Analysis · Charter Rule

120 Buses for 1,660 Fans. Who Pays for the Empty Seats?

The Jacksonville Transportation Authority asked private operators to commit to a fleet that would run barely a quarter full. Federal transit dollars paid for the difference. This is what happens when a transit agency runs a special-event shuttle.

By Kumar Shah, President & CEO, Accelar, Inc. dba Pronto Corporation · FTA Charter Registration ID 6643 · 5 October 2026

Start with the arithmetic, because everything else follows from it.

On 21 July 2026, JTA issued a federal Charter Service Notice for Jacksonville Jaguars game-day shuttle service and asked interested private operators to confirm they could field up to 120 buses . When the City of Jacksonville was later asked to state the requirement plainly, it said 70 buses, running continually — and added that “ridership could potentially be low but they still must run continually.”

JTA's own ridership records, produced to us on 7 August, show the average Jaguars game carries 1,660 riders .

Fourteen people on a fifty-five-seat motorcoach. Even at the City's lower figure, fewer than twenty-four. These are not buses that fill at the peak and run light at the margins. These are buses that run three-quarters empty all day, by design, because the design never asked how many people were coming.

No transit agency covers its costs at the farebox. This isn't close.

Every transit agency in America runs its scheduled service at a loss and makes it up from public subsidy. That is a reasonable bargain: a route serving people with no other way to get to work is worth paying for whether or not the fares cover it. That bargain does not extend to a quarter-full coach taking football fans to a stadium.

JTA's own revenue records show $379,995 from Gameday Xpress across the 2025–26 season — roughly $32,000 for an event day on which it fields a fleet of this size. Anyone who has priced a motorcoach for a day knows what the other side of that ledger looks like. The gap is not a rounding error and it is not covered by the fare. It is covered by the public.

And the fare is already a premium one. JTA charges $10 round trip from its downtown lots and $15 from the suburban lots. Its ordinary fixed-route round-trip fare is $3.50 . Fans are paying 2.9 to 4.3 times the standard fare — and the service still loses money, because the buses are empty.

This is what a transit agency produces when you ask it to run a special event

None of this means anyone at JTA is bad at their job. It means the wrong tool was picked up.

A transit agency is built for fixed routes and fixed schedules. Its competence is putting a bus at the same corner at the same minute every day, whether or not anyone is standing there. That reliability is the product, and nobody minds the quiet hour at ten in the morning.

Special-event demand is the opposite shape — it varies enormously by lot, by game, by kickoff time and by direction. On JTA's own figures one lot carries nearly half the riders and another carries four per cent. A noon kickoff is not a Monday night. Inbound spreads across two hours; outbound happens all at once.

Apply a fixed-schedule model to that and there is only one way to avoid leaving people behind: put enough buses out to cover the busiest possible moment at every location, and run them all day regardless. That is precisely what the City described. Seventy buses, continually, ridership may be low, run them anyway.

You would build a service this way if money were no object. You would build it this way if the point were to generate the maximum number of paid operating hours. You would not build it this way if you had to meet a payroll out of the fares.

A private operator who ran it this way would be out of business inside a season

No private motorcoach company could operate Gameday Xpress as JTA operates it and survive. Not one. The losses are structural — built into the decision to run empty vehicles on a fixed loop — and no amount of good management closes that gap.

So a private operator is asked to bid against a competitor who does not have to be solvent. That is the exact distortion the Federal Charter Service Rule was written to prevent: not an agency doing something malicious, but an agency doing something a business cannot do, because it is spending someone else's money in a market where businesses are trying to compete.

The money was never meant for this

Here is why this is a federal matter and not simply a local one.

The buses, the facilities and a share of the operating budget behind Gameday Xpress were funded to move the public on scheduled transit. The Charter Service Rule, 49 C.F.R. Part 604, exists to stop that funding being turned on the private charter market. Section 604.3(c)(2) defines charter service as transportation for events on an irregular basis where a premium fare is charged or a third party pays.

Gameday Xpress meets every element of that definition, on JTA's own published facts:

None of this is a novel reading of the rule. In August 2012 Accelar asked the Federal Transit Administration whether San Francisco's Muni express buses to Candlestick Park on 49ers game days — the 75X, 77X, 78X and 79X — were charter service. SFMTA's answer was the answer JTA gives now: these are our buses, this is our city, and we have run them this way since 1971. On 10 April 2013 the FTA's Chief Counsel ruled against it (Docket No. FTA-2007-0023). Forty years of practice was not a defence, and the $12 round trip was a premium fare . The service was charter service, and operating it with federally supported assets in competition with registered private operators was a violation of Part 604.

Jacksonville is the same case with worse arithmetic. We set out that decision and the others alongside it in What the FTA Has Already Decided About Game-Day Shuttles.

Pronto contends that running this service with federally supported resources, at a premium fare, in competition with registered private providers, is a violation of Part 604. We served a Notice of Charter Rule Violation and Cease and Desist on JTA on 30 September, copied to the City of Jacksonville and to the Federal Transit Administration.

And then they closed the door on the alternative

The last part is the one that should trouble anyone who cares about public money being spent well.

When the City finally specified what it wanted, it included this: “no pre-registration requirement is allowed.”

Advance booking is the entire answer to this problem. When a fan reserves a seat on a named departure, the operator knows exactly how many vehicles each lot needs, at what time, in each direction. Vehicles run full. Nobody circles an empty loop. The same crowd moves on a fraction of the fleet, at a fraction of the cost, and every passenger has a seat waiting instead of a queue to join.

Barring pre-registration does not express a preference. It writes the private operator's entire advantage out of the requirement , and then prices the job on the fleet that becomes necessary once you have done so. The 120 buses are not unrelated to the ban on booking. They are what the ban on booking costs.

So a private company brings a model that moves the same fans for a great deal less public money, and the specification rules it out before anyone has to argue the merits. That is not protecting a service. That is protecting a way of doing things.

This is not a theory. It is running right now.

Pronto operates the University of Nebraska game-day shuttle in Lincoln. The City of Lincoln issued its charter notice in August, we answered that we were ready, StarTran stood aside from a shuttle it had run for more than forty-five years, and the City announced the change itself on 26 August. We launched fifteen days later and have carried fans to every home game since.

For Jacksonville the plan is already published. For the 1 November game against the Colts, our portal shows:

Every departure has a time, a boarding point, a code and a seat count. Every seat is reserved and paid before the coach moves. Nobody stands, nobody waits for the next one, and nothing runs empty — because we know who is coming before the day begins.

Eighteen coaches. Not a hundred and twenty, and not seventy. Eighteen — because each one runs a full load, turns round, and runs another, instead of circling a loop with fourteen people aboard.

Same stadium. Same crowd. Same Sunday. Six and a half times the work out of every vehicle — and 3,465 published seats, more than twice what an average Jaguars game needs, every one of them reserved before the coach moves.

What we are asking for

We are asking the Jacksonville Transportation Authority to do what the City of Lincoln did: stand aside and let the registered private operator that answered its notice run the service. That is not a favour. It is what Part 604 provides for, and it is what the Charter Rule exists to deliver.

Jaguars fans get a better ride. Private operators get the market federal law already reserves for them. And the public stops paying to move fourteen people on a fifty-five-seat coach.

Sources. JTA Charter Service Notice, 21 July 2026. Correspondence between Pronto Corporation and the Jacksonville Transportation Authority, 21 July to 7 August 2026. Correspondence with the City of Jacksonville Office of Sports & Entertainment, 30 July 2026. Records produced by JTA under Florida's public-records law, 7 August 2026, including season ridership by lot and a four-season revenue summary. JTA published fares, jtafla.com. Pronto's Notice of Charter Rule Violation and Cease and Desist, 30 September 2026. 49 C.F.R. Part 604. Federal Transit Administration, Office of Chief Counsel determination concerning the San Francisco Municipal Transportation Agency, Docket No. FTA-2007-0023, 10 April 2013.

Average ridership of 1,660 is the mean of the eight regular-season Jaguars games in JTA's own ridership file. Individual employee names appearing in the records produced to Pronto have been withheld.

Accelar, Inc. dba Pronto Corporation · FTA Charter Registration ID 6643 · iPronto.com/newsroom · Jacksonville schedules and booking: iPronto.com/jacksonville-jaguars