survey results on draft general and formula rules

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Rail and Public Transit Division Statewide Transportation Improvement Fund

Survey Results on Draft General and Formula Rules December 5, 2017

Introduction

The Oregon Department of Transportation made the draft Oregon State Administrative General and

Formula Rules for the Statewide Transportation Improvement Fund (STIF) available for public comment

Nov. 7 – 21, 2017. Feedback was collected using an online survey with questions focused on four key

elements of the draft rules, including Use of STIF, STIF Formula Planning Requirements, Advisory

Committee Requirements, and Qualified Entities Distribution of Formula Program Moneys. Respondents

were able to comment on any section of the draft rules beyond the four key elements.

ODOT collected a total of 82 survey responses from a variety of stakeholders. Respondents were not

required to answer all survey questions.

Key Findings

• Most respondents agreed the key elements are heading in the right direction.

• The key element with the most notable incident of disagreement was Qualified Entities

Distribution of Formula Program Moneys.

o Respondents representing Cities said there should be instances when Cities are

Qualified Entities, particularly when a City is the primary public transportation provider

in the Qualified Entity’s area and the Qualified Entity has few transportation resources.

o Respondents representing Cities requested that they receive Formula funds

proportional to the tax revenue generated within their jurisdictions.

o Respondents representing non-profit transportation providers requested a mechanism

for their organization to receive STIF funds.

o Respondents requested ODOT provide suggested methods for Qualified Entities to

distribute formula funds to Sub-Recipients.

• Ensure Sub-Recipients are involved in STIF Plan process. Respondents requested that rules

protect Sub-Recipient ability to influence a Qualified Entity’s planning process. Some recipients

suggested allowing Sub-Recipients to participate in advisory committees.

• Advisory committees should represent interests that reflect populations intended to benefit

from STIF. Respondents who shared this comment did not want advisory committees to use

Special Transportation Fund committees or other committees that do not fully reflect STIF

intentions.

• Acknowledge the limited resources and capacity of small and rural entities by providing

flexibility to fulfill the intent of law. Respondents shared concerns that STIF planning, advisory

committee and reporting requirements would be too burdensome for small and rural entities

and present a barrier to implementing public transportation improvements. Respondents

requested that rules utilize existing processes as much as possible and avoid creating new

Statewide Transportation Improvement Fund Survey Results on Draft General and Formula Rules

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paperwork or committees. Respondents also shared that small and rural public transportation

providers have the greatest need for funds. About half of these comments came from

respondents who identified with counties that are qualified entities.

• Require STIF funds for bus purchases be limited to electric or low-emission buses under

certain circumstances. Respondents who shared this comment requested that STIF include a

goal of reducing air quality and climate change impacts of Oregon’s transportation sector by

helping public transportation providers phase out diesel buses. These respondents requested

that providers in areas with more than 50,000 population and buying vehicles over 35 foot in

length be required to purchase electric or low emission buses. These respondents most

commonly identified as individuals or non-profits.

• Items where clarification or definition was requested include:

o Low-income as it relates to the goal of improving service for low-income populations.

o Non-profit regarding the eligibility of non-profit public transportation providers to

receive STIF funds.

o STIF Plan process and timeframe for formula fund applications.

o Eligible uses of STIF funds for low-income fares on light rail and long-term bond

payments.

o Forms of public transportation eligible for STIF.

o Recipient ability to retain unspent funds.

o Role of advisory committee in STIF Plan development.

o Eligibility requirements to sit on advisory committees.

o The allocation formula for Counties that are Qualified Entities.

Summary

A summary of observed comment themes organized by level of agreement begins on the following page.

Respondents who identified with an entity type were grouped into the following categories for reporting

purposes in the pie charts at the beginning of each section.

Qualified Entity: Transportation districts, mass transit districts, counties without a mass transit or

transportation district or Indian Tribe identified as a qualified entity in Section 122 of House Bill 2017.

Not Qualified Entity: City or county that is not a qualified entity, special district or intergovernmental

entity that provides public transportation, non-profit public transportation provider, other non-profit or

other government entity.

Individual/Other: Non-affiliated individuals or other organization that do not fit in one of the above

entity types.


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Level of Agreement with Draft Formula Rules: Use of STIF

All Responses (56)* Individual/Other (18)

Qualified Entity (14) Not Qualified Entity (22)

* Two respondents did not provide an entity type.


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Comments on Draft Formula Rules: Use of STIF

• Most respondents agreed strongly or somewhat with the

draft use of STIF rules

• A small number of individuals and qualified entities

disagreed strongly or somewhat with the draft rules

Strongly agree

• Include a limit for administrative costs

• Allow local communities to define “low-income”

• Clearly state all forms of public transportation that are

eligible for funding

• Light rail transit should be eligible for low-income fare

reduction programs

• Allow funds to be used to pay for bonds

• Retain language that funds service with destinations or

stops in Oregon to allow flexibility to also serve other states

Somewhat agree

• Allow recipients flexibility to retain control of unspent funds

• STIF projects should reduce greenhouse gas emissions

• There should be circumstances when Cities are allowed to

be a Qualified Entity

• Need to prevent other public transportation funds from

being reduced in response to STIF

• Light rail transit should be eligible for low-income fare

reduction programs

• Clarify non-profit public transportation providers eligibility

Somewhat disagree

• Entities should receive the total amount of funds from taxes

in their districts

Strongly disagree

• Rural areas need more resources than large urban areas

Level of agreement not provided

• Do not allow purchase of diesel buses

Reduce air pollutants from buses


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Level of Agreement with Draft Formula Rules: STIF Formula Planning Requirements

All Responses (51)† Individual/Other (15)


† One respondent did not provide an entity type.


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Comments on Draft Formula Rules: STIF Formula Planning Requirements


draft Formula planning requirement rules

• A small number of respondents disagreed somewhat with

the draft rules

• One respondent disagreed strongly with the draft rules

Strongly agree

• Clarify formula fund application cycles

• Suggest using term “low-income riders” instead of “low-

income communities”

Somewhat agree

• Requirements should include reducing air pollution

including greenhouse gas emissions

• Require or expand eligibility for purchase of electric or low-

emission buses

• Avoid duplication of service to seniors and people with

disabilities

• Reduce administrative burden to rural areas and public

transportation providers with few resources

• Use existing reporting and processes

• Funds should be program-based, not project-based

• Application process steps are unclear

• Requirements seem appropriate for large urban areas but

excessive for small rural areas

• Provide some baseline level of funding that does not require

application

Somewhat disagree

• All new buses should use cleaner fuels

Strongly disagree

• Requirements are a barrier to small rural public

transportation providers ability to receive funding


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Level of Agreement with Draft Formula Rules: Advisory Committee Requirements

All Responses (51)‡ Individual/Other (16)


‡ Two respondents did not provide an entity type.


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Comments on Draft Formula Rules: Advisory Committee Requirements


draft Advisory Committee requirement rules

• About a quarter of respondents disagreed somewhat or

strongly with the draft rules

Strongly agree

• Require diverse and equitable representation from interests

of people who use public transportation most

• Allow flexibility for people who live or reside out-of-district

to sit on advisory committees

• Clarify advisory role of committee

Somewhat agree

• Committees are not helpful because members are not

knowledgeable about successful public transportation

service

• Clarify advisory role of committees

• Clarify that people who live or reside in rural areas outside

of a mass transit district Qualified Entity may sit on advisory

committees

• Allow a single member to represent multiple interests

• Expand committee representation beyond Special

Transportation District requirements

• Do not require a minimum number of members

• Allow committees to be larger to reflect community

interests

• Do not require specific interests be represented on

committees

• Sub-Recipients should be involved in developing local

committee requirements with Qualified Entity

• Add social equity and environmental interests to committee

representation requirements

• Require coordination with other advisory committees that

help develop public transportation plans

Somewhat disagree

• Committee membership should reflect public

transportation users within the district

• Allow flexibility for small or rural entities to use existing

committees or adjust requirements

• Allow inclusion of Sub-Recipients on committee

• The number of committee members should be limited

Strongly disagree

• Requirements should guarantee involvement with Sub-

Recipient entities

• Requirements are unrealistic for small and rural entities

• Requirements are too costly and will negatively affect ability

to deliver service


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Level of Agreement with Draft Formula Rules: Qualified Entities Distribution of Formula Program Moneys

All Responses (50)§ Individual/Other (14)


§ Four respondents did not provide an entity type.


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Comments on Draft Formula Rules: Qualified Entities Distribution of Formula Program Moneys


draft rules pertaining to the Qualified Entities distribution of

Formula funding

• A small number of respondents disagreed strongly with the

draft rules, and a small number of respondents who are not

qualified entities disagreed somewhat with the draft rules

Strongly agree

• Allocate funds to subrecipients proportional to the amount

of tax revenue generated in their service areas

Somewhat agree

• Provide suggested sub-allocation methods

Somewhat disagree

• Define a mechanism for non-profit public transportation

providers to receive funds

• Clarify that Qualified Entities that are Counties will receive

funds proportional to the amount of tax revenue generated

in the County

• Counties that do not have a transportation planner on staff

should not be Qualified Entities

• Allow flexibility for Cities or other transportation

organizations to be qualified entities in special

circumstances

• Disburse payments annually

• Reimbursement distribution presents a cash flow issue for

small transportation providers

Strongly disagree

• Municipal public transportation providers should be

qualified entities

• Requirements are too costly and will negatively affect ability

to deliver service


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Additional Comments

• Provide a summary of rules for individuals, public

transportation providers and qualified entities to reference

• Leverage STIF as a tool to reduce greenhouse gas emissions

• Clarify that funds may be used to integrate bicycle share

system with public transportation

• Encourage collaboration between Qualified Entities

• Only purchase electric buses

• It is unfair to give fund allocation power to Counties when

municipal areas generate most tax revenue

• The survey should have focused comments on all rule

sections

• Do not allow funds to purchase diesel buses

• Quarterly reporting is too frequent and unnecessary

• Low-income communities are difficult to define

geographically

• STIF plans should prepare for possibility of fund reduction

resulting from economic recession


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List of survey respondents: Last Name: First Name: Affiliation:

Allen Douglas Individual

Bartko Rick Division Midway Alliance, Portland, OR

Bates Tim City of Corvallis

Bekemeier Chris Individual

Benson-Wood Marnene Transportation Coordinaty

Berg Laura Individual

Bowman David Individual

Brashear Dwight South Metro Area Regional Transit

Bronson Ken [not provided]

Brown Julie Rogue Valley Transportation District

Broyles Anne LIncoln Street United Methodist Church

Carr John Represent Southeast Uplift and Portland Clean Air on TriMet's Division Transit Project Community Advisory Committee

Chancey Scott Josephine County

Chilton Bob Individual

Connolly Meredith Climate Solutions

Cornelison Peter City of Hood River Councilor

Davies Marla Provider

Deas Aaron TriMet

Dodson David Oregon State University

Fitzpatrick Kathy MCEDD

Gordon Andrew Individual

Guptill Kris Individual

Hay Magdaleno Sandra South Tabor Neighborhood Association

Herbert Emily Community for Earth of First Unitarian church Portland

Hinckley Thor Individual

Hogie Leanne Hood River County Transportation District


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Last Name: First Name: Affiliation:

Jackson Aurora (A.J.) Lane Transit District

Kepnick George Individual

Kutasz Barbara Individual

Lamborn Angela Harney County Dial-A-Ride

Lazaro Lee Benton County Transportation

Lighthipe Joshua Individual

Mabbott Tamra City of Umatilla

Malango Christina [not provided]

Miner Julie Individual

Mous Anon Individual

Otis Matt Richmond Neighborhood Association

Patterson Jen Individual

Penn-Hopson Carla Self Enhancement, Inc.

Porch Jennilee [not provided]

Powell Gary City of Tangent- Councilmen

Ray Michael Columbia County Rider Transit

Remmers Susan Individual

Ruby Meg Jr. Warden, St. Michael and All Angel's Episcopal Portland, OR

Scherf Lisa Cities

Shawkat Louise Individual

Sherbeck Jean Special Transportation Fund Citizens Advisory Committee for Marion & Polk Counties

Shurtleff James Individual

Singer Daniel Individual

Steckel Mary City of Corvallis

Thurston Marcelle STNA member; resident

Volmert Mark Linn County Special/Rural Transportation Program

Walters Brice Individual


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Last Name: First Name: Affiliation:

Wehling Julie City of Canby

Whalen Maud Individual

Wheeland Allen Individual

Wiley Alison [not provided]

[not provided] Bob Individual

[not provided] [not provided] [not provided]

[not provided] Angie CCNO


[not provided] [not provided] Individual




[not provided] Carter City of Pendleton




[not provided] [not provided] Individual



[not provided] LINK Public Transit [not provided]




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