Southern California Transit Advocates offers the following comments on the proposed service changes, for implementation in December 2010 or later.

We support the staff recommendations for Lines 168, 202, 608 and 620. We also support the staff recommendation for Line 625-626, as modified by the Metro South Bay governance council.

We suggest the retention of Main St. service on Line 214 but do not object to the cancellation of service on Broadway. We also suggest that the Line 220 service north of Pico Blvd. continue to operate as an extension of selected Line 16 trips presently terminating at Cedars-Sinai Medical Center, but do not object to the cancellation of the segment duplicated by Big Blue Bus Line 12.

We support the Line 607 staff recommendation in concept, but suggest operation in a clockwise direction in one peak period and a counter-clockwise direction in the other, based on existing passenger travel patterns and school schedules, with headway based upon running time for each loop's completion.

We oppose the staff recommendation for Line 177; we consider the service between Jet Propulsion Laboratory and Memorial Park Gold Line Station to be essential to network connectivity and it should not be canceled unless Pasadena ARTS agrees to extend their present peak-hour Line 52 service to JPL to all-day operation as a replacement.

We also oppose the staff recommendation for Line 287. This would be the third change to service in these corridors in 18 months and would cancel the "Line 287A-287B" configuration that was just implemented as part of the June 2010 service change program (and we note that this proposal was made public before the implementation of the most recent change, making for an awkward situation in which Metro has proposed the cancellation of a line it had not yet implemented!). In addition, we are concerned that the staff proposal would result in a very short Line 287 configuration, which might prove non-productive and result in cancellation of the remaining service in the future. We therefore suggest delaying further changes to the line for a minimum of six months to allow evaluation of all past changes.

We oppose the staff recommendation for Line 439 and instead suggest that Line 35 be extended over the route of Line 439 to Fox Hills Mall and that Line 534 be restored to the previous Line 434 configuration and designation, with selected weekday peak-hour trips operating to downtown Los Angeles via the I-10 freeway. We also reiterate our position from the June 2009 service change program that service on La Cienega Blvd. be reevaluated as part of the forthcoming Expo Line bus-rail interface plan, which drives our suggestions.

We continue to object to the operation of Line 902 and advocate its cancellation and restoration of Line 233 peak-hour service. The line has not achieved its stated goals and we note that our own monitoring of afternoon peak hour service, provided to you previously, has provided data consistent with that from Metro's automatic passenger counting system. We do not feel that the pending improvements to the Van Nuys Blvd. corridor will be implemented in a reasonable amount of time, and we do not believe that continuing the non-productive Line 902 service in anticipation of those improvements is a rational use of Metro's finite resources.

We support all of the staff recommendations for Metro Rapid Lines 711, 714, 715, 750, 753, 762, 780 and 920 but suggest that restoration of the previous peak-hour service on limited-stop Lines 311, 315 and 350 be considered.