Johnson City Transit

#3, Chapter IV-4, proposes a new requirement for all Transit Providers, regardless of size (including Transit Providers qualifying for NTD Small System Waivers), to set system-wide service standards and policies. The required standards and policies are listed. Page 60597 of the Federal Register (Vol. 76, No. 189) states, "We expect that most transit providers already have standards and policies for areas such as vehicle load, vehicle assignment, transit amenities, etc, and that reporting them in the Title VI Program would not be burdensome. However, this is NOT accurate for many small Transit Providers, particularly those providers who do not have on-board data collection systems deployed. Some service standards required by the proposed Title VI circular will be VERY burdensome for small Transit Providers without ITS on-board data collection systems to report, such as on-time performance and vehicle load. At least one proposed policy, Transit Amenities Policy, will also be very burdensome for small Transit Providers to report, as small Transit Providers without ITS on-board data collection systems do not collect ridership by each STOP on each route. Johnson City Transit, a small Transit Provider, suggests that small Transit Providers (at a minimum, those who qualify for the NTD Small Systems Waiver) not be required to set and report on the proposed service standards and policies.