Central Oklahoma Transportation & Parking Authority, Rick Cain
Dear Madam Chair and Members of the Board:
I am writing on behalf of the Central Oklahoma Transportation & Parking Authority (COTPA), the regional public transportation system serving the Oklahoma City metropolitan area. There are several proposed changes that will adversely affect the service COTPA can provide to the region's citizens.
1. With the proliferation of various styles and sizes of wheelchairs a revised definition my be in order but forcing COTPA into a position of making a case-by-case determination of every wheelchair user with consideration to each vehicle we operate is an operational burden I don't think was intended by the proposed change.
2. The requirement that all vehicles longer than 22 feet must be equipped with an automated stop identification system means equipping vehicles with Global Positioning Systems. Though COTPA would like to initiate such technology financial capability to do so is currently not available. Federal formula funding is not sufficient to meet annual needs and provide for bus purchases. Local funding for capital needs is extremely limited. Therefore to mandate the need for GPS technology would require specific federal earmarks or services would need to be cut to a level that would allow sufficient capital to be made available to support the technology improvements.
3. The definition change for compliant boarding ramps will cause operational problems in some of COTPA's service areas as it will be difficult to deploy ramps at certain stops.
4. As opposed to more well financed transit agencies COTPA has historically retained buses in service for periods beyond the 12 year federal life. To avoid a mix of old rule vs newer fully compliant vehicles COTPA suggests more attention be given to extending the phase in period for full compliance.
Thank you for your consideration.
Rick Cain, Administrator
Central Oklahoma Transportation & Parking Authority
300 SW 7th St.
Oklahoma City, Oklahoma 73109