ing costs and does not include any local capital share which we have assumed would come from other capital sources. At our current budget level, the Memphis Area Transit Authority would have to eliminate 2.8 percent of its services or 193,626 miles annually. That is approximately 272,000 one-way trips, or 1.9 percent of our total ridership, would be lost due to required service cutbacks. We are, right now, on the verge of having to make either cutbacks or increased fare. Our fare is now 85 cents. This is based only on additional operating costs which we have projected to be $363,000 per year. I think that is fairly conservative, considering that we have got 238 buses on the street and some 20 paratransit vehicles. We have worked very closely during the time that I have been on the board, and this was already in place when I came on, with the handicapped community. Last month, for example, to answer some of the questions that came up earlier, or anticipate some of them, we had 10,300 handilift rides. We have an average of 20 wheel chair rides per day. The addition of lifts to our mainline service would not, in fact, probably provide service for the majority of our handicapped community. The disabled community and the handilift service carries about 4 percent elderly, 10 to 12 percent are in wheel chair and the remaining 84 to 86 percent are, basically, cognitive disability people who go to sheltered workshops and the lifts would not help them. We have, in the past years, worked with social service agencies to train some 188 of the cognitive disability people to ride our mainstream buses. This has been very helpful in financing and in providing space for additional people to use our handilift service. In this current year, we will spend over 3 percent. We are not only meeting but surpassing the regulations under the 504 plan. An additional 2 percent, roughly, would be added by the Americans With Disabilities Act if, in fact, we have to provide comparable paratransit service. In order to continue to provide maximum service while complying with the legislation, we would ask that Congress not require the operation of comparable paratransit, but that it should supplement or coordinate with the fixed-route buses, that the establishment of paratransit eligibility standards and service be left to the local communities and developed in conjunction with the disabled community and that those requirements that are established by Congress be funded by Congress. The flexibility in determining-several people, including Mr. Capozzi, mentioned that it is difficult to pinpoint the number of people who would, in fact, move to mainline buses. We would, probably, have more riders if we did have mainline bus service. I think, even if we tripled our current wheel chair passengers, that would be 60 per day. That is two ways. We would ask that there be standard criteria for wheel chair design in order to facilitate the accommodation of wheel chairs on mass transit vehicles and in mass transit facilities and to insure the safety of wheel chair passengers. The number of passengers who would be affected-I told you the percentages-but the numbers of passengers who would be affected if this goes into effect in its present form would be 272,000 rides for our people. Memphis is 50th in a list of 50 cities that are approximately this size in per capita income. We are not a wealthy area. Seventy-eight percent of our people do not have any other means of transportation. Those 272,000 rides would, in fact, probably deprive those people of means of getting to their jobs as well and would, in fact, put them on welfare. We have tried over the years to provide a balance of the most effective service for the most people in both areas. I thank you for your interest and for allowing me to participate. Mr. MINETA. Thank you very much, Ms. Pierce. Mr. Downey, in your testimony, you asked the committee to consider using a more specific rationale than undue financial burden for exempting public transit operators from the paratransit provisions in the bill. As the MTA Chief Financial Officer, I am surprised that you have a problem with the concept of undue financial burden. But more seriously, from your current view as well as your past experience as Assistant Secretary for Budget and Policy at the Department of Transportation, how would you suggest that we clarify this term or define it more precisely? Mr. DOWNEY. I think it need to be defined both in terms- Mr. MINETA. Ms. Pierce, thank you very, very much. I appreciate your being here as well as your service as a Board member there in the Memphis area. MS. PIERCE. Thank you, very much. I would be glad to answer any questions in writing. Mr. MINETA. Thank you. Mr. Downey. Mr. DOWNEY. I think the criteria have to be both financial and operational. I think the real concern is that paratransit service truly be supplementary, targeted for where it is needed and not offered so broadly as to create a real burden. That has been the approach, for example, in New York under the state legislation. We are offering both lift-equipped buses on our regular routes, and a paratransit service managed by the city. It is clearly specified in our state legislation that that paratransit service is not to be duplicative of the trips that can be provided by the lift-equipped buses. Mr. MINETA. Mr. Louwerse? Mr. LOUWERSE. If I may, I am basically here to speak on behalf of the small operators throughout the country. I think one of our greatest concerns is this clause that says we need to provide comparable paratransit service. There are a number of small operators throughout the country who wonder about the wisdom of having to put lifts on their buses. There are many, for example my own system-I have been since in the 1970's operating a paratransit system that does about 25,000 rides a month, over 4,500 of which are for non-ambulatory persons. We took an order of buses last month, and 10 of the 15 buses are lift-equipped. We are opening bids on Thursday for another 15 buses. 10 of those buses will be lift-equipped. We operated what is known as a coordinated service; that is, using our resources in our community-we have 170,000 people-the fixed-route buses stay in the urban area. The paratransit does some urban work, but mainly goes to the rural areas, We send a bus 40 miles to pick up Mary Jones because she has to go to the hospital. This is a van, a specialized van. Now, if I have to run comparable service, I am going to have to take that van which goes to get Mary Jones and run it on a system where now I have already decided, before you have passed the law-that has a lift. So Mary Jones is going to lose service. So a bill which is supposed to require greater mobility for the citizens of our country will have a negative impact. Specifically, I would suggest from the small operator's point of view, that you allow us to coordinate lift-equipped fixed-route system with specialized or demand-responsive system. I emphasize the word "coordinate," as opposed to comparable because comparable means you have increased my cost, I need more vehicles, and I am going to have to cut service someplace and some people are going to get very disappointed and very hurt. But if I am allowed to coordinate those two types of service, I think we will see greater mobility needs being met. I think that is the kind of specific situation we would recommend to you. Mr. MINETA. Can you use your paratransit to feed your fixedroute system? Mr. LOUWERSE. Yes, we do, as a matter of fact. Mr. MINETA. It doesn't preclude you from doing that; right? Mr. LOUWERSE. No. Our system, for example, our specialized transportation system is open to the public, not just people who have special needs. It is open to the public. For example, in our case, the cost of the ride is $6.00. The fare is $4.50. Mr. MINETA. Is that for operating as well as capital? Mr. LOUWERSE. Now, the cost for a fixed-route ride costs me a dollar, and my fare is 75 cents. So our system has agreed to subsidize both the fixed-route system and the specialized transportation system. Why? Because we are in the business of providing transportation to the citizens of our area. They know me. I know them. I am saying you have this broad ranging Federal mandate. There are a lot of human people who are going to be bypassed. If I may give you just one other good example. Three years ago, in cooperation with our specialized system, our fixed-route system, and the social service agencies in our community, we took 160 people who go to work-these are people with disabilities who go work every day, some to the sheltered workshop, some to other places. They previously had ridden specialized service. The cost of that ride was around $6.00. We, together, worked and trained these individuals to ride the regular fixed-route bus because the fixed-route bus went by their house. Now, a cost of service that was $960 a day, I reduced to $160 a day, thereby saving my system $800 a day. We didn't say, "Isn't this wonderful? We saved $800 a day." We said, "Now, we have $800 a day to invest in providing service where there was no previous service." My point to you is that with the opportunity for coordination, not mandated comparability-the idea of getting together and working with your people and providing the best service whether this is a right, a regulation, that is a debatable philosophical question. What is the reality? We are trying to provide the most mobility with the most effective manner. Whether you think it is a civil right or whether you think it isn't a civil right, you still want to achieve the same thing; the most amount of mobility for the most appropriate amount of funds. So we would emphasize this coordination of our efforts. Thank you. Mr. MINETA. Mr. Downey, regarding the rail provisions of the bill, what criteria were used in New York to identify key rail stations to be made available or accessible? Mr. DOWNEY. The process, Mr. Chairman, was one of negotiation, partially in conjunction with litigation that was going on and partially in conjunction with prospective state legislation. We sat down with representatives of the disabled community, identified the stations that showed the greatest promise for serving large numbers of people, those stations that were downtown locations, those that were good transfer sites, those that were out at the ends of lines, and we created some flexibility in the process. The legislature specified 38 of our 465 stations by name and set up a further process where each side, so to speak, would designate another 8 stations or 9 stations. In fact, as it worked out, we jointly designated the remainder and retained some flexibility, as time goes on, to make substitutions and changes in that list. But it is a relatively small number of stations that cover a wide portion of the system. It will be done over time. There is a timetable for expenditures in the legislation, but not a specific deadline by which the process would be finished. But the cooperative work that went into it has really served us well. We are now at the point, four years or five years after the bill passed, that the first of those stations are now complete. We will be seeing, within the next year, increasing numbers of stations available and, hopefully, increasing numbers of disabled riders using them. Mr. MINETA. What has been the experience of the New York MTA in the usage of wheel chair lift-equipped buses in fixed-route service in the metropolitan area? Mr. LOUWERSE. We operate two separate systems within the metropolitan area. One, of course, is the large system serving New York City. One is a smaller suburban system. In the city system, we have a bus fleet of 3,800 buses. As of today, about 2,900 of them are lift-equipped or 76 percent. We should have that closer to 84 percent when our next bus order is complete. As we have gotten closer to the point of a full lift-equipped fleet, we have seen the rate of increase in the usage go up dramatically. Four years ago, we were carrying about 11,000 people per year on lift-equipped buses. We are now carrying at a rate of about 40,000 persons per year. That works out to somewhere in the neighborhood in 150 rides a day. But the point is, it is growing very rapidly now that that service is perceived as one that is fully reliable, that basically all buses in the off-peak hours and weekend hours, and the vast majority of buses in the peak hours are lift-equipped, people are coming out and using it. Mr. SHUSTER. Let me follow up on the 150 rides a day. How many lift-equipped buses do you have? Ms. PIERCE. We have, as of this point, about 2,900 lift-equipped buses in the fleet. Mr. SHUSTER. Which provide 150 rides a day? Mr. DOWNEY. Per day, yes. Mr. SHUSTER. It has been mentioned that the demonstration project raises the problem of the lack of universal applicability of securement devices. How do most transit authorities with experience with lift-equipped buses currently deal with this problem? Mr. DOWNEY. We have a standard fleet of buses. They all have the same lift and the same securement device. It functions well with the majority of wheel chair users. To the extent that it does not secure any of the existing wheel chairs, it is a point of concern to us, and we instruct the passenger to do whatever they can to assure that their wheel chair is not going to move around. But we would be more comfortable if we knew that there was a device that all those who present themselves to us could make use of. Mr. SHUSTER. You talked about the need to redefine the exemption from comparable paratransit. We had testimony earlier today from the Cambria Transit Authority, which has selected to go the route of lifts on all their buses. I believe if that is the decision that they feel is the best decision for that area, then they should be able to make that decision. Right across, on the other side of the mountain from Johnstown, Cambria County, is Altoona, Pennsylvania where they have no lifts on the buses but a very extensive paratransit program. What is your view about the various transit authorities being able to make those decisions? Should the transit authorities have the flexibility to decide all lifts and no paratransit, all paratransit and no lifts, or somewhere in between, or should we mandate at the Federal level what this should be? Mr. LOUWERSE. I would say that you are finding in the industry, even in the small systems, an increase in the purchase of fixedroute buses with lifts. For example, I know there is some consideration in Altoona right now to look at potentially some vehicles with lifts. The question is like, in my case, we ordered 20 out of 30 with lifts because that is what we feel we need to do the job. So do we need to spend additional money for the 10 which we don't think we really need? The emphasis I would, again, make is, obviously, there are unique and individual circumstances. I will give you an example of a system in Pennsylvania that has four vehicles. They have a bus, a specialized van, and two station wagons. What is the ADA going to say to that system? Are they going to say, "Well, now are going to get a bus with a lift on," which might be all right, but your specialized van has to run comparable service. So that means you are going to have to cut service for some of your people because now you only have three vehicles instead of, practically, four. I think what you will find is that there are a lot of systems out there. I think that is being really missed. We hear about the people that are struggling, and there are some places where there is some turmoil. But there are a lot of places where there is a lot of agreement, where you have local people reaching proper decisions on how to best serve their people. I would say that the greater the amount of flexibility you can provide to the local people to make their own determination, the |