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HomeMy WebLinkAboutAGENDA REPORT 2015 0204 CCSA REG ITEM 09B ITEM 9.B. CITY OF MOORPARK,CALIFORNIA City Council Meeting Of r-2- 0(0/6- MOORPARK CITY COUNCIL ACTION: AGENDA REPORT I/rt- . BY: . TO: Honorable City Council FROM: Dave Klotzle, City Engineer/Public Works Director Prepared by: Shaun Kroes, Senior Management A alyst0' DATE: January 23, 2015 (CC meeting of 02/04/15) SUBJECT: Consider Providing Comments on Possible Unmet Transit Needs to the Ventura County Transportation Commission and Receive Report on Unmet Transit Needs Findings and Goals SUMMARY On April 18, 2002, the City Council directed staff to prepare an annual report on the City's transit performance regarding the findings and goals that the Ventura County Transportation Commission (VCTC) adopts each year at the conclusion of the Unmet Transit Needs process. Attachment "A" serves as this year's annual report on the City's performance. The City Council is being asked to review the annual report, provide comments, and direct staff to forward the comments to VCTC prior to 5:00 p.m. on February 16, 2015. BACKGROUND On December 6, 2013, VCTC approved new Unmet Transit Needs definitions and adjusted its public participation input program. This revision was in response to VCTC's Regional Transit Study as well as the impacts of SB 716 and SB 203 (both of which became effective July 1, 2014). The revised definitions and public participation input program are detailed in Attachment "B" of this report. California Public Utilities Code (PUC) 99401.5(c) requires that VCTC hold at least one public hearing pursuant to PUC Section 99238.5 to solicit comments on Unmet Transit Needs that may exist within the jurisdictions and that may be reasonable to meet by establishing or contracting for new public transportation, or specialized transportation, or by expanding existing services. All Unmet Transit Needs that are reasonable to meet must be funded before any allocation is made from TDA funds to the cities/county for streets and S1Public Works\Everyone\Reports\Staff Reports\2015\February@-4-2015(Unmet Transit Needs).doc 2 Honorable City Council February 4, 2015 Page 2 roads pursuant to PUC 99401.5(e). Effective July 1, 2014, the remaining cities that this is applicable to are Camarillo, Fillmore, Moorpark and Santa Paula(all cities with a population under 100,000 and not a member of the Gold Coast Transit District). Although there are now a limited number of cities that are affected by PUC 99401.5(e), VCTC must perform a countywide Unmet Transit Needs process. VCTC may identify an Unmet Transit Need in a service area not affected by PUC 99401.5(e) (such as Gold Coast Transit or the City of Thousand Oaks); however, it has no ability to require that Unmet Transit Need be implemented because the agency is already committing 100% of its TDA funding for existing transit services). DISCUSSION On February 9, 2015, VCTC will hold its annual public hearing on Unmet Transit Needs at Camarillo City Hall. VCTC also scheduled three additional sessions, including one on January 26, 2015 at the City of Moorpark Community Center, for members of the public to participate in the Unmet Transit Needs process. The public may also fax, email, telephone, or mail comments to VCTC by 5:00 pm, February 16, 2015. The information on how to submit comments is on the attached flyer, Attachment "C". Staff advertised the comment period in the City transit buses, on the City cable TV Channel 10, and on the City website. The public was encouraged to submit their comments to VCTC. Additionally, information about the City Council's consideration of Unmet Transit Needs at its February 4, 2015 meeting was also distributed. According to the PUC, VCTC must decide, by adopting a resolution, either that: 1. There are no unmet transit needs; 2. There are no unmet transit needs that are reasonable to meet; or, 3. There are unmet transit needs, including needs that are reasonable to meet. The resolution must include information that provides the basis for VCTC's decision. A number of the public comments received over the years do not fall into the category of Unmet Transit Needs. However, VCTC recognizes that some of them may be attainable with operational changes. VCTC adopts some of these comments as goals. These goals, where applicable, are included in the City's Report of Performance (Attachment A)and are differentiated from the Unmet Needs Findings. FISCAL IMPACT None. 3 Honorable City Council February 4, 2015 Page 3 STAFF RECOMMENDATION Provide comments and direct staff to forward them to VCTC, prior to the end of the public comment period. Attachment A— Report of Performance Attachment B — Unmet Needs Definition Attachment C — Unmet Transit Needs Flyer Attachment D —VCTC FY 2014/15 Unmet Transit Needs 4 Attachment A Report of Performance 2014/15 Unmet Transit Needs Moorpark City Transit Attachment "D" identifies all Unmet Transit Needs Findings adopted by VCTC including the Commission's approved goals for FY 2014/15. The findings and goals applicable to Moorpark City Transit and the City's efforts to meet the findings and goals are listed below. Findings adopted by VCTC May 9, 2014. 1. Continue all existing bus services substantially as they exist. • Beginning August 10, 2013, Moorpark City Transit began a three-year transit demonstration service, expanding fixed route bus service from 6:00 am to 6:00 pm Monday through Friday to 5:00 am to 8:00 pm Monday through Friday. The bus service also began operating a new route on Saturday, from 8:00 am to 5:00 pm. • During the "standard" hours of service (6:00 am to 6:00 pm, Monday through Friday) FY 2013/14 ridership increased 2.11% to 63,227 (from 61,922 in FY 2012/13). The City's VCTC audited farebox ratio (including Moorpark City Transit, Beach Bus, and Dial-A-Ride services) was calculated at 44.55% for FY 2013/14 (including expanded hours of service). The high farebox ratio is attributed to the City's use of local funds (Traffic Safety Management Fund 2001) for funding of the City's CNG buses and CNG fuel). The City's self-calculated farebox ratio (not including expanded hours) was 19.74% for the City's fixed-route service, which if rounded up would meet the target farebox ratio of 20.0% for the year. • For the City's demonstration service, the City provided 5,002 trips between August 10, 2013 and June 30, 2014. Ridership averaged 2 passengers per hour, compared to 11 passengers per hour during the standard service hours. The City's self-calculated farebox ratio for the demonstration service was 3.40% in FY 2013/14. The general farebox ratio goal for the first year of a transit demonstration service is 6.00%. Staff continues to monitor the demonstration service and will likely return to City Council in the future with recommendations for adjustments to the demonstration service. 2. Continue and improve all public senior and disabled services in all jurisdictions in the County substantially as they exist. • Beginning August 10, 2013, Moorpark City Transit began a three-year transit demonstration service, expanding the Senior Dial-A-Ride and ADA S:\Public Works\Everyone\Reports\Staff Reports\2015\February\Attachment A-Report of Performance 2015.doc 5 Page 2 Paratransit Intra-City (travel within Moorpark) hours from 6:00 am to 6:00 pm Monday through Friday to 5:00 am to 8:00 pm Monday through Friday. It also added weekend (Saturday and Sunday) service, from 8:00 am to 5:00 pm. Inter-City ADA Paratransit service was also expanded to include travel to and from Thousand Oaks, Westlake Village, and Oak Park on Saturday and Sunday. On December 9, 2013, the City also began providing direct service into Simi Valley (instead of transferring with Simi Valley Transit) for Moorpark residents with an ADA card traveling to and from Simi Valley. • During FY 2013/14, the Moorpark senior and disabled (ADA) Dial-A-Ride demonstration services provided 200 trips. The City's self-calculated farebox ratio for the demonstration service was 10.94%. The minimum farebox ratio for Dial-A-Ride service is 10.00%. • During standard service hours (6:00 am to 6:00 pm, Monday through Friday) the Dial-A-Ride services provided 3,754 trips. This is a 67.74% increase compared to 2,238 trips in FY 2012/13. • Senior and disabled travel on Moorpark City Transit buses increased 52.90% in FY 2013/14 (from 3,894 trips to 5,954 trips) during the standard hours of service. This is approximately 9.42% of all passengers on the buses during standard hours. During the demonstration service hours, 423 passengers (or 8.46%) were seniors or disabled. 3. Continue the Ventura County interagency bus transfer program. • Moorpark City Transit continued to accept VISTA's free transfer bus passes from passengers transferring between VISTA and Moorpark City Transit and provided free transfer passes to passengers transferring from Moorpark City Transit to VISTA. VCTC provides the transfer passes to Moorpark City Transit. 4. Monitor the Saturday and expanded hours of service in Moorpark. • Staff provides VCTC a quarterly report covering ridership and cost information for the demonstration service. After adopting the recommendations listed above and on Attachment D and based on the analysis of the written and verbal testimony provided to the Commission, the finding was that there were no Unmet Transit Needs that were reasonable to meet. 6 Page 3 In addition to the Unmet Transit Needs Findings, VCTC also adopted transit goals. The following is the list of adopted goals that relate to Moorpark's transit programs. Attachment D provides the full list of goals. 1. Continue to pursue and identify funding to allow local agencies to install more bus benches and shelters, and transit information, where warranted and feasible. Standards to determine when and where a bus shelter or bus bench is warranted should be adopted and used to implement future placement. • There are eighteen City bus shelters and twelve private bus shelters along the bus routes. There are two more City bus shelters installed at the Metrolink Train Station. There are currently funds available to fund rehabilitation and installation of solar powered lighting at existing bus shelters. • VCTC has not yet developed the bus shelter standards referenced in their finding. 2. Continue to improve schedule coordination and transfer connections between different bus systems where operationally feasible. • VISTA East County connects with Moorpark City Transit. The City's proposed transit demonstration program (approved by City Council on December 19, 2012 and implemented August 10, 2013) enables Moorpark City Transit to connect to additional VISTA East buses (during new service hours of 5:00 am to 8:00 pm Monday through Friday and 8:00 am to 5:00 pm Saturday). 3. Continue to adjust fixed route transit services, stops and schedules throughout Ventura County as needed and operationally feasible. • On August 10, 2013, Moorpark City Transit implemented new hours for the 3-year transit demonstration project. Route 1's new services hours are 5:10 am to 8:00 pm. Route 2's new service hours are 5:00 am to 7:50 pm. A new Saturday service operates 8:00 am to 4:53 pm. • All fixed route services are currently being evaluated with the intention of establishing route and time adjustments effective in FY 2015116. 4. Continue community outreach and marketing efforts to increase awareness of the availability of transit services for the general public, seniors and the disabled, to be coordinated by VCTC. • The City of Moorpark advertises its transit program in the Moorpark City Newsletter and Recreation Guide, which comes out quarterly. For $15 the Summer Youth Bus Pass provides unlimited ridership on Moorpark City Transit between June and the second Friday of September, giving Moorpark youth an opportunity to use the bus system for fun, which may increase their likelihood to continue using Moorpark City Transit throughout the year. 7 Page 4 5. Continue operation of NEXTBUS countywide and provide additional NEXTBUS signs at appropriate locations. • The NEXTBUS web pages are promoted on the Moorpark City buses, website, Ride Guide, and bus stops. 6. Ensure that bus stops and bus signage, vehicles, and operations are all in compliance with the Americans with Disabilities Act (ADA) requirements. • All Moorpark City Transit bus stops have updated route maps and timetables on poles at bus stops to make them readable by a person sitting in a wheelchair. Bus stops are ADA compliant. 7. Encourage cities and transit providers, and not for profits social service agencies to implement elements of the VCTC Countywide Human Services Transportation and Transit Services Coordination Study. • Staff participated in the Coordination Study in 2006 and 2007. Some recommendations, such as core weekday operating hours of 7:00 am to 6:00 pm are already met by Moorpark City Transit. Other recommendations, such as establishing Sunday services, were implemented in FY 2013/14 under the City's transit demonstration project. Still additional recommendations, such as changing the definition of "Senior" to passengers aged 65 or older (instead of Moorpark's current definition of 62 or older) have not yet been implemented. 8. Support cost-effective actions to increase bike capacity on the transit system. • Moorpark City Transit buses currently have carrying capacity for two bicycles per bus. At this time, staff is not aware of user demand exceeding this capacity limitation. 9. Encourage transit trips over auto usage during this time of heightened public awareness of the cost of fuel. • This goal was recommended by the Moorpark City Council. Although gas prices are still high, they have fallen since this original goal was established. As detailed earlier, Moorpark City Transit saw an increase in ridership during FY 2013/14 compared to FY 2012/13. 10. Seek financial support from the cities to provide subsidized fares for low income passengers transferring between local transit systems and VISTA. • The Moorpark City Council suggested to VCTC that there should be an agreement between the VISTA bus service and transit agencies in Ventura County to provide either free or discounted transfers for low income passengers transferring between transit agencies. On January 17, 2011, a free transfer pilot program between VISTA bus services and local transit agencies in Ventura County began. The service enables a VISTA passenger to receive one free transfer between two VISTA bus routes. The program also enables passengers to receive one free transfer between VISTA and a local transit agency (such as Moorpark City 8 Page 5 Transit). The pilot program lasted for nine months and was extended by the City Council on October 10, 2011 as a permanent program. 11. VCTC and the ADA providers in the county continue to improve transfers and transfer locations for inter-agency ADA trips (Dial-A-Ride service). • On December 9, 2013, Moorpark City Transit's ADA Inter-City service began providing direct service into and out of Simi Valley for Moorpark ADA card holders. 12. VCTC integrate evening meetings in different parts of the county as part of future Unmet Transit Needs process. • Moorpark continues to host a listening session in the evening during VCTC's Unmet Transit Needs process. This year, the City will host an event at the Moorpark Community Center on January 26, 2015 from 6:30 pm to 7:30 pm. 9 Attachment B VENTURA COUNTY TRANSPORTATION COMMISSION FY 2014/2015 UNMET TRANSIT NEEDS FINDINGS BACKGROUND Public Utilities Code (PUC) Section 99401.5(c) requires the transportation planning agency(VCTC) to hold at least one public hearing pursuant to Section 99238.5 to solicit comments on the Unmet Transit Needs that may exist within the jurisdiction and that may be reasonable to meet by establishing or contracting for new public transportation, or specialized transportation, or by expanding existing services. All Unmet Transit Needs that are reasonable to meet must be funded before any allocation is made to streets and roads pursuant to PUC Section 99401.5(e). Under Section 99238(c)(2),the Public Utilities Code specifies that the social service transportation advisory council, Citizen's Transportation Advisory Committee/Social Service Transportation Advisory Committee (CTAC/SSTAC) in our County, has the responsibility to participate in the annual process and must review and recommend action by VCTC on the findings. Other advisory groups can also review the findings but it is not required by statute. A panel consisting of a number of the VCTC Commissioners is appointed annually by the VCTC Chairman to act as the hearing board. The full VCTC then considers all the input from these sources as well as the public and adopts the findings. According to the California Public Utilities Code (PUC) Section 99401.5 (d)the Commission must find by adopting a resolution that either: • There are no Unmet Transit Needs; • There are no Unmet Transit Needs that are reasonable to meet; or, • There are Unmet Transit Needs, including needs that are reasonable to meet. The resolution approving the findings must include information that provides the basis for the Commission decision. In accordance with PUC Section 99401.5(c)the Commission adopted definitions of"Unmet Transit Need"and"Reasonable to Meet"at the January 5, 1996 VCTC meeting and revised these definitions at its December 6, 2013 meeting. Following are the adopted definitions of"Unmet Transit Need"and "Reasonable to Meet": VCTC DEFINITION OF UNMET TRANSIT NEEDS (adopted December 6, 2013) Public transportation services identified by the public with sufficient broad-based community support that have not been funded or implemented. Unmet transit needs identified in a government- approved plan meet the definition of an unmet transit need.Sufficient broad-based community support means that persons who will likely use the service on a routine basis demonstrate support: at least 15 requests for general public service and 10 requests for disabled service. INCLUDING: • Public transit services not currently provided to reach employment,medical assistance,shop for food or clothing,to obtain social services such as health care,county welfare programs and educational programs.Service must be needed by and benefit the general public. • Service expansions including new routes, significant modifications to existing routes,and major increases in service hours and frequency. EXCLUDING: • Operational changes such as minor route changes,bus stop changes,or changes in schedule. • Requests for extended hours or days of service. • Service for groups or individuals that is not needed by or will not benefit the general public. 107 10 • Comments about vehicles,facilities,driver performance and transit organizational structure. • Requests for better coordination. • Requests for reduced fares and changes to fare restrictions. • Improvements funded or scheduled for implementation in the following year. • Future transportation needs. • Duplication or replacement of existing service. It must be stressed that these definitions are intended to be helpful to the public and stakeholders and are not intended to exclude or minimize the testimony received because the comment submitted does not exactly fit the definition. The intention of the Commission is to work with the cities/County to ensure maximum public input and that all reasonable transit concerns are addressed. Consistent with Public Utilities Code Section 99401.5, the Commission must use the adopted definitions of"Unmet Transit Need"and "Reasonable To Meet"and give special consideration to the transit needs of senior citizens, the mentally/physically challenged and persons of limited means. Also consistent with Public Utilities Code Section 99401.5, the hearing board shall not make its recommendation, nor shall the Commission make its determination of needs that are reasonable to meet, by comparing Unmet Transit Needs with the need for streets and roads. PUC Section 99401.5(c) also states that the fact that an identified transit need cannot be fully met based on available resources shall not be the sole reason for finding that a transit need is not reasonable to meet. 108 11 Contact Us: . --a Attachment C :::-- . ‘'::.1. 1 -800-438- 1 1 12 - x 0 Kelam@goventura.org G • • _.._. •. www.goventura.org ...: b H A R E .... ._. x, I • tai•Cp .. i YOUR IDEAS FOR : ` :. NEW SERVICE 1.- k.. . � '1•.• WITH US! •.•• E t lioNS z, tNC i ifitotz, 4T 407 higi,, ,:,,&Nk' �, , joilD cs------- iiiii e ....._................................ 111116' * I ; p 0 4t'' .. \ lir Y,Ti Iifiia`. � r11110.10 te",r' (� NE\N g.--..i„,„.., * ORTELL US IN PERSON: ' Y p��7 1 f Jan. 26th,6:30-7:30pm @ Moorpark City Hall Community Room, 799 Moorpark Avenue Jan. 27th,6:30-7:30pm @ Oxnard Transportation Center,Conference Room 209,201 E. Fourth St. — 171,---,x , Joint Meeting w/Gold Coast Transit District Staff regarding their Short Range Transit Plan k '• Jan.28th,6:30-7:30pm @ Santa Paula Community Center, 530 W. Main Street 44 -5T. Feb.9th, 1:30-3:OOpm @ Camarillo City Hall, Council Chambers Room, 601 Carmen Drive Y �g`I w -, ..1 # �'vt r ', i k* '`'11(1 Iz r —.54,--<0‘j: °'0' L,.,' `''''1",-. 3xs wY �'�y ,.,� aa.q' • ''e;F I:. 'n'r" � 4 a - t a 7 , I. r� ,5,,. ",' � .r� ' 3=3, . ' -,€k.; ti7.1;,x a, 1� y X'+ t xp r .+re,t .tnt.r, � 1z : tn,�,.r.4<3•t , a' . .`',.4...'YA k"�M rfi 'C ,' t� N :,-4 vi:. is 1 2 Attachment D comments. CTAC/SSTAC approved the recommendations with two minor additions. They recommended adding the words"and improve"to the finding regarding the continuation of public senior and disabled services—without specifying actions, they felt that there is room for improvement and that should be encouraged. They also recommended the goal regarding bus stops be expanded to state"Standards to determine when and where a bus shelter or bus bench is warranted should be adopted and used to implement future placement." Also, the VCTC Transit Operators Advisory Committee(TRANSCOM) reviewed the draft report on April 10, 2014. TRANSCOM recommended that the report be condensed without losing the content. The TRANSCOM also felt is important to note that Gold Coast Transit, the City of Thousand Oaks, and the City of Simi Valley all welcome public input from any source, however, those agencies receive comments from a number of sources, none having higher or lower priorities than those received in the VCTC UTN process. Because by state law those agencies must use all their TDA funds for transit, there is no requirement for them to consider the Unmet Transit Needs findings as anything but advisory. TRANSCOM recommended that VCTC refine the UTN process to better reflect the overlapping responsibilities for both decision makers and the general public. RECOMMENDED FINDINGS: 9. Continue all existing bus services substantially as they exist. 10. Continue and improve [RECOMMENDED BY CTAC/SSTAC] all public senior and disabled services in all jurisdictions in the County substantially as they exist. Work to implement the recommendations of the VCTC Countywide Human Services Transportation and Transit Services Coordination Study. 11. Monitor the service demonstrations on the VISTA 126 (expanded hours and extension to Piru), the Gold Coast Transit Channel Islands Blvd.Nictoria Ave. (Route 21), service expansions to northeast Oxnard/El Rio (Route 17) and service to East Oxnard (Routes 19/20)to determine if a transit need which is reasonable to meet exists. 12. Continue the Ventura County interagency bus transfer program. 13. Monitor implementation of the planned modifications to the Heritage Valley transit service. 14. Monitor the Saturday and expanded hours of service (including the Metrolink shuttle) in Thousand Oaks. 15. Monitor the Saturday and expanded hours of service in Moorpark. 16. Monitor the Sunday and expanded hours of service in Camarillo. After adopting the recommendations listed above, and based on the analysis of the written and verbal testimony provided to the Commission: 17. Find by VCTC Resolution#2014-01 that there are no Unmet Transit Needs that are reasonable to meet. In addition to the above findings, VCTC will continue efforts to meet the following goals frdm prior hearings: A. Continue to pursue and identify funding to allow local agencies to install more bus benches and shelters, and transit information signs, where warranted and feasible. Standards to determine when and where a bus shelter or bus bench is warranted should be adopted and used to implement future placement. [ADDED BY CTAC/SSTAC] B. Continue to improve schedule coordination and transfer connections between different bus systems where operationally feasible. C. Continue to adjust fixed route transit services, stops and schedules throughout Ventura County as needed and operationally feasible. D. Continue community outreach and marketing efforts to increase awareness of the availability of transit services for the general public, seniors, and disabled, to be coordinated by VCTC. E. Continue operation of NEXTBUS countywide and provide additional NEXTBUS signs at appropriate 114 13 locations. F. Continue to ensure that bus stops and bus signage, vehicles, and operations are all in compliance with the Americans with Disabilities Act(ADA) requirements. G. Continue to assist social service agencies in obtaining grant funding for equipment and rolling stock, utilizing Federal Section 5310 and any other funds available for those purposes. H. Encourage cities, transit providers, and social service agencies to implement elements of the VCTC Countywide Human Services Transportation and Transit Services Coordination Study. I. Continue discussions and possible studies cooperatively with the City of Santa Clarita to determine the potential demand and feasibility for transit services connecting Fillmore with Santa Clarita. J. Initiate a countywide transit study to identify short range and long range transit needs. K. Continue to encourage AMTRAK, LOSSAN, and Caltrans Division of Rail to adjust the schedule times of the Surfliner to better serve commuters traveling between Ventura and Santa Barbara Counties. L. Formally comment during the CEQA process regarding the potential difficulties and costs of providing transit services to low income housing and other public facilities with high transit dependent use which are not sited at locations served or easily served by public transit. M. Support cost-effective actions to increase bike capacity on the transit system. N. Encourage transit trips over auto usage during this time of heightened public awareness of the cost of fuel. O. Seek financial support from the cities/County to provide subsidized fares for low income passengers who are transferring between local transit systems and VISTA. P. Work with LOSSAN, Caltrans, Amtrak, and Metrolink to improve rail safety and maintain or increase speeds on the rail services. Q. Encourage VCTC and the ADA providers in the county continue to improve transfers and transfer locations for inter-agency ADA trips. R. Continue to integrate evening meetings in different parts of the county as part of future Unmet Transit Needs process. After adopting the recommendations listed above, and based on the analysis of the written and verbal testimony provided to the Commission: Find by VCTC Resolution#2014-01 that there are no Unmet Transit Needs, including needs that are reasonable to meet. Analysis of Testimony Received: The 2014 VCTC amended Unmet Needs Process simplifies and makes more clearly understood the process. All comments were reviewed to determine if they meet the definition of an Unmet Transit Need. Those comments that are determined to be either new services which did not meet the minimum criteria as an Unmet Transit Need, or are operational, are being forwarded to the appropriate transit agency for consideration as part of their future planning and scheduling activities. Following the Hearing Board action, contact will be made to the commenter regarding the recommended action. Those comments which meet the criteria as an Unmet Transit Need will be evaluated against the seven adopted "Reasonable to Meet"criteria. Those projects which meet all the criteria will be recommend as Unmet Transit Needs which are Reasonable to Meet. In the case of the cities of Moorpark, Camarillo, Fillmore, and Santa Paula, if a comment is found to be an Unmet Transit Needs Which is Reasonable to Meet, the VCTC will withhold any TDA street and road funds until the agency demonstrates it will meet the transit service need. In all other parts of the County, the finding will be conveyed to the appropriate agency for their consideration. Finally, for those comments which are found to be not reasonable to meet due to one or more of the"Reasonable to Meet"criteria will also be conveyed to the appropriate agency for their consideration. Following is a discussion of those comments which met the VCTC definition of an Unmet Transit Need, and provides the evaluation of the Reasonable to Meet criteria for each project. 115 14