title vi and public transit service and fare equity analyses apta marketing seminar february 2015
TRANSCRIPT
Title VI and Public Transit
Service and Fare Equity Analyses
APTA Marketing SeminarFebruary 2015
Title VI and Public Transit
Title VI Basic Principles
• Civil Rights Act of 1964 product of nationwide movement against racial discrimination
• Kennedy identified “simple justice” as justification for Title VI
• Section 601 defines non-discrimination;
• Section 602 directs agencies (FTA) to institute the principles, and to take action against non-compliant recipients
2
“No person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied benefits of, or be subjected to discrimination
under any program or activity receiving Federal financial assistance.”
Title VI and Public Transit
Definitions – Beneficiary
• Beneficiary – individuals or entities that directly or indirectly receive an advantage through a Federal program
Conduct is not subject to nor covered by Title VI
Compliance with Title VI is not a condition to receive assistance
Beneficiaries are not protected by Title VI from actions of others not receiving Federal financial assistance
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Title VI and Public Transit
Disparate Treatment
Disparate treatment – actions that result in circumstances where similarly situated persons are intentionally treated differently (i.e., less favorably) than others because of their race, color, or national origin
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Title VI and Public Transit
Disparate Impact
Disparate impact – a facially neutral policy or practice that disproportionately affects members of a group identified by race, color, or national origin, where the recipient’s policy or practice lacks a substantial legitimate justification and where there exists one or more alternatives that would serve the same legitimate objectives but with less disproportionate effect on the basis of race, color, or national origin
6
Title VI and Public Transit
Disparate Impact – ExamplesScenario Yes No
Bus shelter placement based on advertising revenue potential
Clean-fuel vehicles to non-minority areas
Bus line gets rerouted to serve low-income area that was previously underserved
Fixed guideway in minority area, but does not include stations or comparable amenities
Service reductions or fare increases that disproportionately effect minorities
Signs about service changes are placed evenly throughout the service area
Title VI and Public Transit
Disproportionate Burden
Disproportionate burden – a neutral policy or practice that disproportionately affects low-income populations more than non-low-income populations. A finding of disproportionate burden requires the recipient to evaluate alternatives and mitigate burdens where practicable
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Title VI Requirements and Guidelines for
Recipients
Title VI and Public Transit
Organization of Circular• Chapter I: Introduction and
Background
• Chapter II: Program Overview
• Chapter III: General Requirements and Guidelines
• Chapter IV: Requirements and Guidelines for Fixed Route Transit Providers
• Chapter V: Requirements for States
• Chapter VI: Requirements for MPOs
• Chapter VII: Effectuating Compliance with DOT Title VI Regulations
• Chapter VIII: Compliance Reviews
• Chapter IX: Complaints
• Appendices
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Title VI and Public Transit
Submitting Title VI Program
• All primary recipients must submit Title VI Program every three years (TEAM)
• Title VI Program must be approved by grantee’s Board of Directors or appropriate governing entity (including sub-recipients) and submit documentation of such action
• Title VI Programs will be due 60 days prior to expiration dates
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Title VI and Public Transit
Board Communication
There are several areas where you will need Board approval:
• The Title VI Program of all recipients and sub-recipients
• Certain elements within the Title VI Program must be approved; Service standards (for all Transit Providers) Major service change policy, disparate impact
policy and disproportionate burden policy Results of any service and fare equity analyses Results of service monitoring
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Title VI and Public Transit
Contents of the Title VI Program
Additional requirements for transit providers that operate 50 or more fixed route vehicles in peak service and are located in a large UZA:
a. A demographic analysis of the transit provider’s service area.
b. Data regarding customer demographics and travel patterns;
c. Results of the monitoring program of service standards and policies and any action taken
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Title VI and Public Transit
Contents of the Title VI Program, cont.
d. A description of the public engagement process for “major service change policy” and disparate impact policy;
e. A copy of board meeting minutes/resolution;
f. Results of equity analyses;
g. A copy of board meeting minutes or a resolution demonstrating consideration, awareness, and approval of the equity analyses
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Title VI and Public Transit
Requirements for Fixed Route Transit Providers
1.
2.
3.
4.
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Service Equity Analysis
Title VI and Public Transit
Overview
• Describe FTA’s role in reviewing the methodology
• Data used and why
• Step-by-step illustrations on a service equity analysis
• Examples are for ILLUSTRATIVE PURPOSES ONLY
• Examples will use population data or ridership data
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Title VI and Public Transit
Analysis Submission and Assistance
• Service Equity analyses are part of your Title VI program if you are a transit provider with 50 or more fixed route vehicles in peak service located in a UZA of 200,000+ population
• FTA regions can provide technical assistance on the methodology to examine whether the analysis is properly documented prior to Board Action
After Board Approval, FTA will not provide technical assistance
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What Should be Included in Service
Equity AnalysisRequirements and
Guidelines
Title VI and Public Transit
Chapter IV Requirements for Fixed Route• “Major Service Change” policy defined
• Describe how proposed service change meets your definition of a major service change as defined in your Title VI Program
• Analysis Framework:
Data Set(s) described
Comparison analysis
• Comparison of impacts using population data around impacted routes to population of service area
• Comparison of impacts using ridership data of impacted routes to ridership of service area
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Title VI and Public Transit
Chapter IV Requirements for Fixed Route
Analysis should include:
• Step-by step analytical methodology
• Overlay maps if using population data
• Accompanied by the tables describing impacts
• Narrative of method of analysis
• Applies “adverse effects” definition consistently
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Title VI and Public Transit
Chapter IV Requirements for Fixed Route
Analysis should include:
• Applies “disparate impact/disproportionate burden policy” consistently
• Provides a conclusion (e.g., whether there is disparate impact or not)
• If there is a disparate impact, the legal test must be properly documented
• If there is a disproportionate burden, take steps to avoid, minimize or mitigate impacts where practicable
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Title VI and Public Transit
What is the proper analysis?
Disparate Impact
Analysis
Disparate Impact
Analysis
Disproportionate Burden
Analysis
Minority population
only (no low-income
population)
Minority population that is also low income
Low-income population only (no minority
population)
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Title VI and Public Transit
Consistent Disparate Impact Policy
• Policy is clearly stated• Consistent with the policy in your approved
Title VI program• Application is mathematically consistent
throughout the analysis• Disparate impact policy defines a
material difference May be presented as a statistical percentage
of impacts borne by minority populations Has to pass the “so what” test
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Title VI and Public Transit
Example – Disparate Impact Policy
• Disparate Impact Policy is a policy where the change is deemed materially different:
Our Sample agency has defined its disparate impact policy to be ±2% statistical difference between the effects on minorities compared to the impacts borne by non-minority passengers:
• Material differences like this must be applied to system-wide demographics to a) individual routes and b) routes cumulatively
25
Title VI and Public Transit
Example – Disproportionate Burden Policy
• Disproportionate Burden Policy is a policy where the change is deemed materially different on low-income populations
Our Sample agency has defined its disproportionate burden policy as ±2% statistical difference between the effects on low-income populations compared to the impacts borne by non-low-income passengers:
• Material difference will apply system-wide demographics to a) individual routes and b) routes cumulatively
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Title VI and Public Transit
Disproportionate Burden Policy
• “Low income” should be defined:
Department of Health and Human Services definition can be found at aspe.hhs.gov/poverty
Your definition may be more inclusive, but not less
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Title VI and Public Transit
Public Participation• Public participation activities provide more value when they are open,
relevant, timely, and appropriate for the intended goal of the public involvement process.
• The public, in any one area or jurisdiction, may hold a diverse array of views and concerns on issues pertaining to their own specific transportation needs.
Conducting meaningful public participation involves seeking public input at specific and key points in the decision-making process issues where such input has a real potential to help shape the final decision or set of actions.
• Early and continuous public involvement brings diverse viewpoints and values into the decision-making process.
• Successful public participation is a continuous process that is system-wide and consists of a series of activities and actions to both inform the public and stakeholders and to obtain input from them which influence decisions that affect their lives.
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Title VI and Public Transit
Example – Major Service Change Policy
Definition:
• The establishment of new bus or rail routes
• A reduction of service on a given route of more than 20% of its route miles on any bus or rail route
• The elimination of any bus or rail service
• A major modification that results in a 25% or greater reduction in the number of daily service hours provided
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Title VI and Public Transit
Example – Aggregate Service Changes
Year RoutePercentage of Service
Reduction (Route Miles)
2012 B-17 10%
2013 B-17 15%
2014 B-17 10%
Total B-17 35%
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Title VI and Public Transit
Example – Adverse EffectsImpacts in relation to “Major Service Change”
• Consider the degree of adverse effects/impacts, and analyze those impacts when planning changes.
• Analysis between existing and proposed service changes:
Service changes that reduce service (eliminate route, removing trips on a route, changing span of service)
Service changes that change the frequency of service (headway changes)
Disparate impact analysis should consider the degree of adverse affects
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Title VI and Public Transit
Example – Disparate Impact Finding
If a disparate impact is found, the transit provider may implement the service change only if:
• “…the recipient (1) has a substantial legitimate justification for the proposed service change; and (2) the transit provider can show that there are no alternatives that would have a less disparate impact on minority riders but would still accomplish the transit provider’s legitimate program goals.”
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Collect and Report Data
Title VI and Public Transit
Pre-Analysis Considerations
Population
• Compares the population in Census blocks or block groups served by the affected route(s) with the population of the service area
Ridership
• Compares the ridership of the affected route(s) with the ridership of the system
What datasets will you use?
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Title VI and Public Transit
Clear Analytical Approach • Dataset(s) in the analysis must be clear (using either
population or ridership data), and include reasons for the dataset(s) chosen, and techniques for collecting the data
• If agency uses population data, it must describe the geographic level used to measure minority and low-income concentrations (Census tract, block, or Traffic Analysis Zone (TAZ) to compare with population of service area)
• If agency uses ridership data, it must describe the routes impacted and the minority and low-income concentrations (to compare to system-wide ridership)
A Traffic Analysis Zone (TAZ) is a special area delineated by state and/or local officials for tabulating traffic-related data
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Title VI and Public Transit
Pre-Analysis Considerations
• If using population data, at which geographic level will you measure minority and low-income concentrations?
Census blocks, block groups, tracts
Traffic analysis zones
• Describe reasons for your choice and techniques/technologies used to collect data
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Title VI and Public Transit
Determining Data for GIS Analysis
• Obtain Block, Census tract, or Traffic Analysis Zone-level Household data
Race and ethnicity
Income
National origin
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Title VI and Public Transit
Assemble Necessary Data
• Demographic Data
U.S. Census
Local Data
• Ridership Data
Transit Rider Origin and Destination Surveys
• GIS Layers
Census Block
Census Tract
Traffic Analysis Zone (TAZ)
Route maps
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Title VI and Public Transit
Ridership Data for Rider Analysis
• Identify transit riders using affected routes
Route change
Headway change
Span of service change
Route elimination
• Identify minority and low-income riders
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Evaluate Service and Fare Equity Changes
Title VI and Public Transit
Assessing Impacts
• Assess impacts on minority and low-income populations at GIS level:
Maps of proposed changes and demographic data will assist in this analysis
• Tables showing impacts of each type of route or service change (routing frequency, span of service, addition or elimination of routes)
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Examples
NOTE: The following examples are for illustrative purposes
ONLY; to assist you in understanding
course concepts
Title VI and Public Transit
Service Equity Analysis Framework• Evaluate service change impacts on minority and low-income
populations separately
• Using the following framework:
Requirement 1: Develop Disparate Impact Policy and Disproportionate Burden Policy with Public Participation
Requirement 2: Analyze data
Requirement 3: Assess Impacts
• If there is a potential disparate impact or disproportionate burden:
Modify Proposal if Necessary
Finding a Disparate Impact
Examining Alternatives
Finding a Disproportionate Burden
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Example – Assessing Service with Population
Data
NOTE: The following examples are for illustrative purposes ONLY;
to assist you in understanding course concepts
Title VI and Public Transit
Example A: 11-County Area
MWRTA, MA – Area Map
Metro West Regional Transit Authority (MWRTA) Data
Total Pop = 242,916
Total HH = 97,524
Minority Pop = 50,829
Median HH Income = $93,000
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Example A: 11-County Area
Set System-Wide Standards and Policies
Title VI and Public Transit
Agency Policies
• These policies are set and approved by the Agency Board:
Low-Income Threshold: 60% of Median Household Income
Disproportionate Burden Policy: ±2%
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Title VI and Public Transit
Thresholds
• Minority: 50,829 people = 21% of population
• Low-Income Threshold: 60% of Median Household Income = $57,000
• 18% of population is low-income
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Example A: 11-County Area
Collect and Report Data
Title VI and Public Transit
MWRTA Transit System Map
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Title VI and Public Transit
GIS Analysis – Transit Network LayerMap existing transit routes on TAZ layer
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Title VI and Public Transit
GIS Analysis – Low Income Areas
Map of low-income areas
Low-income threshold is 18% of regional population
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Title VI and Public Transit
GIS Analysis
Transit routes on low-income areas
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Title VI and Public Transit
Minority threshold of 21% determined by total service area population
GIS Analysis – Minority Areas
Map of minority areas
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Title VI and Public Transit
GIS Analysis
Transit routes on minority areas
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Example A: 11-County Area
Evaluate Service and Fare Equity Changes
Title VI and Public Transit
Service Change
Analysis must identify impacts of service change to:
• Low-income and minority populations
• Population around impacted transit routes as compared to population of service area
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Title VI and Public Transit
GIS Analysis
Overlay affected routes to identify low-income TAZs
• ¼ mile buffer is used to identify the affected population
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Title VI and Public Transit
GIS Analysis
Eliminated routes on minority TAZs
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Title VI and Public Transit
GIS Analysis
Overlay affected route to determine minority TAZs
• ¼ mile buffer is used to identify the affected population
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Title VI and Public Transit
Set threshold with
demographic data
Analysis with demographic data
Disparate Impact Policy ±2%. Disproportionate Burden Policy ±2%Regional Population DATA of 21% compared to 21% of total routes adversely affected; compare the 21% to Route 7 which is 26%
Calculate Effects of Service Change Using Population
MWRTA - Regional Population & Household Data
Total Populat
ion
Minority Populatio
n
Percent Minority
Low-income
Population
Percent Low-
income
242,916
50,829 21% 43,000 18% MWRTA - Affected TAZ Area Population Data
Route #Change
type
Total Population
in the Corridor
Minority Populatio
n
Percent Minority
Low-income
Population
Percent Low-
income
Route 6
Discontinued
5,870 800 14% 250 4%
Route 7
Discontinued
9,500 2,500 26% 2,100 22%
Total 15,370 3,300 21% 2,350 15%
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Title VI and Public Transit
Calculate Effects of Service Change
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Example C – Assessing Service with Ridership
Data
NOTE: The following examples are for illustrative purposes ONLY;
to assist you in understanding course concepts
Example C: Assessing Service with Ridership
DataSet System-Wide
Standards and Policies
Title VI and Public Transit
Agency Policy
For this example we will use the same disparate impact policy as the previous examples: ± 2%
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Title VI and Public Transit
Thresholds
• Weekday system-wide ridership statistics
Percent minority = 42%
Percent low-income = 37%
Minority Riders
Percent Minority
Low-Income Riders
Percent Low-
Income
Table 3 - MWRTA - Regional Ridership Data
Total Systemwide Riders
Weekday 2,542 1,057 42% 950 37%
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Example C: Assessing Service with Ridership
DataCollect and Report
Data
Title VI and Public Transit
Ridership
• GIS maps can be helpful but are not required
• Ridership data must be by route in order to compare the minority and low-income populations riding the impacted routes with the minority and low-income populations of the system
• Document surveys taken, sample sizes, etc. to show adequate ridership data for the service equity analysis
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Example C: Assessing Service with Ridership
DataEvaluate Service and Fare Equity Changes
Title VI and Public Transit
Analysis with ridership data
Route No. Day
Route 6 Weekday 184 55 30% 37 20%
Route 7 Weekday 672 380 57% 400 60%
Total Weekday 856 435 51% 437 51%
Table 4 - MWRTA - Affected Route Ridership Data
% Low-Income Riders
Route No & Day Discontinued Segment - Ridership
Minority Riders
% Minority Riders
Low-Income Riders
Regional Ridership:•Minority: 42% •Low-Income: 37%
Calculate Effects of Service Change Using Ridership Data
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Title VI and Public Transit
Calculate Effects of Service Change
Statistical Significance
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“Impacted Ons” calculated by taking the number of trips eliminated in a given hour times the number of passengers per trip during that hour and adding up the number of passengers impacted in a week. Disparate Impact Policy ±5%
Impact of Potential Service Adjustments on Minority and Low Income PassengersWeekly Numbers
Bus Lines Wkly Ons Under20k Minority %<20k % Min Impacted OnsUnder20k Minority6 50,340 25,081 21,602 50% 43% 1,453 724 62414 56,929 20,727 10,639 36% 19% 4,623 1,683 86415 39,479 15,902 7,414 40% 19% 2,396 965 45019 18,396 7,309 4,509 40% 25% 688 273 16920 52,845 21,450 13,172 41% 25% 1,572 638 39223 952 446 248 47% 26% 237 111 6247 4,562 679 2,012 15% 44% 659 98 29159 1,781 455 414 26% 23% 280 71 6562 13,596 4,177 4,093 31% 30% 1,161 357 34967 6,294 3,264 3,079 52% 49% 0 0 070 19,346 7,186 4,965 37% 26% 1,014 377 26075 65,337 33,005 22,653 51% 35% 998 402 187115 19,406 7,565 3,864 39% 20% 378 150 93119 21,728 7,379 4,359 34% 20% 931 378 232Ridership Adjusted Lines 370,990 154,623 103,022 42% 28% 16,390 6,228 4,037
Total Percent Impacted 38% 25%
Ridership All Bus Lines 1,266,568 527,728 381,169 42% 30%
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Title VI and Public Transit
If There is a Potential Disparate Impact
If a disparate impact is found, the transit provider may implement the service change only if:
“…the recipient (1) has a substantial legitimate justification for the proposed service change; and (2) the transit provider can show that there are no alternatives that would have a less disparate impact on minority riders but would still accomplish the transit provider’s legitimate program goals.”
73
Title VI and Public Transit
Steps Taken if Disparate Impact Found
Reanalyze changes for disparate
impact
Yes
Legal test met?
Yes Analysis Complete
No
Possible Title VI Violation
No
Analysis Complet
e
No
Analysis Complet
e
Disparate Impact?
Yes
Take actions to avoid, minimize, mitigate (revise
changes)
74
Title VI and Public Transit
Alternative Services Available
• What alternative services are available for people impacted by the service change?
• How would the use of alternatives affect riders’ travel times and costs?
Example: Other lines or services, potentially involving transfers and/or other modes, that connect affected riders with destinations they typically access
Can test alternatives using a trip planner
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Title VI and Public Transit
Determine Mitigation
Avoid• The service
change that results in WORST IMPACTS
• Revise service change, requiring reanalysis
Minimize• Alignment changes
located to nearby lines with same origin and trip destinations
• Cost containment strategies to limit impacts to riders.
• Market mitigation strategies that may help offset impacts
Mitigate• Expand demand-
response service in impact area
• Guaranteed ride home program
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Fare Equity Analysis
Title VI and Public Transit
What is a Fare Equity Analysis?
An assessment conducted by a transit provider to determine whether fare changes, either increases or decreases, will result in a disparate impact on Title VI-protected populations and/or disproportionate burden on low-income populations
78
Title VI and Public Transit
Fare Equity Analysis
• Must be completed by transit providers with 50+ vehicles in peak period in large UZAs
• Applies to all fare and fare media changes
Regardless of amount
Regardless whether increase or decrease
Changes in transfer policies affected
Completed during the planning stage
• Evaluate effect on Title VI-protected populations and low-income populations
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Title VI and Public Transit
Fare Equity Analysis Exceptions
• “Spare the air days”
• Temporary fare reductions that are mitigation measures for other actions
• Promotional fare reductions. If a promotional or temporary fare reduction lasts longer than six months, then FTA considers the fare reduction permanent and the transit provider must conduct a fare equity analysis
• Paratransit fares
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Title VI and Public Transit
Submission
• Fare Equity analyses will be submitted to FTA as part of a transit provider’s Title VI program
• Conduct fare equity analysis prior to fare change to determine whether planned changes will have a disparate impact
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Steps in the Analysis
Requirements and Guidelines
Title VI and Public Transit
Fare Equity Analysis Framework
• Evaluate fare impacts on minority and low-income populations separately
• Using the following framework: Requirement 1: Develop Disparate Impact Policy and
Disproportionate Burden Policy with Public Participation Requirement 2: Analyze data Requirement 3: Assess Impacts
• If there is a potential disparate impact or disproportionate burden: Modify Proposal if Necessary Finding a Disparate Impact Examining Alternatives Finding a Disproportionate Burden
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Title VI and Public Transit
Disparate Impact Definition
Facially neutral policy or practice that disproportionately affects members of a protected class identified by race, color, or national origin.
84
Title VI and Public Transit
Disparate Impact Legal Test
• The transit provider’s policy or practice lacks a substantial legitimate justification; and
• Where there exists one or more alternatives that would serve the same legitimate objectives, but with less disproportionate effect on the basis of race, color, or national origin
85
Title VI and Public Transit
Sample Disparate Impact Policy
• Fares
• Applied to fare changes consistently, i.e. mathematically consistent throughout the analysis
• Use the Board approved disparate impact policy until next Title VI program submittal
• Disparate Impact Policy Example: Statistical significance is deemed a ±5% difference
between the impacts of the fare changes before and after on minority passengers compared to the impacts borne by non-minority passengers
86
Title VI and Public Transit
Fare Equity Changes – Data Analysis
• Analyze information generated from ridership surveys
• Transit Provider shall: Determine the number and percent of
users of each fare media being changed; Review fares before and after the change; Compare the differences for each
particular fare; media – minority riders; and Compare the differences for each
particular fare media – low-income riders.
87
Title VI and Public Transit
Fare Change Analysis
Presentation and analysis of fare changesCount Cost Change Usage by Group
Fare typeExistin
gPropose
dAbsolut
e%
Low-Income
Minority Overall
Cash $1.50 $2.00 $0.50 33.3% 308,287 402,021 451,1521-Day Pass $4.50 $5.50 $1.00 22.2% 299,880 290,456 448,907Senior $0.50 $0.75 $0.25 50.0% 37,536 17,681 46,077
Disability $0.50 $1.00 $0.50100.0
%75,440 29,280 38,600
Adult 31-Day Pass
$57.00 $63.00 $6.00 10.5% 132,720 311,225 746,769
Student 31-Day Pass
$30.00 $35.00 $5.00 16.7% 205,708 192,661 323,150
Adult 7-Day Pass
$15.00 $17.00 $2.00 13.3% 105,831 132,135 170,300
10-Ride Card $13.50 $18.00 $4.50 33.3% 184 780 11,400
Total 1,165,58
61,376,23
92,236,35
588
Title VI and Public Transit
Fare Change Analysis
Presentation and analysis of fare changes
Disparate Impact Policy & Disproportionate Burden Policy: ±5% comparing ridership to usage
% of Total Cost Change Usage by Group
Fare typeExistin
gPropose
dAbsolut
ePercentag
eLow-
IncomeMinorit
yOverall
Cash $1.50 $2.00 $0.50 33.3% 26.4% 29.2% 20.2%1-Day Pass $4.50 $5.50 $1.00 22.2% 25.7% 21.1% 20.1%Senior $0.50 $0.75 $0.25 50.0% 3.2% 1.3% 2.1%Disability $0.50 $1.00 $0.50 100.0% 6.5% 2.1% 1.7%Adult 31-Day Pass
$57.00 $63.00 $6.00 10.5% 11.4% 22.6% 33.4%
Student 31-Day Pass
$30.00 $35.00 $5.00 16.7% 17.6% 14.0% 14.4%
Adult 7-Day Pass
$15.00 $17.00 $2.00 13.3% 9.1% 9.6% 7.6%
Stored Value Card
$13.50 $18.00 $4.50 33.3% 0.0% 0.1% 0.5%
Total 100.0% 100.0% 100.0%
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Calculate Effects of Fare Change on Riders
Route #Ridership Information
MinorityPercent Minority
Non-minority Low-Income
Percent Low-Income
Non low-income
BE 10 70 13% 490 170 26% 480 BE 18 170 14% 1006 140 12% 1016 LB 21 460 35% 857 370 30% 866 LB 11 570 39% 888 300 25% 915 LB 25 250 40% 377 290 42% 399
Total 1,520 30% 3,618 1,270 26% 3,676 210,000 32% 450,000 260,000 39% 400,000
Route #Fare Information Average Fare Change
Current fareProposed
fareFare change Percent Fare
Change MinorityNon-
minority Low-incomeNon-low-income
BE 10 $2.00 $2.50 $0.50 25% $35.00 $245.00 $85.00 $240.00 BE 18 $2.00 $2.50 $0.50 25% $85.00 $503.00 $70.00 $508.00 LB 21 $1.25 $1.50 $0.25 20% $115.00 $214.25 $92.50 $216.50 LB 11 $1.25 $1.50 $0.25 20% $142.50 $222.00 $75.00 $228.75 LB 25 $1.25 $1.50 $0.25 20% $62.50 $94.25 $72.50 $99.75
Average Fare Increase $0.29 $0.35 $0.31 $0.35 Percent Increase 45% 55% 47% 53%
90
Title VI and Public Transit
Effects of Fare Changes on Riders
Minority riders and low-income riders will have a lower average fare increase than non-minority and non-low-income households 91
Title VI and Public Transit
Steps Taken if Disparate Impact Found
Reanalyze changes
for disparate impact
(if grantee revises changes)
Yes
Legal test met?
Yes Analysis Complete
No
Possible Title VI Violation
No
Analysis Complet
e
No
Analysis Complet
e
Disparate Impact?
Yes
Take actions to avoid, minimize, mitigate (revise
changes)
92
Title VI and Public Transit
If There is a Potential Disparate Impact
• If a disparate impact is found, the transit provider may implement the service change only if:
“…the transit provider (1) has a substantial legitimate justification for the proposed service change; and (2) the transit provider can show that there are no alternatives that would have a less disparate impact on minority riders but would still accomplish the transit provider’s legitimate program goals.”
93
Title VI and Public Transit
If There is a Disproportionate Burden
At the conclusion of the analysis, if the transit provider finds that low-income populations will bear a disproportionate burden of the proposed fare change, the transit provider should take steps to avoid, minimize or mitigate impacts where practicable. The transit provider should describe alternatives available to low-income populations affected by the fare changes
94
Title VI and Public Transit
Avoid, Minimize and Mitigate
• Partnerships
• Subsidy for bulk pass purchases
• Ticket purchases by CBOs or social service agencies
• Outreach!
95
Title VI and Public Transit
Alternatives Available
• What alternatives are available? Analyze any alternative transit modes, fare
payment types or fare media available for affected people
• Alternative fare media
• Timing of fare increase
• Increase fares on some media
• Studies indicate passengers desire smaller & incremental fare increases; rather than a LARGE ONE all at once
96
Title VI and Public Transit
Fare Equity Analysis Recap• Evaluate fare impacts on minority and low-income
populations separately
• Using the following framework:
Develop Disparate Impact Policy and Disproportionate Burden Policy with Public Participation
Analyze data
Assess Impacts
Modify Proposal if Necessary
Finding a Disparate Impact
Examining Alternatives
Finding a Disproportionate Burden
97
Questions?
Aida B. DouglasAdjunct InstructorNational Transit Institute
98