TECHNICAL MEMORANDUM
DATE: March 16, 2023
TO: Boston Region Metropolitan Planning Organization
FROM: Sam Taylor, MPO Staff
RE: Transit
Safety Performance Targets and Requirements
While public transportation is among the safest surface transportation
modes in the United States, recent federal transportation legislation includes
specific mandates to strengthen the safety of transit systems.[1]
Under the Federal Transit Administration’s (FTA) Public Transportation Agency
Safety Plan (PTASP) Rule, applicable transit agencies are required to develop
safety plans that define how these agencies will implement Safety Management
Systems (SMS).[2]
These transit plans are required to include targets for performance measures
defined in the National Public Transportation Safety Plan, which relate to
fatalities, injuries, safety events, and system reliability.[3]
Metropolitan planning organizations (MPOs) are federally required to set
performance targets for these transit safety performance measures for their
regions, in coordination with transit and state agencies. These requirements
acknowledge the collaborative relationships needed to manage safety risks on
transit systems.
This memorandum summarizes federal transit safety performance
requirements and related planning activities conducted by applicable transit
agencies in the Boston region. It also describes federally defined transit
safety performance measures and the most recent set of transit safety targets
set by the Massachusetts Bay Transportation Authority (MBTA), the Cape Ann
Transportation Authority (CATA), and the MetroWest Regional Transit Authority
(MWRTA). Boston Region MPO staff proposes that the MPO board adopt these
targets as presented to serve as targets for the Boston region, and staff
requests that the board do so at its March 16, 2023, meeting. Finally, the
memorandum discusses next steps for the MPO to incorporate these targets into
its performance-based planning and programming process. These transit safety
performance activities support the MPO’s goal to make the region’s
transportation system safe and addresses related objectives:
The Moving Ahead for Progress in the 21st Century Act, which
was passed by Congress in 2012, created a new Public Transportation Agency
Safety Program.[4]
This new program resulted in several new FTA rulemakings:
The work of the Boston Region MPO relates most directly to the Transit
Asset Management and PTASP rules, as well as the Statewide and Nonmetropolitan
Transportation Planning and Metropolitan Transportation Planning rule, which
defines MPOs and states’ planning and performance management responsibilities.[5]
The TAM rule requires public transit providers, MPOs, and states to develop
targets for federally established transit asset performance measures in
coordination with one another, and the Boston Region MPO has adopted and
updated targets for these measures since 2018.[6]
The PTASP rule similarly requires transit providers, MPOs, and states to
develop targets for established transit safety measures.
The PTASP rule requires certain public transit operators that receive
federal funds from FTA’s Urbanized Area Formula Grants (Title 49, Section 5307,
of the US Code) or that operate rail systems subject to FTA’s State Safety
Oversight Program to develop agency safety plans (ASPs) that will support
implementation of Safety Management Systems (SMS).[7] A safety management system is a “formal,
top-down, organization-wide data-driven approach to managing safety risks and
assuring the effectiveness of safety risk mitigations” that “includes
systematic procedures, practices, and policies for managing risks and hazards.[8]
Examples of these components include protocols for reporting incidents and
specific methods for identifying, categorizing, and responding to safety risks.
Overall, these systems are designed to help transit agency leaders and
employees “control risk better, detect and correct safety problems earlier,
analyze safety data more effectively, and measure safety performance more
precisely.”[9]
Under the PTASP rule, transit providers are required to create ASPs that
describe the processes and procedures they will use to implement their SMS.[10]
Large bus and rail transit systems develop their own ASPs, while smaller
transit providers can work with their state department of transportation to
create their ASPs or choose to do it on their own. The content of these plans
is shaped by the National Public Transportation Safety Plan, which guides the
national effort to improve safety on public transportation systems. In general
ASPs define roles and responsibilities, and they discuss how transit agencies
will comply with federal, state, and local regulations and incorporate safety
best practices. They address the four main components of SMS, which include
safety management policies, safety risk management strategies, safety assurance
methods (which includes performance monitoring), and safety promotion (including
training and communication practices). These plans also describe performance
targets for federally required measures, which will be discussed in the next
section, and they may also discuss other measures the transit agency may use to
monitor its safety performance. Transit agencies must update and certify these
plans on an annual basis.
The National Public Transportation Safety Plan identifies safety
performance measurement as a key component of safety management processes. It
defines measures in four areas—fatalities, serious injuries, safety events, and
system reliability—that transit providers can use to understand their
performance and that the FTA and other federal agencies can use to understand
safety trends nationwide. Transit providers track performance in these areas by
transit modes, such as fixed-route bus service, light and heavy rail for rapid
transit systems, and demand response service. The ASPs and performance measures
do not apply to modes that fall under the jurisdiction of the Federal Railroad
Administration, such as commuter rail, or the US Coast Guard, which covers
ferries.[11]
These modes are subject to other federal safety requirements and management
processes.
Table 1 describes the measures discussed in transit agency ASPs. For all
measures except for the system reliability measure, the goal is to minimize the
value.
Table 1
Federally Required Transit Safety Performance Measures
Measure Category |
Measure |
Desired Direction |
Fatalities |
Total number of reportable fatalities |
Decrease |
Fatalities |
Fatality rate per total VRM
by mode |
Decrease |
Injuries |
Total number of reportable injuries |
Decrease |
Injuries |
Injury rate per total VRM by
mode |
Decrease |
Safety Events |
Total number of reportable safety events by mode |
Decrease |
Safety Events |
Rate of safety events per
total VRM by mode |
Decrease |
System Reliability |
Mean distance between major mechanical failures by mode |
Increase |
VRM = vehicle revenue-miles.
Several definitions, which relate to information that transit agencies need to report to the National Transit Database (NTD), apply to these performance measures[12]:
· Reportable fatalities: These include deaths (confirmed within 30 days) due to collision, derailment, fire, hazardous material spill, acts of God, system or personal security event, or other safety event. Fatalities resulting from illness or other natural causes (including those who have been found deceased) are excluded. The PTASP fatality measures also exclude deaths from trespassing or suicide.
· Reportable injuries: These include instances of damage or harm to persons that require immediate medical attention away from the scene because of a reportable transit safety event. Serious injuries, which are defined based on severity, are always reportable, even if a person was not immediately transported from the scene for medical attention. The PTASP injury measures exclude injuries resulting from assaults or other crimes.
· Reportable safety events: These include incidents (including accidents and derailments) meeting NTD major reporting thresholds for transit rail, bus, and paratransit. These events may occur on transit right-of-way or infrastructure, or at a transit revenue facility, maintenance facility, or rail yard. They may take place during a transit-related maintenance activity or otherwise involve a transit revenue vehicle. Examples of these events include
o collisions;
o fires;
o derailments (mainline and yard), including non-revenue vehicles;
o hazardous materials spills; and
o acts of God.[13]
NTD reporting thresholds for safety events are based on factors such as fatalities, injuries requiring immediate medical attention away from the scene, substantial damage, and evacuation for protection of life and safety reasons. Major security events, such as arson or hijacking, are not included in this measure.
· Major mechanical failures: The NTD defines major mechanical failures as “a failure of some mechanical element of the revenue vehicle that prevents the vehicle from completing a scheduled revenue trip or from starting the next scheduled revenue trip because actual movement is limited or because of safety concerns.”[14] For example, major mechanical failures on the bus network include breakdowns of brakes, doors, engine cooling systems, steering, axles, and suspension.[15]
Generally, transit agencies set safety performance targets for each applicable transit mode for the upcoming year. The FTA provides transit agencies with flexibility to set their targets to meet the specific context of their transit service. These agencies can choose (1) the reporting timeframe they use (calendar, fiscal, or NTD reporting year), (2) the vehicle-revenue-miles (VRM) denominator values that transit agencies use for the rate measures, and (3) the methodologies for picking a target value.[16] The FTA encourages transit providers to set realistic safety targets that consider relevant safety goals and objectives, but these providers have the latitude to set aspirational targets, targets that represent improvement over current safety performance levels, or targets that maintain current performance levels. The FTA has not established, and will not impose, penalties for transit agencies that do not meet their targets, which FTA reviews during a transit agency’s Triennial Review.
Like the TAM rule, the PTASP rule requires transit providers to make their safety performance targets available to states and MPOs. These providers must also coordinate with states and MPOs as these entities set their transit safety performance targets, to the maximum extent practicable. As part of this coordination, transit agencies may choose to use a particular year (calendar, fiscal, or NTD reporting year) or VRM denominator value (for reporting rate targets) at the request of states or MPOs.
MPOs must also incorporate these targets into their planning processes and documents, as is required for targets for all federal performance areas. In general, an MPO can consider how the projects and programs it selects to receive federal funding may improve transit safety outcomes. In the Boston Region MPO’s case, MPO board members can review projects and programs that the MBTA, CATA, and MWRTA submit for inclusion in the Transportation Improvement Program (TIP) in this context, and they can also consider how the MPO’s discretionary dollars can be used to reduce fatalities, injuries, safety events, and mechanical failures that may occur on the region’s transit systems.
In addition to integrating safety performance measures and targets into their planning processes, MPOs must also reflect them in their planning documents:
· MPOs must incorporate transit safety performance measures, baseline values, and targets in the system performance report included in their next Long-Range Transportation Plan (LRTP). Subsequent LRTPs must describe progress that has been made compared to the baseline values and targets recorded in prior system performance reports.
· When developing TIP documents, MPOs must describe transit safety measures and targets and, “to the maximum extent practicable, provide a description of the anticipated effect of the TIP toward achieving the performance targets identified in the metropolitan transportation plan,” the goal of which is to link investment priorities to those performance targets.[17]
MPOs must revisit their transit safety targets whenever the TIP or LRTP is updated, at which point the MPOs can decide to maintain or update the targets. MPOs will neither be penalized for not achieving regional transit safety performance targets nor rewarded for attaining them. The FTA will review MPO performance-based planning and programming activities, including those related to transit safety performance, as part of MPO certification reviews.
To meet federal transit safety requirements, the Boston Region MPO coordinates with the MBTA, CATA and MWRTA, which all receive FTA Urbanized Area Formula Grant funding and submit projects and programs to the MPO’s TIP. As previously mentioned, the FTA gives transit agencies flexibility when developing targets for their specific service areas. The MBTA, CATA, and MWRTA systems have distinct operating contexts that may shape their decisions when setting safety targets. In this case, each agency has taken a somewhat different approach to setting targets, so their targets are presented separately. MPO staff recommends adopting these transit agencies’ safety targets as presented, as they reflect each agency’s understanding of the factors that will affect safety outcomes in their service areas, including the characteristics of their local operating environments and contexts and planned investment, policies, and safety-management activities. This first set of targets will provide a baseline for future coordination on improving transit safety outcomes in the region.
The MBTA monitors performance and sets federally required targets for four modes: heavy rail (Red, Orange, and Blue Lines), light rail (Green Line and the Mattapan High Speed Line), bus, and The RIDE paratransit system. Based on calendar year (CY) 2019–21 averages, the MBTA runs approximately 1,897,000 VRM of service on its heavy rail system; 463,000 VRM on its light rail system; 1,925,000 VRM on its bus network; and 11,475,000 VRM for The RIDE. Its commuter rail network and ferry service are not subject to these FTA requirements and are addressed outside of the PTASP process.
Table 2 shows past averages for the federally required transit safety measures for MBTA heavy rail, light rail, bus, and The RIDE, based on data provided by the MBTA. These averages reflect safety data from CYs 2019 to 2021.
Table 2
Past Safety Performance Data for
MBTA Transit Services (CYs 2019–21
Averages)
MBTA Mode |
Average Fatalities |
Average
Fatality Rate |
Average Injuries |
Average Injury Rate |
Average Safety Events |
Average
Safety Event |
Average System Reliabilty Value (miles) |
Heavy Rail |
0.33 |
0.01 |
184 |
8.16 |
25 |
1.09 |
43,713.00 |
Light Rail |
0.00 |
0.00 |
81 |
14.64 |
28 |
5.04 |
7,515.00 |
Bus |
1.00 |
0.05 |
292 |
12.48 |
100 |
4.29 |
29,099.00 |
The RIDE |
0.00 |
0.00 |
27 |
2.31 |
21 |
1.77 |
61,231.00 |
CY = calendar year.
Source: MBTA.
The MBTA established performance targets for CY 2022 and chose to change these targets for CY 2023. These targets are shown in Table 3. When setting targets, the MBTA varied its approach by measure:
· Fatalities and Fatality Rates: The MBTA notes that fatality rates vary across modes due to the distinct operating environments and the inherent safety risk exposure associated with each mode.[18] The MBTA is committed to reducing the number of fatalities across its system to zero and continues to invest in proactive solutions to achieve this goal.[19]
· Injuries and Injury Rates: The MBTA developed its targets for CY 2023 for these two injury measures by assuming a two percent decrease in the injury rate per vehicle-miles traveled from the CYs 2019–21 average.
· Safety Events and Safety Event Rates: The MBTA established its CY 2023 targets for these two measures by assuming a two percent decrease in the safety event rate from the CYs 2019–21 average. The MBTA uses both proactive and reactive safety risk management strategies to reduce the rate of safety events on its system.[20]
· System Reliability: As previously mentioned, transit system reliability is measured by the mean number of VRM traveled between major mechanical failures. Overall, the MBTA plans to introduce new vehicles into its fleets on multiple modes over the next few years. As these new vehicles are brought into revenue service (once initial safety conditions are met), the MBTA will continue to monitor them. During this additional “burn-in” period, there may be a decrease in reliability. With this possibility in mind, the MBTA will strive to maintain the highest level of system reliability in CY 2023.[21]
Table 3
MBTA CY 2023 Safety Performance Targets Summary
MBTA Mode |
Fatalities Target |
Fatality Rate Target |
Injuries Target |
Injury Rate Target |
Safety Events Target |
Safety Event Target |
System Reliability Target (miles) |
Heavy Rail |
0.00 |
0.00 |
180.00 |
7.99 |
24.00 |
1.07 |
44,500.00 |
Light Rail |
0.00 |
0.00 |
79.00 |
14.35 |
27.00 |
4.94 |
7,650.00 |
Bus |
0.00 |
0.00 |
286.00 |
12.23 |
98.00 |
4.21 |
29,500.00 |
The RIDE |
0.00 |
0.00 |
27.00 |
2.27 |
20.00 |
1.74 |
62,500.00 |
CY = calendar year.
Source: MBTA.
CATA monitors performance and sets federally required targets for its fixed-route bus service and its demand response service. According to averages calculated using CYs 2018–22 data, CATA’s demand response system runs about 136,000 VRM annually, and its fixed-route bus system runs about 279,000 VRM annually. CATA has established targets for state fiscal year (SFY) 2023 (July 2022 to June 2023), and it expresses its rate targets per one million vehicle-miles traveled.
Table 4 shows past averages for the federally required transit safety measures for CATA’s fixed-route and demand response services. While this historic data is shown in calendar years, as opposed to state fiscal years, this table does provide details about expected fatalities, injuries, safety events and expected system reliability within a 12-month period. The table provides CYs 2018–22 averages for the fatality, injury and safety event measures, and system reliability measure.[22]
Table 4
Past Safety Performance Data for CATA Transit Services (in CY Averages)
CATA Mode |
2018–22 Average
Fatalities |
2018–22 Average Fatality Rate |
2018–22 Average Injuries |
2018–22 Average Injury Rate |
2018–22 Average Safety Events |
2018–22 Average
Safety Event Rate |
2018–22 Average System Reliabilty Value (miles)* |
Fixed- Route Bus |
0.0 |
0.0 |
0.2 |
0.1 |
2.4 |
0.2 |
73,603 |
Demand Response |
0.0 |
0.0 |
0.2 |
0.2 |
1.2 |
0.8 |
133,848 |
* Average System Reliability does not include CY 2022, since major mechanical failure data was not available at the time of the presentation.
CATA = Cape Ann Transportation Authority. CY = calendar year.
Source: CATA.
In general, CATA used past data and averages as the basis for determining its transit safety performance targets. When CATA set targets, it reviewed data for years when injuries or safety events did take place and reflected those values when setting injury and safety event rate targets for SFY 2023. Table 5 provides a summary of CATA’s SFY 2023 performance targets.
Table 5
CATA SFY 2023 Safety Performance Targets Summary
CATA Mode |
Fatalities Target |
Fatality Rate Target |
Injuries Target |
Injury Rate Target |
Safety Events Target |
Safety Event Target |
System Reliabilty Target (miles) |
Fixed- Route Bus |
0.0 |
0.0 |
1.0 |
0.5 |
2.5 |
1.5 |
70,000 |
Demand Response |
0.0 |
0.0 |
1.0 |
0.5 |
1.5 |
1.0 |
135,000 |
CATA = Cape Ann Transportation Authority. SFY = state fiscal year.
Source: CATA.
Like CATA, MWRTA monitors performance and sets federally required targets for fixed-route bus service and demand response services, and the agency has set targets for SFY 2023. However, MWRTA expresses its fatality, injury, and safety event rates per one hundred thousand vehicle revenue-miles to align with data that it reports to the Massachusetts Department of Transportation (MassDOT). MWRTA runs, on average, approximately 1,124,000 VRM of fixed-route service per calendar year and approximately 843,000 VRM of demand response service per calendar year, based on NTD safety data for CYs 2018–22.
Table 6 shows past averages for the federally required transit safety measures for MWRTA’s fixed-route and demand response services in calendar year format, which is similar to the data presented for the MBTA and CATA. As with the data shown for CATA, this NTD data is shown in calendar years, as opposed to state fiscal years, but it does provide details about expected fatalities, injuries, safety events and expected system reliability within a 12-month period. As previously mentioned, MWRTA’s rate values are expressed in 100,000 VRM.
Table 6
Past Safety Performance Data for
MWRTA Transit Services (CYs 2018–22 Averages)
MWRTA Mode |
2018–22 Average Fatalities |
2018–22 Average
Fatality Rate |
2018–22 Average Injuries |
2018–22 Average
Injury Rate |
2018–22 Average Safety
Events |
2018–22 Average
Safety Event Rate |
2018–21 Average System Reliabilty Value (miles)* |
Fixed- Route Bus |
0.0 |
0.0 |
0.6 |
0.05 |
1.4 |
0.13 |
128,551 |
Demand Response |
0.0 |
0.0 |
0.6 |
0.07 |
1.6 |
0.20 |
67,468 |
* Average System Reliability does not include CY 2022, since major mechanical failure data was not available at the time of the presentation. Average System Reliability Value is adjusted for fiscal year, not calendar year.
CY = calendar year. MWRTA = MetroWest Regional Transit Authority.
Source: MWRTA.
Table 7 provides a summary of MWRTA’s SFY 2023 performance targets. MWRTA sought to set attainable values for these federally required performance measures. These target values maintain zero fatalities on MWRTA’s fixed-route bus and demand response systems and are somewhat higher than recent actual values for other performance measures.
Table 7
MWRTA SFY 2023 Safety Performance Targets Summary
MWRTA Mode |
Fatalities Target |
Fatality Rate Target |
Injuries Target |
Injury Rate Target |
Safety Events Target |
Safety Event Target |
System Reliability Target (miles) |
Fixed- Route Bus |
0.00 |
0.00 |
12.00 |
1.00 |
15.00 |
1.25 |
75,000.00 |
Demand Response |
0.00 |
0.00 |
8.00 |
1.00 |
10.00 |
1.25 |
75,000.00 |
MWRTA = MetroWest Regional Transit Authority. SFY = state fiscal year.
Source: MWRTA.
MPO staff recommends that the Boston Region MPO vote to adopt this set of MBTA, CATA, and MWRTA performance targets for the Boston region. As previously mentioned, each agency’s set of targets reflect its operating context and anticipated safety-related investments, policies, and safety management activities. Should the MPO adopt this set of transit agency targets as its regional targets, staff will present and describe these targets in the performance chapters of the FFYs 2024–28 TIP document. Going forward, the MPO will work with transit agencies and MassDOT to use transit performance measures and targets to monitor transit safety outcomes in the region, and to consider what effect the transit programs and projects proposed for the MPO’s TIP will have on safety outcomes on the region’s transit systems.
The Boston Region Metropolitan Planning
Organization (MPO) operates its programs, services, and activities in
compliance with federal nondiscrimination laws including Title VI of the
Civil Rights Act of 1964 (Title VI), the Civil Rights Restoration Act of 1987,
and related statutes and regulations. Title VI prohibits discrimination in
federally assisted programs and requires that no person in the United States
of America shall, on the grounds of race, color, or national origin
(including limited English proficiency), be excluded from participation in,
denied the benefits of, or be otherwise subjected to discrimination under any
program or activity that receives federal assistance. Related federal
nondiscrimination laws administered by the Federal Highway Administration,
Federal Transit Administration, or both, prohibit discrimination on the basis
of age, sex, and disability. The Boston Region MPO considers these protected
populations in its Title VI Programs, consistent with federal interpretation
and administration. In addition, the Boston Region MPO provides meaningful
access to its programs, services, and activities to individuals with limited
English proficiency, in compliance with U.S. Department of Transportation
policy and guidance on federal Executive Order 13166. The Boston Region MPO also complies with the
Massachusetts Public Accommodation Law, M.G.L. c 272 sections 92a, 98, 98a,
which prohibits making any distinction, discrimination, or restriction in
admission to, or treatment in a place of public accommodation based on race,
color, religious creed, national origin, sex, sexual orientation, disability,
or ancestry. Likewise, the Boston Region MPO complies with the Governor's
Executive Order 526, section 4, which requires that all programs, activities,
and services provided, performed, licensed, chartered, funded, regulated, or
contracted for by the state shall be conducted without unlawful
discrimination based on race, color, age, gender, ethnicity, sexual
orientation, gender identity or expression, religion, creed, ancestry,
national origin, disability, veteran's status (including Vietnam-era
veterans), or background. A complaint form and additional information can be
obtained by contacting the MPO or at http://www.bostonmpo.org/mpo_non_discrimination. To
request this information in a different language or in an accessible format,
please contact Title VI Specialist By Telephone: For people with hearing or speaking
difficulties, connect through the state MassRelay service: ·
Relay Using
TTY or Hearing Carry-over: 800.439.2370 ·
Relay Using
Voice Carry-over: 866.887.6619 ·
Relay Using
Text to Speech: 866.645.9870 For more information, including
numbers for Spanish speakers, visit https://www.mass.gov/massrelay. |
[1] Bureau of Transportation Statistics, Transportation Statistics Annual Report 2022 (2022), pgs. 5-1 to 5-29, accessed February 23, 2023, at https://rosap.ntl.bts.gov/view/dot/65841.
[2]
Title 49, Part 673, of the Code of Federal Regulations.
[3] Federal Transit Administration, National Public Transportation Safety Plan (January 2017), accessed February 23, 2023, at https://www.transit.dot.gov/regulations-and-guidance/safety/national-public-transportation-safety-plan.
[4] MBTA, MBTA Transit Safety Plan (June 15, 2020), pg. 23.
[5]
The Statewide and Nonmetropolitan Transportation Planning and Metropolitan
Transportation Planning rule is codified in 23 CFR Part 450, 23 CFR Part 771,
and 49 CFR Part 613.
[6] Information about the MPO’s current and past TAM targets is available at bostonmpo.org/performance.
[7]
The FTA is deferring applicability of PTASP requirements for operators that
only receive funds through FTA’s Enhanced Mobility of Seniors and Individuals
with Disabilities Formula Program (Section 5310) and/or Rural Area Formula
Program (Section 5311). For more information, visit transit.dot.gov/PTASP.
[8]
MBTA Transit Safety Plan, pg. 14.
[9]
FTA, “PTASP Frequently Asked Questions” (July 7, 2022), accessed February 23,
2023, at transit.dot.gov/PTASP-FAQs.
[10] MBTA, CATA, and MWRTA ASPs are available on the March 16, 2023, page of the MPO meeting calendar. See https://www.ctps.org/calendar/day/20230316.
[11]
FTA, “PTASP Frequently Asked Questions.”
[12] See the NTD Safety and Security Policy Manual, January 2022, available at https://www.transit.dot.gov/sites/fta.dot.gov/files/2022-02/2022%20Safety%20and%20Security%20Policy%20Manual%20Version%201.0_0.pdf
[13] FTA, National Transit Database Safety and Security Policy Manual (January 2022), pg. 26, accessed February 23, 2023, at https://www.transit.dot.gov/sites/fta.dot.gov/files/2022-02/2022%20Safety%20and%20Security%20Policy%20Manual%20Version%201.0_0.pdf.
[14]
FTA, “Safety Performance Target Fact Sheet,” pg. 2.
[15] MBTA Transit Safety Plan, pg. 39.
[16] FTA, “Safety Performance Target Fact Sheet,” pg. 1.
[17] 23 CFR Part 450.326.
[18] MBTA Transit Safety Plan, pg. 37.
[19] MBTA Transit Safety Plan, pg. 37.
[20] MBTA Transit Safety Plan, pg. 39.
[21] MBTA Transit Safety Plan, pg. 40.
[22] CATA’s rate measures are expressed per one million VRM. CATA runs fewer than one million VRM on each of its services, which can result in the target year fatality rate appearing larger than the number of injuries expected to happen in that year.