East Texas Just Transportation Alliance’s draft response is highlighted in bold blue italic after each section of the letter. ETJTA members and anyone else who wants to should add any comments they have via the “comments” tab below. This will help us revise and extend our remarks for publication in other formats. In no way do these comments intend to suggest that anyone who wrote a letter of support or participated in the regional planning process as conducted by ETCOG is doing anything illegal, immoral or even fattening here. Signing a letter of support is something we all do. I've signed letters of support for competitors for a grant because I felt either would do a fine job of it. We merely feel that the process so far is flawed and needs to be done right or it will cost the whole region in dollars, efficiency and badly needed transportation resources for the future.
WE have been hearing some things from throughout the State that I would like to clarify.
The first is that ETCOG has designated themselves as the Lead Agency for the Coordinated Transit Plan. This is clearly not true. ETCOG has received Letters of Support, from various agencies, indicating that they support ETCOG as the Lead Agency. Some of the agencies are the City of Tyler MPO, Tyler Transit, City of Longview Transportation, City of Longview MPO, Texas United Mounted Peace Officers Association, TxDOT Atlanta District Engineer.
This is not clearly true either. It’s murky as a New Orleans Mardi Gras fountain! The two MPO’s and their partner transit agencies were both invited to the planning process by ETCOG in December 2004. The Mounted Peace Officers received the benefits of a recent transportation project in their county and it would have been impolite to say no. The Atlanta District Engineer doesn’t have a clue that anyone objects to it, so she signed a letter of support. Not surprising.
All these letters were REQUESTED by ETCOG and those who signed them were a small group with one token human services provider included for show. For something this big and this important, ETCOG should have lots more folks than that signed on and not just through a letter of support request. Letters of support are often a “You scratch my back, I’ll scratch yours” process anyway and prove little or nothing, especially if the signers are at all beholden to ETCOG in some way or other.
Also, Roxanne doesn't mention GETTA as one of the supporting entities, although in the letter to TxDOT's Tyler District they claim that GETTA supports their leadership. I’m on GETTA and I don’t remember that vote at all! She also doesn't mention that some at Tyler and Longview Transit have suggested retracting their letters of support on the grounds that such letters were "premature".
The ETCOG Executive Committee has passed and signed a Resolution supporting ETCOG as the Lead Agency. The Executive Committee is comprised of local elected officials from the entire 14 counties, all of which are offices we are to invite to the Coordination Planning Effort.
Roxanne does not mention that ETCOG's board and all other "supporters" were garnered in discussions completely controlled by ETCOG staff and conducted behind closed doors, i.e. no real discussion or community consensus building occurred.
ETCOG has been giving it’s Executive Committee the mushroom treatment for many years. Many of its members and former members are concerned that the information they are often given by the COG and upon which they have to make decisions may be incomplete or inadequate or even slanted to support ETCOG's position. If the presentation on Regional Service Planning at the regional transportation summit last month is any indication of how they presented it to their executive committee, then the execs certainly didn’t have a clear picture. A person without prior knowledge of what Regional Service Planning is actually supposed to be and who understood the potential consequences for screwing it up, would have assumed from what they were told in the breakout session that the state had anointed ETCOG as the lead agency based.
This is NOT true as I pointed out at the summit. The decision on lead agency should by made by a consensus of the community which it clearly was not. This "consensus" building process went more like “Whew, we got that vote done and they didn’t even ask too many questions!” (insert High Five here)
Also note the future tense of the last sentence. They ARE going to invite the 14 counties to the table. Eight months into the process and they haven’t done it yet. So, what’s wrong with this picture?
I've discussed this with TxDOT staff in Austin. I asked them what other agency in East Texas has stepped up the plate to take on the roll of Lead Agency. She mentioned maybe the local MPO's. That would be Longview or Tyler MPO, they have already stated they were not interested in being the planning agency for the 14 county region. We received a letter of support from each of these MPO's.
Roxanne mentions that she talked to TxDOT’s PTN staff, but doesn't mention that the Tyler District held its own meeting on regional service planning because they do not think the public has been involved and find that an unacceptable response to their commission's charge, nor does she mention that PTN refused to intervene on ETCOG's behalf when they complained about the meeting being held at all!
Is anyone out there aware of an agency that wants to be the Lead Agency? If so, we have not heard from them.
There’s a reason for that. As long as the only people you’ve had at the table were people you invited, who depend on funding from you in some way, either directly or indirectly, nobody is going to buck you if you make yourself captain of the football team - especially if you claim to own the football!
I can name several agencies that could lead including the Workforce Development Board, The Regional Mobility Authority, any one of a dozen large nonprofit agencies, The Economic Development Councils (could form an advisory board to lead out)….
The COG has worked on regional service planning for 8 months and all they’ve come up with so far is:
- We’re the lead agency and we’ll decide who gets what money (that’s essentially what the RFP process is for).
- We’re going to hire a consultant and decide what we want him or her to do
- TxDOT should pay for the consultant
Meanwhile, other COG’s have released draft regional service planning documents that include the work of 20-50 agencies and individuals who reached a consensus as to who should lead, who should plan, whether they wanted to hire a consultant, what they want the consultant to do and built a framework on which inclusive regional service planning could take place. All I can see that ETCOG has done is stewed for 8 months over how to do regional service planning without running the risk that the communities served could do something the COG didn’t want them to do.
If you don’t tell people what you’re up to, invite them to the table, include them in the discussions, who do you expect is going to be clairvoyant enough to call you up one day and suggest a lead agency? ETCOG HAS proclaimed itself lead agency (which is what the ETCOG resolution did and don’t give me any BS about the COG board being diverse – it’s not the same as having substantive discussions ahead of time with people who disagree with you actually in the room).
The second thing is that ETCOG is putting the plan together and not involving Local Stakeholders. I believe that this is coming from the fact that ETCOG, the City of Longview and Tyler have gotten together and are issuing a Request for Proposal. Someone is misconstruing this as a step in the Regional Coordination Plan. It is not. It is an Administrative Function that will bring a third party on board, a Consultant, to facilitate the Coordinated Planning process. The Consultant will also perform some other Scopes of Work that are identified by the ETCOG, Longview and Tyler.
Okay, first, let’s get the terms right. It’s a regional “service” plan. This includes coordination, but is more than that. It includes decisions about leadership, relationships and inclusion of communities in the planning process. We are not supposed to be producing another of those “Coordination” Plans that wind up being all about moving buses around more efficiently. It has to include elements that address how the system reacts to things like economic development, disasters, population boom or bust and public demand. If you only want to move buses around, you only invite transit people to the table and you write a scope of work for the “consultant” that gets what you want and only what you want. It seems very important to the COG to design the scope of work BEFORE they consult any non-transit providers. If they do that they can keep the consultant from meddling where they don’t want him to meddle (even though the community itself might well want a little meddling there).
The Solicitation process we must follow requires that ETCOG be accountable for all steps of the process and that persons involved in the process are knowledgeable of the rules we must follow. It is not that this RFP process is secret, but it is sensitive. An example of the sensitive nature of the information would be the Medicaid Transportation RFP that TxDOT is currently working on. Over the last couple months, at meetings I have attended, questions came up about the Medicaid Transportation Program and changes that might be made. TxDOT informed everyone that they were in the middle of putting an RFP out on the street and they could not discuss the Medicaid Transportation Program at all. We as operators were not offended by this, we are aware of the sensitivity of the process and we know that TxDOT cannot comment on or discuss the RFP.
ETCOG-speak for “This stuff is just way too complicated for you rubes, so you should just stay out of it and let the pro’s handle things for you.” I find that patronizing and offensive. There are lots of folks out there with pretty solid skills in community planning and transportation issues that they haven’t seen fit to include in the process. They’ve certainly never invited me and I represent rural East Texas on the state Public Transportation Advisory Committee.
ETCOG wants to create an RFP process that we may ultimately decide we don’t even need (if anyone else is ever allowed to comment on that subject). Other COG’s have done a great deal of the work using resources within their own communities and done some damned fine work in the process. When communities participate in the process, they invest in the process. If they don’t, they keep their dollars in their pockets. So far, only Tyler and Longview and Mini-Bus were invited to be a part of the process. If I were Marshall, Kilgore, Henderson, Rusk, Jacksonville, Athens, Canton, Mineola or any one of the dozens of other towns and communities in the 14 county region, I’d have to wonder why this has gone so far along and no one has talked to me. ETCOG has a couple of highly trained community development people on their staff. Why haven’t they been beating the streets and roads talking to local communities, hosting little public forums and fact finding meetings out there, trying to find out what they need and, more importantly, what resources these communities could contribute to the regional service planning process?
Roxanne does not mention that anyone and everyone that wishes to can have as much public involvement as they want in scoping a project prior to actually posting an RFP, but that this process is specifically designed to secure ETCOG's lead "status." She doesn't even mention that the money they are likely to use is funding that is supposed to be used for services, not planning.
Once ETCOG puts the RFP out on the street, unless people attend the Pre Bidders Conference, we will not be able to answer any questions about the RFP to anyone. This is to ensure that potential bidders/proposers are not given information that is not shared with every potential bidder/proposer.
AT LAST – BEHOLD THE FINE PRINT! To translate - once they get an RFP done, they won’t have to answer any uncomfortable questions – the famed “That train’s already left the station” Principle. This only looks more and more secretive and underhanded the more they “explain” it to us simpletons.
One other thing the RFP would do is confirm ETCOG in the role of lead agency. Could that explain the rush to get the RFP done?
There are other COG's who are going to hire Consultants to help them through this Regional Coordination Planning Process.
Ah, yes, the old "But Mom, everybody else is doing it!" argument. Well, in most cases, the decision to hire a consultant was made by a team of dozens of local participants from a wide range of backgrounds (not just transit providers) and it was made out in the open with everyone participating. Questions were not given the bum’s rush. Agenda’s were not tightly controlled by a lead agency that had every reason to “control” the process. Most of those COG’s were not transit providers themselves and could, therefore, be neutral since they didn’t have assets to protect. ETCOG’s extraordinarily tight relationship with Mini-Bus, essentially makes the COG the provider.
If anyone has any questions or concerns please call me.
Call soon and call often…
CCTM Rural Transportation Manager - ETCOG
903-984-8641, ext 217
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I’ve already discussed this puppy (see “If You Tell Anybody, I'm Gonna Sock You!”)
SOME FINAL QUESTIONS OF OUR OWN PROVIDED BY JTA DIRECTOR GLENN GADBOIS:
1. There is not a requirement to have a consultant in place by October, in fact most areas are waiting until they figure out where the money will come from and how much is available, so why the hurry in East Texas?
2. Where exactly is the money coming from to pay for the RFP and is it budgeted already? What happens if this money is not available for the RFP, will ETCOG cover the expense with its own funds?
3. Would ETCOG be willing to follow the Capital Area model (in which one entity funds the contractor, ETCOG in this case-the Austin District in their case; but a technical steering committee of stakeholders manages the development of an RFP, selection of a contractor, and management of work)?
3. What exactly was communicated to the ETCOG board, to the others, when they voted (please provide in writing)?
4. If there were another entity that could serve as lead and the preponderance of community interests in an open meeting chose the other entity to serve as lead, would ETCOG support the decision?
Thanks for wading through all this. Please put in your two cents worth. Your contribution to our strategy on this issue could be more important than you know.
Coordinator, East Texas Just Transportation Alliance