstown Area Rapid Transit

PA

High Point, NC

5

under 10

0.0

6,732

12,452

30098

Washington County Commissioners

OH

Goldsboro, NC

5

under 10

0.0

3,728

839

40131

Davidson County Transportation

NC

San Juan, PR

5

under 10

188.9

23,092

6,684

40165

Municipality of Juncos

PR

Cleveland, TN

5

under 10

238.2

7,992

3,220

40170

Southeast Tennessee Human Resource Agency -Cleveland Urban Area Transit System Division

TN

Port St. Lucie, FL

5

under 10

182.4

13,200

4,822

40192

Martin County

FL

San Juan, PR

5

under 10

1.9

24,674

1,771

40199

Autonomous Municipality of Vega Alta

PR

Asheville, NC

5

under 10

361.0

8,629

1,624

40224

Buncombe County

NC

Augusta-Richmond County, GA-SC

5

under 10

0.0

33,841

1,404

40235

Aiken Area Council on Aging, Inc.

SC

Milwaukee, WI

5

under 10

107.6

22,935

1,788

50161

Ozaukee County Transit Services

WI

Huntington, WV-KY-OH

5

under 10

0.0

10,539

5,577

50186

Lawrence County Port Authority

OH

Cleveland, OH

5

under 10

59.5

23,161

1,060

50198

Medina County Public Transit

OH

Port Arthur, TX

5

under 10

356.8

24,300

929

60013

Port Arthur Transit

TX

Lake Charles, LA

5

under 10

54.8

9,356

6,073

60023

Lake Charles Transit System

LA

Longview, TX

5

under 10

452.8

13,152

13,089

60081

Longview Transit

TX

Tyler, TX

5

under 10

391.0

11,262

12,197

60089

City of Tyler

TX

Kansas City, MO-KS

5

under 10

0.0

13,811

7,945

70046

City of Independence

MO

St. George, UT

5

under 10

393.1

14,721

13,906

80026

City of St. George

UT

Riverside-San Bernardino, CA

5

under 10

0.0

10,050

22,268

90052

City of Corona

CA

Sierra Vista, AZ

5

under 10

45.8

15,840

8,318

00061

City of Albany

OR

Idaho Falls, ID

4

under 10

55.7

8,572

10,458

00065

Benton County

OR

Albany, OR

4

under 10

64.1

9,005

463

50132

Twin Cities Area Transportation Authority

MI

Corvallis, OR

4

under 10

73.4

3,942

3,433

50145

City of Kokomo

IN

Hartford, CT

4

under 10

0.0

9,514

19,734

50177

ColumBUS Transit

IN

Manchester, NH

4

under 10

0.0

6,130

10,007

60034

Pine Bluff Transit

AR

Poughkeepsie-Newburgh, NY-NJ

4

under 10

0.0

8,491

3,952

90215

Carson Area Metropolitan Planning Organization

NV

New York-Newark, NY-NJ-CT

4

under 10

119.2

7,056

8,964

90238

City of Delano

CA

Weirton-Steubenville, WV-OH-PA

4

under 10

124.1

5,824

8,441

90240

City of Lake Havasu

AZ

Westminster-Eldersburg, MD

4

under 10

114.4

12,586

3,537

00042

Targhee Regional Public Transit Authority

ID

Winchester, VA

4

under 10

127.5

11,432

899

10132

State of Connecticut - CTTransit - Nason - Torrington-Winsted

CT

Hattiesburg, MS

4

under 10

172.5

5,818

971

11154

Flight Line, Inc.

NH

Anniston-Oxford, AL

4

under 10

163.7

39,747

316

20187

Village of Kiryas Joel

NY

Anderson, SC

4

under 10

149.5

2,520

5,525

20192

Bergen County Community Transportation

NJ

Spring Hill, FL

4

under 10

213.6

91,417

1,401

30066

Weirton Transit Corporation

WV

Arecibo, PR

4

under 10

0.0

3,828

2,838

30092

Carroll County Department of Public Works

MD

Charlotte, NC-SC

4

under 10

402.3

16,254

814

30099

City of Winchester

VA

Middletown, OH

4

under 10

0.0

3,016

5,231

40060

Hub City Transit

MS

Michigan City-La Porte, IN-MI

4

under 10

105.8

9,706

4,447

40064

East Alabama Regional Planning and Development Commission

AL

Benton Harbor-St. Joseph-Fair Plain, MI

4

under 10

230.5

57,423

8,735

40081

Anderson Transit Authority

SC

Kokomo, IN

4

under 10

84.6

3,904

16,559

40146

Hernando County Board of County Commissioners

FL

Columbus, IN

4

under 10

94.0

16,207

4,392

40160

Municipality of Camuy

PR

DeKalb, IL

4

under 10

0.0

6,510

1,266

40205

Iredell County Area Transportation Services

NC

Pine Bluff, AR

4

under 10

209.3

15,314

288

50019

City of Middletown - Middletown Transit System

OH

New Orleans, LA

4

under 10

8.9

8,859

8,053

50098

Michigan City Transit

IN

Turlock, CA

4

under 10

0.0

4,407

7,660

50215

Voluntary Action Center

IL

Carson City, NV

4

under 10

461.4

5,515

7,053

60058

St. Bernard Urban Rapid Transit

LA

Manteca, CA

4

under 10

465.0

5,207

4,257

90201

City of Turlock

CA

Sacramento, CA

4

under 10

0.0

11,686

5,207

90217

City of Manteca

CA

Delano, CA

4

under 10

0.0

6,969

2,913

90235

City of Lincoln

CA

Lake Havasu City, AZ

4

under 10

91.0

5,682

2,128

00051

Asotin County PTBA

WA

Lewiston, ID-WA

3

under 10

0.0

3,984

2,857

20191

City of Kingston Citibus

NY

Kingston, NY

3

under 10

0.0

3,475

3,812

20215

Watertown CitiBus

NY

Watertown, NY

3

under 10

6.6

3,929

7,077

40193

Liberty Transit

GA

Bristol-Bristol, TN-VA

3

under 10

0.0

3,210

796

60105

Intracity Transit

AR

Bristol-Bristol, TN-VA

3

under 10

0.0

6,722

8,053

70051

Cape Girardeau County Transit Authority

MO

San Juan, PR

3

under 10

49.8

9,762

1,263

30053

Bristol Virginia Transit

VA

San Juan, PR

3

under 10

0.0

3,852

4,059

40055

Bristol Tennessee Transit System

TN

Arecibo, PR

3

under 10

114.7

5,768

2,942

40122

Municipality of Cayey

PR

Nashville-Davidson, TN

3

under 10

655.4

10,232

1,463

40126

Municipality of Humacao

PR

Fajardo, PR

3

under 10

0.0

5,400

5,795

40151

Municipality of Hatillo

PR

San Juan, PR

3

under 10

180.0

7,254

929

40162

Franklin Transit Authority

TN

Hinesville, GA

3

under 10

0.0

7,012

2,445

40164

Municipality of Fajardo

PR

San Juan, PR

3

under 10

0.0

56

2,305

40182

Municipality of Toa Baja

PR

Asheville, NC

3

under 10

0.0

16,200

9,346

40198

Municipality of Dorado

PR

Concord, NC

3

under 10

0.0

8,244

1,775

40229

Henderson County/ Apple Country Public Transit

NC

Miami, FL

3

under 10

0.0

10,114

5,068

40233

City of Salisbury - Salisbury

NC

Chicago, IL-IN

3

under 10

0.0

4,108

8,132

44929

City of Fort Lauderdale

FL

Evansville, IN-KY

3

under 10

73.8

19,712

723

50042

East Chicago Transit

IN

Indianapolis, IN

3

under 10

0.0

2,940

9,001

50107

Henderson Area Rapid Transit

KY

Hot Springs, AR

3

under 10

63.5

4,239

6,613

50209

Central Indiana Regional Transportation Authority

IN

Dallas-Fort Worth-Arlington, TX

3

under 10

0.0

249,189

1,291

60113

City of Cleburne

TX

Dallas-Fort Worth-Arlington, TX

3

under 10

4.5

14,388

274

60115

Public Transit Services

TX

Joplin, MO

3

under 10

356.5

13,886

427

70040

City of Joplin Metro Area Public

MO

Cape Girardeau, MO-IL

3

under 10

97.0

13,500

4,829

80025

City of Loveland Transit

CO

Fort Collins, CO

3

under 10

0.0

5,640

6,371

90034

City of Glendale Transit

AZ

Phoenix-Mesa, AZ

3

under 10

869.3

25,166

5,682

90195

Paso Robles Transit Services

CA

El Paso de Robles (Paso Robles)-Atascadero, CA

3

under 10

70.0

3,477

6,977

00048

Lewiston Transit System

ID

Lewiston, ID-WA

2

under 10

203.7

5,642

1,826

00063

City of Milton-Freewater

OR

Coeur d'Alene, ID

2

under 10

231.8

1,500

353

00053

Coeur d'Alene Tribe dba Citylink Transit

ID

Coeur d'Alene, ID

2

under 10

574.6

3,030

10,003

00055

Kootenai County

ID

Marysville, WA

2

under 10

0.0

11,254

9,395

00060

The Tulalip Tribes of Washington

WA

Walla Walla, WA-OR

2

under 10

0.0

647

442

10049

The Greater New Haven Transit District

CT

New Haven, CT

2

under 10

1,516.3

49,212

228

20176

Kaser Bus Service

NY

New York-Newark, NY-NJ-CT

2

under 10

0.0

477

1,809

20212

County of Hunterdon

NJ

New York-Newark, NY-NJ-CT

2

under 10

0.0

30,199

758

20213

City of Mechanicville

NY

Albany-Schenectady, NY

2

under 10

0.0

608

396

30111

Washington Rides

PA

Pittsburgh, PA

2

under 10

90.1

27,848

1,042

40073

Lee-Russell Council of Governments

AL

Auburn, AL

2

under 10

0.0

20,285

1,011

40121

Municipality of Hormigueros

PR

Mayaguez, PR

2

under 10

4.0

4,813

2,770

40124

Municipality of Cidra

PR

San Juan, PR

2

under 10

0.0

515

491

40145

Municipality of Manati

PR

San Juan, PR

2

under 10

0.0

3,852

2,578

40161

Cherokee County Board of Commissioners

GA

Atlanta, GA

2

under 10

0.0

1,839

1,532

40183

Municipality of San Sebastian

PR

Aguadilla-Isabela-San Sebastian, PR

2

under 10

0.0

10,025

298

40217

Iredell County Area Transportation Services

NC

Charlotte, NC-SC

2

under 10

230.7

15,314

1,327

40218

Oldham's Public Bus

KY

Louisville/Jefferson County, KY-IN

2

under 10

0.0

1,172

1,178

40231

Orange Public Transportation

NC

Durham, NC

2

under 10

0.0

13,555

818

50038

Niles Dial-A-Ride

MI

South Bend, IN-MI

2

under 10

71.3

33,786

720

50095

Lorain County Transit

OH

Lorain-Elyria, OH

2

under 10

235.7

24,897

2,422

50143

Brunswick Transit Alternative

OH

Cleveland, OH

2

under 10

0.0

6,296

1,600

90220

City of Folsom

CA

Sacramento, CA

2

under 10

0.0

9,090

4,055

20203

Cape May County Fare Free Transportation

NJ

Boston, MA-NH-RI

1

under 10

0.0

13,325

135

10123

Greater Derry Salem Cooperative Alliance for Regional Transportation

NH

Worcester, MA-CT

1

under 10

85.5

12,080

81

10126

Worcester Regional Transit Authority COA

MA

New York-Newark, NY-NJ-CT

1

under 10

0.0

21,036

9

20089

Village of Spring Valley Bus

NY

Twin Rivers-Hightstown, NJ

1

under 10

0.0

4,040

342

20194

East Windsor Township

NJ

Philadelphia, PA-NJ-DE-MD

1

under 10

208.5

2,366

403

20195

Gloucester County Division of Transportation Services

NJ

New York-Newark, NY-NJ-CT

1

under 10

0.0

35,703

100

20198

TransOptions, Inc.

NJ

Villas, NJ

1

under 10

0.0

5,448

49

20214

Town of Warwick Dial A Bus

NY

Poughkeepsie-Newburgh, NY-NJ

1

under 10

27.3

6,032

487

40114

Municipality of Aguada

PR

Aguadilla-Isabela-San Sebastian, PR

1

under 10

0.0

10,032

269

40117

Municipality of Vega Baja

PR

San Juan, PR

1

under 10

116.1

12,887

1,588

40123

Federal Programs Municipality of Gurabo

PR

San Juan, PR

1

under 10

41.9

9,800

998

40221

Gaston County

NC

Gastonia, NC-SC

1

under 10

63.8

39,162

491

60114

STAR Transit

TX

Dallas-Fort Worth-Arlington, TX

1

under 10

328.6

18,025

279

70049

River Bend Transit

IA

Davenport, IA-IL

1

under 10

34.7

59,375

517

90163

Camarillo Area Transit

CA

Camarillo, CA

1

under 10

81.4

7,656

676

90194

City of Atascadero

CA

El Paso de Robles (Paso Robles)-Atascadero, CA

1

under 10

0.0

3,044

1,460

 

Totals =

   

52,328

 

6,272,837.2

44,404,008

258,796,035

Notes/Data Sources:

(a)   Primary Urbanized Area (UZA) –Primary UZA of reporting transit agency as listed in 2014 NTD annual data; UZAs are based on Census 2010 UZA designations (which total 486 UZAs in the US and Puerto Rico).

(b)   Bus VOMS - Calculated from 2014 NTD annual data by combining data for all fixed-route bus modes reported by each reporting transit agency (i.e., per 5-Digit NTD ID number).  All 2014 NTD data is available on the NTD website (https://www.transit.dot.gov/ntd/ntd-data).

(c)   Bus VOMS Category (by NTD Group) – Transit agencies assigned to one of seven Bus VOMS categories based on the Bus VOMS for each reporting transit agency. Bus VOMS categories mirror the seven VOMS-based size groupings used by FTA when reporting NTD annual summary data.  See, e.g., 2014 NTD Annual Summary – Tables 3 (Federal Government Sources for Transit Operating Funds Applied) & 7 (Transit Capital Funds Applied – Summary and Federal Sources).

(d)   Total Federal Capital Funds -  Calculated from 2014 NTD annual data based on all reported sources of federal "transit capital funds applied" for each reporting transit agency.  See 2014 NTD Annual Data, 2014 Table 7: Transit Capital Funds Applied - Summary and Federal Sources.

(e)   Service Area Population - Persons with Disabilities (PWD) - Estimated for each reporting transit agency as follows: (service area population per 2014 NTD annual data) x (applicable urbanized area (UZA) % of persons with disabilities (PWD)), with UZA PWD % based on US Census Bureau, Percent of People with a Disability - United States - Urbanized Areas and Puerto Rico (GCT1810) (2014 1-Yr Estimates, or, if unavailable, 2008-2010 ACS 3-Yr Estimates) (All Census data can be accessed through the Census Bureau's "American Fact Finder" data portal, available at: http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml).

(f)   Unlinked Passenger Trips (UPT) - Persons with Disabilities (PWD) - Estimated for each reporting transit agency as follows: (total UPT for all bus modes per 2014 NTD annual data) x (.049), with .049 equal to the calculated average national fixed-route bus ridership by persons with disabilities from survey data in TCRP Report 163 (see discussion in FRIA, Section 6.1).