Southern California Transit Advocates strongly objects to the proposed Dual Hub BRT (Line 910/Silver Line), replacing portions of several lines presently operating on the El Monte Busway and the Harbor Transitway. We have concerns in several areas.

There are obvious operational issues, with severe potential adverse effects on Metro's passengers. At present, any service-affecting event in downtown Los Angeles, such as at Staples Center, only has an effect on Harbor Transitway service. Under this proposal, anything affecting service coming from the south will also have a negative effect on eastbound El Monte Busway service, due to the interlined nature of the proposed service. We also have concerns that when the El Monte Busway is closed for construction, forcing service onto mixed traffic lanes on the I-10 freeway, southbound Harbor Transitway service will be adversely affected; again, such service-affecting conditions under the current configuration would be limited to the El Monte Busway service.

There is no reference in the proposal to the maintenance of span of service to match the existing service on Lines 446-447, 484 and 490, and to guarantee timed transfer connections to the replacement local lines, especially for connections made by the last southbound trips at Artesia Transit Center and the last eastbound trips at El Monte Station.

At present, most passengers ride through the proposed hub locations on Lines 446-447, 484 and 490. We are concerned that there will be insufficient security for passengers forced to disembark at the Line 910 terminals and wait for connecting service. We are especially concerned about this condition at Artesia Transit Center.

We also believe this proposal will result in considerably higher service levels on the Harbor Transitway than passenger needs dictate, and fear that this will result in the creation of shortline "El Monte Busway-only" trips in future service change programs. Should that prove true, we would have to ask why there was a combination of the two corridors in the first place; we instead suggest that question be asked now.

Finally, the question of premium express zone charges appears to be one that Metro staff cannot find an equitable solution to. When originally proposed, the normal express charges were to apply; however, when presented to the San Gabriel Valley and South Bay sector governance councils for approval, statements were made that the premium charges would not be charged for the new service. This would appear to place the other lines that operate via the El Monte Busway (Line 487 and 489) and the Harbor Transitway (Lines 445, 450X, 460, and 550) at a competitive disadvantage as they would continue to charge the premium fare; we had considered advocating that the express charge be eliminated from those lines as well, but that would create a new imbalance for Metro's passengers as other lines using the I-10 (Lines 439 and 534) and I-605 (Line 577X) freeways would continue to carry this premium charge.

Southern California Transit Advocates must therefore suggest that the Line 910 proposal, as it presently exists, is flawed and should not be considered for implementation without further study. We urge the Board to delay approval of this line until the above issues can be addressed in a manner that both ensure quality service for Metro's customers and avoids creating inequities for them.