Southern California Transit Advocates wishes to submit the following comments for the record regarding the March 2010 service change program.

We recognize that OCTA, like virtually every public transit agency in California, has been hard hit by actions of the Legislature that eliminated the State Transit Assistance (STA) fund, which is the only state funding source that can be used for transit service operations. Nevertheless, we hope that whatever changes need to be made in order to balance the OCTA operating budget will be those which impact the lowest number of passengers.

OCTA is to be commended for creating a transparent public process. Making all relevant information - including all possible strategies, by line number - available via the OCTA website gives all affected parties not only a voice in the process, but also an education as to the difficult decisions that must be made in order to allocate scarce resources to maintain service for as many patrons as possible.

With that said, we have chosen not to make line-specific recommendations, but rather to make our preferences for strategies part of the record.

We suggest that the highest priority be given to widening headways and removing selected trips from schedules ("trip thinning"). Both of these strategies allow for lines to continue operation at lower service levels, which has the least impact on mobility via transit.

If trip thinning and headway widening by themselves do not provide sufficient savings to balance the operating budget, we suggest that lines which have low ridership but operate within a reasonable walking distance of parallel service be the ones considered for peak-hour only operation or cancellation. Access to service within a close radius of affected passengers must be the primary concern when considering total (or near-total) elimination of a line.

It is our sincere hope that these two strategies, in combination, can create sufficient savings of resources to prevent more severe actions from having to be considered.

We would also like to comment on the proposed cancellation of overnight ("night owl") service, which appears from the documentation we have seen to be a foregone conclusion. We know that those who use such services develop an attachment which goes beyond the rationality of cost vs. ridership; however, our own observations are that the use of this service is so low that its continued operation cannot be justified. We do, however, strongly suggest that service in the night owl corridors (Lines 43, 50, 57, and 60) discontinue operation no earlier than midnight and resume service in the 4:00am hour, as there appears to us to be sufficient ridership during those late evening and early morning hours to justify operating service.

Again, we appreciate the availability of information to allow us to provide relevant and informed comment.