CUMBERLAND-DAUPHIN-HARRISBURG TRANSIT AUTHORITY
Title VI Equity Analysis
May 23, 2016 Proposed Service Change
Tom Young
4/13/2016
Capital Area Transit Service Change
Title VI Equity Analysis
I.
Purpose and Executive Summary
Title VI of the Civil Rights Act of 1964 ensures that “no person in the United States shall, on the
basis of race, color, or national origin, be excluded from participation in, be denied the benefits
of, or be subjected to discrimination under any program or activity receiving Federal financial
assistance.” The Cumberland-Dauphin-Harrisburg Transit Authority, d.b.a. Capital Area Transit
(CAT), has committed to the Federal Transit Administration (FTA) Title VI objectives set forth
in Circular 4702.1B ensuring that FTA‐assisted benefits and related services are made available
and are equitably distributed without regard to race, color, or national origin.
This analysis of the proposed Capital Area Transit Service change was prepared in conformity
with Chapter IV of the FTA’s Circular 4702.1B, issued October 1, 2012. The core of the
proposed service change is a restructuring of CAT bus service within the Allison Hill area in
Harrisburg, PA as well as the Union Deposit Road area by shortening the Route 17 which
provides a direct link to Hamilton Health Center (located at 110 South 17th Street). Allison Hill is
one of the most densely populated and lowest income communities in Harrisburg. By ending
Route 17 at the Kline Village shopping center, we were able to add an addition four trips,
increasing the frequency and level of service. In addition, we are adding a new route (Route 18)
which will provide a direct connection from the Kline Village shopping center to the Union
Deposit Road / Rutherford Road area, extending the service past its current location and adding
five additional trips, increasing the frequency and level of service.
In addition, CAT is adding a new weekday shuttle service through the Capitol Complex which
will provide service every 30 minutes to and from the Riverfront Office Complex (PennDOT),
making connections to all CAT routes either at our Market Square Transfer Center or the
Harrisburg Transportation Center (Train Station), assisting in the movement of people
throughout the city center area of Harrisburg.
CAT is also modifying the Carlisle Circulator by eliminating service around the Army War
College (which generated almost no ridership) and adding service to the warehouse district along
Allen Road in Carlisle, allowing low- or no-income individuals to access paying jobs. Other
changes being made throughout the system are time point adjustments for several routes that
consistently run late due to traffic / population changes in the area.
In crafting these recommendations, CAT was careful to ensure adverse effects were off‐set or
mitigated through improvements to frequency and level of service, offsetting adverse effects
with complementary benefits. The implementation phase for the new routing is slated to begin
May 23, 2016, the first day of our scheduled May service change.
The following table illustrates the scope of changes for each category of route proposals in
Vehicle Service Miles.
Exhibit 1: Scope of Changes by Category
Vehicle Service Miles
Current
Weekday
Current
Saturday
91
0
0
0
Current
Weekly
Proposed
Weekday
Proposed
Saturday
Proposed
Weekly
455
0
0
0
-455
-1.5%
0
187
0
935
+935
+3.18%
Category
Discontinue
Service
New
Service
Change
in
Weekly
Percent
Change
CAT followed the methodology outlined in the FTA Circular 4702.1B to analyze how the menu of
proposed changes would impact CAT’s minority and low‐income customers. Exhibit 2 illustrates the
impacts by the category of change proposed.
Exhibit 2: Impact of Proposed Changes by Category
Weekly
Boardings
LowIncome
Boardings
Minority
Boardings
Percent
LowIncome
Boardings
Percent
Minority
Boardings
Total
Impact
Boardings
Impacted
LowIncome
Boardings
Impacted
Minority
Boardings
175
161
89
92.19%
50.75%
0% *
0% *
0% *
333
321
215
93.16%
64.57%
93.16%
93.16%
64.57%
Category
Discontinue
Service
New
Service
*
For the discontinued service, the total impact boardings, low-income boardings and minority
boardings are designated at 0% impact due to the addition of Route 18 and Route 2 as stated below.
Route 18 replaces and enhances the shortened portion of the current Route 17, servicing the same
general area and timespan that the discontinued route served and beyond. The same applies to the
Route W and the Carlisle Circulator.
The results of CAT’s analysis of the impacts of the service change on minority and low‐income
populations indicate there is neither a disparate impact nor a disproportionate burden associated
with the change, but an overall increase in service availability as illustrated in Exhibit 3.
Exhibit 3: Disparate Impact and Disproportionate Burden Calculations
Category
Low-income Persons
Minorities
Percentage
of Current
Users
96.13%
64.57%
Percentage
Impacted by
Changes
0%
0%
Disparate
Impact
0%
0%
Disproportionate
Burden
0%
0%
II. Background
Capital Area Transit Overview
The Cumberland-Dauphin-Harrisburg Transit Authority, d.b.a. Capital Area Transit (CAT), was
formed in 1973 after the dissolution of the Harrisburg Railways Company. In order to continue
to provide mass transit, the local municipalities formed the Authority under the Commonwealth
of Pennsylvania’s Municipal Authorities Act of 1945, as amended. Formed by the Cumberland
County and Dauphin County Commissioners and the City of Harrisburg, CAT was designated as
the public transportation provider in the greater Harrisburg area. The population of the service
area is approximately 508,279.
CAT directly operates 35 fixed routes on weekdays and 14 on Saturdays and contracts for the
operation of two fixed routes with Wolf Bus Lines. Service is provided in portions of Dauphin
and Cumberland Counties and the City of Harrisburg, Shippensburg and portions of Franklin
County. Fixed route service is provided weekdays from 4:50 a.m. to 12:20 a.m. Saturday service
is operated from 6:00 a.m. to 12:25 a.m. There is no service provided on Sunday.
There are three fixed-route fare zones ($0.60 a zone), each zone adding to the base fare for a
maximum of $3.20. The base adult zone fare for bus service is $1.75. There is a special fare of
$0.75 for one route, the proposed Capitol Complex shuttle. Multiple ride tickets and passes are
available at reduced prices.
A reduced fare of $0.85 is offered to persons with disabilities and Medicare cardholders during
all hours. Additional zones and transfers are half of the corresponding full fares, rounding down
to the nearest nickel. Funding from the Commonwealth of Pennsylvania supports the senior
citizen fare-free program.
CAT provides ADA complementary paratransit service, known as Special Efforts Transportation
(SET), in the fixed-route area. CAT manages the ADA paratransit service, performs all eligibility
determinations and operates the reservation system. CAT provides approximately 54% of the
ADA paratransit trips with its own employees and vehicles. One contractor, Easton Coach
Company, provides the balance as needed. CAT provides all revenue vehicles to Easton Coach.
CAT provides fixed route service called “Raider Regional Transit” in Shippensburg. Wolf Bus
Lines operates this service and its complementary paratransit with funding from the Federal and
state governments and Cumberland County. Shippensburg University and the Shippensburg
University Student Association also provide funds in support of Raider Regional Transit.
CAT operates a fleet of 79 buses for fixed-route service, three of which are operated for the
Shippensburg service. Its bus fleet consists of standard 30 and 40-foot transit coaches, 30, 35 and
40-foot low-floor buses, and 45-foot coaches. The current peak requirement is for 64 vehicles.
CAT also has a fleet of 52 vans, 18 of which are operated by one of its contractors for ADA
paratransit service. CAT transports approximately 2.7 million riders per year.
CAT’s administrative and principle maintenance headquarters is in the City of Harrisburg. A
transit center on South Second Street in downtown Harrisburg is the transfer point for all fixed
routes. CAT also operates shared-ride service in Dauphin County.
CAT’s Service Change
Capital Area Transit’s service change proposed for May 23, 2016 was originally developed and
designed to improve on-time performance for specific routes, enhance midday service to
improve efficiencies, add capacity, and lower the amount of split shifts scheduled for our vehicle
operators.
During the winter of 2015, CAT began planning for the service change by identifying the routes
and trips that were having difficulty providing on-time service. Specifically, Routes 7, 12, 39, C,
and the Carlisle Circulator were identified as being affected. Initially, our approach was to
identify times of the day the routes were having difficulty and adjusting the times to improve
service reliability.
However, during the re-routing process and public outreach efforts (16 public meetings) CAT
identified several trips that were non-productive and other trips that warranted additional
capacity. In addition, feedback from community outreach efforts highlighted a significant gap in
service to several areas including the Union Deposit area, the Capitol Complex including the
River Front Office Complex (PennDOT) and midday service from Carlisle. The majority of the
areas where service is being adjusted and/or added are populated by low-income residents.
Service within these communities is being enhanced by time of day and frequency. Within these
areas many cultures are represented – including African American / Black, Asian, Asian Indian,
Hispanic, Pacific Islander, and American Indian populations. The residents themselves are also
diverse in interest. The area is home to many business professionals, as well as individuals
active in the arts and social justice. In addition, the local community identified the need to have
bus service to the Hamilton Health Center located on 17th Street as well as the Osteopathic
Hospital, located within the Union Deposit area.
The above information led CAT staff to research deeper into the service we were providing in
and around the community and identify if we could provide enhanced service.
III. Proposed Service Changes
As part of the service change process including input from the public, the operations staff, and
CAT drivers, CAT is proposing the following route changes:
Route #
7
Summary of Change
Adjust time-points to improve on-time performance
Add 1 additional evening trip (outbound and inbound)
Eliminate trips to the ROC (to be covered under new service)
Adjust time-points to improve on-time performance
12
39
Adjust time-points to improve on-time performance
C
Adjust time-points to improve on-time performance
322
Specific Trips - Cross at Market Street, across 13th to Derry Street
Carlisle
Adjust time-points to improve on-time performance
Circulator Eliminate loop to War College (minimal ridership)
Eliminate Friday late night service (minimal ridership)
Detour or
Change
Timing and
Area
Timing
Timing
Timing
Detour
Timing and
Area
2
ROC / Capitol Complex - Service every 30 minutes between the Capitol
Complex and the ROC from 6:30 am to 5:30 pm.
18
Expanded midday service from Kline Village along Union Deposit Road to
Rutherford Road
C
Midday extension from Camp Hill Mall to Carlisle (connections to Route M
for individuals needing to travel beyond Camp Hill Mall).
Carlisle
Add early AM trip from Warehouse district for night shift employees
Circulator Add early AM trip to Warehouse district for day shift employees
Add PM trip to and from Warehouse district for day and night shift
employees
W
Allen Road Warehouses
Add AM trip from Carlisle Warehouse District, through Enola, to Harrisburg
Transportation Center
Add AM trip from Harrisburg Transportation Center through Enola, to
Carlisle Warehouse District
Add PM trip from Harrisburg Transportation Center through Enola, to
Carlisle Warehouse District
Add PM trip from Carlisle Warehouse District, through Enola, to Harrisburg
Transportation Center
C
Allen Road Warehouses
Eliminate new 4:14 am trip to Warehouse district (did not generate any
ridership)
Eliminate new 4:45 pm trip from Warehouse district (did not generate any
ridership)
Move 5:30 am trip to Warehouses and 3:15 pm trip from Warehouses from
Route C to Route W
New and
expanded
Increased
frequency
Increase
frequency
Time and
Area
Time and
Area
Service
Elimination
While developing recommendations for service changes and enhancements, care was taken to
maintain passengers' access within a reasonable walk‐shed (one quarter of a mile) of CAT’s
network.
Exhibit 1: Maps of Routes with Alignment Changes and New Route
IV. CAT’s Title VI Policies
Requirements for compliance with Title VI of the Civil Rights Act of 1964 were updated in 2012
by the Federal Transit Administration and now require each large public transportation
provider’s governing board to approve four policies:




Fare Change Policy
Major Service Change Policy
Disparate Impact Policy
Disproportionate Burden Policy
These new policies were included as a requirement within FTA Circular 4702.1B, released
October 2012. Following release of the new guidance, CAT crafted policies based on a number
of factors, including existing policies already in use, consultation with other transit agencies, and
analysis of impacts of past service and fare change decisions.
The three policies were released for review by the public originally in February 2013 and again
in January 2016; significant public outreach was conducted to solicit input regarding these
policies. Following the public engagement phase, CAT Board of Directors held a public hearing
on March 31, 2016 and the policies were adopted at the regular board meeting held later that
same day. The adopted policies are as follows:
Fare Change Policy
It is the policy of CAT to engage the public in any fare change and address adverse effects of
those changes. Fare change includes both increases and decreases in fares and types as well as
cost of fare instruments. Promotional fares and temporary fare reductions for mitigating
measures that are in effect less than six months are exempt from this policy.
At a minimum, CAT will:
 Develop and implement a public participation plan to engage underserved populations,
including minorities, low income, limited English proficiency (LEP) and the disabled.
 Conduct a separate fare equity analysis to determine adverse effects, disparate impact and/or
disproportionate burden on minority and low income communities.
 Provide a method for the public to provide comments on both the proposed fare change and
results of the equity analysis.
 Conduct a public hearing.
 Advertise the public hearing at least two weeks in advance.
Major Service Change Policy
It is the policy of CAT to engage the public in major service changes and address adverse effects
of those changes. Major service changes include both increases and decreases in service levels. A
major service change is defined as a 25% or greater change in route miles or revenue vehicle
miles for any one route. Service changes that have adverse effects include route elimination,
shortlining, rerouting and headway changes.
At a minimum, CAT will:
 Develop and implement a public participation plan to engage underserved populations,
including minorities, low income, LEP and the disabled.
 Conduct a separate service equity analysis to determine adverse effects, disparate impact
and/or disproportionate burden on minority and low income communities.
 Provide a method for the public to provide comments on both the proposed service change
and the results of the equity analysis.
 Conduct a public hearing.
 Advertise the public hearing at least two weeks in advance.
Disparate Impact Policy
It is CAT’s policy to evaluate fare and major service changes at the planning or programming
stages to determine whether those changes will have a disparate impact on minorities (groups
identified by race, color or national origin).
CAT has established a threshold of 20% which means that a disparate impact occurs when the
fare or service change affects a minority population 20% more than the non-minority population.
Span of service or headway changes will be analyzed using all routes. All other changes will be
evaluated on a route-by-route basis.
CAT will take corrective actions if the analysis shows a disparate impact. CAT’s goal is to avoid,
minimize or mitigate the impacts. All corrective actions will be reanalyzed for disparate impacts.
CAT may proceed if it can demonstrate a substantial legitimate justification for the fare or
service change and there are no comparably effective alternative practices that would result in
less disparate impacts.
Disproportionate Burden Policy
It is the policy of CAT to evaluate fare and major service changes at the planning or
programming stages to determine whether those changes will have a disproportionate burden on
low income populations.
CAT has established a threshold of 20% which means that a disproportionate burden occurs
when the fare or service change affects a low-income population 20% more than non-low income
populations. Span of service or headway changes will be analyzed using all routes. All other
changes will be evaluated on a route-by-route basis.
CAT will take corrective actions if the analysis shows a disproportionate burden. CAT’s goal is
to avoid, minimize or mitigate the impacts. All corrective actions will be reanalyzed for
disproportionate burden. CAT may proceed with the fare or service change if mitigation
measures or alternatives are not practical – this would include taking into account the social,
economic (including costs) and environmental effects of avoiding or mitigating the adverse
effects.
V. Finding of Major Service Change
The May 23, 2016 proposed service change includes three route changes that are affected by our
major service change policy. Those routes are the shortening of the Route 17, having a total
impact of a 12.36 reduction on route miles; and the implementation of a new route, Route 18,
having a 77.96 percent increase in route miles; and the addition of Route 2, having a 86.68
percent increase in route miles. As stated in our major service change policy above, route
elimination is included in changes that have an adverse effect, and although on the surface it
appears a portion of the Route 17 is being eliminated, the addition of Route 18 covers the
majority of the destinations and areas previously served by the Route 17; therefore it has been
determined the service has not been eliminated. In addition, this adjustment allowed additional
trips to be provided, actually increasing service frequency and availability on both the Route 17
and the Route 18.
VI. Effects of Major Service Changes on Minority and Low‐
Income Populations
Methodology
The methodology developed to analyze the impact of the proposed service change on minority
and low‐income populations included the following steps, several of which are discussed in more
detail below:
1. Conducted a special route specific onboard customer survey (rather than Census data) as the
data source for the analysis.
2. Defining the term low‐income to mean those with a reported correlated survey household
size and income against Federal Poverty Guidelines
(http://www.uscis.gov/sites/default/files/form/i-864p.pdf).
3. Defining the term “minority” to mean those who self‐identified as any ethnicity other than
“White alone”.
4. Analyzing data from the route specific onboard customer survey for low‐income and
minority populations to determine current ridership patterns.
5. Defining possible adverse effects and benefits that could result from the service change; and
determining net effects associated with the various elements of the proposed changes.
6. Utilizing the route specific survey data to analyze the distribution of potential adverse effects
and benefits and to evaluate the distribution of net effects on minority/non‐minority and low‐
income/non‐low income populations.
Step 1: Data Source Selection
The nature of the service changes proposed in the May 23, 2016 service change led CAT to
analyze ridership data versus Census data. This allows CAT to accurately gauge the number of
actual users who will be affected by proposed changes in the service at the individual route level.
Census data would only provide CAT with the ability to determine the number of minorities and
low‐income persons in a given geographical area, which staff deemed to be much less accurate
and informative than ridership survey data. The route specific onboard survey was conducted as
a stratified‐random‐sample by CAT planning staff. Surveys were collected via pen‐and‐paper.
Given the size and scope of the route specific onboard survey (i.e., 423 total respondents who
answered questions regarding race and income with a margin of error of +/‐ 5 percent), the route
specific data are accurate enough to develop data cross‐tabulations to conduct in‐depth analysis
regarding the potential impact of the proposal on minority and low‐income populations.
To determine how the proposed service changes would impact minority and low‐income
populations, CAT calculated the percentage of survey respondents who indicated they were
“minority” for the route in the system. The same process was repeated for those indicating they
met the threshold for “low income.”
Step 5: Defining and applying the definitions of adverse effects and benefits to elements of the SSP
As required under the FTA’s guidance, staff considered how the service changes proposed would
impact CAT’s customers on a day‐to‐day basis. For example, if a route was being eliminated but
another route was being added or adjusted to provide essentially the same or an increased level
of service, the adverse effect of a lost route would be offset by the benefit of a new or expanded
route. In general, the adverse effects associated with the various categories of changes proposed
in the change are as follows:

No change: No adverse effects are anticipated relative to existing service.

Discontinued service: Existing customers will have increased frequency and/or standardized
headways based on the new service design that has replaced the discontinued service.
The positive effects associated with proposed changes in the service are:



Additional frequency to currently under‐served areas;
Improved effects to frequency;
Areas gain service
Throughout development of the service change, CAT staff strived to ensure negative effects were
mitigated through improvements/changes to nearby routes. Developing and then applying the
definitions of adverse effects and benefits allowed Staff to review the change to determine
whether these efforts were successful.
Step 6: Applying Step 5 Results to CAT’s Customer Data
Based on the definitions and determinations made in Step 5, staff applied a model based on the
example provided in FTA Circular 4702.1B to determine the number of users who would be
impacted by the proposed changes, as well as the percentage of minority and low‐income
persons within the ranks of those being impacted.
The net positive (or negative) changes associated with the individual routes are summarized
cumulatively in the “Ridership Adjusted Lines” line‐item below. These figures are then used to
calculate the percentage of low‐income and minority riders impacted by the proposed changes.
This is then compared to the current route specific percentage of minorities and low-income
persons (as revealed by survey data). Below illustrates the impacts of each of the following
categories of changes associated with the service change (those without changes are not
included):
Ridership Adjusted Lines
Weekly
Boardings
Category
LowIncome
Boardings
Minority
Boardings
Percent
LowIncome
Boardings
Percent
Minority
Boardings
Total
Impact
Boardings
Impacted
LowIncome
Boardings
Impacted
Minority
Boardings
Discontinue
175
161
89
92.19%
50.75%
0% *
0% *
0% *
Service
New
2,135
1,989
1,379
93.16%
64.57%
91.80%
91.91%
93.55%
Service
* For the discontinued service, the total impact boardings, low-income boardings and minority
boardings are designated at 0% impact due to the addition of Route 18 and Route 2 as stated below.
Route 18 replaces and enhances the shortened portion of the current Route 17 servicing the same
general area and timespan that the discontinued route served and beyond. The same applies to the
Route W and the Carlisle Circulator.
Findings
When viewed cumulatively, the adverse effects anticipated to arise from the service change will
be borne by minority/non‐minority and low‐income/non‐low‐income populations in proportions
that reflect almost exactly the population that responded to the route specific on‐board customer
survey.
Disparate Impact and Disproportionate Burden Calculations
Category
Low-income Persons
Minorities
Percentage
of Current
Users
93.16%
64.57%
Percentage
Impacted by
Changes
0%
0%
Disparate
Impact
0%
0%
Disproportionate
Burden
0%
0%
The chart above illustrates that the proposed changes fall well within the adopted 20% thresholds
for Disparate Impact and Disproportionate Burden. This illustrates that the package of route‐
specific proposals included in the service change and honed through significant input from the
public, CAT operators, stakeholders, and policymakers has resulted in a proposal with impacts
spread in such a way to shield CAT’s core customers from negative impacts to the extent
possible.
In conclusion, there is no finding of any Disparate Impact or Disproportionate Burden
associated with the proposed CAT Service Change.
Route 2
Routes 17 & 18
Carlisle Circulator
Route W