[bouldercouncilhotline] Hotline: RTD update on EcoPasses and current issues

[cmosupport at bouldercolorado.gov]

Sender: Appelbaum, Matt

Colleagues – You’ve no doubt seen the recent news about RTD’s proposed increase in EcoPass fares, in particular the note from our city manager as well as other emails and articles.  I’d like to offer some thoughts on this as well, although I need to start with some broader RTD concerns.
 
As you know, we and the US36 MCC have worked very hard to try to find way to partner with RTD, recognize RTD’s concerns and limited funding, and as best as possible reach our goal of providing significantly better transit mobility along
 the US36 corridor, other key corridors in the area, and local service as well, particularly the “first and final mile.”
 
We have been, I think, moderately successful with the NAMS (Northwest Area Mobility Study) process, which clearly indicated the viability of creating BRT-lite service along various arterial corridors.  And we recently were quite pleased with RTD’s reexamination of their original proposal to increase system-wide fares in a manner that would have been extremely unfair to the BRT; instead, the new fare structure will be reasonably equitable, particularly for the BRT.
 
However, we were much less successful regarding BRT schedules.  While indeed getting some increased service for the BRT, we lost other service, Boulder Junction remains woefully underserved by transit, the airport bus will still be hourly and often standing-room only (this year alone, I’ve been on seven AB trips, most recently last Wednesday, where people stood all the way to the airport), etc.
 
And although RTD is working with us on NAMS recommendations, most notably for possible BRT-type service along the Diagonal, it clearly remains to be seen how soon, if at all, such service might begin, and if such service will spread to the other arterial corridors any time soon.  (I’ll note that we must work with CDOT on these corridors as well.)
 
Taken as a whole, it is unfortunately very hard to conclude that we’re getting anything close to a fair deal from RTD.  Now having said that, it’s important that I also make clear that NW Rail makes no sense whatsoever, as conclusively
 demonstrated by NAMS.  In fact, if I could wave the much-needed magic wand, I’d jettison NW Rail – which won’t come for many decades, if at all, and has no funding source whatsoever – and use a “fair” share of that funding – particularly operating funds even more so than capital – to create far better transit mobility via better BRT service, arterial BRT routes, first-and-final-mile solutions, etc.
 
Efforts at calculating Boulder’s tax contribution to RTD versus our return are not at all straightforward.  I would always expect that Boulder would subsidize portions of the network – particularly in Denver – just as we subsidize BVSD,
 Boulder County, and just about everything else we are part of.  That said, it is clear that FasTracks is extraordinarily unfair: after considering RTD’s capital investments in our BRT, we will now receive on the order of 5% of the tax revenues we give to RTD.
 
Bus schedules can, of course, be changed over time (unlike the underlying fare structure, which is unlikely to be reexamined for many years).  But RTD’s standards make it extremely difficult for heavily used routes to be granted additional service – thus the overcrowded airport buses.  And RTD really has no way to determine when new service – which doesn’t yet exist – is “justified”; thus it will be overly difficult for us to get back the midday BRT expresses, or start service from Boulder Junction to Union Station or the airport.
 
Meanwhile, RTD’s rail lines appear to be devouring all the revenue in sight.  While each BRT ride is subsidized less than $2, each rail ride gets a subsidy of more than $6.  Whether that will continue once the new rail lines open isn’t known, of course, but certainly seems likely.  While FasTracks revenues are correctly allocated to rail (both capital and operating), it is important to note that: first, somehow BRT doesn’t get anything close to a proportional share of that revenue even though it too is part of FasTracks; and second, it seems very likely that base RTD revenues are being used – and/or will need to be used – to fund the rail lines, thus “stealing” money from the base (bus) system.
 
Solutions to these problems are obviously not very forthcoming.  No, we cannot leave the RTD district; it was created by the state legislature and a citizen vote, and I see no chance of that being modified.  Yes, we can continue to put our own city money into transit – as we already do to the tune of ~$2M/year, I believe – but while that is no doubt needed, it also means that we are essentially paying twice for transit service.
 
And we can, and will, continue to work with our partners in the US36 MCC, as well as with our legislative delegation, the business community, CU, etc.  But it is very much an uphill fight

 
Which, finally, brings me back to the EcoPass.
 
As you know, I’ve been somewhat skeptical of the plan to provide all county residents with such passes, although I think that getting them in the hands of every employee who works in the city would be an excellent, and perhaps achievable, goal.  There are many reasons for my concerns, but of course one main reason is that I’ve long been aware that RTD does not like EcoPasses and is quite convinced that they are underpriced and thus subsidized by the district.  Our city/county staff, on the other hand, is equally convinced that EcoPasses are overpriced.
 
(I can’t resist noting one of my other main beefs with RTD’s response to our efforts to provide more EcoPasses.  They would require that any increased demand due to the passes that results in RTD’s needing to run more buses due to overcrowding would need to be funded by us and all of the pass purchasers.  Really?!!  So, if a city, say, decides to increase the cost of parking or reduce parking availability, or run a shuttle service to regional routes, or do anything that increases transit ridership – that city must pay for the increased service that might result?  Nope – that only applies to EcoPasses
which RTD really doesn’t like.  Rather unfortunately, in my view, both city and county staff, and key elected officials, seem to believe this type of requirement is just fine if that’s what it takes; I strongly disagree.)
 
This happens to be a somewhat unusual example of a problem that can actually be greatly informed by data, and our agreement with RTD was that we’d all use the new Smart Card data to determine a reasonably accurate pricing scheme for EcoPasses.  That data was originally supposed to be available last year, and now still isn’t available and perhaps never will be.  Given that Smart Card-like systems have been around for decades, it is rather difficult to understand why the data either doesn’t exist or
 isn’t being used.  As I understand it, RTD claims the data isn’t valid on their rail lines; even if so, it would be extremely helpful to see the data for the bus routes (even if the results might not be to RTD’s liking).
 
Without any good data – RTD is using a rider survey conducted several years ago for their analysis – we are left where we’ve always been, disagreeing with RTD about how to establish a reasonably fair price for EcoPasses.  Given that systemwide fares will increase next year, RTD at minimum wants to increase EcoPass fares accordingly.  Perhaps this is reasonable, but it depends on first getting the base EcoPass fare correct (which it obviously isn’t), and second having good data on which routes EcoPasses are used on (which they don’t have).
 
On top of that increase, RTD seems to have discovered that Title VI of the Federal code requires that the EcoPass program meets the criteria for not inappropriately benefitting wealthier riders.  Using their own mysterious analysis, RTD then tacks on another ~5% increase for business EcoPasses.
 
Now I’m quite proud to not be a lawyer
but I find it extremely hard to believe that Title VI can or should be interpreted to mean that each and every RTD program must, by itself, meet the criteria.  Like many, perhaps all, transit agencies, RTD provides discounted fares to lower-income riders – and surely Title VI can only make sense if the transit agency’s entire set of programs and fares are taken as a whole.  But RTD’s sudden interpretation makes it rather convenient for them to put the burden solely on the EcoPass program.  And then to make the claims that: first, without this fare increase RTD will need to cut other services; and second, the increase is needed to meet Federal rules – both of which of course seem understandably rather powerful to the RTD Board.
 
I need to add here that Boulder, as you may recall, has tried to work with RTD to create a “neighborhood”-like EcoPass program for lower-income residents of the city, but RTD has not allowed the creation of such a non-geographically based
 program.
 
Given that pricing programs such as EcoPasses is inherently rather difficult, it is rather obvious that RTD must convene a stakeholders group consisting of entities and businesses that buy those passes, as well as riders who use them (note
 that there has been essentially no public process on this issue).  The Smart Card data must be made available in a form we can use and analyze.  The Title VI rules must be fully examined to determine their applicability, and to work towards getting passes into the hands of more lower-income riders.  Importantly, there are complex underlying assumptions relating to induced demand that also must be reexamined using best practices.
 
More immediately, I suppose we could, just barely, accept the ~13% increase in EcoPass fares that are being “justified” by the systemwide fare increase – but only if the additional ~5% isn’t included, and there is a very firm agreement
 that the working group will be formed and all of the data will be made available.  The recent RTD Board meeting suggests that the Board will simply adopt RTD’s recommendation, although I want to publicly thank the RTD Board members who raised some of the issues we’ve noted and offered our suggested approach.
 
Clearly, there is much more work to be done with RTD.  RTD does, of course, provide some very good transit service and in many ways – the Boulder Junction bus facility comes to mind – they have been a good partner.  But we could accomplish so much more together if we could create a true collaboration with the goal of increasing transit mobility in our region.
 
--Matt