Labor Community Strategy Center v. Los Angeles County Metropolitan Transportation Authority Consent Decree

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CONSTANCE L. RICE 
ROBERT GARCIA 
BILL LANN LEE 
MOLLY MUNGER 
NAACP LEGAL DEFENSE AND 
EDUCATIONAL FUND, INC.

315 West Ninth Street, Suite 208 
Los Angeles, CA 90015 
(213) 624-2405

FILED
CLERK, U.S. DISTRICT COURT

OCT 1 9 1996
___ _ _ Y r

CENTRAL DISTRICT OF CALIFORNIA 
BY______________________ DEPUTY

ELAINE R. JONES 
THEODORE M. SHAW 
NAACP LEGAL DEFENSE AND 
EDUCATIONAL FUND, INC.
99 Hudson Street, 16th Floor 
New York, NY 10013 
(212) 219-1900

DEWITT W. CLINTON, COUNTY 
COUNSEL
DAVID B. KELSEY 
JOYCE CHANG 
One Gateway Plaza 
Los Angeles, CA 90012 
(213) 922-2000

E. RICHARD LARSON 
MARK D . ROSENBAUM 
ACLU FOUNDATION OF 
SOUTHERN CALIFORNIA 

1616 Beverly Boulevard 
Los Angeles, CA 90026 
(213) 977-9500

Attorneys for Plaintiffs 
Continued on the next page

RIORDAN & McKINZIE
A Professional Corporation 

KENNETH KLEIN 
PAMELA A. KELLEY 
300 South Grand Avenue 
29th Floor
Los Angeles, CA 90071-3155 
(213) 629-4824

Actorneys for Defendants

entered _TBK. U.S, DISTRICT COURT

OCT 3 I 199b

AL D IS »tC T  OF CALIFORNIA 
^  DEPUTY3 E

UNITED STATES DISTRICT COURT
. i ■'■V ov CALIFORNIA 

WESTERN DIVISION

LABOR/COMMUNITY STRATEGY CENTER, ) 
et al., )

)
Plaintiffs, )

)
v s . )

)
LOS ANGELES COUNTY METROPOLITAN ) 
TRANSPORTATION AUTHORITY and )
JOSEPH DREW, etc. )

)
Defendants. )

THIS CONSTITUTES NOTICE OF ENTRY 
AS REQUIRED BY FRCP, RULE 77(d).

CASE NO. CV 94-5936 TJH (Mcx)

CONSENT DECREE

Date: Not Applicable
Time:
Place:

, •-':£ * CERTIFY THAT THIS DOCUMENT WAS SERVED BY
; . ■ CUSS M AIL POSTAGE PREPAID. TO A U  COUNSEL______

I u K’ il S) AT THEIR RESPECTIVE MOST RECENT ADORESS OF 
RECORD in  THIS ACTION ON THIS DATE.

DAI Eft:

DEPUTY CLERK

,, Docketed
,. Mid copy Ptya 
r . Mid Notice Ftya 
. .  JS-6

O CT 3 11996



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PAUL L . HOFFMAN 
GARY L. BOSTWICK
100 Wilshire Boulevard, Suite 1000 
Santa Monica, CA 90401 
(310) 260-9585

Attorneys for Plaintiffs

/  /  /

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The Los Angeles County Metropolitan Transportation Authority ("MTA") and the 

Labor/Comraunity Strategy Center, the Bus Riders Union, the Southern Christian Leadership 

Conference of Greater Los Angeles, the Korean Immigrant Workers Advocates and other bus 

riders in Los Angeles County share a strong common commitment to the improvement of bus 

service for the transit-dependent populations of Los Angeles County. In furtherance of that 

commitment, the parties have agreed to settle the litigation, Labor/Community Strategy Center, 

et al. v. Los Angeles County Metropolitan Transportation Authority, et a l., in accordance with 

the following terms and conditions of this Consent Decree. Attachments A and B shall be 

deemed to be parts of this Consent Decree and are fully incorporated by reference here.

I. BASIC PRINCIPLES AND OBJECTIVES

A. MTA is fully committed to insuring that all transit patrons in Los Angeles 

County, without regard to race, color, or national origin, have equal and equitable access to a 

fully integrated mass transportation system that effectively meets the needs of all riders.

B. In September 1995, the MTA Board adopted as its "highest priority, 

improvement of the quality of bus service in Los Angeles."

C. MTA shall institute and maintain a policy of charging equitable fares for the 

provision of transit services.

D. MTA shall institute and maintain a policy of fairly distributing resources 

devoted to transit security in the form of uniformed officers, improved waiting areas, and 

other measures, among all classes of service, all modes of transit, and all geographic areas 

served by MTA.

E. Capital improvement planning and programming for MTA shall include attention 

to all modes of transportation and all areas of the County from which riders are drawn. 

Improvements meeting the needs of transit-dependent populations shall be given priority, 

consistent with MTA’s other statutory responsibilities and obligations.

F. "Transit-dependents" are residents of Los Angeles County whose access to 

automobiles is limited by income, age or disability. Consistent with MTA’s other statutory 

responsibilities and obligations, MTA’s first p«er for the use of all bus-eligible revenue

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realized in excess of funds already specifically budgeted for other purposes shall be to improve 

bus service for the transit-dependent by implementing MTA’s obligations pursuant to this 

Consent Decree. If sufficient funding is not provided to meet the obligations set forth in this 

Consent Decree, the matter shall be addressed in accordance with the procedures set forth in 

this Consent Decree.

G. Future MTA long-range plans, major capital projects, and annual budgets shall

include a section devoted to the means by which the transit needs of transit-dependent residents 
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are being and shall jnet. Such section shall address specifically how these principles and 

objectives are being met.

H. MTA will work with representatives of the plaintiffs’ class in implementing 

these principles and objectives and the Consent Decree. To that end, a Joint Working Group 

(JWG), described in Section IV, below, shall be established to provide for cooperation 

between representatives of the plaintiffs’ class and MTA.

n .  SERVICE IMPROVEMENTS

A. Reducing Overcrowding By Adding New Service.

I. Improved Performance Goal: Reduced Loan Factor Targets. MTA’s 

performance in meeting this critical objective of responding to consumer demand for bus 

services efficiently shall be measured by the reduction in levels of crowding on board buses. 

MTA shall establish as a five-year goal to be reached by the end of the fifth complete fiscal 

year following the approval of this Consent Decree, the reduction of the maximum load factor 

ceiling for all bus routes from 1.45 to 1.2 in the following increments ("target load factors"):

December 31, 1997, 1.35 

June 30, 2000, 1.25 

June 30, 2002, 1.2

Thereafter, MTA shall maintain the 1.2 load factor for the duration of this 

Consent Decree.

2. Load Factor Definition. "Peak load factor" shall mean (total number of 

passengers/total number of seats) which shall be determined by computing the highest ratio of

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total number of passengers to total number of seats achieved during any 20 minute weekday 

peak period in the peak direction of travel on each bus line. This load factor computation 

would be based on a one hour time interval during non-peak periods. Target load factors shall 

not be achieved by by-passing passengers at bus stops. MTA shall conduct ride checks to 

determine load factors using current MTA procedures and schedules. MTA shall supply the 

JWG with all such data, including on-board surveys, ride and point checks and passenger 

surveys, throughout the year, and inform the JWG of any change in data gathering/processing 

procedures. The JWG may request that MTA collect additional data as appropriate to monitor 

compliance with the load factor targets.

3. MTA Plans to Meet Targets. MTA will plan to make available sufficient

additional buses and other vehicles to meet these target load factors. While MTA will have
&/=

the discretion in determining how the targets will he met, MTA will consult with the JWG in 

formulating and implementing this plan. MTA will prepare at least 90 days prior to the 

beginning of each fiscal year, and make publicly available, a report setting forth its plan to 

meet the targets as of the date the report is issued, recognizing that changes in ridership, fares, 

the economy and other factors may require modifications to the plan. In addition, when MTA 

makes its scheduled modification to its long range plan it shall incorporate plans to insure the 

availability and operation of the additional buses and other vehicles required to meet these 

targets. If ridership shall increase by more than 15 percent on any bus line MTA shall 

nevertheless make its best efforts to meet the target for that line and the target for that line 

may be deferred for one (and only one) year. In addition, the JWG will designate a list of bus 

lines which may be exempted from the load factor reduction requirement, such as lines with 

low frequency service.

4. Failure to Meet Targets. If MTA fails to meet the target load factors for all bus 

lines by the dates specified in paragraph 1 above, (except those exempted or deferred under 

paragraph 3 above), MTA shall meet the target as soon as possible and reallocate sufficient 

funds from other programs to meet the next lower target load factor as scheduled. The 

reprogrammed funds, which may include but not be limited to revenues from Propositions A

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ar\d C discretionary funds, shall be used to meet the target load factors. Any dispute

concerning whether the targets have been met; or if the targets have not been met, whether

sufficient funds have been reprogrammed to meet the next target will be reviewed by the
tr-

JWG. EE* the JWG cannot resolve the matter it will be referred to the Special Master. The 

failure o^M TA to meet the target load factors shall not be deemed a changed or unforeseen 

factual condition for purposes of seeking a modification of this Consent Decree by MTA.

B. Expanded Bus Service Improvement Program. MTA shall initiate the bus 

service improvement program during the remaining months of calendar year 1996 that will 

result in immediate, visible and tangible benefits in improved bus service for the transit- 

dependent communities of Los Angeles County, including but not limited to areas in south and 

east Los Angeles and Pico Union. This program will make available 51 additional buses (i.e., 

buses in addition to those already planned for replacement purposes) by the end of calendar 

year 1996 to reduce overcrowding, initiate new services, and improve mobility and access for 

transit-dependent riders. Another 51 additional buses (i.e., buses in addition to those already 

planned for replacement purposes) to reduce overcrowding will be available by June 30, 1997, 

for a net of 102 additional buses. Bus service improvement plans that have already been 

funded by MTA will be implemented expeditiously following the approval of this Consent 

Decree.

C. New Bus Service To Facilitate Access To County-wide Job, Education and 
Health Centers.

1. MTA shall work with the JWG to develop and implement a plan to provide 

additional bus service that is designed to improve access by the transit-dependent community 

to Los Angefc^j^unty-wide educational, employment, and health care centers, as well as 

enhancing personal mobility throughout the region. See Attachment A, Section IV.A for 

examples of specific service improvements that could facilitate access to health care centers. 

Routes to increase service to job and education centers or to add service to existing routes also 

shall be developed by MTA working with the JWG, as set out in Attachment A, Section IV.B.

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Tfye parties understand that the addition of these routes must be responsive to sufficient rider 

demand and economically feasible and that such new routes will be closely monitored and 

terminated if there is not sufficient customer demand.

2. After consultation with the JWG, MTA will initiate as expeditiously as possible 

a pilot project to provide a minimum of fifty additional buses (i. e. , buses in addition to those 

buses already planned for replacement purposes) during the next two years to demonstrate how 

this program can meet the needs of transit-dependent areas for access to jobs, education and 

health services. The JWG will evaluate the pilot project and develop a plan for additional bus 

and other transit services over the following five years, which shall include a projection of the 

number of buses and other vehicles needed to provide such services. If the JWG cannot agree 

on a five-year plan by December 31, 1998, the issue may be referred to the Special Master.

D. Comprehensive Program To Enhance Security, Improve Bus Stops, Increase 

User-Friendliness, and Improve Bus Service Efficiency For Transit-Dependent Riders 

("Program"). A description of the service improvements contained in this Program is 

provided at Attachment B.

E. Consultation With Riders in Improving Bus Service to the Transit-Dependent. 

Implementation of significant improvements in bus service for the transit-dependent population 

over the next seven years will require some reallocation of the existing fleet, the procurement 

of additional buses, a wide variety of service enhancements and other innovative responses as 

devised by MTA. MTA agrees to work w id /g y G  in a spirit of cooperation in achieving the 

objectives of this Consent Decree. MTA may also work through neighborhood advisory 

councils in soliciting advice and in evaluating MTA’s progress in meeting the principles and 

objectives. Consultation with the neighborhood advisory councils, however, shall not 

constitute a part of the monitoring process for insuring compliance with this Consent Decree.

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IIJ. FARES

A. General Pass. The monthly pass is essential to ensure affordable transportation 

for transit-dependent persons who utilize the bus for work and personal mobility throughout 

the day. MTA will provide general passes at the following prices:

1. monthly pass: $42.00

2. semi-monthly pass: $21.00

3. weekly pass: $11.00

MTA shall effectively market and distribute passes and tokens.

B. Base Fare. The general base fare shall be $1.35. Transfers shall be 25 cents.

C. Off-Peak Discounts. The fare shall be 75 cents during off-peak periods on 

selected lines that are heavily used by transit-dependents, as determined by MTA.

D. Tokens. The 90 cent token will be continued.

E. Other Fares. The prices for MTA’s other passes, such as passes for seniors, 

disabled and students, shall be maintained at current levels for the duration of the general pass 

price, as set out in Section III.F (introductory paragraph), below.

F. Duration. The above fare structure will be effective December 1, 1996. and 

will remain in effect through November 1, 1998. Except as set forth in 1 and 2 below, from 

November 1, 1998 through November 1, 2003, MTA may increase fares up to a level 

reflecting any increase in the Long Beach/Los Angeles Standard Metropolitan Statistical Area 

Consumer Price Index ("the CPI") from October 1, 1995 to the time the fare increase is 

proposed, with special reference to any increase or decrease in the household income of the 

bottom quartile of the Los Angeles County population (as published by the United States 

Department of Commerce) for the same period, or at a lesser rate if MTA chooses. In 

adjusting pass prices, the Board may round off the price to the nearest dollar. In adjusting

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fares other than passes and transfers, the Board may round off the price to the nearest nickel. 

This Consent Decree will not restrict MTA’s authority to adjust fares after November 1, 2003. 

These provisions are subject to the following two conditions:

1. The prices of the general monthly, semi-monthly and weekly passes (the 

"general pass") shall not be increased until after November 1, 1999 unless MTA develops and 

adopts a new pass (or alternative system based on new technology) that ensures that pass 

prices for transit-dependent, low income riders will not be increased before November 1,

1999. If at any time MTA adopts a pass exclusively for transit-dependent, low income riders 

(a "low income pass") that is administratively feasible, then MTA may increase the price of 

the general pass without restrictions. A low income pass may require some type of income- 

related qualification or may be linked to appropriate government programs that assist low 

income people. MTA will consult with the JWG before it implements a low income pass. 

After November 1, 1999, the price of the new low income pass may be increased up to a level 

reflecting any increase in the CPI from October 1, 1995 to the time the low income pass price 

increase is proposed, with special reference to any increase or decrease in the household 

income of the bottom quartile of the Los Angeles County population (as published by the 

United States Department of Commerce) for the same period, or at a lesser rate if MTA 

chooses. In adjusting low income and general pass prices, the Board may round off the price 

to the nearest dollar. All restrictions on low income pass increases shall terminate on 

November 1, 2003. MTA may exclude corporate buyers from eligibility for any and all 

passes at any time.

2. At any time, MTA, after consultation with the JWG, may propose an 

adjustment in fare levels and categories that reflects new technology and is consistent with the 

principles and objectives of this Consent Decree. If the JWG does not agree to the

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adjustments in fare level and categories resulting from the new technology, the matter may be 

submitted to the Special Master.

IV. JOIN T W ORKING GROUP

A. The parties shall establish a small Joint Working Group (JWG) consisting of an 

equal number of representatives of MTA and the plaintiffs’ class. Each party shall select its 

own representatives. The purpose of the JWG will be to foster cooperation in the 

implementation of this Consent Decree.

B. MTA shall work with the JWG in the development and implementation of bus 

service improvement plans and on fare adjustment issues.

C. MTA shall engage in rider surveys, and shall seek the participation and 

concurrence of the JWG in developing the methodology and procedures for such surveys.

V. SPECIAL M ASTER

A. The parties have agreed upon Donald T. Bliss to serve as the Special Master, 

subject to the approval of the District Court, to facilitate the resolution of disputes arising 

under any provision of this Consent Decree. If Mr. Bliss does not or cannot serve as the 

Special Master now or in the future, the parties shall try to agree on the selection of a Special 

Master, subject to the approval of the District Court. To the extent that the parties cannot 

agree on a Special Master, or if the District Court rejects the parties’ selection, the District 

Court will appoint the Special Master.

B. Any dispute arising under any provision of Sections I through IV of this 

Consent Decree in which the JWG has a role shall initially be addressed by the JWG. If the 

JWG cannot resolve the matter, or if the JWG does not have a role in the disputed function, 

this dispute shall be referred to the attorneys to the parties. If the attorneys cannot resolve the 

matter informally, the attorneys shall refer the matter to the Special Master for resolution,

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pursuant to procedures set forth by the Special Master. Any matter resolved by or referred to 

the Special Master may be reviewed by the District Court, along with the recommendations of 

the Special Master, if any, upon motion by either of the parties.

C. Subject to mutually agreeable conditions, the Special Master shall be 

compensated for his time and expense by MTA within 30 days of the submission of time 

charges and expenses to MTA Chief Executive Officer or his or her delegee.

VI. M ODIFICATION OF THE CONSENT DECREE

A. Any party to this Consent Decree may seek to modify any provision or 

provisions of this Consent Decree. The party seeking modification bears the burden of 

establishing, to the satisfaction of the Special Master and ultimately to the satisfaction of the 

Court, that a significant change in circumstances warrants revision of the Consent Decree, and 

that the proposed revision or revisions are suitably tailored to the changed circumstances.

B. Modification of this Consent Decree may be warranted when changed factual 

conditions make compliance with the Consent Decree unworkable or substantially more 

onerous, and when the changed factual conditions were unforeseen at the time of the entry into 

this Consent Decree.

VII. INTERPRETATION OF THE CONSENT DECREE

If any dispute arises as to the interpretation of any provision of this Consent Decree, no 

prior written drafts of this Consent Decree shall be used in any way to interpret any provision 

of this Consent Decree.

VIH. CONTINUING JURISDICTION

The District Court shall retain jurisdiction over this litigation for ten years from the 

date of the approval of this Consent Decree in order to monitor compliance with this Consent 

Decree. At the end of seven years MTA may file a motion with the District Court to

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terminate the Consent Decree and the Court shall grant such motion if MTA shows to the 

Court’s satisfaction that it has substantially complied with the Consent Decree and that it has 

in place a service plan that will enable continued adherence to the principles and objectives of 

the Consent Decree during the five years subsequent to the termination of this Consent 

Decree.

IX. ATTORNEYS’ FEES, COSTS AND EXPENSES

A. Plaintiffs intend to apply for reasonable attorneys’ fees, costs and expenses in 

connection with the litigation that resulted in this Consent Decree.

B. Plaintiffs shall be entitled to reasonable attorneys’ fees, costs and expenses for 

monitoring compliance with the Consent Decree, subject to mutually agreeable conditions.

C. The parties will endeavor to resolve the foregoing matters informally, and, if 

they are not able to do so, the matter will be submitted to the Special Master, who shall make 

recommendations to the parties. If either party or both parties do not accept those 

recommendations, the matter will be submitted, along with the recommendations of the Special 

Master, to the District Court through a motion filed within 45 days of the date of the Special 

Master’s recommendations.

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ATTACHMENT A

THE NEED FOR ADDITIONAL MTA BUS SERVICE

This Attachment describes MTA bus service improvements for the transit-dependent of 

Los Angeles County, as required by Section II of the Consent Decree. MTA shall have 

flexibility to use alternative service delivery options in fulfilling its obligations pursuant to this 

Consent Decree.

I. OVERALL PRINCIPLES

A. Additional bus service in Los Angeles County would achieve the following

goals:

•  To reduce overcrowding

•  To reduce waiting and transfer times

•  To meet unmet employment, medical, educational and other needs

•  To serve new areas

•  To allow greater mobility to other parts of the County for the transit-dependent

•  To meet uumei ride.tsldp nf.erls

•  To replace old buses and bring the fleet up to modem standards

B. MTA shall reallocate and expand its bus fleet to meet the most basic needs of 

the transit-dependent. The additional service will address the following categories of need:

•  Reduction of overcrowded lines

•  Essential non-emergency medical transportation

•  Access to County-wide job and education centers

H. REDUCTION OF OVERCROWDED LINES THROUGH TARGET LOAD 
FACTORS

These target load factors are set out in Section II.A of the Consent Decree above and

shall be achieved in the manner set forth therein.

A -l

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III. EXPANDED BUS SERVICE IMPROVEMENT PROGRAM

The manner in which MTA shall implement the expanded bus service improvement 

program is set forth in Section II.B of the Consent Decree above.

IV. NEW BUS SERVICES

A. Essential Non-Emergency Medical Transportation Needs. With the 

restructuring of the County Health Care system, patients often have to travel long distances to 

clinics in other communities. It is essential that transit-dependent people be able to get to 

these clinics in a reasonable amount of time. In the design of the pilot project set forth in 

Section II.C .2 of the Consent Decree, MTA shall consider the feasibility of (1) adding buses 

for lines 120-121, 117 and 264 to bring more reliable service to the Los Amigos Medical 

Center, and (2) adding buses on line 205 and extending a branch of line 204 to the 

Harbor/UCLA Hospital. MTA shall undertake a more detailed analysis, along with the JWG, 

to assess the transit needs at other public hospitals in connection with the five-year plan 

described in Section II. C. 2.

B. New Bus Service To Job and Education Centers. In designing the pilot project 

and developing the five-year plan in consultation with the JWG, as set forth in Section II.C .2 

of the Consent Decree, MTA shall develop a plan to provide additional service, or to add 

service to existing routes, via bus and other vehicles to meet the needs of the transit-dependent 

attempting to travel to and from job and education centers. This plan shall enable transit- 

dependent riders to move from their neighborhoods to areas of employment and health care. 

The plan shall expand bus and other vehicle service to serve important centers outside 

downtown Los Angeles. If the JWG cannot agree on a five-year plan, the issue may be 

referred to the Special Master.

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ATTACHMENT B

This attachment sets forth action steps to enhance security, improve bus stops, increase 

user-friendliness, and improve bus service efficiency for transit-dependent riders, as required 

by Section II.D of the Consent Decree, above.

I. BUS SECURITY

A. 48 Additional Officers. MTA shall take specific steps to improve security fo r  

bus riders. In this regard, in 1995 MTA received a matching grant from the Department of 

Justice ("DOJ") which has provided approximately $2 million to improve bus security and 

ultimately could lead to additional grants totalling another $2 million. Specifically, last year 

the DOJ grant provided $1.1 million to MTA that was used to hire 12 transit officers 

exclusively assigned to buses in South Central Los Angeles. The grant was a three-year grant 

and MTA agrees to continue to fund those additional 12 officers after the grant expires.

MTA received an additional DOJ matching grant of $900,000 in fiscal year 1996 to 

fund the hiring of 12 transit officers to be assigned exclusively to bus operations in East ^  5 

Angeles. MTA agrees to hire these 12 officers and assign them to bus operations in East Los 

Angeles and to continue the funding of these additional 12 officers after the DOJ grant 

expires.

MTA has applied for a third matching grant from the DOJ that would provide 12 

additional officers dedicated exclusively to bus operations in the

Hollywood-Rampart-Koreatown area, which is another high crime, highly transit-dependent 

area of the city. Next year MTA shall apply for a fourth matching grant from the DOJ that 

would result in 12 officers being added to police bus operations in another highly transit- 

dependent area, the east San Fernando Valley. If these two additional grants are approved, 

then another 24 officers shall be added within the next two years.

B-l 

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, As set forth above, MTA shall authorize the MTA matching funds to provide a net 

increase over 4 years of 48 transit officers (which includes continued funding of the 12 

officers already working in South Central Los Angeles) and, if the grants are approved, MTA 

will assign such officers exclusively to bus operations in transit-dependent areas.

B. Women In Transit Grant. MTA shall apply for a special $400,000 grant from 

the U.S. Department of Transportation under the Omnibus Crime Bill of 1994. This grant 

shall fund a special unit to concentrate on safety and security for women who use the MTA 

regional public transit system, with special emphasis on heavily transit-dependent areas.

II. BUS STOPS

Bus-stop improvement involves the cooperation and approval of the different 

jurisdictions which own the bus stops.

A. Pilot Program fo r  Bus Shelter Improvement. MTA shall make available as part 

of its Call For Projects a total of $500,000 over the next five years to be dedicated to bus-stop 

improvement. While the local jurisdictions will apply for such funds, MTA agrees that any 

funds provided through such grants shall go first to communities that are heavily 

transit-dependent. The JWG will evaluate this pilot project and recommend to the MTA Board 

an expanded program for bus stop improvements.

B. Los Angeles Neighborhood Initiative Program (LANI). MTA has received a 

grant from the Department of Transportation for $3.9 million to fund the Los Angeles 

Neighborhood Initiative Program ("LANI"). LANI is focused on eight neighborhoods, each of 

which has been identified as transit-dependent and economically challenged. The program 

organizes local councils to suggest local transit improvements. To date, the local councils have 

asked for and MTA has provided at least 21 new bus shelters, the planting of street trees near 

bus stops in these neighborhoods, and additional landscaping to improve the pedestrian

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environment at bus stops.

Phase 2 of LANI, which is just beginning, shall include the purchase and installation of 

security cameras and additional lighting at bus stops, as well as the placement of route 

information machines at transit information booths in the chosen neighborhoods.

Additionally, the LANI councils applied for and received $320,000 from MTA to be 

used for additional improvements to bus stops and for the establishment of transit information 

booths. MTA will work with the JWG to evaluate whether the LANI concept should be 

continued and expanded.

III. USER FRIENDLINESS

A. Smart Shuttle. In last year’s Call For Projects, MTA awarded a total of 

approximately $8 million for a two-year demonstration project to test the viability of Smart 

Shuttles. Four demonstration projects, three of which are in areas containing large minority 

populations, were designated: (1) Westlake-MacArthur; (2) South Central Los Angeles; (3) 

Northeast Valley; and (4) West San Fernando Valley.

With respect to the Smart Shuttle service in the Northeast Valley, service is expected to 

begin in 1997 and continue for approximately two years. Such service is expected to include 

putting in a circulator service, which will aid transit-dependent riders who must travel long 

distances to reach transit stops. This circulator will utilize vans as well as smaller sized buses 

operating in a more flexible manner than would be available with fixed-route bus service. It is 

expected to allow riders to call in beforehand so that they can most efficiently be picked up 

and taken to their destinations. In South Central Los Angeles and MacArthur Park, where the 

transit systems are overcrowded, the Smart Shuttle will provide connections to regional 

transportation systems such as the Blue Line, Green Line, Red Line and Harbor Transitway. 

Smart Shuttle is expected to permit individual passengers and vehicle operators to become

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acquainted with each other in a way not normally possible with fixed-route bus service. MTA 

shall work with the JWG to find ways to utilize Smart Shuttles to improve personal mobility in 

transit-dependent areas. Smart Shuttle programs shall not adversely affect bus improvements 

for the transit-dependent and shall seek to provide greater service to the transit-dependent.

B. Bus Restructuring Study. In 1993 MTA initiated the Bus Restructuring Study 

in an effort to make the entire bus system more user friendly. The study divides the bus 

system into eight areas and analyzes each area to determine the nature of the problems 

experienced by riders and what can be done to eliminate or reduce those problems. In this 

regard, recently an evaluation began of the mid-cities area, which includes South Central Los 

Angeles, to determine how bus service can be improved. The study will cost approximately 

$450,000, will seek community input, will examine innovative transit services, will improve 

coordination between MTA and municipal operators, and should result in substantial 

improvement in the nature of bus service in the inner city. MTA will consult with the JWG 

on the findings of the Bus Restructuring Study.

C. Service Planning/Market Research Study. MTA is currently cormrissioumg a 

very extensive customer satisfaction market research study. This study involves extensive 

surveys of current bus riders, former bus riders and non-users to determine their attitudes
-facOAM 5
tew w *t|e^bus system. The goal is to get an accurate portrait of who is riding the buses and 

what can be done to make the buses more attractive to bus riders. MTA will consult with the 

JWG on the design and the findings of the study.

D. Fare Debit Cards and Smart Cards. MTA is in the process of analyzing both a 

fare debit card and a "smart" card. In this regard, MTA recently funded a demonstration 

project in which three municipal bus operators utilized the fare debit card. This type of fare 

mechanism will facilitate the integration and coordination of all of the transit operators in Los

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Angeles County, which will permit riders to move easily from one system to another. This 

demonstration study and implementation cost $5.8 million. MTA will consult with the JWG 

in evaluating the demonstration project and the feasibility of using a fare debit card or smart 

card system-wide.

E. Immediate Needs Transportation Program. Pursuant to this program, each year 

MTA provides $5 million in subsidies to pay for taxi vouchers and bus tokens to social service 

and health care organizations for the transportation of their most needy clients. The program 

currently provides such vouchers and tokens to over 400 agencies in Los Angeles County.

MTA shall use its best efforts to continue this program.

F. Signal Priority For Buses and Exclusive Bus Lanes. MTA shall implement 

signal priority and bus preference projects that would involve synchronizing traffic lights to 

favor buses and designating traffic lanes as being solely for buses in order to improve service 

for the transit-dependent. MTA has committed $5 million to the continued analysis of these 

options. MTA will use its best efforts to implement feasible options.

G. Mobility Allowance. MTA has and continues to make extensive plans involving 

mobility allowance. The essence of the mobility allowance is to provide vans, taxis and 

smaller buses to: (1) areas that MTA is responsible for serving but which do not need 

regularly scheduled fixed-route service, and (2) areas that do not need fixed-route service in 

hours of lower demand. MTA believes that millions of dollars could be saved and that transit 

service could be substantially improved by substituting vans and taxicabs for such fixed-route 

service and that any resulting savings could be used to provide additional buses in those areas 

where overcrowding is occurring. Mobility allowance programs shall not adversely affect bus 

improvements for the transit-dependent and shall seek to provide greater service to the transit- 

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dependent. MTA will consult with the JWG in identifying ways to provide more flexible 

transit services in transit-dependent areas.

SO ORDERED:

Dated: October 1996
m./Terry J. Hatter, 

'United States District Judge

Submitted by:

tobert Garcia > 
Attorney for F̂ lai. 
and the Clas

Attorney for Defendants

126945.3

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PROOF OF SERVICE BY MAIL
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I am employed in the county aforesaid; I am over the age of 
18 years and not a party to the within action; my business 
address is 300 South Grand Avenue, 29th Floor, Los Angeles, 
California 90071-3155.

On October 29, 1996, I served the within STIPULATION RE 
SUBMISSION OF CONSENT DECREE on interested parties in this action 
by placing a true copy thereof in a mail box maintained by the 
U.S. Postal Service, enclosed in a sealed envelope with postage 
thereon fully prepaid at Los Angeles, California, addressed as 
follows:
NAACP Legal Defense and 

Educational Fund, Inc.
Elaine R. Jones, Esq.
99 Hudson Street, 16th Floor 
New York, New York 10013
ACLU Foundation of Southern California 
E. Richard Larson, Esq.
1616 Beverly Boulevard
Los Angeles, California 90026

Paul Hoffman, Esq.
100 Wilshire Boulevard, Suite 1000 
Santa Monica, California 90401

NAACP Legal Defense and 
Educational Fund, Inc.

Robert Garcia, Esq.
315 West Ninth Street, Suite 208 
Los Angeles, California 90015

I am aware that on motion of party served, service is 
presumed invalid if postal cancellation date or postage meter 
date is more than 1 day after date of deposit for mailing in 
affidavit.

Executed on October 29, 1996, at Los Angeles, California.

I declare that I am employed in the office of a member of 
the bar of this court at whose direction the service was made.

Louise A. Monroe