Transit Brief · City of Asheville
The Bus Trilemma: the working detail
Every figure behind the paper, with its basis, its margin and what it cannot show. This is the page for anyone who wants to check the work.
Start with the paper, not this page
This is the working detail. It exists to be checked, not read straight through. The argument, the options and the sequence are in The Bus Trilemma, and every figure there links back down to the section here that shows its basis, its margin and its limit. If you have not read the paper yet, read that first.
Prepared 2026-08-23, updated 2026-09-26 · Figures from the National Transit Database (Time Series 2.1, npsm-38gk; Complete Monthly Ridership, 8bui-9xvu, which runs through June 2026), the City of Asheville's adopted budget books, its council documents of 24 March and 28 July 2026, and the signed operations contract released on 18 September 2026 · Peer band is rule-defined, not hand-picked
On August 18 the redesigned bus network was pulled from the city council's August 25 agenda, and the vote is now delayed indefinitely. The public argument is about money: a system that "costs three times as much to run as it did in 2018." That framing is measuring the wrong thing. On three of the four standard cost rulers, Asheville runs a cheaper bus system than most comparable American cities. What changed is not the price of the service. It is how many riders are on it.
First, the 2018 comparison crosses a reporting break
The "three times as much as 2018" figure straddles a change in how ART is run and reported. Through FY2018 the city operated the buses itself and reported $5,420,991. From FY2019 it contracted operations out, and reported $7,807,142 for the same mode: a 44.0 percent single-year rise landing in the year the classification changed. Some of that is real cost and some is the reporting boundary moving, and NTD does not separate them. Nothing below rests on a 2018-to-now cost comparison for that reason. The ridership and service-hour series are unaffected by the change, and those run from FY2018.
1 · The problem, stated exactly
Four rulers exist for what a bus system costs. The council's argument, and the coverage of it, has been conducted almost entirely on the fourth one.
| FY2024, fixed-route bus | Asheville | Peer median | Reading |
|---|---|---|---|
| Cost per rider | $7.92 | $10.10 | 22% below |
| Cost per revenue hour | $123.28 | $130.86 | 6% below |
| Cost per passenger mile | $2.16 | $2.26 | 4% below |
| Cost per revenue vehicle mile | $9.96 | $9.36 | 6% above |
| Riders per revenue hour | 15.56 | 13.09 | 19% above median |
The band is 145 agencies, chosen by rule rather than by hand: every US fixed-route bus system in an urbanized area of 150,000 to 500,000 people, carrying at least 150,000 trips a year. Thirty of them report no passenger miles, so that median is over the other 115. Two limits of that rule are worth stating, since the rule is the whole defense of the comparison. It counts agencies, not areas. Thirteen urbanized areas contribute more than one agency, and 28 of the 145 sit in them, so a town-scale operator can share a class with a city-scale one. Durham carries three. And ART runs only 19 vehicles in peak service, which would let it file a reduced NTD return. It files a full one anyway.
The one ruler where Asheville looks expensive divides by vehicle miles, and Asheville's buses are slow: 12.4 miles in a revenue hour against Roanoke's 16.3. Roanoke's buses cost within one cent of Asheville's per rider.
One caution about the year. FY2024 is the latest full annual release, and it is also a local high. ART carried 1,377,810 trips in FY2023 and 1,607,423 in FY2024, then 1,416,025 and 1,458,089 in the two years after. FY2024 sits 16.7 percent above FY2023 and 10.2 percent above FY2026. The peer comparison above is like-for-like, because every agency in the band is measured in the same year. But a cost per rider computed on a peak year flatters the agency, and the FY2026 productivity figures used later in this brief are the harder number. The direction survives the check: the same FY2024 cost over FY2026's lower ridership is $8.73 a rider, still 14 percent below the peer median.
So the sentence to hold onto is this one
ART is not an expensive bus system. It is a cheap bus system that used to be an extraordinarily productive one. That distinction is not academic: if the problem is price, the remedy is to cut; if the problem is productivity, cutting the wrong thing makes it worse.
2 · One cliff, then seven flat years
Riders per revenue hour is the cleanest measure of whether a bus is doing its job, and the federal database publishes the two numbers behind it every month. Asheville's own July-to-June fiscal years, every bar from the same file:
Riders per revenue hour, ART fixed-route bus, which is boardings per revenue hour: the federal count has no way to tell one rider making two boardings from two riders making one each. All nine years computed from the same monthly file and reconciling with the annual release to the digit. Peer median is FY2024.
The loss is one year wide. Between FY2019 and FY2020 ridership fell 28.8 percent while service grew 13.1 percent. That is the pandemic, and it happened to every transit system in the country. What is specific to Asheville is what came after. Since FY2021 riders are up 1.8 percent on 3.0 percent fewer hours. That is a slow improvement, and it is very small next to what was lost. FY2019 to FY2020 cost 570,197 trips. The gain since FY2021 is 25,900. Five years of recovery has clawed back under 5 percent of one bad year.
One year in that run needs naming. Helene falls in FY2025, and it shows: trips fell 11.9 percent from FY2024 and service fell 8.5 percent in the same year. FY2026 took both back up, trips by 3.0 percent and hours by 5.5 percent, which is why productivity kept drifting down while ridership recovered. The storm is a dip in this series. It is not the story of it.
So the honest version of the headline is not that the buses got expensive and not that they keep emptying. It is that Asheville bought a third more service around a collapse it did not cause, has never filled it, and has never published a target for filling it.
3 · The trilemma
Two lines of arithmetic govern every option anyone can propose:
total cost = revenue hours × cost per revenue hour
cost per rider = cost per revenue hour ÷ riders per revenue hour
Which leaves four things anyone can actually move: hours bought, price per hour, riders per hour, and who pays. Fares are not one of them. In FY2024 they were $601,698 against $12,732,832 of operating expense, 4.7 percent. Spread over 1,607,423 boardings that is 37 cents a ride actually collected. That is the number to reason from in either direction. A fare rise starts from 37 cents, not from the posted fare.
The price per hour is close to fixed. Asheville is already below its peer median there, and the operations contract with RATP Dev runs through the four base years, with the caveats in Step 5 about how the city can end it early. Those years are priced in the 24 March 2026 council packet at $12,671,301, $13,309,046, $14,102,049 and $14,817,546. The executed contract, released on 18 September 2026, has no clause that raises its prices automatically with inflation. It sets a monthly fee and a rate per revenue hour for each year, higher every year on a fixed schedule, and calls them firm fixed prices. Several of its clauses can still move them. The triggers include sustained inflation above the contractor's assumptions (§105.D(2)), a change of more than 10 percent in the hours run (§105.D(2) and §304.B(3)), and the city keeping 30-foot buses in service past 12 years or 600,000 miles (§103.A(6)). The city's September 2026 roster shows nine 30-foot buses in service past 12 years. So the 5.35 percent a year used here is still the compound rate across those four yearly totals, computed for this brief rather than quoted from the contract. Once the contract is paid, the FY2027 budget leaves $3,414,759 of the city's own cost. Hold that flat and total operating cost grows about 4.26 percent a year. So ridership has to rise 4.26 percent a year for cost per rider merely to stand still, about 13.3 percent from the first base year to the fourth. That is the bar before any improvement counts as improvement.
Coverage, service hours, and the current local contribution. Pick two. Every proposal anyone has made is one of these three rows, and only one of them has been put in front of council.
You need new revenue. Cost rises 4.26 percent a year whatever the council decides about MAHEC. This is the revenue conversation, and Step 4 sets out the two roads to it.
Frequency falls everywhere. Fewer hours across the same map. Nobody has proposed this. It saves between $1.34 million and $3.02 million a year. The low end is the contract's hourly rate plus fuel at its first-year prices, and the high end needs every cost to fall with the hours, the contract's fixed monthly fee included.
Coverage falls. Same hours, fewer places. This is the redesign, and it is the only one of the three the council has been shown.
The one thing that moves the triangle instead of trading along it Cost per revenue hour. Asheville's is $123.28, already below the band median of $130.86. Among the 47 agencies in the band that contract their operations out it is the 16th cheapest, against a contracted median of $140.98. There is no easy saving there, and the base contract runs through FY2030. Which is why Step 5 matters more than it looks.
The second row has never been put in front of council, so here is what it is worth.
ART added 18,730 revenue hours between FY2019 and FY2026, which is 18.8 percent of what it runs now. What removing them would save depends entirely on which cost you charge them at, and taking the lower of the two rates below cuts the answer by more than half.
The signed contract, released on 18 September 2026, splits what the city pays RATP Dev in two (§105.B). A fixed monthly fee, $510,019.64 a month in the first year, covers the contractor's fixed costs. A rate per revenue hour, $63.60 in the first year, covers its variable costs. Each month's bill is the fee plus the revenue hours actually run times the rate, before deductions and incentives (§401.C). Fuel for the buses is in neither (§105.C(2)); the city buys it (Attachment A-2). NTD put ART's fuel and lubricants at $8.08 per revenue hour in FY2024.
| Removing 18,730 hours, priced at… | Per revenue hour | Annual saving | Break-even rider loss |
|---|---|---|---|
| Fully allocated cost | $161.26 | $3,020,379 | 18.8% |
| The contract's hourly rate, plus fuel | $71.68 | $1,342,572 | 8.3% |
The first row is the FY2027 adopted budget over FY2026 revenue hours. The contract's first-year price works out to about 103,000 revenue hours, more than the 99,753 run in FY2026, so measured from the hours its prices imply, getting back to FY2019's hours would mean cutting about 22,000, not 18,730. The second is the contract's first-year rate per revenue hour, $63.60, plus $8.08 an hour for fuel. That $8.08 is NTD's FY2024 fuel-and-lubricants cost per revenue hour, and it may count some lubricant the contract rate now covers. The second row holds only at the contract's first-year prices. Section 304.B(3) lets RATP Dev hold off on any service change of more than 10 percent in revenue hours until the two sides agree to raise the fee and the rate. A cut of 18.8 percent is past that line. Section 514.B lets the city reduce service on 30 days' notice with no price term, and the contract does not say which one a deliberate cut falls under. Treat the first row as an upper bound, and the second as the saving at unchanged prices, not a floor.
What it would cost in riders is the part nobody can answer:
| If shrinking back to FY2019 hours costs… | Annual trips | Per rider, all costs cut | Per rider, contract rate and fuel cut |
|---|---|---|---|
| no riders at all | 1,458,089 | $8.96 | $10.11 |
| 10 percent of them | 1,312,280 | $9.96 | $11.24 |
| 18.8 percent, in proportion to the hours | 1,184,313 | $11.03 | $12.45 |
| 26.3 percent, the share ridership fell FY2019 to FY2026 | 1,074,466 | $12.16 | $13.72 |
| Today, for comparison | 1,458,089 | $11.03 | $11.03 |
The break-evens are the whole finding, and they are far apart. Cut every dollar with the hours and shrinking beats today's cost per rider if the rider loss stays under 18.8 percent. It beats the redesign's own best case of $9.35 only under 4.2 percent. At the contract's hourly rate plus fuel the first bar falls to 8.3 percent and the second disappears: losing no riders at all still lands at $10.11, above the redesign's best case. Two honest cautions on top of that. The added service did not cause the lost ridership: the pandemic did, and nothing here shows the marginal hours carry nobody, only that in aggregate they never filled. And cutting hours without cutting destinations means worse frequency everywhere, so this is the coverage fight in a less honest form. What it really is, is the cheapest experiment available, and it needs the route-level data in Step 1 before anyone could run it responsibly.
4 · What the fight is actually over
The draft network removes service to seven destinations. Council's stated alternative is to add some of them back, at the cost of the fifteen-minute frequency the redesign is built to deliver. The $16 million gets spent either way. What stalled was the decision about how to arrange it, and here is the scale of the thing that stalled it:
Average daily riders, from the city's own 28 July 2026 council deck. The seven are the Outlets/Brevard Road/Transformation Village segment (40), West Haywood between Brevard and Patton (34), and the Grove Park Inn (30). Then MAHEC (11), the Social Security office (8), Kenilworth (7) and Beaverdam (2). The deck's Option 2 offers council four of the seven to add back: the Outlets segment, West Haywood, MAHEC and the Social Security office. The two smallest of those four are the Social Security office and MAHEC, at 8 riders a day and 11: a federal benefits office and a safety-net clinic, 19 riders between them. Kenilworth and Beaverdam are smaller still, at 7 and 2, but the deck does not offer them for add-back.
Who in Asheville cannot drive
The coverage argument is about people with no alternative. Nobody can say who the 132 riders are, because ART's rider data is not public. The city-level picture is measurable, and it is the closest thing to an equity measure available today. In the Census Bureau's 2020 to 2024 estimates, 13.9 percent of Asheville renter households had no vehicle, against 1.8 percent of the households that owned their home. Of the city's households with no car, 87.7 percent were renters. Over the same years 1.3 percent of Asheville workers commuted by bus and 20.1 percent worked from home. Those are levels, not trends: this five-year estimate spans the pandemic and there is no pre-2020 figure here to compare it against.
None of that describes the riders at the seven destinations. It describes the population the bus exists for. Turning it into an impact finding needs ART's Title VI Program, which is Step 1 below.
5 · What other cities got when they tried this
Asheville is not first. The relevant question is not whether a frequency-first redesign is a good idea in principle, but what happened to ridership in the cities that ran one.
| City | What it did | Riders after |
|---|---|---|
| Knoxville | KAT Reimagined, launched 26 August 2024. The consultant cited an 18% gain here. | −4.1% on +22.8% service, first year after launch |
| Wilmington | Cost-neutral redesign, January 2025. Its plan protected coverage in writing, so the easier half of Asheville's trade. | −3.2% calendar; +2.8% fiscal |
| Winston-Salem | Approved unanimously, April 2026. Had already cut its three worst routes separately 15 months earlier, and bought microtransit as an explicit coverage substitute. | Too recent to measure |
| Roanoke | No redesign. Cited as cheaper per vehicle mile. | Costs within a cent of Asheville per rider |
Four cities are not a law, and none of them is Asheville. Read the rows as evidence that the promised gain is not automatic, not as a forecast. Knoxville and Wilmington are computed from the monthly federal file, and the window is the thing to check. Knoxville is given on the twelve months either side of its 26 August 2024 launch, which is what isolates the redesign: 2,730,918 riders on 199,562 revenue hours before, 2,619,353 on 245,060 after. On Knoxville's own July-to-June fiscal years the same data gives −4.0% on +19.9% service, and a second year of −4.5%; a launch-aligned second year cannot be computed yet, because the monthly file ends in June 2026, two months short. Do not pair a launch-aligned ridership change with a fiscal-year service figure: they are different windows, and 4.1% belongs with 22.8%, not with 19.9%. Wilmington's two figures are the same data on two windows, and both are given because the choice of window changes the sign; Wave's own staff have told their board ridership rose 8.6 percent, in a January 2026 board packet read here. The federal file does not reproduce that on any window tested. The Knoxville launch date comes from a research pass rather than a primary document read here.
And the van question, which comes up every time
Of 126 peer agencies that run both a fixed-route bus and a demand-response van service, the van costs more per trip than that agency's own bus in all 126. Los Angeles Metro's own board report puts Metro Micro at $42 a ride in September 2023 against a $20 to $25 target, and records operational changes cutting it to $29.06 by the second quarter of FY2024. Sacramento cancelled SmaRT Ride at over $47 a passenger.
The closest comparison is not in another state, it is in the same county. Buncombe County's Mountain Mobility files its own NTD return for the Asheville urbanized area, same year, same reporting standard. FY2024: $3,239,954 over 91,770 trips, $35.31 a trip at 1.94 riders per revenue hour, against ART's bus at $7.92 and 15.56. That is 4.5 to one against the van. Note also that ART reports no demand-response mode at all, in any year from 2015 to 2024, so a van tail is not an expansion of something the city already runs. It is a contract with the county or a service stood up from nothing.
Wilson, North Carolina is the cheapest general-public van service in the state at $11.17 a ride, still 41 percent more per rider than Asheville's buses already cost. Two things about that number. Wilson files as a Rural Reporter under "North Carolina Non-UZA," so it is not one of the 145 agencies in the band used everywhere else here, and its return carries no expense breakdown and no passenger miles. And it is cheap per hour ($53.73 against Asheville's $123.28) while still being dearer per trip. Small vehicles and low wages buy a cheap hour, not a cheap ride.
Vans do not replace a network. What they can do is serve a tail too thin for a bus, which is section 6.
6 · What is actually available, cheapest first
There is no single solution. There is a sequence, and it is ordered by price, which puts the biggest number last because it is a decision rather than a purchase.
STEP 0
Attach a number to the money
There is no published ridership target for ART. No cost-per-rider target, no productivity target. The new contract does raise the bar. The monthly on-time-performance goal goes to 80 percent from 72, so the old contract already had one. Three liquidated damages are genuinely new: buses departing early, on top of an existing damage for missed trips; complaints not responded to within 24 hours; and supervisors or dispatchers driving routes because there are not enough drivers. A fifth measure raises an existing damage for the appearance and cleanliness of ART facilities and stops. Four of those five are about reliability and the fifth is about condition. None of them says how many people ride. Increasing the budget of a system with no stated goal is an accounting decision, not a transit one. The measure to set one on already exists, is federal, is free, and is built from two numbers published every month: riders per revenue hour. Any target is checkable within about 90 days and any failure is visible inside a year.
$0A council resolution and a monthly line on the city website
STEP 1
Ask for the two documents that would settle the coverage fight
ART's Title VI Program. FTA requires direct and primary recipients to submit one every three years; a subrecipient files with its primary recipient instead. Asheville is a primary recipient, and a body can be more than one kind at once. The city told its council, in the March 2025 staff report authorizing the disbursement, that FTA money is "disbursed by the City of Asheville, as the Designated Recipient, to the regional transit agencies (Subrecipients), including Buncombe County, Haywood County and Henderson County," and the list is open: the same report's tables also name Mountain Projects, Madison County, the Council on Aging and Land of Sky Regional Council. The French Broad River MPO sets the formula for the 5307 urban transit share; the JARC and 5310 money is applied for each year instead. The circular's test for a primary recipient is exactly that: it extends federal assistance to a subrecipient, where a direct recipient passes none on. So the city submits its program to FTA, the bodies it funds submit theirs to the city on a schedule the city sets, and the city's program has to carry one item a direct recipient's would not, a description of how it monitors its subrecipients for Title VI compliance and a schedule of when their programs are due. The city says the document exists. Two city pages and ART's own policies page each tell readers to "see Asheville's entire Title VI program," and none of the three links it. What is posted is a Title VI policy statement, which carries the city's complaint procedure, and a complaint form: on the city pages in English, Spanish and Russian, on ART's page without the Russian complaint form. The service standards are not posted. Ask for the rest, but expect less than the argument needs. FTA Circular 4702.1B attaches its full Chapter IV set to a provider that either runs 50 or more fixed route vehicles in peak service and sits in an urbanized area of 200,000 or more, both halves holding, or has been placed in that category at the discretion of the Director of Civil Rights, in consultation with the FTA Administrator. Asheville's urbanized area is 285,776, so it clears the population half; ART runs 19 vehicles in peak service, so it does not clear the other, and that is the half that decides it. Nothing on the record says the discretion has been used here.
What falls away is that whole set, not the survey alone: the demographic maps and charts, the monitoring of service, the three written policies a provider above the threshold has to adopt, on major service change, disparate impact and disproportionate burden, the first two of which its board has to approve as well, and the service and fare equity analysis it runs before a major service change or any fare change. What remains is every general requirement the circular puts on all recipients, and on top of that the duty to set and submit system-wide service standards and policies, one of whose four required standards is service availability, which the circular describes as a general measure of the distribution of routes within a provider's own service area. That is the nearest thing to a written answer on coverage that ART has to produce.
One duty does not fall away with size. The circular says providers below the threshold are responsible for complying with the DOT Title VI regulations against disparate impact, and should review their policies and practices so that service and fare changes do not fall harder by race, color or national origin. A network redesign is that kind of change. What ART is not required to hold is a written disparate impact policy, because that is one of the threshold-only items.
Where the survey requirement does attach it is broader than a headcount, covering race, color, national origin, English proficiency, language spoken at home, household income and travel patterns, on a schedule of no less than every five years. A separate requirement adds fare usage by fare type, collected among minority and low-income riders so the provider can check whether a fare change lands unevenly. Because ART does not clear the threshold, it is not required to run the demographic rider survey the circular asks providers above it to repeat at least every five years. The second document to ask for is the route-level boardings per revenue hour, which would show which of the added hours carry anyone. The Choices Report publishes them once, on page 50, as a scatter plot that labels each route but prints no values, and its prose names only the best route, WE1, at almost 50 boardings per service hour. The other markers can be measured off the picture to about half a boarding an hour, but an estimate read off a chart is not the city's own figures. The city holds the counts behind those numbers stop by stop, not just route by route. Its resolution of 27 August 2024 describes the devices as counting “the number of passengers boarding and exiting at each stop.” That resolution approved buying automated passenger counters from Urban Transportation Associates without taking other bids. Twelve of the thirty-five buses were running counters that could only send data over Wi-Fi. The resolution put the cost of the equipment and services at $21,660, budgeted in the transit operations fund for the budget year that ended in June 2025.
$0Two records requests
STEP 2
Buy out the two smallest add-backs and take the vote
The deadlock is not about money. It is about 19 riders a day at the Social Security office and MAHEC, the two smallest of the four destinations the deck offers council for add-back. Adopt the redesign for what it actually does (reliability, transfers, job access) with the coverage objection bought out rather than argued down. Do it as an experiment and not a settlement: a fixed term, a published cost per ride, and boardings reported monthly against a number agreed in advance.
$53k to $168k a year0.33% to 1.05% of the transit budget
STEP 3
Apply to MEE-NC before spending local money on vans
NCDOT's Integrated Mobility Division has run a statewide microtransit program since late 2022, with a published implementation guide and eleven participating communities. Asheville, Buncombe County, Mountain Mobility and Land-of-Sky appear nowhere in its case study. McDowell County is in it. So is Wilmington's Wave Transit. Whether Asheville ever applied is a phone call.
Grant moneyPossibly nothing; possibly already closed
STEP 4
Look at the Winston-Salem route before any referendum
Winston-Salem funds its transit authority with a dedicated city property-tax slice, and raised it from 4.86 to 7.36 cents in FY2024-25, with no referendum and no act of the legislature. Winston-Salem budgeted $7,007,910 more from that slice than the year before, most of it from the 2.50-cent rise and the rest from growth in the tax base. The county quarter-cent is the harder road, and Part 6 of Article 43 of the North Carolina General Statutes sets several conditions on it rather than one. Part 6 is the version for counties outside the six big ones, which is why a quarter cent is the ceiling here and not a half, and the commissioners have to hold a public hearing at least thirty days before the vote. A county may not levy at all unless it, or a unit inside it, already operates a system, which Buncombe satisfies through Asheville. The Article requires a referendum, and Part 6 frames it as advisory: a majority yes lets the commissioners levy, it does not oblige them to. The split is per capita but not by county population. The county's share counts only the population that is not in an incorporated area, and each town's counts its own, or the part of it lying inside the county. The county's share also turns on the county operating or contracting for a system in its own right, not on Asheville doing so. Mountain Mobility is what puts Buncombe inside that test. A county or a town that neither operates nor contracts for a system drops out of the calculation until the first July more than thirty days after it starts. Contracting counts as operating, including a contract with a private firm, so a town buying service from ART or the county is in. Finally the statute does two separate things. It allows the money to be spent only on financing, building, running and maintaining transit. And it requires the proceeds to supplement and not supplant existing funds or other resources for public transportation, which is about the relationship between new money and old rather than about the spending category. Neither freezes the city's $8,429,293 transfer, and the statute names no transfer, no baseline year and no consequence. It is what New Hanover County tried in 2022 and lost, 47.1 to 52.9 percent.
A council voteWhether Asheville's structure permits it is a question for city finance
STEP 5
Decide the contract option years now, not in 2030
The base contract is $54,899,942 through year four. Four option years worth $65,417,313 have not been decided, which would take the all-in total to $120,317,255 and the final year to $17,440,670. They come as two renewals of two years each rather than four separate calls, so the first decision covers years five and six. Declining it returns the city to procurement in year five rather than year nine. The base years are less fixed than they look. Asked about it on 24 March, the city attorney told council the city always writes in a nonappropriation clause, and that his staff negotiates a termination provision as far as it can. The executed contract has both. If council does not fund it for any budget year, the city may end it without penalty on at least 30 days' written notice documenting the lack of funding (§519.B(3)). The city may also end it for its own convenience, in whole or in part, on 45 days' written notice, with the contractor's claims settled under 48 CFR Part 49 (§408). The option years are the biggest decision on this page, and the contract does not settle who makes it. It says an option is exercised "upon mutual agreement between the Parties" (§104.B(1)) and also that it is the city's "unilateral right" (§104.B(2)), that the parties are to negotiate adjustments to the option-year prices already set in its price proposal, and that any change to either side's obligations needs a written amendment approved by council (§525). Resolution 26-56 authorizes the city manager to execute the contract and to sign all documents necessary to effect it, and nothing in the packet says a renewal returns to council. No committee forwarded it either. A PEDE motion to do so failed for want of a second on 17 March, with two members present, and the contract itself then carried 4 to 3.
$65,417,313The decision window is open now
Step 0, what a target is worth. Against the FY2027 budget of $16,086,060 and FY2026's service:
Cost per rider implied by each productivity target, at the FY2027 adopted budget over FY2026 revenue hours. This is a budget divided by an actual, which is why today's figure reads $11.03 against the $7.92 actual for FY2024. Because the federal file is monthly, any target set here is checkable within about 90 days and any failure is visible inside a year. Knoxville's redesign was measurably failing in twelve months.
And the FY2027 budget is not a clean run rate. The city balances it with a one-time draw of $1,288,715 from fund balance, 8.0 percent of the transit fund. One-time is the budget book's own description, and it puts the draw down to increased expenses and decreased revenues. It is about twice what the first year of escalation costs, $637,745. One more line is worth watching. The parking fund transferred $951,892 to transit in FY2024 and nothing in FY2025, and the FY2027 budget counts on $950,000 from it again. Replacing money that may not recur is a different ask from paying for escalation, and only the second is priced here.
Step 2, the legal point that belongs with it.
One legal point belongs with it. Under 49 CFR 37.121, the obligation to run complementary paratransit attaches to operating a fixed route system at all. A companion rule, 49 CFR 37.131, sets the corridor at a minimum of three-quarters of a mile either side of every route, and adds a circle of the same radius at each end of it. Outside the built-up core a provider may draw it wider, up to a mile and a half. Inside the core, small pockets ringed by corridors stay covered even though no corridor reaches them. Asheville is not proposing to abolish fixed route, only to trim seven tails off it, so every surviving route keeps its paratransit corridor, and a van on a removed tail does not automatically stand in for it. Substitution is possible, but not by default: the city would have to put that service in its paratransit plan and certify that eligible riders can actually use it, that it runs as described, and that it will be coordinated.
That cuts both ways, and both belong in the decision. Cutting a tail shrinks the mandated corridor, though by less than it looks, because the end circle moves to the new end of the route rather than disappearing. It is a saving nobody has claimed and also a service reduction for a protected group, and it changes what Buncombe County carries, since the county files Asheville's ADA paratransit under its own agency. Against that, a van run as complementary paratransit takes on six sections of the regulation, 49 CFR 37.123 through 37.133, and they are not a short list. Beyond the service criteria below, they set an eligibility process with a written appeal, a twenty-one-day presumption if the provider does not decide in time, service to visitors from other places without a fresh certification, and door-to-door rather than stop-to-stop service. The entity has to schedule any eligible trip requested the previous day, at any requested time on that day. It may not require a rider to start a trip more than an hour before or after their desired departure time. It may not charge a rider more than twice the full fixed route fare for a trip of similar length at a similar time of day, and may not charge a personal care attendant at all. That cap does not bind an agency buying trips: the rule lets a provider charge a social service agency more than it may charge a rider, for trips guaranteed to that agency. It has to run the same hours and days as the fixed route. And it may not restrict or prioritize trips by purpose, cap the number of trips, or keep a waiting list. All three of those come back for standing bookings, which the rule calls subscription service and caps at half the trips available at any time of day. Nor may it fall into any operational pattern that significantly limits availability, a catch-all whose own examples are substantial numbers of significantly late pickups, of denied or missed trips, and of excessively long trips. Weather and traffic that nobody could have scheduled around do not count toward it. A plain cost per trip prices none of that. One caution the other way: the service criteria are not immovable. A provider carrying an undue financial burden can ask to be released from some of them. It is a request, not a decision: it runs through a public process first, the federal transit administrator rules on it case by case, and any relief granted runs for a set period.
Step 5, the fleet.
The fleet is worth a line here, because it is the one long-horizon cost that moves with this decision and because "the buses are old" gets said. Two comparable measures answer that differently. ART owned 35 buses in FY2024 and ran 19 of them in peak service, the same count the Title VI test above turns on. On average age the fleet sits in the middle: 7.51 years against a band median of 7.68. Of the 143 band agencies that report a bus fleet, 64 are younger. On the share of buses past their useful life benchmark it does not sit in the middle. That benchmark is the expected life of a bus, or the period it is acceptable to keep it in service. The transit agency either sets its own or takes the default FTA publishes, which for a bus is fourteen years. ART files three, at ten, twelve and fourteen years. Fourteen of the 35 had met or exceeded theirs, which is 40 percent of the fleet against a band median of 19 percent. And 113 of those 143 agencies carried a smaller share. Both readings hold because the ages are a barbell rather than a slope. Seven buses were a year old in FY2024 and fourteen were twelve years or older, so a recent order pulls the average down while the oldest group sits at the end of its life. The over-age count was five a year earlier; nine buses passed twelve years between the two filings. By September 2026 the city's own roster listed seven of the fourteen as out of service and seven new buses as in service. That left seven of the city's 30 buses in service past their benchmark. What matters for the option years is that any change of vehicle type, toward smaller buses on thin segments for instance, is a nine-year commitment if both option pairs are exercised and a five-year one if they are not. The full capital working is in section 9 →
7 · What is not a solution
- The redesign as a budget fix. The plan says so itself. The Draft Network Report tells readers: "Remember, this is cost-neutral, so if you want more service on your street, that must be paid for by cutting something else!" The alternative Growth Network, which uses 60 percent more resources, is labelled "not a proposal." So the redesign was never offered as a saving, and on the arithmetic it is not one: at the consultant's own +18 percent it cuts cost per rider 15.3 percent, and escalation takes all of that back in 4.0 years. Adopt it for reliability, transfers and job access if those are worth having.
- Replacing the network with vans. 126 out of 126, above.
- Fare-free, in either direction. Fare revenue was $601,698 in FY2024, the same dollars as in section 3: 4.7 percent of that year's actual cost, or 3.7 percent of the FY2027 adopted budget. Both are true and they are different ratios, which is this brief's own point turned on itself. And the money at stake is 37 cents a boarding, not the posted fare. Either way it is an access decision, not a cost decision.
- "Efficiency" without a denominator. The ruler the public argument is being conducted on is the only one of four where Asheville looks worse than its peers, and it looks worse mostly because the buses are slow.
8 · Three things nobody has established, and each decides the answer
- Whether the hours added since FY2019 carry anyone. Route-level boardings per revenue hour would settle it. The city has the data and has published it only as a chart, with one route's figure in words. Its buses count boardings and exits at each stop.
- What Asheville's riders actually need. There is no weighted survey, and as Step 1 shows, ART is not required to run one. Whatever the Title VI Program holds is the closest thing that exists, and it may hold nothing about riders at all. Filling this gap probably means commissioning a survey, not requesting a document.
- How long each of the seven detours takes. The city has priced them in lost frequency and never in minutes, which is the number a van comparison needs.
The whole decision space, in one line
Eighteen riders per revenue hour is reachable two ways, and they are the same target. Carry 23 percent more riders on today's buses, or carry today's riders on 18.8 percent less service. Today's riders on FY2019 hours come to just under 18 an hour (17.996).
They do not cost the same, and the gap is the whole argument. Growing to 18 lands at $8.96 a rider and assumes nothing about which costs are fixed. Shrinking to 18 lands at $8.96 only if every dollar falls with the hours, and at $10.11 if only the contract's hourly payments and the fuel do. That is at the contract's first-year prices, which a cut this deep may not keep, and whether anything else falls is not established.
And Asheville has published no target on either side of it.
9 · The capital side, in full
Step 5 above gives the fleet one paragraph, because the operating question is what that page is about. This section is the working behind The small print on the buses, which is the capital brief. Everything here is a federal or city record, and every derivation says which file it came from and what it assumes.
Updated 25 September 2026, revised 26 September 2026. Unless a passage says otherwise, the fleet figures below are from the city's 2024 federal filing. The city's own bus roster, released under a public records request on 24 September 2026, is newer. It lists 30 buses in service, and the five electric buses as out of service. Seven of the fourteen buses past their benchmark have left service and been marked surplus. Seven new buses went into service, three in November 2025 and four in September 2026. That leaves seven of the 30 past their benchmark. Nine are past the roster's own working life of twelve years. The city's replacement schedule lists five 35-foot hybrids due in January 2027. The capital brief carries the same update.
The fleet, every row as filed
NTD Revenue Vehicle Inventory, report year 2024, NTD ID 40005. Ten rows, 35 buses. The useful life benchmark is reported by the agency per group, which is why the Crosses column would change if every bus were measured against twelve years.
| RVI id | Built | What | Buses | ULB | Avg lifetime miles | Crosses |
|---|---|---|---|---|---|---|
| 380775 | 2010 | Gillig Low Floor, hybrid diesel, 29 ft | 5 | 12 | 570,590 | 2022 |
| 380776 | 2012 | Gillig Low Floor, hybrid diesel, 29 ft | 2 | 12 | 553,019 | 2024 |
| 380779 | 2012 | Gillig Low Floor, diesel, 29 ft | 7 | 12 | 558,186 | 2024 |
| 384270 | 2014 | Gillig, diesel, 29 ft | 2 | 14 | 494,638 | 2028 |
| 380780 | 2018 | Proterra Catalyst, electric battery, 35 ft | 5 | 12 | 139,911 | 2030 |
| 382587 | 2019 | Gillig, diesel, 30 ft | 2 | 10 | 266,810 | 2029 |
| 392805 | 2020 | Gillig Low Floor, diesel, 30 ft | 3 | 10 | 219,171 | 2030 |
| 392806 | 2021 | Gillig Low Floor, diesel, 30 ft | 2 | 10 | 156,484 | 2031 |
| 403486 | 2023 | Gillig 30' Low Floor, diesel | 3 | 10 | 64,228 | 2033 |
| 411858 | 2023 | Gillig Low Floor, diesel, 30 ft | 4 | 12 | 126,009 | 2035 |
The two 2023 purchases do not share a benchmark. Three buses carry ten years and four carry twelve, so they cross two years apart. Every bus is owned outright by the public agency on Urbanized Area Formula money. Only the Proterra batteries are leased, and that lease is a separate contract.
Buses past their own benchmark, year by year
Cumulative, of 35 owned. Each group is measured against its own reported ULB and the series assumes no retirements, no rebuilds and no replacements. It is arithmetic from the fleet record, not a city forecast. Nine buses crossed in 2024 alone and eight cross together in 2030, because the buses were bought in lumps rather than evenly.
The band comparison, and the denominator that decides it
Re-derived live on 25 August 2026 from NTD Vehicles (Type Count by Agency),
nimp-626k, report year 2024. The band is the committed 145-agency file at
_docs/research/transit/ntd-analysis-peer-band-bus.csv.
Both published figures reproduce, and all four rows below were recomputed
independently from the same file on 26 August 2026 and reproduce to four decimal places.
NTD splits buses into three columns, and the whole answer turns on which two
you divide. Bus is every bus owned; Bus with ULB Reported is
those that filed a benchmark; Bus at or over ULB is those at or past it. Their
names in the file are bus, busrptulb and bus_ulb, given
once here so a re-derivation can find them, and written out in English everywhere else.
| Denominator | Band median | Smaller share |
|---|---|---|
| Bus at or over ULB, over Bus with ULB Reported — the one used | 18.97% | 113 |
| Bus at or over ULB, over every bus owned | 18.97% | 114 |
| adding articulated buses to both sides | 18.03% | 114 |
| articulated buses, on reported-ULB denominators | 18.03% | 113 |
Basis. The numerator counts only vehicles that report a benchmark. NTD's own definition of the column says so: "Only vehicles with a reported Useful Life Benchmark are counted in this subset." So the denominator has to be the numerator's own population, the buses that filed a benchmark, and the comparison must be bus against bus. Asheville owns no articulated buses, and it reports 35 buses of which all 35 filed a benchmark, so its own 40.0 percent is identical on all four bases. Only the band moves.
Margin. The median is 18.9655 percent, which rounds to 19. The 113 holds under a strict comparison and under rounding to whole percents. Windham Region Transit District sits at exactly 40.00 percent, which is why the count is sensitive to how the tie is treated. Excluding Asheville from the band moves the median to 18.50 percent, still 19 rounded.
⛔ Recorded because it nearly went the other way. An
independent recomputation on 25 August 2026 used a bus + articulated_bus denominator,
got 18.03 percent and 114, and reported the page as wrong. It was not. The two
results count different populations, which is the failure this site's own rule names: check what a
number COUNTS, not what it says. Any future re-derivation of these two figures must state its
denominator before comparing.
Settled 25 August 2026: the average-age comparison, and it was right
The claim gate could not check 7.68 and 64 of 143 on its first pass. The 10.1 MB Revenue Vehicle Inventory text extract will not parse, because its cells carry embedded newlines. Three reassembly attempts recovered 2, 6 and 2 Asheville rows against a ground truth of 10. That was a finding about the instrument, not the figure.
Settled from a better one: NTD Vehicles (Age Distribution), 6abt-uhgq, report
year 2024, field average_age_of_fleet_in_years, Bus rows, same 143-agency band.
The band median is 7.6800 and 64 agencies are strictly
younger than Asheville's 7.51, which is the published value rather than a
computed one. Bus rows are the right basis, because 7.51 is itself a Bus
row. Folding articulated buses into the band keeps the median at 7.68 and moves the count
to 66. That variant compares a different population against Asheville, which is the same trap as
the benchmark denominator above.
And the two federal files agree bar for bar. Every bucket in the age distribution maps onto a row of the vehicle inventory above, with nothing left over either way.
| Age in 2024 | 1 | 3 | 4 | 5 | 6 | 10 | 12 | 13–15 |
|---|---|---|---|---|---|---|---|---|
| Buses | 7 | 2 | 3 | 2 | 5 | 2 | 9 | 5 |
| Built | 2023 | 2021 | 2020 | 2019 | 2018 | 2014 | 2012 | 2010 |
The buckets sum to 35. The last two columns are the ones past their benchmark, and 9 + 5 = the fourteen.
The spare ratio, and its arithmetic
| Reporting year | Peak | Available | Spare | Ratio |
|---|---|---|---|---|
| 2018 | 17 | 22 | 5 | 29.4% |
| 2019 | 17 | 27 | 10 | 58.8% |
| 2020 | 19 | 29 | 10 | 52.6% |
| 2021 | 19 | 31 | 12 | 63.2% |
| 2022 | 19 | 31 | 12 | 63.2% |
| 2023 | 19 | 33 | 14 | 73.7% |
| 2024 | 19 | 35 | 16 | 84.2% |
Ratio is spare divided by peak. FTA prints the 2022, 2023 and 2024 figures; the earlier four are the same arithmetic on the same two published counts. The series is not monotonic, so it must not be described as climbing every year: it falls between 2019 and 2020 and is flat between 2021 and 2022. Band comparison, same measure: median 45.6 percent, and 127 of the 145 sit below Asheville.
The capital plan, three adopted budgets
Same program, same Fleet & Equipment section, same line name, read from three cached budget extracts.
| Adopted budget | Covers | Transit Bus Replacement, by year | Five-year total |
|---|---|---|---|
| FY 2021-22 | FY2022–FY2026 | 1,000,000 · 4,496,000 · 4,563,000 · 4,631,000 · 4,862,550 | $19,552,550 |
| FY 2025-26 | FY2026–FY2030 | 1,238,000 · 1,288,000 · 1,339,520 · 1,393,101 · 1,448,825 | $6,707,446 |
| FY 2026-27 | FY2027–FY2031 | 1,238,000 · 1,288,000 · 1,339,520 · 1,393,101 · 1,448,820 | $6,707,441 |
The newest five-year total is 34.3 percent of the oldest, a 66 percent reduction. On out-year run rate, the FY2023–FY2026 average of $4,638,138 against the FY2027–FY2031 average of $1,341,488 is 71 percent lower.
The sharpest line in the three books. Both the FY 2025-26 and FY 2026-27 editions carry an identical $1,238,000. The older says it "will provide for the purchase of two diesel buses"; the newer says "one diesel bus." Neither book says why, and neither does the brief.
Who pays for a bus
Asheville does not buy buses on its own, and the dedicated federal bus program is the smallest part of it. This section moved here from the brief on 25 August 2026, because it is the answer to a question most readers will not ask and every transit-literate reader will.
| When | What | Amount | Source |
|---|---|---|---|
| 2018 | Federal grant funds through the French Broad River MPO, to buy transit buses | $5,700,000 | City release, 27 Aug 2019 |
| 2018 | City match against that grant. The city called the two together a $7.1m budget for bus procurement, to be spent over three years | $1,400,000 | same |
| Aug 2022 | FTA Low and No Emission award: six hybrid replacement buses and three replacement batteries, to replace hybrids running since 2010 | $4,200,000 | City release, 16 Aug 2022 |
| Feb 2024 | Share of a $1.9m purchase of three clean diesel Gilligs still drawn from the 2018 grant, against $922,540 of city money | $974,066 | Staff report, 27 Feb 2024 |
| 2026 | Section 5339, Buses and Bus Facilities: the dedicated federal bus program, for the whole urbanized area, for the year | $371,372 | FTA FY2026 apportionment |
Council authorized seven buses in August 2019 and three more in December 2021. The December 2021 purchase drew on the 2018 MPO money together with Section 5339, with the twenty percent local share already programmed in the capital plan. Section 5339 is about 30 percent of what the city's own plan budgets for a single bus. Every large purchase in the last eight years came from somewhere else.
| Capital expended, reporting year 2024 | Amount |
|---|---|
| Federal | $663,910 |
| City | $550,436 |
| State | $0 |
| Total, all of it on passenger vehicles | $1,214,346 |
None of it went to buildings, stations, fare equipment or expanding service. No cause is given here for the February 2024 split. The December 2021 purchase ran at the ordinary eighty/twenty and February 2024 ran at roughly half and half. The obvious reading is that the 2018 grant was nearly exhausted, and nothing on hand establishes it.
The five electric buses, the full record
In May 2019 the city announced that five all-new electric buses would go into service on ART routes on June 1. They are 2018 Proterra Catalyst buses, 35 feet long, and every other bus in the fleet is 29 or 30 feet. They were bought with federal Urbanized Area Formula money and the city owns them outright. Only the batteries are leased.
| Reporting year | Miles on battery | Share of all bus miles | Miles per kWh |
|---|---|---|---|
| 2022 | 163,344 | 12.9% | 0.40 |
| 2023 | 151,386 | 11.4% | 0.40 |
| 2024 | 42,210 | 3.2% | 0.18 |
NTD Fuel and Energy, 8ehq-7his. Battery miles fell 72
percent in a single year and efficiency more than halved at the same time. The buses
used 236,149 kilowatt hours to cover 42,210 miles, which is what the numbers look like when a
vehicle is drawing power but barely moving.
The vehicle record makes the same point a second way. By the 2024 filing, the five had averaged 139,911 miles each since they were built. Two Gillig diesels bought a year later had averaged 266,810.
Where they are now
By January 2026 all five had stopped. A city spokesperson told Asheville Watchdog they "are currently not running due to several factors, primarily the inability to procure parts," and that staff were working with the City Attorney's office on their eventual disposition. The City Attorney said his office had spent months trying to terminate the leases attached to the buses. One had been settled early and a second was in negotiation. In February 2026 the maintenance director at RATP Dev, which runs ART for the city, took the date of each bus's last repair as its last day on the road. The earliest was 20 February 2024 and the latest 28 April 2025.
The city's own contract register still carried the Proterra battery
lease, contract 91900342, with a revised value of $1,203,735, when
it was last updated on 7 August 2026. The city has said it will not buy more electric buses from
any manufacturer until range, reliability and cost meet what ART needs.
What is NOT established, and must not be inferred
- The plan's per-bus price. The FY2027 line implies $1,238,000 for one bus against $632,202 a bus actually paid in February 2024 and $566,180 in February 2023. The gap could be price, specification, contingency or a reserved local match. Nothing on hand decides it, so no unit price is drawn from the budget anywhere.
- Whether the six Low-No hybrid buses were delivered. FTA awarded the city $4.2m in August 2022 for six hybrid replacements and three replacement batteries, to replace hybrids "on the road since 2010". Those 2010 hybrids are still in the report-year-2024 inventory. The city's September 2026 roster lists all five as out of service and marked surplus. The same roster lists five 35-foot hybrids with no status, and the city's replacement schedule shows five 35-foot hybrids ordered in FY2026 and due in January 2027. Neither says whether those are the Low-No buses. It bears on the crossing schedule, which states its own assumption.
- The February 2024 funding split has no stated cause. The December 2021 purchase ran at the ordinary eighty/twenty and February 2024 ran at roughly half and half. The obvious reading is that the 2018 grant was nearly exhausted. The staff report, released under a public records request, gives the split: $974,066 of "previously received 2018 federal grant funding", and $922,540 for "the federally-required local match and the remaining funding needed to purchase the buses". Both splits are stated and neither is explained.
- What "about four buses a year" assumes. The figure is from the staff report for the 27 February 2024 Council meeting, released under a public records request. Staff wrote that "it is necessary to replace approximately four buses annually (at current service level)." The report does not define "current service level" in buses or hours.
- No comparison is made between the 2018 electric bus price and the FY2027 diesel budget. Different propulsion, different inclusions, eight years apart, and one is a debt-funded project budget.
Sources. Cost, ridership, service and peer figures: National Transit
Database, Time Series 2.1 (npsm-38gk) and Complete Monthly Ridership
(8bui-9xvu), FY2024 annual release and monthly data through June 2026. Peer band:
145 US fixed-route bus systems in urbanized areas of 150,000 to 500,000 with at least 150,000
annual trips; the passenger-mile median is over the 115 that report passenger miles. Budget
figures: City of Asheville adopted budget books. Contract figures and the seven destinations:
City of Asheville council documents, 24 March and 28 July 2026, including the adopted minutes of
the 24 March meeting (Resolution No. 26-56, carried 4 to 3), which are also the source for the
city attorney's account of the nonappropriation clause. The executed RATP Dev contract, released to us on 18 September 2026 under PRR-2026-889, is the source for the clause itself and for every contract term quoted here; it was not an attachment to the March packet. Two figures in the city's own record
disagree by $2: $120,317,257 on the presentation's offeror-score slide and in the minutes' account of it, and $120,317,255 in the staff report's tables and elsewhere in the presentation and minutes. The page uses $120,317,255, the sum of the whole-dollar yearly amounts; the contract's Attachment C gives the eight years to the cent, and they sum to $120,317,256.81. Fuel and lubricants per revenue hour, FY2024: NTD operating expense by object class for ART's bus mode, $834,574, over NTD FY2024 vehicle revenue hours, 103,285. Van costs: NTD demand-response
filings for Wilson (NC) and Buncombe County, plus board reports from LA Metro and Sacramento
Regional Transit. The pulled agenda item: 828newsNOW, 18 August 2026, reporting the redesign
removed from the council's 25 August agenda, and Asheville Watchdog, 22 August 2026, reporting
the vote delayed indefinitely. Fleet: NTD FY2024 Vehicles (Age Distribution)
(6abt-uhgq), which is the source of the 35-bus count, the 7.51-year average age
and the age distribution, and which reports 19 vehicles operated in maximum service on the
same record. That is the peak-service count used above, and it matches Time Series 2.1.
Buses at or past their useful life benchmark, for ART and for the 143 band agencies that
report a bus fleet: NTD FY2024 vehicle type count by agency (nimp-626k), fields
Bus, Bus with ULB Reported and Bus >= ULB. The benchmark itself is defined at 49 CFR 625.5.
Operating expense by function: the same Time Series 2.1 resource,
which reports vehicle operations, vehicle maintenance, facility maintenance and general
administration separately. Title VI thresholds: FTA Circular 4702.1B, Chapter IV; the board-approval item at Chapter IV, Contents of the Title VI Program (e); the four recipient roles at chapter I and Appendix L; the eleven-box
Chapter III filing list is Appendix A of the same circular. What is published of ART's Title VI
Program: the City of Asheville's
transit complaint page
and general bus policies page,
and ART's own policies and tips page,
each fetched 27 August 2026, with the policy statement read from its Google Docs plain-text
export rather than its editor view. The automated passenger counters, the quoted description of what
they measure, the twelve of thirty-five buses on Wi-Fi-only hardware, the sole-source basis at
N.C.G.S. 143-129(e)(6) and the $21,660 FY2025 cost: City of Asheville Resolution No. 24-198, adopted
27 August 2024, Resolution Book No. 45 page 165, read from the minutes of that meeting.
Asheville's designated-recipient status: the city's staff
report for the 11 March 2025 council meeting, which authorized the disbursement and names
Buncombe, Haywood and Henderson counties as subrecipients on a French Broad River MPO formula,
and the MPO's own Fall 2021 JARC call for projects, which states it independently. The
primary-recipient monitoring item is Appendix A of FTA Circular 4702.1B. Complementary paratransit: 49 CFR 37.121 through 37.139, read directly, including the subscription-service carve-out at 37.133, the agency-fare provision at 37.131(c)(4), the capacity-constraint qualifiers at 37.131(f)(3), the substitution certifications at 37.139(h)(4), and the undue-burden waiver process at 37.151 to 37.155. FTA Circular 4710.1, the ADA guidance that sits above the regulation, is not held here. Article 43 Part 6's applicability gate and its 30-day public hearing: N.C.G.S. 105-511 and 105-511.2(a); the definition of a public transportation system, amended in 2025, is 105-506.1(3). The 200,000-population
line between a designated recipient and the Governor is FTA's Section 5307 program page. The county
sales-tax route: North Carolina General Statutes Chapter 105, Article 43, Part 6, read
directly. Mountain Mobility and Wilson: their own FY2024 NTD returns (Buncombe County
NTD 40224; City of Wilson NTD 44931, a Rural Reporter). The FY2018-to-FY2019 reporting change:
NTD's own type-of-service field, which flips from directly operated to purchased transportation
in FY2019. The plan's cost-neutral language and the Growth Network: ART's Draft Network Report,
quoted directly.
Household vehicle access and commute mode: U.S. Census Bureau, American Community Survey
five-year estimates, 2020 to 2024, tables B25044, B08201 and B08301, Asheville city.
What is not first-hand here. Two items come from a delegated research pass rather than a primary document read for this brief, and each is marked in the text: Knoxville's August 2024 launch date, and New Hanover County's 2022 referendum result. Three more were listed here until 25 August 2026 and have since been read against cached primaries: Winston-Salem's property-tax figures against that city's FY2024–25 adopted budget, Wave Transit's 8.6 percent against a Cape Fear Public Transportation Authority board packet, and 49 CFR 37.121 and 37.131 against the eCFR text. The arithmetic in this brief does not rest on any of them.
Found an error? Tell us and we will correct it. The framing and conclusions here are our own.