Southern California Transit Advocates wishes to submit the following additional comments for the record regarding the March 2010 service change program. (Note: Our previous comments, on the public input process for this service change program, may be read here.)

We do not object to the changes proposed for owl service on Lines 43, 50, 57 and 60 as the proposal is consistent with the position we submitted on October 29. Likewise, we do not object to the proposed reductions in service levels on Lines 21, 25, 30, 35, 37, 50, 55, 64, 66, 72, 76, 89, 145, and 167 as this strategy is one we urged OCTA to undertake in our previous comments.

We have concerns, however, about the proposed restructuring of Lines 29, 43, 47, 53, 57 and 59. (We do not object to the proposed breaking of Line 70 into two lines.) The proposed route segment consolidations to form Lines 129, 143 and 153 will create, in our view, lines that will be difficult to operate on-time because of their length and wide headways. We also foresee that passengers will have great difficulty making transfer connections to the former parent routes because of the above, as well as the disparate headways between connecting lines. We suggest that the existing lines continue to operate their entire length, but that OCTA create shortlines at the proposed break points to reduce service levels based on demand in the North County area.

There is one additional caveat we would like to add on the preceding. We believe that existing service levels must be maintained on Line 57 to and from Brea Mall in order to properly serve ridership to and from Cal State University Fullerton.

We do not object to the cancellation, in whole or in part, of Lines 24, 51, 62, 74, 75, 76, 82, 86, 131, 147, 164, 172, 193 and 693. However, we urge that weekend service on Line 85 be retained due to the resultant loss of direct service between San Juan Capistrano and Laguna Beach and the thin service network in that part of Orange County that would make it extremely difficult - if not impossible - for displaced patrons to replace that lost service with any reasonable degree of efficiency.

We agree with the proposed extension of Line 167 to replace the viable route segment of Line 24.

We also share the hope of OCTA that further reductions will not be made necessary by the delayed replacement of State Transit Assistance funds.