Charter Regulation Update
Earlier this month the Federal Transit Administration released the final version of the regulations governing Charter Service. This update was written by Dale Marsico, Executive Director of the CTAA and appeared on the CTAA website recently.
I want to begin this letter by thanking all of you who participated in responding to the regulation during the comment period. When you read the first section of these rules you’ll see that many of the issues we raised together have been addressed by FTA. For a copy of the rule, http://www.ctaa.org/webmodules/webarticles/articlefiles/fta0114.pdf
There are several new items in this rule that were not in the proposed rule, including an expanded exemption for rural transit as well as ones for 5310, the JARC program and the New Freedom. Rural transit is given special protection for training activities, and all transit agencies receive an important exemption relative to disaster training. The regulations also address with clarity the concerns many of you have expressed about how they might affect demand-responsive transportation by clearly saying they are not within the scope of the rule and exempt from these requirements.
The rule itself appears in basically three sections. The first section reflects FTA’s responses on the comments people submitted, the second part is the rule itself, and the third is a series of questions and answers that respond to realistic situations. I’d suggest you consider starting with the question and answer section as you approach your review of the regulation. It makes the more formal discussion on other pages easier to understand.
It’s very important to understand that Federal Regulations are an ongoing process. Like many other issues in our government, no rule or decision is ever final. I invite you to read and study these rules carefully and try to address how they may effect you and what concerns they may create. We want you to send us your concerns so that we can request further information or search for possible changes that may be helpful. You can send these concerns to us at charterregs@ctaa.org. Speaking of final, this is not our final communication on this subject, but our first this year. We shall be completing a summary of the new rules to add to this discussion shortly.
Again, thanks to all of you for your help and contribution to this important process. Without your help this progress would have been impossible.
Dale J. Marsico, CCTM
Executive Director
CTAA