Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report (2012)

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Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 27 CHAPTER 2 Findings INTRODUCTION This chapter summarizes the findings gathered from various tribes throughout this study. In the first phase of this study, a short-form survey questionnaire was sent to 95 tribes of the 565 federally recognized tribes and 67 completed responses were received, for a response rate of 71 percent. Only two tribes explicitly stated that they would not participate in the study. Table 2-1 lists the tribes which participated in the Phase 1 data collection. METHODOLOGY The questionnaire was distributed to a variety of tribes that provide a wide range of transit services in diverse geographical locations. As the number of tribes in the western portion of the country is greater than those in the east, the majority of respondent tribes are located west of the Mississippi River. Size of tribes (both number of people and amount of land), connection with adjacent communities and counties, and the rural nature of reservation location all vary widely between tribes and have an impact on the types of transit service provided. From the responses, most tribes that operate transit provide a com- bination of demand-response, deviated fixed-route, and fixed-route service. However, the single most common service type is demand- response service. The goal of the first round of data collection was to determine generally the range and scope of transit services provided by tribes across the country. Additionally, the first round of data collection allowed the tribes to become familiar with the study itself and the personnel collecting the information. From the data collection effort, the level of participation a tribe was willing to contribute in Phase 2 was surmised. The first step in the data collection process was to determine the correct person with whom to speak regarding transit service at each tribe. Some contacts were already established due to previous work with members of the research team. Most, however, needed to be deter- mined through phone calls and e-mails to the tribes and Federal Transit Administration (FTA) regional tribal liaisons. For some tribes, it took nearly two months to find the appropriate contact.

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Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 29 Once the appropriate contact was determined, phone conversations with descriptions of the project and a request for participation ensued. Many tribes described their programs or attempts to start a program over the phone and also completed the survey questionnaire. Questionnaires and cover letters were distributed via e-mail unless requested in hard copy format. As noted in the cover letter, surveys could be completed electronically via a Microsoft Excel file attached to an e-mail or online on the study data collection website. Surveys could also be completed by hand and mailed or faxed. Tribes were given two weeks in which to respond to the survey. Then there were follow-up phone calls and e-mails periodically through the end of the data collection period. As noted, in the end, 71 percent of the tribes that were contacted responded to the survey. The high response rate underlines the interest the tribes maintain in transit service, both currently and in the future. This rate also reflects the extensive personal contact and follow-up by the research team. The Phase 2 long-form questionnaire was then distributed to 54 tribes who had previously answered the short-form questionnaire. These 54 tribes were chosen based on an assessment of their willingness to participate in Phase 2 and their responses to the Phase 1 short-form survey. In Phase 2, the tribes were asked more detailed information about the challenges and successes of their transit program. Of the 54 tribes contacted, 48 responses were received, for a response rate of 89 percent. Table 2-2 lists the tribes that responded in Phase 2. In this phase, tribes were asked to respond using the electronic question- naire. However, many tribes were contacted by telephone and the data collection was completed through a telephone interview. After detailed information was collected through the longer question- naire, some tribes were visited to gain an in-depth understanding of their transit programs or the barriers that have kept them from developing a successful transit program. The tribes that were inter- viewed in depth are shown in Table 2-3.

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Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 31 Table 2-3 Tribes That Were Visited Tribe State Eastern Band of Cherokee Indians NC Coeur d'Alene Tribe ID The Confederated Tribes of Grand Ronde OR Lac du Flambeau Indian Tribe WI Menominee Indian Tribe WI Navajo Nation AZ/NM/UT Oglala Sioux Tribe SD Confederated Salish and Kootenai Tribes MT Seneca Indian Tribe NY Sitka Tribe of Alaska AK Southern Ute Indian Tribe CO Standing Rock Sioux Tribe ND/SD Stillaguamish Tribe of Indians WA Turtle Mountain Band of Chippewa Indians ND Yakama Indian Nation WA Source: Tribal Transit Program Survey, 2010. TRIBAL CHARACTERISTICS Characteristics of the tribes that provided data are summarized in this section. The data collection was not meant to be a comprehensive inventory of tribal transit programs, but rather to determine the diversity of tribal transit systems and the characteristics of those transit systems. The focus was to examine a broad cross section of representative tribes throughout the country. Geographic Characteristics Figure 2-1 shows the distribution by state of the tribes which responded to the Phase 1 questionnaire. Tribes participating in the Phase 2 survey are shown in Figure 2-2. Participating tribes are distributed throughout the country, although the majority are in the midwestern and western states reflecting the higher number of tribes located in these states. The participating tribes represent small reservations, large reservations, and tribes not located on reservation lands.

Findings Chapter 2 Page 32 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Figure 2-1 Locations of Tribes Participating in Phase 1 Survey

Chapter 2    Findings    Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report  Page 33    The  Navajo  Nation  is  the  largest  reservation  in  the  United  States,  covering  approximately  25,000  square  miles  in  northeast  Arizona,  northwest New Mexico, and southeast Utah. Several tribes have large  service  areas  including  Choctaw  Nation,  Chickasaw  Nation,  and  Cherokee Nation  in Oklahoma although  these  tribes are not  located  on  reservations.  In addition  to  large  land areas,  tribal  lands  tend  to  have  fewer  residents  and  lower  population  densities.  The  Navajo  Nation  has  one  of  the  most  populated  reservations  with  175,000  people living within the reservation boundaries, but has a population  density  of  only  seven persons per  square mile. While  not  all  reser‐ vations  exhibit  these  characteristics,  many  have  low  population  densities.  Low  population  densities  create  challenges  for  operating  transit service and tend to make transit routes less efficient.   Figure 2-2 Locations of Tribes Participating in Phase 2 Survey

Findings Chapter 2 Page 34 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Many of the tribes must cover long distances to serve tribal members. The Navajo Nation operates long-distance services, including a four- hour route from Tuba City to Window Rock. Even if low population density is not an issue, many reservations are physically isolated from urban or regional centers where basic services are located. The Choctaw Nation serves 11,000 square miles over a 10½-county area (Choctaw, Bryan, McCurtain, Pushmataha, Pittsburg, Atoka, Laflore, Hughes, Coal, Latimer, and Haskell) in southeast Oklahoma. Johnny James, the Director of Choctaw Transit, elaborates on the large geographic area they serve, “Most of these areas are rural and many of our clients live on dirt roads.” In addition to the huge service area, they operate many long-distance trips to Oklahoma City and Tulsa, Oklahoma; Dallas, Texas; and Fort Smith, Arkansas. Since the local hospital does not provide dialysis, chemotherapy, or radiation ser- vices, Choctaw Transit provides long-distance trips for those services outside the Choctaw Nation boundaries. Some tribes have geographic constraints or physical barriers such as mountainous terrain or lakes, requiring longer travel distances for access to basic services such as medical, employment, and grocery shopping. The Seneca Nation has geographical challenges because there are two separate territories that need to be served, located approximately 35 miles apart. Red Lake Transit service is operated around a large lake. The straight-line distance is 11 miles, but due to the lake, the driving distance is 35 miles. Demographic Many tribes have high poverty and unemployment rates. The Pine Ridge Indian Reservation is one of the most impoverished reserva- tions, with unemployment as high as 85 percent and, according to the US Census, has approximately 61 percent of residents living below the federal poverty level. Standing Rock Transportation, of the Standing Rock Sioux Tribe, provides transit service to the poorest counties in North Dakota and South Dakota. Carson County in North Dakota is the second poorest county in the country. There are high poverty rates and little access to services or employment oppor- tunities. Looking at the recent 2007-2009 American Community Survey 3-Year Estimate, the poverty rate for American Indian and Alaska Natives is 26 percent, nearly twice the national average of 14 percent. The nation- wide unemployment rate for American Indian and Alaska Natives is about 14 percent, well above the national rate of approximately nine

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 35 percent. Prior to the recession in 2007-2008, the unemployment rate for American Indian and Alaska Natives has historically been around eight percent, well above the national average. These high rates demonstrate the need for transportation on tribal lands. Political This is not a characteristic unique to tribes, but is seen very often in rural areas around the nation. Many times, political leaders are not aware of the transportation needs in the community and do not have the expertise to go about providing such a service. Transportation needs often come to light as tribal departments that already provide transportation services for a certain market segment or trip purpose become aware of grants that may fill gaps in service and later realize that the need for transportation in the community is much greater than can be provided by the current service. This was seen in the Confederated Salish and Kootenai Tribes (CSKT) when the need for transit was initiated by the CSKT Department of Human Resource Development (DHRD). The DHRD began transportation in 1999 by accessing Temporary Assistance for Needy Families (TANF) funds to purchase two vans. It was then they realized that the need for trans- portation was much larger than what they were serving for TANF clients. According to DHRD statistics, in 2006, a total of 14,000 pas- senger-trips were provided. In 2009, the ridership had more than doubled to approximately 30,000 passenger-trips. Some tribes experience a high turnover of tribal councils and senior level staff. In some cases, the entire tribal council is up for election every two years. Transit staff have experienced a complete change in policy for transit services, either increasing the level of support or losing support for the transit program. This may result in a lack of continuity, diffuses momentum built for providing transit services, and the departing staff take with them valuable knowledge and experience. This is extremely difficult for a transit program that is just starting up or is being modified to better meet the needs of the com- munity. In addition to the routine staff responsibilities, the new staff are faced with understanding the background and learning what strategies have worked and those that have not worked in the past. The Crow Tribe in Montana experienced difficulty is starting a transit program because of changes in tribal council and key staff. Some tribes face resistance to starting a public transit program from another department within the tribe. This may occur when an existing transportation program is asked to coordinate services or share resources. The existing transportation program may have vehicles

Findings Chapter 2 Page 36 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report that are used for transportation of their clients and are often reluctant to share resources for fear that their clients will not get the services they need when they need them. Legal Understanding tribal transit program operations requires familiarity with the nature and scope of tribal sovereignty. Tribal sovereignty is the inherent power of a tribe to create its own laws and to apply those laws to the people, property and activities within the tribe’s jurisdiction. The U.S. Constitution does not define specific parameters for the relationship between tribes and the federal government. Supreme Court decisions have interpreted Art. 1, Sec. 8, Cl. 3 of the U.S. Constitution (aka, the Indian Commerce Clause) delegated plenary power over Indian affairs to the Congress to the exclusion of states. The Indian Commerce Clause states: “The Congress shall have Power…to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes.” The resulting legal framework allows for the Congress to adopt laws that impact tribes individually and collectively. States may not subject tribes to state law unless Congress adopts a specific law allowing a state such authority. Today, tribes possess sovereignty subject to the limitations of Congress and decisions of the Supreme Court of the United States. Those limitations make up the body of Federal Indian Law and Policy. Federal Indian Law and Policy is not comprehensive and often leaves tribes, states and the federal government in positions of complying with existing law and policy while trying to negotiate agreements to manage the voids in that law and policy. Federal Indian Law and Policy has been subject to radical shifts resulting from changes in political and social perspectives on the role of tribes in the United States. Those perspectives ranged to and from annihilation to tribal self determination. In 1969, Congressional policy shifted away from unilateral federal control and administration of tribal governance to a policy supporting tribal self governance. The new policies governing federal activities impacting tribal lands began to require tribal consent and recognized the continuing vitality of tribal sovereignty. The U.S. Supreme Court experienced shifts in its decisions in cases challenging jurisdiction over people and activities on tribal lands. While Congressional shifts turned towards tribal self-governance,

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 37 Supreme Court case precedent shifted towards expansion of state authorities and limitation of tribal authorities over non-Indian activities on tribal lands. A case that underscores the complex legal environment that tribes face in administering public transit agencies is Strate v. A-1 Contractors, 520 U.S. 438 (1997)). The Supreme Court found that the Three Affiliated Tribes of the Fort Berthold Reservation lacked civil adjudicatory jurisdiction over a personal injury dispute between two non-Indian parties to an automobile crash that occurred on a state right-of-way running through the reservation. Prior to Strate, the primarily used definition of Indian Country included right-of-ways running through tribal lands which were generally subject to tribal jurisdiction. The Court in Strate ruled that, absent congressional legislation, Indian tribes are presumed to lack civil jurisdiction over the conduct of non- Indians on non-Indian owned land within a reservation, subject to two exceptions: (1) non-members who enter consensual relationships with the tribe or its members; (2) non-members whose activity directly affects the tribe’s political integrity, economic security, health, or welfare. This decision has resulted in questions and concern over just who is subject to tribal jurisdiction within the boundaries of an Indian reservation. With this jurisdictional backdrop, the Executive Branch has adopted federal policy that encourages its agencies to consult with tribal governments in an effort to communicate about projects and policies that may impact tribal communities. This effort is viewed as action that supports tribal self governance. Through the Federal Transit Administration tribes can compete for grants for planning and administration of transit programs that serves tribal lands and surrounding non-tribal jurisdictions. A sustainable tribal transit program entails inviting non-tribal members to pay fares and use their services. The payment of the fare results in a contractual relationship between the tribe and the non-tribal transit patron. Tribes must also enter into various contractual relationships with non-Indian entities to purchase buses and vans, fuel, insurance, construction, other products, and services required to operate the transit program. These contractual relationships would be subject to tribal jurisdiction should a dispute arise pursuant to the reasoning in Strate. In addition to tribal civil jurisdiction, a non-Indian tribal transit patron may also be subject to federal criminal jurisdiction. Title 18,

Findings Chapter 2 Page 38 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Section 1160 of the United States Code (18 USC 1160) provides tribes with a federal claim against non-Indians who damage tribal property, including property of a tribal transit authority. Simply stated, patrons would be overwhelmed by the number of jurisdictions that they have submitted themselves in purchasing a ticket to ride a tribal transit bus within the boundaries of reservation. While tribes are government agencies capable of operating public transit authorities, the legal climate under which they do so is vastly different from other non-tribal entities. Tribes, like their state and local government counterparts, seek to assert sovereign immunity from suit and manage their financial risk very closely. (See Transit Cooperative Research Program Legal Research Digest 24; Transit Bus Stops: Ownership, Liability, and Access (2008) for a detailed discus- sion of transit agency assertion and waiver of sovereign immunity.) These differences must be recognized and incorporated into the business operation plan for each tribal transit agency. Another layer of jurisdictional concern for tribal transit agencies is the contract or grant award and the legal authority governing its provisions. A state may as a condition of awarding public transit funds to a tribe require a specific waiver of tribal sovereign immunity and require consent to suit in state courts. Several tribes have been unwilling to execute such waivers and decline federal transit funds passed through state agencies that are subject to such requirements. Alternative dispute resolution can be incorporated in the contract or grant award and may be structured in a manner respectful of each sovereign’s forums. Tribal governments have been cautious in safeguarding their sovereign immunity from suit; however, administering a transit program creates the risk of liabilities to the public, transit agency employees, to the contractual relationships with funding agencies and to vendors. As tribes continue to engage the public, there is a greater need for fundamental fairness to their patrons. Tribes can provide limited waivers of sovereign immunity designed to protect and assert tribal sovereignty while addressing the need for responsibility for any harm resulting from that activity. Though tribes are reluctant to submit themselves to the jurisdiction of a foreign court (state or federal), these same entities are reluctant to submit their agencies to tribal court jurisdiction for the resolution of disputes. Congress has passed several laws that require tribes to obtain transit funding by application to state agencies without

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 39 addressing the need for effective dispute resolution between those separate sovereigns. In the absence of clear Congressional directives in this area, tribes, states, and local agencies must negotiate terms for transit funding agreements. Economic Many tribes initiate transit services because of the need for transporta- tion to support tribal members’ daily activities—grocery shopping, employment, and other important needs such as doctors’ appoint- ments—that thereby enhance the economic well-being of the com- munity. On the Pine Ridge Reservation, very few people actually own a vehicle in this impoverished area. The Oglala Transit system was therefore planned to boost the economy and give people a way to get to work and around the community. Emma Featherman-Sam, the Transit Coordinator of Oglala Sioux Transit, says that, “Personal vehicles are a luxury for many residents living on the Pine Ridge Reservation. Some people buy a cheap used car, but when the car breaks down and there is no money for repairs, they are again without a car.” The Cherokee Nation transit program is a service that is provided to tribal members and the general public through contractual agree- ments with existing public transit systems such as KATS Transit and Pelivan Transit. The partnership between the two transit systems and the Cherokee Nation began a few years ago as a response to sky- rocketing gas prices and economic factors that made it hard for some tribal employees to afford their daily work commutes. The strategy of the Tribe was to assist people with transportation in order to increase and maintain jobs. Michael Lynn and Rob Endicott of the Cherokee Nation emphasize the need for transportation in economic develop- ment. “Most of our clients are in the rural area and they have to drive 30-40 miles to work and when you add the cost for fuel to the wear and tear on the vehicle, it all adds up.” They also add that a rural worker is likely to pay twice as much for transportation as an urban worker. PURPOSE OF SERVICES DELIVERED There are many types of transportation programs that are developed to serve a particular purpose, need, or market segment. Some of the main transportation programs that are likely to be found in tribal areas are described in this section.

Findings Chapter 2 Page 40 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Human Services Transportation: Social Services These transportation programs are designed to get people to various social services. Transportation for social service programs can be categorized into programs for seniors, for welfare recipients, and for medical purposes. These are described below. These programs may or may not be served by public transit. Transportation is often vital in ensuring that people have access to these programs. Coordinated efforts with these programs may allow tribes to leverage existing funds and to set up a more efficient service. Most tribes have human service transportation programs available for certain segments of the population that meet the requirements of the specific programs. Thirty of the tribes which responded have Head Start program transportation. Thirty tribes have Community Health Representatives transportation (CHR), and 27 tribes have services for the elders in the community. Figure 2-3 shows other transportation programs offered by tribes. A number of tribes have coordinated human services transportation programs with their public transit service. While this has occurred with some programs in a number of tribes, there remain many tribes with

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 41 transportation programs that operate independently with no progress toward coordination or consolidation of the various programs. Blackfeet Transit provides a demand-response service that incorporates many of the human services programs. The transit service provides transportation to various social services—including Head Start, Com- munity Health Representative, senior centers, Eagle Shields, Indian Health Services, centers for mental health, Blackfeet Community Col- lege, Blackfeet Care Center, Glacier County Office of Public Assistance, Browning Public School, Blackfeet Academy, and Blackfeet Manpower- Vocational Rehab-Work Investment Act-Tribal TANF—and is also open to the general public. Cherokee Transit—provided by the Eastern Band of Cherokee— started their transit service in 1997 to provide human service trans- portation for dialysis, Medicaid patients, and other types of human service trips using a demand-response transportation service. In 2000, the transit department was asked to expand to include general public service. Service was provided five days per week. Since 2000, the Tribe has been operating human service transportation—such as services for seniors, dialysis patients, human service agency clients, and for vocational opportunities in Cherokee—as well as general public transit. The service is now operated 20 hours per day, seven days per week, 361 days per year. The transit service operates a variety of services including a fixed-route shuttle service within the Cherokee town limits, a regional route through the Great Smoky Mountains National Park, a deviated fixed route serving the com- munities within the Qualla Indian Boundary, demand-response ser- vice, subscription service, and medical trips with services to areas within and outside the Qualla Boundary. The eligibility requirement varies by tribe. Some tribes have eligibility requirements set at 55 years and older, some include people with disabilities, and others keep them consistent with the federal guide- lines of 60 years and older. Senior transportation is provided to older adults and is often affiliated with a senior center or other senior programs. This transportation is focused on providing transportation to congregate meal sites, medical appointments, grocery shopping, human services offices, social events, and others. Senior Transportation Within the Native American culture, there is a high regard for elders. Many tribes provide transportation service dedicated to serving the elders. Almost all of the tribes which participated in Phase 2 have

Findings Chapter 2 Page 42 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report some type of transportation service for elders. In some cases this transportation is integrated with the public transit service such as the Eastern Band of Cherokee, but in many tribes the elder transportation program remains a separate function. Standing Rock Transportation provides transportation for seniors. The senior center has Title IIIB funding for state social services. The center was transporting three to five elders and was paying the driver for eight hours. Recognizing the high cost of providing this service, they chose to have Standing Rock Transportation, the public trans- portation program operated by Sitting Bull College, provide trans- portation for the seniors. The Fort Belknap Indian Community started the Fort Belknap Transit Service (FBTS) based on their senior transportation program that served the three senior centers in the three communities of Fort Belknap Agency, Hays, and Lodge Pole. The transit service was expanded to provide public transit and has since been working as part of North Central Montana Transit, which provides service to nearby communities, the Rocky Boy’s Reservation, and Great Falls. This type of transportation is designed to help recipients of public assistance and low-income families transition from assistance to the workforce. Recipients of assistance generally have a low rate of car ownership which further emphasizes the need for such transporta- tion. Several tribal transit programs that serve such a need make use of the Federal Transit Administration (FTA) Section 5316 - Job Access and Reverse Commute (JARC) program. Some of the tribal transit programs that are able to serve this need and access these funds are Blackfeet Transit, Chickasaw Road to Work program, DHRD Transit (through the Department of Human Resources Development) of the Confederated Salish and Kootenai Tribes, Oglala Sioux Transit, and the Standing Rock Transportation of the Standing Rock Sioux Tribe of North and South Dakota. Transportation for Welfare Recipients In some cases, while tribes do not directly apply for these funds, they are able to access JARC funds through their transit partners and collaborations. For example, the Cherokee Nation Transit Program does not access JARC funds because their transit partners—Ki Bois Area Transit (KATS) and Pelivan Transit—that serve different areas both access JARC funds through the state. In Oklahoma, 18 public transit operators that get low-income employees to work have collaboratively created “Road to Work Oklahoma.” The Ki Bois Com-

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 43 munity Action Foundation, Inc., based in Stigler, is the administrator of the Job Access Reverse Commute Grant in Oklahoma. Some tribes have job training and employment departments to access funds available through the TANF block grant program and Native Employment Works (NEW) administered by the US Department of Health and Human Services and Administration for Children and Families (ACF) and Welfare-to-Work funds (WtW) funds from the US Department of Labor and the Employment and Training Admin- istration (ETA). While the JARC program is being used by some tribes, there were only six of the 48 tribes responding that make use of this program. There appear to be even fewer that use TANF funds in a coordinated program with the public transit service. These funding programs which provide access to employment are an untapped resource for many tribal transit programs. Many programs provide transportation for non-emergency medical needs. These transportation programs are generally provided by nursing homes, treatment centers, Community Health Representative (CHR) programs, and hospitals. The Chickasaw Nation in Oklahoma provides medical transportation to any Native Americans residing in its 13-county service area. The program also does pick up and delivery of prescriptions. Transportation for Medical Purposes The Choctaw Nation of Oklahoma provides general public transit services with priority given to non-emergency medical trips. It started when the Choctaw Nation developed an Outreach Services effort. Through this effort, the Nation realized that while heath care services were important, access of participants to health care was more important as there were few or no transportation options. The Tribe then applied for and was awarded a FTA Tribal Transit grant in 2007. The Tribe contacted CTAA for a technical assistance program. The Tribe—along with CTAA and its consultants—were able to under- stand the needs within the community and the type of service to be provided. The transit program then integrated the existing CHR medical transportation service by providing service to the Indian Health Hospital and the other tribal clinics. The program—which started in October 2007 as a one-vehicle operation—currently has 17 vehicles that serve 88,000 members within the Choctaw Nation boundaries.

Findings Chapter 2 Page 44 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report The Southern Ute Indian - Tribal Health Services provides transpor- tation to dialysis and other medical appointments. The Chickaloon Village Health and Social Services Transportation Program in Alaska provides transportation for medical, dental, and mental health appoint- ments in the Mat-Su Valley and to the Anchorage area. The Alaska Native Medical Center in Anchorage, Southcentral Foundation’s primary care center, and the Valley Native Primary Care Center in Wasilla are some of the agency’s major medical destinations. Oneida Public Transit started as a demand-response service for elder nutrition and for medical trips. A small percentage of the trips were recreation center trips for youth. Since then, the service has expanded into a general public transit service. Yakama Nation has a CHR pro- gram which provides transportation for medical-related trips only. Clients must have no other forms of transportation and must have limited income to be eligible to use this transportation service for medical purposes. A two-week advance notice is preferred for such service. The Confederated Tribes of Grand Ronde also have a CHR program that provides transportation for medical trips. The program provides approximately 600 annual medical trips. As seen from these examples, many tribes have a separate department within the tribe that provides medical transportation while others started providing medical transportation and transitioned into a public transit program that serves hospitals, medical facilities, and other medical destinations. Education This transportation service is provided by colleges or universities for education purposes. Some of the reasons that colleges may decide to provide transportation are to decrease the number of single-occupancy vehicles on campus or to support the transit-dependent student population. Tribal colleges have found that lack of transportation is often associated with failure to complete an education program. The Salish and Kootenai College—located on the Flathead Indian Res- ervation in Pablo, Montana—supports transportation for its students to access the campus using the tribal transit system. Prior to contracting with the tribal transit program, the college operated a separate transportation program. The Standing Rock Sioux Tribe has public transit service operated by Sitting Bull College. Originally operated to provide access to education, the service was expanded to a full transit system. This arrangement has allowed the transit system to pool funds from a variety of sources.

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 45 There are some tribes that start a public transit service and incor- porate the needs of tribal college students in addition to the other needs of the community. Oglala Sioux Transit—on the Pine Ridge Reservation—started providing transit service in 2009. While open to the general public, one of the aims of this transit service is to serve Oglala Sioux College. Transit service is provided to the college and for students taking night classes. Private Sector Enterprises and Gaming There may be private transportation providers serving areas near a tribe. Examples include taxis, airport shuttles, tour operators, charter bus companies, casino buses, and intercity bus services. Private oper- ators may be geared to a certain market segment, such as tourists, or to a specific destination, such as service to and from the tribal casino. Tribes with gaming operations often have transportation service associated with the casino, whether for patrons or employees. In most cases, the gaming transportation services are operated separately from the transit service. Gaming revenues are sometimes used to support the tribal transit program, but this is the exception rather than the rule. The Lake of the Torches Resort Casino—a casino of the Lac du Flam- beau Band of Lake Superior Chippewa Indians—has a shuttle bus that travels long distances to pick up patrons. This shuttle bus makes stops at various locations in the nearby communities on different days of the week. On Tuesday, the shuttle bus serves the communities of Prentice, Phillips, Fifield, and Park Falls. On Thursday, the shuttle bus serves Hurley-Ironwood and Mercer, and on Friday, the shuttle bus serves Rhinelander, McNaughton, and Lake Tomahawk. The shuttle bus also serves tribal campgrounds which are about one-half mile from the casino. A patron to the casino can also book a motor coach day trip to the casino through other private transportation providers from Wisconsin, Minnesota, and Michigan that are listed on their website. Leech Lake Gaming Division, of the Leech Lake Band of Ojibwe Indians in north-central Minnesota, provides transportation service to and from the casino and various tribal businesses and locations such as Northern Lights Casino, Palace Casino Hotel, and White Oak Casino. This transportation is solely financed through tribal gaming revenues. Leech Lake Gaming Transportation provides mainly fixed- route service, but will deviate off route to pick up a passenger if a request is received. This transit service is for guests going to and from

Findings Chapter 2 Page 46 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report casinos, residents of Leech Lake, employees, and college students. This transportation service is free and has no eligibility requirements for riding the service. Cherokee Transit in North Carolina serves the casino with their scheduled routes but does not receive revenues from the gaming enterprise to support the service. The Southern Ute Tribe uses gaming revenues to fund the tribe’s portion of the operating cost. Mass Transit: Public Transit Since the need for transportation is so great, many tribes have started their own transportation service. Nearly all of the transit services that have been started by tribes are open to the general public. A vast majority of tribes that provide these public transportation services access the FTA Tribal Transit Section 5311 (c) program. These funds are meant to complement other sources of FTA, state, and local funding, including FTA Section 5311 funds. The key element of this service is that anyone may ride. Many tribes have integrated specialized transportation services with a public transit program to reduce duplication of services. In the short-form questionnaire that was part of Phase 1 of this study, out of the 67 tribes that responded, 44 tribes (66 percent) had some type of transit service. Thirty-one tribes provided some transit service, eight tribes contracted their transit services, and five tribes had a com- bination of providing and funding transit service. Out of tribes that had a transit service, all tribal transit services were open to the general public, except for one tribe that reported that the service was open to tribal members only. While in the list of eligibility some tribes gave priority to Native American, non-emergency medical services, or seniors and people with disabilities, the transit services were open to the general public. Access to Employment Access to employment for tribal members is a consistent theme among tribal transit programs. While for some tribes this is secondary to the human service program transportation needs, other tribes have established access to employment as a priority. The Cherokee Nation Transit Program’s main focus is getting people to and from work, followed by other generalized transportation

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 47 purposes. Most of their passengers are in rural areas and have to drive 30-40 miles to work. The transit program implemented a work route in 2008 and a second in the first part of 2009. These routes provide rural access from Pryor Creek to the main casino in Catoosa and from Stilwell to the tribal complex in Tahlequah. The Catoosa route runs six days per week to accommodate three shifts. The Stilwell route runs five days per week for the 8:00 a.m. to 5:00 p.m. workers at the tribal complex. Since then, two additional work routes were added in the latter part of 2009 to provide transportation from Salina and Sallisaw to the tribal complex in Tahlequah. Both routes run five days per week to accommodate the 8:00 a.m. to 5:00 p.m. workers at various tribal work sites in Tahlequah. The Department of Human Resources Development (DHRD) Transit, provided by the Confederated Salish and Kootenai Tribes, has set up their transportation service to serve commuters, followed by other needs. They currently have four routes. The first route serves Dixon, Charlo, and Ronan. The second route serves Arlee and Polson. The third route serves Elmo and Ronan. The fourth route serves Polson and St. Ignatius. These routes provide service in the morning (6:00 to 8:30 a.m.) and in the evening (3:30 to 5:30 p.m.), and are mainly serving commuters. From 8:30 a.m. to 3:30 p.m., the DHRD Transit provides demand-response service for other non-work trips. The tribe has also worked with the Missoula-Ravalli Transportation Manage- ment Agency to establish vanpool service for commuters to Missoula. The Chickaloon Village Health & Social Services Transportation Program—provided by the Chickaloon Native Village of Alaska— provides transportation for medical appointments in the Mat-Su Valley and to the Anchorage area. However, one of the unmet needs identified by the tribe was providing transportation to work or for obtaining employment. The new general public transit program was planned in part to help meet those needs. Standing Rock Transportation—provided by Sitting Bull College—is open to the general public to serve all transportation needs. The transportation program operates a variety of services including inter- city, dial-a-ride, interstate, and veteran services to/from hospitals. However, Standing Rock Transportation reports that their highest ridership and most popular routes are the “reverse commute” from the urban areas to tribal/rural areas for employment. Approximately 70 percent of the trips are for employment. Many people come to the Bureau of Indian Affairs (BIA), Indian Health Services (IHS), college, and other locations for employment.

Findings Chapter 2 Page 48 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report There are many tribal transit programs which serve employees to access employment, but that is not the only purpose of the transit service. Cherokee Transit provides transportation services that meet the needs of employees, but also serve residents and tourists. Similarly, Leech Lake Gaming Transportation provides transportation for employees, residents, patrons going to and from the casino, and college students. TYPES OF SERVICE DELIVERY SCHEMES Tribes were asked to indicate the types of transit service they provide. Most tribes provide a combination of demand-response, deviated fixed-route, and fixed-route services. However, the service type with the largest number of responses is demand-response alone. Table 2-4 summarizes the results for the tribes that responded. Table 2-4 Types of Service Operated by Tribes Fixed-Route 10.6 % Demand-Response 18.2 % Deviated Fixed-Route 3.0 % Combination of Services 36.4 % Not Applicable or No Service 31.8% While many tribes operate a combination of services, most of these included demand-response service as a portion of their program. Demand-response service is the best option for many tribal settings with low population densities and low levels of demand. Demand-Response Service Demand-response transit service—frequently termed dial-a-ride—is characterized as door-to-door transit service scheduled by a dis- patcher. With demand-response service, advance reservations are typically required, although some immediate requests may be filled if time permits. The general public transit service operated by Blackfeet Transit in Montana, Tribal Transit operated by the Choctaw Nation of Oklahoma, DHRD Transit operated by the Confederated Salish and Kootenai Tribes in Montana, Cowlitz Tribal Transit Service in Wash- ington, Oneida Public Transit in Wisconsin, and Snoqualmie Valley Transportation (SVT) in Washington are some of the examples of successful demand-response services.

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 49 Fixed-Route Service This type of service operates on designated routes and follows set schedules. Specific bus stops are typically identified for the locations where passengers will be picked up and dropped off. Routes are usually laid out in either a radial or grid pattern. The advantages of fixed-route service are that it can be provided at a relatively low cost on a per-passenger-trip basis, schedule reliability is high since buses do not deviate from their routes, service does not require advance reservations, and service is easy to understand. Many of the fixed-route services operated by tribes are along cor- ridors with higher levels of demand than other areas of their service. The Navajo Nation operates an extensive fixed-route system that connects many of their Chapters or communities. As an urban system, Citylink—operated by the Coeur d’Alene Tribe—is a fixed-route system. Other tribes, such as the Sitka Tribe of Alaska and Fort Peck Transportation operate small fixed-route services along key routes. The Americans with Disabilities Act (ADA) requires that communities with fixed-route transit service also provide complementary para- transit service that operates, at a minimum, in a three-quarter-mile radius of each fixed route. This is a factor for tribes which select fixed- route service. A number have chosen to operate demand-response service or route-deviation service to avoid this requirement. Route-Deviation and Point-Deviation Service With route-deviation, transit vehicles follow a specific route but can leave the route to serve demand-response origins and destinations. Vehicles are required to return to the designated route within one block of the point of deviation to ensure that all intersections along the route are served. The passengers on the bus may have a longer travel time than for fixed-route service and service reliability is lower. However, the ADA-mandated complementary paratransit service is not necessary since the bus can deviate from the route to pick up disabled passengers. Under checkpoint service, transit vehicles make periodic scheduled stops at major activity centers. Specific routes are not established between checkpoints, which allow the vehicles to provide demand- response service and alleviates the need for ADA-mandated comple- mentary paratransit service. Riders are picked up, typically at a reduced fare, at the checkpoints and are taken either to another checkpoint or to a demand-response-specific destination. Service

Findings Chapter 2 Page 50 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report between the checkpoints does not require advance reservations. However, service from any other location on a demand-response basis requires an advance reservation so that the vehicles can be scheduled for pick-up and drop-off. Checkpoint service offers an advantage over route-deviation because there is no specified route for the vehicles to use. Checkpoint service requires only that the vehicle arrive at the next checkpoint within the designated time window. Twenty of the tribes that responded operate a point- or route- deviation type of service. This approach is well-suited to many tribal settings where a regular schedule is desired, but levels of demand do not support fixed-route service. Tribes that operate route-deviation service include the Cherokee Nation, Fort Peck Transportation Service, and the Squaxin Island Tribe. Commuter Services A number of tribes have established routes and schedules to serve people commuting to jobs. However, these services to accommodate commuters are typically integrated as part of the service and are not identified as commuter service comparable to what might be found in larger urban systems. For example, Fort Peck Transportation Service has routes that start early on the eastern and western ends of the reservation and travel to Poplar to serve commuters. As mentioned earlier, a number of tribes with gaming operations provide trans- portation service for employees of casinos. A number of systems operating near urban areas effectively operate a reverse commute system for people traveling to tribal offices and gaming facilities. Special Needs and ADA Paratransit Transportation The Americans with Disabilities Act of 1990 (ADA) paratransit service requires that transportation agencies that operate fixed-route service provide complementary paratransit service for people with dis- abilities who cannot use the fixed-route service. This paratransit ser- vice must be provided within three-quarters of a mile of a fixed route. The hours and days of the paratransit service should be the same as the fixed route, and transportation agencies cannot charge more than twice the regular fare on this paratransit service. Paratransit service is typically much more costly to operate than fixed-route service because of the service’s characteristics. Fixed routes are established to meet the highest demand travel patterns, while paratransit service must serve many origins and destinations in a dispersed pattern.

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 51 The tribes that have fixed-route service also provide complementary paratransit service. In some cases this is done with partnerships in the community such as in Sitka where the Sitka Tribe operates the fixed- route public transit and Southeast Senior Services operates the para- transit service. In other cases the tribe operates both services. The requirement to provide complementary paratransit service has been a factor in tribes choosing to operate a route- or point-deviation service rather than fixed-route service. According to the Federal Transit Administration, Indian tribes must comply with most FTA requirements (such as drug and alcohol testing) and most civil rights regulations. The only two exceptions for tribes are Title VII of the Civil Rights Act of 1964 (Equal Employment Opportunity) and Title I of the Americans with Disabilities Act of 1990 (discrimination against individuals with disabilities). According to the RTC: Rural, (January 1999), Congress has specifically excluded tribes and reservations from the requirements of the Americans with Disabilities Act (ADA). While many tribes do not have to follow ADA, most tribes follow the intent of ADA. According to the RTC: Rural study, there are some tribes—such as the Oglala Lakota Sioux Indians—that have chosen to adopt ADA as a whole. Some tribes, such as the Confederated Salish and Kootenai Tribes, have passed a resolution that adopts the spirit of ADA and has a committee to develop and implement disability policies. There were some tribes that have changed their policies in accordance with ADA. In cases where a tribe provides public transit for an entity that uses Federal Transit Administration funds—such as the Coeur d’Alene tribe that operates Citylink—this exclusion from ADA would not apply. The Coeur d’Alene tribe complies with ADA requirements and all of their vehicles are ADA-compliant.

Findings Chapter 2 Page 52 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report ORGANIZATIONAL STRUCTURES There are many types of organizational structures providing transit service to tribes across the country. Many different types of arrange- ments are made between tribal departments and between tribes and external partners to make transit service work. This section includes an overview of factors leading to transit service organizational structures as well as descriptions of and examples of different organizational structures. Organizational structures are categorized and generalized for comparison and summary purposes, but examples are also used to illustrate the range of organizational options available to tribes for providing transit service. Laws and Motivating Factors There are many reasons for tribes establishing different organizational structures for their transit programs. By law, tribes hold the ability to determine their own governmental structure. As the legislative bodies of sovereign nations, elected tribal officials are responsible for creating and sustaining a wide scope of government services. Once elected, a tribal official must make decisions regarding law and order, environmental protection, economic development, education, health care, and all the other elements of modern life for their citizens. They act to create and modify tribal laws supportive of the agency’s operations and approve plans, budgets, grant applications, and inter- governmental agreements. Federal laws and regulations affecting many of these areas require tribal council resolutions of support as part of the proposal package. Regulations and policies are established to specify how laws are enforced and handled in practice. Such regulations can be challenging to implement and uphold over time, particularly when multiple departments and agencies are involved in operating transit service. Often the regulations and policies of government departments create issues that impede the ability of tribes to work with those agencies. For example, many state funding agreements require tribes to waive sovereignty rights which may be unacceptable to the tribe. State agreements may require that all legal issues be resolved in state courts or that tribes comply with other specific state requirements. FTA grant requirements have included clauses which were unacceptable to some tribes. Although the requirements may not have been established by law, they have been implemented as part of the agency’s administration of specific laws. Some states and agencies have been willing to waive those requirements while others are not willing. The end result is that in some states tribes have good working

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 53 relationships with their state department of transportation while in other states tribes avoid funding through programs administered by the state. In order to work around the state requirement that disputes be resolved in state courts as part of the grant agreement, the Southern Ute Tribe set up a private nonprofit corporation—Southern Ute Com- munity Action Programs, Inc. (SUCAP)—to be the recipient of grant funds from the state. The nonprofit was chartered to be the transit authority for the Tribe, but the Tribe was not a part of the grant agree- ments so the issue of sovereignty in legal matters could be avoided. For the Sitka Tribe of Alaska, most of the funding is procured by the local nonprofit Center for Community (CFC). The Tribe operates the fixed-route service under contract to CFC, and a senior services agency operates the paratransit service (also under contract to CFC). CFC receives FTA 5311 funds. With use of these funds, FTA requires that a contract operation go through a procurement process every three to five years for the operation of fixed routes. CFC reported that the regulation ignores existing partnerships and requires them to go through the procurement process again, which weakens the relationship between CFC and the Tribe, and interrupts successful existing coordination. Incentives Cooperation between tribal departments and between tribes and other entities is encouraged because it makes a tribe more competitive for limited federal, state, local, and tribal funds. The potential to tap into additional sources of federal, state, and other funding provides an incentive for tribes to offer a sustainable transit service to their members. The majority of tribes that operate transit services use multiple sources of funding. This has allowed tribes to survive reductions in funding from individual sources without completely eliminating the transit program. Organizational Structure for Service Delivery Organizational structure involves the cooperation of the tribe with one or more additional government entities for the purpose of transit service delivery and are not relationships developed for funding. Many tribes receive transit funding through a state or regional government, most commonly the state. Many tribes also rely on a regional body such as a Metropolitan Planning Organization (MPO) or regional planning agency for transit planning resources and, in

Findings Chapter 2 Page 54 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report some cases, funding. On a local scale, many tribes are associated with local social service or senior centers to provide transit service. The level of cooperation varies from very little to very high and the types of agreements and arrangements also range from informal to formal. Examples are provided for each type of multi-government organiza- tion structure. Some tribes are able to provide transit service by partnering with a regional planning body or entity such as a Metropolitan Planning Organization (MPO). For example, the Coeur d’Alene Tribe in Idaho is the operator of the transit system for the city—Citylink—which is funded by the Tribe and Kootenai County, and planned and imple- mented by the Kootenai Metropolitan Planning Organization (KMPO) along with the Tribe and the County. Regional/MPO The impetus for this multi-government structure started with the need for transportation to serve the Coeur d’Alene Reservation. The tribe had high poverty and unemployment rates. A large percentage of their people did not drive and had no access to a car. To meet those needs, the Tribe started a transit service in 2004. This service was operated using one bus. In 2005, Kootenai County passed the 50,000 population mark and approached the Tribe to contract services with the KMPO to supplement transit services already provided by the Tribe. Tribal funds were then used as local match for the FTA Section 5307 grant through Kootenai County. Kootenai County is the recipient of this FTA Section 5307 grant and hired Panhandle Action Council (PAC) to administer funds to Citylink and Kootenai Area Trans- portation System (KATS). The KMPO has been active and works to coordinate services with Citylink and KATS to eliminate redundant services. The San Diego Association of Governments (SANDAG) has estab- lished a Tribal Transportation Working Group which has representa- tion from tribes within the greater San Diego area. All transportation issues related to tribes are reviewed and commented upon by the Working Group. Tribes also have representation on the policy boards and committees of SANDAG. The Working Group initially focused on roadway improvements and the Indian Reservation Roads pro- gram, but has become involved with transit. Recently a tribal transit needs analysis was completed for the region and funding was obtained through the tribal transit program for bus stop improve- ments. The transit service is provided by the two regional transit

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 55 agencies, but tribes have become involved in prioritizing improve- ments for routes serving tribal lands. Many tribes receive transit funding through their state or states. However, few operate service with state partnership. One example of a state partnership is the Standing Rock Sioux Tribe, which was asked by the State of South Dakota to operate transit service in an adjacent non-tribal community where there was great need for public transit (Mobridge). The City is unable to provide the transit, so the state asked Standing Rock Transit and the State Social Service Department to work together to provide service in a low-income community without school busing. Regional/State Some tribes operate transit service through partnership with the local community. For example, the Sitka Tribe of Alaska operates fixed- route transit service in Sitka under contract to the local Center for Community (CFC). The CFC is the umbrella agency that receives federal transit funds and contracts out the fixed-route and paratransit service. Another agency—Southeast Senior Services (SESS)—is con- tracted by the CFC to provide the paratransit service in the com- munity. The unique thing about Southeast Senior Services is that they have been providing transit service since 1997, even before a public transportation program was started in Sitka. (The public tribal transit program in Sitka began in 2002). SESS provided transportation to seniors and people with disabilities. However, with this collaboration, public transit is provided and SESS receives additional funds (through the Tribe) that can be used to serve seniors. Regional/Local The Sitka Tribe of Alaska also receives tribal transit funding and with this funding the Tribe was able to expand the existing public fixed- route transit service (starting November 2007). It is an intertwined collaborative effort by the Tribe and the community that created the opportunity for transit service in Sitka and produced the potential to access unique funding sources. North Central Montana Transit is organized as a partnership of city governments, county governments, tribal governments, social service agencies, and educational organizations. North Central Montana Transit operates in a low-density area with two or fewer persons per square mile. The two counties they serve—Hill and Blaine—have high poverty rates compared to statewide poverty rates and include the

Findings Chapter 2 Page 56 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Fort Belknap and Rocky Boy’s Indian Reservations with unemploy- ment rates as high as 70 percent. North Central Montana Transit is operated by Opportunity Link, Inc., a regional nonprofit agency that attempts to implement strategies and encourage public-private partnerships to reduce poverty in the region. This agency has identified transportation as an important factor that will help reduce poverty. For most people in this community, driving long distances is the only way to get to work, attend education programs, get to medical appointments, access grocery stores, and get to basic services and amenities. North Central Montana Transit was able to access operational funds through the Montana Department of Transporta- tion, the Federal Transit Administration, and capital funds from the American Recovery and Reinvestment Act to purchase vehicles. Local funds to match these state and federal funds were provided by Hill and Blaine Counties, the Fort Belknap Indian Community at Fort Belknap Reservation, the Chippewa Cree Tribe at Rocky Boy’s Res- ervation, and Montana State University-Northern. This system offers fixed routes and intercity routes that operate Monday through Friday from Fort Belknap (tribal headquarters of the Fort Belknap Indian Tribe) to Havre and Havre to Box Elder (tribal headquarters of the Rocky Boy’s Tribe/Chippewa Cree Tribe). There is also a twice-a-week connection from Fort Belknap to Great Falls, which is approximately 190 miles away. These services also connect with the Fort Belknap Transit and the Rocky Boy’s Transit service that provide services within their reservation boundaries. Opportunity Link, Inc. is also taking the lead to plan and coordinate transportation at different jurisdictional levels that include the Hi-Line communities in northern Montana. Tribal Government Most tribes operate transit service as part of the tribal government (76 percent of surveyed tribes with transit service). In most cases, several departments within the tribe operate some sort of transportation service. Some tribes have consolidated transportation services under the transit department, but most tribes have multiple departments that provide transportation for different purposes. The different types of transportation services offered are generally program- or funding- source-specific, including transportation services for the Head Start program, senior transportation, or medical transportation for Indian Health Services (IHS) or Community Health Representatives (CHR).

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 57 Some tribes have consolidated transportation services under the transit department. In this case, the transit department provides all transportation services regardless of program or eligibility require- ments. Generally, a formal agreement has been signed stating that the transit department will operate transportation services for another department. Intra-Tribal Consolidated In the Oneida Tribe of Indians in Wisconsin, Oneida Public Transit has taken over providing transportation services for several pro- grams. For example, the health center’s two drivers and vans were absorbed by the transit department through a signed agreement and the transit department bills the health center for the service it provides on behalf of its clients. Oneida Public Transit is striving to consolidate more programs’ transportation services to avoid service duplication, increase efficiency, and reduce cost. When consolidating services, Oneida Public Transit tries to absorb the program’s drivers, vehicles, and service rights. The Menominee Department of Transit Services (MDOTS), of the Menominee Indian Tribe of Wisconsin, has established the Menominee Transportation Advisory Committee (MTAC) which consists of all stakeholders and agencies that have transportation services. As a result of MTAC coordination efforts, just about all transportation services within Menominee County are currently being coordinated through MDOTS. Additionally, MDOTS has established a one-call dispatch center for all stakeholders/partners which allows the entire community to call one number for all transportation services. In the case of the Confederated Salish and Kootenai Tribes (DHRD Transit) of Montana, IHS used to provide passenger transportation, but now DHRD Transit provides services for their passengers. DHRD Transit has coordination plans with providers—including Lake County Council on Aging, the hospitals (St. Luke’s Hospital and St. Joe’s Hospital), retirement homes (Evergreen Retirement Home, St. Luke’s Retirement Home), Closer to Home, Mill Point, and the Retreat (Polson)—which allow DHRD Transit to operate transit for these entities who reimburse DHRD Transit for trips provided. DHRD Transit also has memoranda of understanding with the Tribal Health Department and Salish Kootenai College, which again allows DHRD Transit to provide trips for these agencies with reimbursement for trips provided.

Findings Chapter 2 Page 58 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report The most common organizational typology discovered as part of this study is the intra-tribal redundant scenario where transportation services are operated by multiple departments or programs with little or no coordination. Of the 48 tribes surveyed, 36 percent said that there was no coordination between tribal departments providing some sort of transit service. Many other tribes said that coordination was informal and infrequent. A distinct minority of tribes have a consolidated structure as described in the previous section. Intra-Tribal Redundant Tribes keep the various transit services separate for a range of reasons including a history of operating separate programs, differing types and needs of clients, lack of familiarity and awareness between departments, and different funding sources. Some tribes are wary of consolidating transit services as they fear that would make them ineligible for specific types of funding they currently use to operate their separate services. The Poarch Band of Creek Indians, for example, receives funding to operate service through their SAIL Senior Center and do not wish to jeopardize that funding relationship by seeking general transit funding. The Narragansett Indian Tribe of Rhode Island said that the different programs offering transportation service communicate but do not necessarily coordinate. The Nez Perce Tribe of Idaho reported that each program operates their transportation services separately. The Confederated Tribes of the Grand Ronde Community of Oregon contract their transit service with two local providers and there is little or no coordination between these contracted providers and the other tribal programs that provide limited transportation services. The biggest reason for this is the different hours and types of service needed for providing services to different clientele. For example, the transit program cannot coordinate with Head Start because of the different hours of service necessary for the Head Start program and their clientele being children. Many tribes have informal or formal agreements between depart- ments that result in sharing of resources on a range of levels—64 per- cent of surveyed tribes share this characteristic. Sharing of resources generally includes sharing vehicles, equipment, maintenance, staff, planning, or expertise, on a semi-regular or regular basis. If the transit program provides service for other departments, that is a consoli- dated intra-tribal organization as discussed earlier. Inter-Tribal Shared

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 59 For example, the Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation, Montana (Fort Peck Transportation) share vehicles with a local transit provider, Valley Transit. Also, Fort Peck Transportation provides rides to St. Lutheran Home and the Poplar Swing Bed residents and is reimbursed by these agencies to provide those trips. Fort Peck Transportation also coordinates with the IHS and CHR programs by providing transportation locally. While these agencies have vehicles, they do not have wheelchair-accessible vehicles, so Fort Peck Transportation provides trips where an accessible vehicle is needed. The Chickasaw Nation of Oklahoma Transportation Department coordinates both the Road to Work program and medical transporta- tion. The transportation department has a single 800 number, so when a client calls, they could be scheduled for trips on the Road to Work program or the medical transportation service. Regardless of the type of trip, all passengers are scheduled on the same daily schedule. They also coordinate with CHR to provide trips that they are unable to fulfill because of a lack of staff or for which they do not have enough vehicles. They have limited coordination with the Elders program. The Hualapai Indian Tribe of Arizona coordinates with the CHR program on a regular basis. They also work with other passenger transportation programs. For example, the transit department will loan a vehicle to the Head Start program if a vehicle needs to be taken out of service. Also, the transit department drivers will go out and help other programs if they are needed and available. The Northern Cheyenne Tribe of Montana coordinates with other tribal departments informally and formally. For example, on a few occasions when a transit department vehicle has broken down, they have borrowed a vehicle from the Head Start program to keep their regular routes operating on a normal schedule. Some tribes choose to contract transit service through a separate transit operator. The contracted operators are either private com- panies or other governmental entities. The tribes pay for the service and specify how the service will be operated including routes and times of operation, but another entity actually operates the day-to-day service. The tribes apply for traditional transit funds to pay for the contracted service. Generally, the tribes do not own the buses or equipment but may apply for capital funding jointly with the transit operator. Contracted Service

Findings Chapter 2 Page 60 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report For example, the Confederated Tribes of the Grand Ronde Com- munity of Oregon contract their transit services through two local government transit operators—Salem Area Mass Transit District (SAMTD) and Yamhill County Transit Area (YCTA). The Tribe is billed a flat rate by each of the contracted operators. The Tribe pays for the service with state and federal transportation funds. One person on the tribal staff dedicates 20 percent of a full-time position to the responsibilities required to contract and pay for the transit service. The Tribe decided to contract service as opposed to operating the service themselves due to lack of experience and knowledge of bus service and the existence of two experienced transit operators in the vicinity. The Cherokee Nation Transit Program in Oklahoma contracts transit service through agreements with two existing public transit systems—KATS Transit and Pelivan Transit. The Cherokee Nation works with the providers to set the schedule. The Tribe does not own any vehicles, but at the time of the survey was in the process of acquiring three transit vehicles that would be leased out to the contracted transit service providers. With the decision to contract service, the Cherokee Nation decided to work within the existing community transit infrastructure to strengthen it as opposed to creating new transit infrastructure to compete with the existing transportation providers in the area. Non-Tribal Some tribal transit programs are operated for tribal members by non- tribal entities. These entities include private for-profit and not-for- profit agencies and other local governments. Some tribal transit programs are operated by private sector entities. For example, the Southern Ute Indian Tribe receives transit service provided by the Southern Ute Community Action Programs, Inc. (SUCAP), a nonprofit organization. It was established by the Southern Ute Indian Tribe in October 1966. SUCAP is not part of the tribe or tribal government but is a delegate agency that provides programs for the tribe. SUCAP is the operator of the transit service, Road Runner Transit, which connects Ignacio and Bayfield with Durango. SUCAP also has five other programs that it operates under this nonprofit organization structure. Private Sector (For Profit and Private Not for Profit)

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 61 Yakama Nation Tribal Transit in Washington is provided through a contract with People for People, a nonprofit organization providing a variety of transportation services for people throughout central and south-central Washington. The Tribe chose to contract with People for People because they had the required insurance to cover the liability associated with the transit service, they were knowledgeable of the service area, and they were agreeable to entering into a service con- tract with the Tribe. Some tribes are served by other local governments for transit service. This includes a public transit program that is not directly operated or funded by the tribe. This type of service is provided by a non‐tribal entity and geared toward meeting the needs of the general public. This is a resource that the tribe may choose to use to benefit from transit services offered and to provide the needed transit service to tribal members. Other Local Governments In the case of the Osage Tribe in Oklahoma, the local transit service is provided by Cimarron Transit. Cimarron Transit serves the entire county and parts of the surrounding counties. While the Tribe has an excellent relationship with Cimarron Transit, they do not have a financial agreement and Cimarron Transit does not provide any tribe- specific or tribe-funded services. However, they do provide fixed- route and demand-response service for the general public, which includes tribal members both on the reservation and in the surround- ing communities. At the time of the survey, the Osage Tribe was applying for federal transit funds to supplement the Cimarron Transit service to better meet the needs of tribal members. The Tribe does not want to operate its own transit service, but would like to contract with Cimarron Transit to provide more tribe-specific service. If the funding was obtained and the Osage Tribe contracted with the local provider, the organization structure would be modified. CULTURAL ISSUES Weaving through the organizational structures described in the pre- vious section are cultural issues that play a large role in decision making on a tribal level. While many tribes have strong and positive relationships with other governmental bodies, some tribes are hesitant to partner with other governments because of past difficulties encountered when attempting to work with outside groups. The issue

Findings Chapter 2 Page 62 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report of tribal sovereignty is frequently cited as the reason that partnerships have not been formed. In many cases, tribal transit programs coordinate with other adjacent tribes both in terms of providing trips and in terms of sharing exper- tise and support. For example, the Choctaw Nation of Oklahoma connects with the transit services of nearby Chickasaw Nation. The high esteem in which elders are held is not always understood by funding agencies. Many tribes seek to have a vehicle dedicated to serve tribal elders, but many funding programs desire to have vehicles shared among programs and not dedicated to any specific group. Tribes have received comments during compliance reviews or have not been funded for vehicles because of a perceived redundancy in the number of vehicles available to the tribe. Another cultural issue faced by tribes is requesting volunteers in providing tribal transit services. Many tribal transit agencies find it morally incorrect to ask tribal members who are so poor to volunteer when they really need the money to meet basic needs. Shared Rides Many tribes share rides between tribal departments and with other local transit service providers. To continue with the example of the Choctaw Nation of Oklahoma, their transit service shares rides with four local providers—Little Dixie Community Action Agency, KATS (Ki Bois Area Transit System), JAMM Transit, and Southern Okla- homa Rural Transit System (SORTS) in addition to the Chickasaw Nation. Since these other transportation providers are larger agencies, they generally help the Choctaw Nation provide trips if it is unable. The Eastern Band of Cherokee Indians in North Carolina has tokens that other departments and programs can purchase and give to their clients. For example, the IHS hospital has difficulty purchasing trans- portation due to their contractual requirements, but they can use petty cash or some other small fund to purchase tokens to keep at the nurses’ stations or at the emergency room desk for patients who do not have money for transit fare back to their homes. However, some tribes are hesitant to share rides because they are not confident that their clients would be served in an adequate manner. Additionally, there are other demographic and cultural issues that limit the sharing of rides between tribal programs within a single tribe.

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 63 For example, the Oglala Sioux Tribe of the Pine Ridge Reservation, South Dakota cannot transport children for the Head Start program because of the type of funding received from the FTA. Also, they cannot transport veterans because the VA centers are located off the reservation and the transit service cannot operate beyond the reserva- tion boundaries. The inability to transport Head Start children is not unique to the Oglala Sioux or tribal transit services. The lack of coordination between Head Start and public transit services is usually attributable to Head Start regulations. Cooperation with Other Local Governments Many tribes cooperate with other local tribes or governments to share limited resources or to make connections that benefit their tribal members. For example, the Navajo Transit program coordinates schedules with other non-tribal transit services in the area including Mountain Line in Flagstaff, Arizona; Red Apple in Farmington, New Mexico; Gallup Express in Gallup, New Mexico; and the Page Senior Transportation Program in Page, Arizona. Navajo Transit is paying for four bus shelters to share with the city line (Gallup Express) which both services will use and the City will pay to maintain. Also, Gulkana Village of Alaska coordinates with Mat-Su Transit (out of Wasilla), Connecting Ties (out of Valdez), Copper River Native Association (CRNA), and at the time of the survey, was trying to coordinate a service from Valdez to Anchorage. They have also worked with Chickaloon Native Village in the past. Some tribes are fearful of cooperating with local governments because they do not believe that the tribal members would receive the services when they need them the most. Some tribes are also reluctant to cooperate with other local governments because of previous attempts at cooperation that have ended badly. There are other geographic barriers (both natural and cultural) that isolate tribes from other communities—both tribal and non-tribal—which limit cooperation even if there is interest in cooperation. Many tribes are located on rural reservations with large distances to travel, rough terrain, and complicated natural features to navigate (such as large or multiple lakes or river systems), which limit their ability to cooperate with other local governments. Additionally, some tribes do not cooperate with other local governments because those governments are located in metropolitan areas. Both the Cherokee Nation in Oklahoma (near Tulsa) and the Seneca Nation in New York (near Buffalo) stated that they could not coordinate with the metropolitan transit provider because they are not allowed to use FTA tribal transit funds in urban

Findings Chapter 2 Page 64 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report areas (they can only be used in rural counties). Examples from both of these tribes are detailed next. The Seneca Nation of New York reported that they do not currently operate transit service due in part to their reluctance to accept state transit funding for fear that their sovereignty may be impacted. They feel that the state would not be flexible enough to fit with the Tribe’s operating environment. However, the Tribe has attempted to have a realistic discussion with the state transit department regarding how a potential relationship would work, but they feel they have been largely ignored. The Tribe is willing to work with and has an excellent relationship with the federal government and with local transit providers and planning agencies, but not with the state. The Tribe is working with approximately a dozen towns and tribes south of Buffalo, New York to try to coordinate a connection with the Niagara Frontier Transportation Authority, the local transit service provider in Buffalo. The Cherokee Nation in Oklahoma reported that they do not coordi- nate with neighboring tribal or non-tribal transportation providers because of their geographic location. There are few opportunities and natural barriers to potential opportunities. For example, there is a metropolitan area separating the Cherokee Nation from the Osage Nation to the west and a large river separating the Cherokee Nation from the Choctaw Nation to the south. There is considerable com- munication between the Cherokee Nation and other transportation providers—both tribal and non-tribal—but not in terms of service provision. ENVIRONMENTAL ISSUES Tribal transit programs are generally designed and offered to meet the most basic of needs. For the most part, the transit service provides mobility to people who have no other options. The services bring people to medical or social service appointments, school, work, or shopping so that they are able to live day-to-day, particularly in rural, lower-income areas. Tribal transit programs are generally less con- cerned with environmental considerations as a goal or purpose of the transit service. While tribes are interested in reducing environmental impacts as a general rule, it is not in response to these interests that transit service is planned or implemented. The team looked specifically at the use of transit as a mitigation strategy and found only one example of a tribe actively using Con- gestion Mitigation and Air Quality Improvement (CMAQ) federal

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 65 funds to operate transit service. The Eastern Band of Cherokee Indians in North Carolina receives CMAQ funds to operate one transit route through Great Smoky Mountains National Park. Few tribes that operate a transit service are within non-attainment areas and have focused more on meeting basic mobility needs. With regard to green technology, Navajo Transit has partnered with the Ford Motor Company in Detroit to build the first fully electric bus for mass transit. Ford will build the chassis, and another company will provide the batteries. Ford is giving $1.6 million to the project, and Navajo Transit has received a two-year grant for test operations. This project is the result of a green technology proposal, and Navajo Transit has been chosen to test the buses. They will start with a “boost bus” (a smaller bus with a one-hour charge) running from Window Rock to Gallup, with a charge station in Gallup. They are receiving $6.6 million from the FTA Green Technologies Fund. Some tribes expressed interest in using alternative fuels. The Lac du Flambeau Band of Lake Superior Chippewa in Wisconsin, for example, does not currently operate transit service but maintains that use of alternative-fuel vehicles and bike racks on vehicles would be pre- requisites for service implementation. There is a sustainability initiative for the whole tribe, including green construction of a tribe building, and transit service provision would fit well into the overall scheme. SAFETY As part of the research effort, tribes were asked if safety was a primary reason for starting a transit system. Of the tribes that responded, approximately one-half indicated that safety had been a consideration. Only five indicated that traffic and automobile safety were an issue. While not a primary reason for starting the transit service, pedestrian safety was a consideration with the desire to remove pedestrians from the roadways. Many of the areas lack adequate pedestrian facilities, and pedestrians must often walk on the roadway. While a consideration in developing the transit service, most systems were started to meet basic mobility needs rather than address safety issues. No data were available from the tribes to deter- mine any changes in the number of pedestrian injuries or fatalities after introduction of transit service. BARRIERS TO IMPLEMENTING TRANSIT SERVICE Of the 48 tribes that were interviewed in Phase 2, 16 did not have a transit program. Many of these had taken steps to implement a transit

Findings Chapter 2 Page 66 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report service but had not yet been successful. Follow-up interviews and site visits provided additional insight into the reasons these tribes had not been able to start a transit service. Lack of Planning Four tribes had not implemented a service yet because they did not have a plan in place. Two of these were in the process of conducting a transit feasibility study and were in the early stages of the process. One tribe had received a $25,000 planning grant through the FTA tribal transit program but decided not to use the funds because of the reporting requirements. The tribe decided that the cost to prepare the reports did not justify using a $25,000 grant and chose to pursue other sources of funding to support a larger planning study. One tribe had completed a feasibility study but did not know what steps should be taken after the feasibility study to implement a transit service. Lack of Leadership Support Four tribes indicated that transit service had not started because of a lack of support from tribal leadership. This lack of support took several forms. In two cases, a change in tribal leadership or admin- istration resulted in loss of support to start the transit service. In others, there was lack of support to either pursue funding through grants or to provide local funding for operation of the transit service. One tribe experienced personality conflicts among tribal leadership which halted the process of starting the transit service. Funding Four tribes indicated a lack of funding as the barrier that had kept them from implementing transit service. In some cases this was failure to obtain a grant through the FTA tribal transit program. In other cases it was lack of funding from the tribe to match other grant programs. Tribes may have the option to match money received from non-FTA sources (such as funds available from FHWA, DHHS, DOL, and HUD funds) already received by the tribe to match FTA funds. It is important for tribal transit programs to explore multiple sources of funding, so that reduction or elimination from one grant funding source does not adversely affect the services provided by the pro- gram. A common theme among tribes that have sought funding through the FTA Section 5311c tribal transit program is the lack of feedback on grant applications. Tribes have not received funding through the grant program and have sought feedback but have been unable to

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 67 learn the reasons for not being funded. Several tribes received funding in subsequent years but not the first year and were unable to determine the reasons for not being funded the first year but funded the following year. Other tribes have lost funding through the programs and again were unable to learn the reasons for the loss in funding. Tribes also indicate there is a lack of criteria for funding through the FTA tribal transit program. Specific criteria had not been published by FTA and tribes have been uncertain as to what criteria they should meet in order to be funded. Many of the tribes interviewed expressed concern about the lack of consistency in funding through the tribal transit program. Several tribes have had to curtail service because funding was decreased in subsequent years even though the same amount had been requested. As more tribes have sought funding and implemented transit service, the limited funds available have had to support more tribes. While this was not cited as a specific barrier to starting a new transit service, it was acknowledged as a growing concern for tribes. Tribes have started questioning the sustainability of their programs if funding levels will fluctuate or decrease significantly in subsequent years. KEYS TO SUSTAINABILITY The information from tribes with successful transit programs pointed to several common themes as keys to their success. In most cases, the key to implementing a successful program incorporated all of these. As tribes consider developing or enhancing a transit program, these keys should be kept in mind. While the process described in this Guidebook will help in establishing a sustainable transit program, the path to sustainability will be found in these keys. Planning All successful tribal transit programs were implemented following some type of plan. However, the common theme that emerged is that the process of preparing a plan was as important, or more important, than the plan itself. Developing the plan required those involved to assess the needs for transit service and determine the best approaches to meet those needs. Existing resources were identified and additional resource requirements could be determined. As the plan was imple- mented, conditions inevitably were different, but having gone through the process allowed the key leadership to adjust to changing conditions. The planning process provides detailed information and “In preparing for battle I have always found that plans are useless, but planning is indispensable.” Dwight Eisenhower

Findings Chapter 2 Page 68 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report the tools to make decisions as the implementation steps are under- taken. Many of the tribes have received either funding or technical assistance for preparation of their plans. The Community Transpor- tation Association of America (CTAA) Tribal Technical Assistance Program and planning grants through the Federal Transit Administration (FTA) Tribal Transit Program were cited as very valuable in planning for a new transit service. These resources are described in Appendix B. Other tribes have received planning grants from their state department of transportation. Many tribes obtained assistance for preparing their plans, relying on expertise from professional transit planners. While not essential, assistance from experienced transit planners may provide insight and expertise not available locally. Local Leadership Strong local leadership has been proven to be essential for imple- menting and sustaining a transit program. Invariably, challenges and barriers will arise that may make implementation difficult. Having someone who is committed to success is vital. Every successful pro- gram attributed their success at least in part to having strong leader- ship within the tribe. As challenges and barriers arise, strong leader- ship will find ways to overcome the challenge. The leadership may be someone on tribal council, a tribal employee, or a tribal member. In some cases, the tribal elders have provided the leadership to ensure implementation of the service. Support from elected tribal officials is important to the sustainability and long-term success of a transit program. This support will facilitate approval of grant applications, development of agreements, coopera- tion from various tribal government departments, and tribal funding. When support is lacking, transit programs may lose support from one year to another and have significant challenges in sustaining the program. Support from Tribal Government Among many tribes, the tribal elders have significant influence on the decisions made by the elected officials. Strong support among tribal elders has been found to increase the level of support from the elected Support from Tribal Elders “Plans may not work, but planning does!” Mike Moritz, Sequoia

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 69 officials and is able to make the difference between having a transit program that is a priority or ending up with a transit program that lacks support and may not be sustained. Cooperation and Coordination Many of the successful transit programs have worked in cooperation with other transportation programs. In some cases these have been other transportation programs within the tribe, such as medical transportation or a tribal college. Other tribes have worked with non- tribal transit programs to coordinate schedules, allow transfers between systems, or establish a consolidated transit service. The Standing Rock Sioux transit system is operated by Sitting Bull College. The Con- federated Tribes of the Grand Ronde Community of Oregon primarily provide transportation by contracting on a government-to-government basis with the Salem Area Mass Transit District and Yamhill County Transit Area. The Coeur d’Alene Tribe in Idaho operates public transit for the urban area of Coeur d’Alene. Fort Belknap joined a regional partnership to provide transit service in north-central Montana. Cooperation and coordination of services have allowed tribes to pool existing resources and leverage those financial resources to obtain additional funding. Coordinated efforts result in greater efficiency in delivering service and often allows for a greater service area. Participation in state and national organizations—such as a state transit association, the Community Transportation Association of America, or the Intertribal Transportation Association—gives transit staff access to many resources. Tribes that have established successful transit programs have often been involved in these outside organiza- tions. Attendance at conferences and training programs helps tribal transit personnel develop the skills and expertise necessary to operate a good system. These organizations provide access to technical assistance as well. The Community Transportation Association of America (CTAA) and the National Rural Transit Assistance Program (RTAP) have training programs and technical assistance that have benefited many tribes with successful transit programs. Participation in State and National Organizations Interaction with other transit providers is another benefit of partici- pating in these organizations. The peer-to-peer connections that are established serve as a resource for tribal transit programs to increase expertise and obtain informal assistance.

Findings Chapter 2 Page 70 Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Trained Key Staff It is important to have key staff trained with the skills necessary to operate a transit program. Much of the training can be obtained through participation in state and national organizations. A key area where training is essential is in financial management. Tribes have failed to receive funding in subsequent years because the required reporting and draws on grants were not completed. While the money was being spent, the grants were not being used and the Federal Transit Administration did not approve additional funding because the records showed that the funds had not been used. Budgeting and financial reporting are essential to sustaining a transit program. If costs are not tracked and not known, the necessary revenue may not be available. A thorough understanding of financial management is critical to the long-term sustainability of a tribal transit program. Multiple Funding Sources Sustainability of a tribal transit program is linked directly to funding. The most successful tribal transit programs have obtained funding from a variety of sources. If one source of funding is reduced, the program does not suffer as much as if it relied only on that one source. Multiple sources of funding may also provide the opportunity to use some sources as local match for other sources of funding. The broader the range of funding sources, the more sustainable the transit program will be. A broad range of funding sources available to tribes is presented in Chapter 9 of the Guidebook. To ensure sustainability of funding and to advocate for tribal transit, it is important to inform and educate policy makers and elected officials about the importance and benefits of transit services. This is not only important at the local level, but at the state and federal levels as well. Funding for local transit service often comes from state and federal sources. Tribal officials should be active in ensuring that their representatives are well informed about the needs and benefits of transit.

Chapter 2 Findings Developing, Enhancing, and Sustaining Tribal Transit Services: Final Research Report Page 71 REFERENCES American Indian Disability Legislation Research, Rural Disability and Rehabilitation Research Progress Report #2, Research and Training Center on Disability in Rural Communities (RTC: Rural), (January 1999). http://rtc.ruralinstitute.umt.edu/Indian/AIDLReProgressRpt.htm (as of August 4, 2011).

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