16 December 2002

Mr. Charles Shannon, Board Chairperson

VIA Metropolitan Transit Authority

Dear Mr. Shannon:

The Just Transportation Alliance of San Antonio is a newly-formed coalition of VIA customers, VIATrans riders, and others who support improved livability, opportunity and mobility in the city and region.  Representing diverse constituencies, the San Antonio Just Transportation Alliance respectfully requests that the members of the VIA Board delay the anticipated vote to approve the Comprehensive Service Plan (“the Plan”) scheduled for 17 December 2002.

The current version of the Plan represents significant changes to VIA's essential fixed route and paratransit services.  We believe that because the implications of these changes have not been fully considered, the approval of these changes should be delayed to:  
· Allow VIA to engage more meaningfully with its current fixed route and paratransit consumers; 
· Ensure that the proposed Comprehensive Service Plan to which the public is asked to respond is both comprehensive and a plan, a proposal that clearly integrates VIA's fixed route, downtown, and VIATrans, or paratransit services;
· Ensure that VIA's proposed changes are consistent with the Metropolitan Transportation Plan, approved in 1999, which outlined the region's priorities, objectives, and strategies for mobility;
· Guard against premature changes prior to the outcome of a publicly-announced effort to increase local sales tax revenues;  and
· To provide VIATrans customers whose service is likely to be severed with viable alternatives for transportation.
The attached document provides significantly more detail on these concerns.  

As conscientious stewards of the city's public transportation service, the Board should not move forward or approve the proposed Plan until (1) the community- particularly VIA riders- can be assured that system modifications reflect explicitly the input of those affected; (2) the Plan clearly integrates VIA, VIATrans, and downtown services effectively and efficiently; (3) the Plan links to and furthers the region's overall mobility goals; (4) VIA details its fiscal priorities and plans for enhancing services with or without a successful initiative to increase its revenues; and (5) provides alternative means of transportation for displaced VIATrans customers.

We propose to work with VIA to improve the current Plan.  As consumers that depend on and use VIA, we share a common and mutual goal with the Board and staff of VIA: The enhancement and further development of a first-class public transportation system that effectively and efficiently provides mobility to the San Antonio community. As parties who share that interest, we stand both as individuals and members of numerous community organizations in San Antonio ready to engage with each of you as fellow community partners.

Sincerely,
The San Antonio Just Transportation Alliance

Allen Townsend Donna McBee Manuel Gonzalez

Alliance Representative Alliance Representative Alliance Representative

210 924 3767 210 337 3312 210 493 9272

I. VIA's public participation process should be characterized not by technical compliance with the law, but by a proactive, inclusive outreach, innovation, planning, and evaluation process of its proposed changes by the San Antonio community, including fixed route and paratransit customers.

As a public transportation provider, VIA provides essential services that "bring people together and meets community needs" by linking persons with disabilities, seniors, low-income citizens, students, and others with employment, education/training, medical care, and communities of faith. In a community in which 3% of the population has a physical or mental disability that limits independent mobility, the proportion of the population that is aging is disproportionately large with nearly one in three seniors over age 75 reporting mobility limitations, and an estimated one in ten households reporting that they do not own an automobile, access to and availability of these services is imperative to the well-being of the community and its citizens.

VIA's public participation process should have been markedly more inclusive, participatory, and democratic, particularly targeting the inclusion and input of those most likely to bear the consequences of these changes. Instead, VIA' s public participation process has been relatively perfunctory with "VIA staff present at (five) public hearings to answer questions and record the concerns and suggestions of the public" with assurances that "comments will be taken into consideration by the members of the VIA Board before they accept the final plan," according to the VIA press release which announced these meetings. What these 'public hearings' did not include was the meaningful engagement of consumers. Instead, citizens were provided with maps and route changes of a plan which appeared "sealed and delivered" to which they were to "respond" for "consideration." Given the essential link that VIA services provide to the community's economic, educational, social, medical, and cultural resources, the San Antonio community- and in particular, VIA’s consumers- deserve nothing less than meaningful engagement in and dialogue regarding these changes.

VIA consumers and the San Antonio community were asked to respond to a

proposed Comprehensive Service Plan that is neither comprehensive nor a plan.

As described in the opening paragraph of the Detailed Service Scenarios, Final Report, "the Comprehensive Service Plan (the Plan or CSP) is a study of the general service design of the VIA system. The focus of the study is on the bus system, excluding the downtown streetcars and the senior-disabled paratransit service known as VIATrans. The goals of the study are to optimize the design of the service to increase ridership while retaining some level of access throughout the region." This description contains a perplexing irony: While purporting to provide a "study of the general service design," the PLAN explicitly excluded two of the system's most important components for VIA's current customer base: downtown service and VIATrans. Given these omissions, it is difficult to take seriously the "comprehensiveness" of the subsequent plan, an incomplete proposal to which the community was, additionally, asked to respond.

The CSP, currently, contains no implementation schedules. Thus, while it references thirteen (13) transfer centers as essential amenities in increasing the use of and comfort of riders, these centers are not expected to be completed for five (5) to eight (8) years. Instead of a plan for implementation, VIA presents a system design for fixed route service without a realistic timeline that makes clear that some of its most important elements will not be on-line until the beginning of the next decade.

RECOMMENDATION: We would urge members of the VIA Board to use the extra time to signal their commitment to a inclusive public participation process in which each component of its transportation services is comprehensively evaluated. The Board should instruct the staff to implement a process that includes in its public evaluation process (1) downtown service proposals, (2) visual documentation of changes to current paratransit service customers under varying scenarios, and (3) a timeline of the amenities construction upon which service is based. This integration will, in fact, provide a comprehensive plan.

II. VIA's proposed changes represent a departure from existing plans outlined by the Authority in the region's Metropolitan Transportation Plan, a document that is designed to serve as the basic framework for the continuous, comprehensive, and coordinated regional transportation planning, funding, and implementation.

As a member of the San Antonio Metropolitan Planning Organization (SAMPO), VIA was a participating party in the compilation and formulation of Mobility 2025- Metropolitan Transportation Plan (MTP), approved 6 December 1999. Described as "the basic framework for the San Antonio-Bexar County Metropolitan Planning Organization's continuous, comprehensive, and coordinated regional transportation planning efforts for the next twenty-five years," the MTP contains VIA's plans for a rigorous implementation schedule of innovative transit services and amenities. Included in this framework are "additional bus services (with or without fixed guideway transit service), "an orderly expansion of the bus system," completion of bus stop improvements as ADA compliance projects, and the initiation of a "neighborhood feeder service" to serve "relatively short distance nonwork trip purposes by designing bus (or van ) routes which serve specific neighborhoods and converge on neighborhood activity centers," improvements scheduled through 2025.

The MTP also includes VIA's operating projections with paratransit services expected to increase "slight(ly) in the level of directly operated service and a greater increase in the level of purchased (contract) service" over this same planning window. Fiscally, VIA stated that these initiatives were financially feasible based on "forecasts (which) indicate that future revenues will keep pace with future costs," excluding the cost of light rail construction. Designed to respond to the perennially disjointed planning and implementation schemes in which regional transportation providers rarely collaborated or coordinated, the MTP process, as well as its plans, are "necessary to insure that transportation decisions are not made independently and that federal tax dollars are used in accordance with legitimate public needs and desires."

While the proposed Plan may provide some riders with increased bus service, VIA has yet to demonstrate how the proposed modifications further the achievement of the regional goals it outlined and adopted in the MTP, improvements on which the region's overall transportation plan for the next two decades are predicated. Further, while VIA has referred to revenue constraints as a principal catalyst for the CSP, there has been no public discussion of those fiscal conditions that have changed between the favorable financial projections of the MTP in 1999 and the muted financial warnings which underpin the PLAN today.

RECOMMENDATION: The San Antonio Just Transportation Alliance urges VIA to present clearly how the changes of the CSP coordinate with and further the planning goals of the region's MTP.

III. VIA has publicly announced its intention to pursue initiatives to increase its share of sales tax revenues. In the absence of public information that demonstrates VIA's impending financial collapse and the yet unknown outcome of this tax revenue increase initiative, significant changes in the fixed route and paratransit services appear premature.

We appreciate the difficult balance that the Board and staff have often struck between system revenues and service. Because VIA receives a comparably small share of sales tax revenues, relative to the state's other metropolitan transit authorities, we understand the need for the Authority to pursue additional funds. However, in the absence of publicly-available information that demonstrates VIA's impending financial collapse and the yet-unknown outcome of this tax revenue increase initiative, we believe the sweeping changes of the Plan- particularly its impacts on fixed route and paratransit service- are premature.

RECOMMENDATION: We urge VIA to delay the premature changes of the proposed Plan until the outcome of its additional funding through the Legislature and voters is finalized.

IV. VIATrans customers whose services are being threatened are often being presented with untenable choices. In the absence of viable transportation alternatives, VIA should grandfather these riders into system modifications adopted by the Board.

In its most recent estimate, VIA projected that changes in VIA’s route structure will eliminate approximately 77 of its current paratransit customers from the service area. Responding to the difficulties these changes will create, VIA has countered that if customers can reach the outer

boundaries of the service area, they can link to the newly reconfigured paratransit service. VIA's response, however, assumes that a viable alternative infrastructure somehow exists for these 77 customers.

However, as the MTP to which VIA was a party clearly describes, this alternative does not inevitably exist as ”pedestrian facilities are incomplete, inadequate, and inaccessible… the existing system does not adequately link neighborhoods with public transit or activity centers. Sidewalks are too narrow, are discontinuous, are in poor condition, have obstacles, and a general lack of curb cuts.” Nearly four years after the adoption of the MTP, the state of pedestrian infrastructure have not been markedly improved and in some cases, have further deteriorated.

Thus, VIA presents these paratransit customers with an untenable choice: Without any assurance that pedestrian infrastructure along the route to the outer limits of the VIA service area is , in fact, adequate, accessible, or even, passable, risk personal injury and/or safety or simply go without the services that have made employment, medical services, education, and community participation accessible and possible.

RECOMMENDATION: In response to these concerns, the members of the San Antonio Just Transportation Alliance believe that the VIA's current customers and the community would be best served by delaying a vote on the current configuration of the PLAN. We would urge VIA to ensure that current VIATrans customers whose s ervice is likely to be severed have viable transportation alternatives and failing that, to grandfather these riders into the plan that is adopted by the Board.