Comment from Jacob Wasserman

Jacob WassermanSupportIndividual
Summary: The commenter, submitting on their own behalf, provides a research report from the UCLA Institute of Transportation Studies regarding gaps in public transit ridership data. They argue for clearer labeling of "report years" in the National Transit Database (NTD) and suggest requiring agencies to report calendar year or standardized fiscal year totals to improve data comparability.
Comment submitted on my own behalf, not representing my employer or any other affiliation: Adapted from: Wasserman, J., and Taylor, B. (2021, January 20). Sources of and Gaps in Data for Understanding Public Transit Ridership (UC-ITS-2020-33). UCLA Institute of Transportation Studies. https://doi.org/10.17610/t66893. One major caveat in the annual time series data in the NTD concerns how years are reported. NTD data appear, at first glance, to break down data by calendar year, and that is how many reports and public uses of the data treat them. For instance, the American Society of Civil Engineers' Infrastructure Report Card uses the NTD annual time series figure for total trips by calendar year. However, years in the NTD data are not actually calendar years; they are instead "report years" or "reporting years." Report Year 2018—most often labeled simply as "2018" in NTD datasets—is in fact the aggregate of each agency’s fiscal year ending in 2018. Across operators in the NTD, there were ten different fiscal year end dates in Report Year 2018. For almost six in ten operators, the data given for Report Year 2018 cover a timespan more than half in calendar year 2017. Thus, the annual national totals in each database aggregate different periods of time for different agencies, complicating comparisons between operators. For example, NTD totals for Report Year 2020 combine some operator fiscal years that ended before the COVID-19 pandemic or just after its onset and other operator fiscal years that occurred almost entirely during the pandemic. Given the pandemic’s significant negative effects on transit use, this truly makes for an apples-and-oranges comparison. To be sure, the dataset includes an explanation of "report years" in its data documentation, but I suggest clearer labeling throughout the data. If possible, the NTD could also require all agencies to report calendar year or standardized fiscal year (July 1st to June 30th) totals instead of or in addition to their particular reporting year totals.

View on Regulations.gov