Service and Fare Equity
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Title VI
• “No person in the
United States shall, on
the grounds of race,
color, or national 2
origin, be excluded
from participation in,
be denied the benefits
of, or be subjected to
discrimination under
3 any program or activity
receiving Federal 4
Financial assistance.”
42 U.S.C § 2000d, et seq
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Race, Color & National Origin:
the three protected classes
• Race
– U.S. Census categories define race
– Persons of any race are protected classes
• Color
– Discrimination based on skin color or
complexion is prohibited
• National Origin
– Foreign born ancestry
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Program or Activity
Applies institution-wide
• Title VI applies institution-wide; it is not
limited to the program that receives FTA
funding (e.g., planning, capital,
operations)
• Examples?
• Are Title VI requirements limited to
primary recipients?
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Title VI applies to both
Recipients & Subrecipients
• Recipient:
• State DOT
• Transit Agency
• Any public or private agency, institution,
department or other organizational unit
receiving funding from FTA
• Subrecipient:
• Any entity that receives FTA financial
assistance as a pass-through from another
entity
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Discrimination Prohibitions
• Disparate Treatment (Intentional Discrimination):
Actions that result in circumstances where similarly
situated persons are treated differently because of their
race, color, or national origin.
• Disparate Impact (Unintentional Discrimination):
The recipient’s procedure or practice, while neutral on its
face, has the effect of disproportionately excluding or
adversely affecting members of the projected class
without substantial legitimate justification.
• Examples?
FTA Direct Grant Recipients must meet
Title VI obligations defined in the Circular
• FTA Title VI Circular
4702.1A
– AKA “The Circular”
• Submission Cycle
– Direct recipients every 3
years
– MPOs every 4 yrs
http://www.fta.dot.gov/documents/Title_VI_Circular_4702.1A.pdf
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Disproportionate
Service/Fare Changes
“Recipients can implement a service/fare
increase that would have
disproportionately high and adverse
effects provided that the recipient (1)
demonstrates that the action meets a
substantial need that is in the public
interest; and (2) that alternatives would
have more severe adverse effects than the
preferred alternative.”*
*Circular 4702.1A, Title VI Guidelines for FTA Recipients
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Establishing a
Major Service Change Policy
• Recipient should have established
guidelines or threshold for what it
considers to be “major” change
• Often defined as a numerical standard
– e.g. change effects greater than 25% of
service hours on any route
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Should I conduct a
Service
Equity
YES
Analysis?
Major Service
Change?
NO
Service Equity
Analysis
Disproportionate
Impact?
YES
AVOID
MINIMIZE
NO
MITIGATE
NO
ACTION
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Service & Fare Equity Analysis
• When: Conducted at programming stage
• Who: Urbanized area with population of
200,000 or more that proposes
major service change or fare
change (Note: There is no threshold
for fare changes – one penny makes a
fare change.)
• Why:
Required by FTA Circular 4702.1A
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SERVICE &
FARE EQUITY ANALYSIS
Customary Steps
Get Data
Convert
Data, e.g.
Apples to
Apples
ID
Minority
Calculate
Average
Compare
Benefits
&
Burdens
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Option A:
Create Maps
Span of Service,
Modes
Assess Alternatives
Travel Time, Cost
Determine if
disproportionate impact
Mitigate
Most
Option B:
agencies
Create youruse
Option B
own method
Evaluate changes
during planning
Explain your own
methodology
Determine if
disproportionate
impact
Identify Alternatives
& Mitigate
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Analytical Approach
• What dataset(s) will you use?
• At what geographic levels will you assess disparate
impacts? (By route, for the entire service area, …)
• At what geographic level will you measure minority
and low-income concentrations? (Census tract,
block group, TAZ, … or by ridership)
• Within which population will you identify disparate
impacts? (Riders, service area population, …)
• Regardless of option: analytical method for
determining disparate impact
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Golden Rule for Preparing
Service Equity Analysis
APPLES
ORANGES
TO
TO
APPLES
ORANGES
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General idea of the analysis
• Detail major service changes and how
they qualify as major relative to policy
• How would the proposed service changes
impact L-I & minority populations at the
geographic level(s) you identified?
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Presentation of analysis
• GIS Maps
• Impacts associated with each type of
service change
Headway
Span-ofService
Route
Elimination
Vehicle
Type
Load
Factor
Cost
Location
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Example: Impacts of route-level changes on
surrounding populations
Summary of service
changes
Segment
discontinuation,
headway reduction
Minority proportion of
population
Along line
Threshold
38.9%
34.3%
Low-income proportion of
population
Along line
Threshold
16.7%
12.2%
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Maps with overlays
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Example: impacts of span of
service changes on ridership
- An agency proposes to eliminate late-evening service on ALL routes.
Type of service
change
Service span
Minority proportion of ridership
Low-income proportion of
ridership
Affected trips
Threshold
Affected trips
Threshold
39.9%
43.7%
48.6%
41.4%
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Example: impacts of span of service
changes by route classification
- An agency has classified certain routes as “low-income” based on the
Census tracts they serve. The agency proposes span of service changes to
many of its routes.
Average span of
service (hours)
Existing
Proposed
Change
LowIncome
HigherIncome
LowIncome
HigherIncome
LowIncome
HigherIncome
Weekday
16.6
16.2
16.1
16.1
-0.5
-0.1
Saturday
16.1
14.7
15.8
14.5
-0.3
-0.2
Sunday
14.8
13.2
13.9
12.9
-0.9
-0.3
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Example: impacts of a service
improvement on existing riders
- An agency proposes to replace an express bus route with a faster fixed
guideway service. The agency analyzes travel time differences for existing
riders based on their origin locations.
Average travel time by
ridership group
(minutes)
Existing bus
service
New fixedguideway
Change
Absolute
Percentage
Minority
57.1
48.8
-8.3
-14.5%
Low-income
58.6
50.3
-8.3
-14.2%
Overall
62.1
53.8
-8.3
-13.4%
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Example: impacts of headway changes by
route classification
- An agency has classified certain routes as “minority” based on the
Census tracts they serve. The agency proposes headway changes to
many of its routes.
Average headway
(minutes)
Existing
Proposed
Change
Minority
Non-Minority
Minority
Non-Minority
Minority
Non-Minority
Weekday Peak
23.5
22.7
23.8
22.9
0.3
0.2
Weekday Midday
25.9
27.5
27.2
28.3
1.3
0.8
Weekday Evening
28.4
31.0
31.5
33.4
3.1
2.4
Saturday
35.4
36.9
36.3
38.0
0.9
1.1
Sunday
42.2
45.2
44.7
46.4
2.5
1.2
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Mode Change
• If an agency operates multiple modes of
service but proposed service changes only
affect one mode: an equity analysis must
be performed at the modal level based on
proportions of L-I & minority ridership for
each mode.
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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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MITIGATE, MINIMIZE & OFFSET
DISPARATE IMPACTS!
 Alignment or frequency changes to nearby
lines or services to offer more convenience to
affected areas
 Expansion of demand-response service in
affected areas
 Guaranteed ride home program
 Other budgetary actions to taken to limit
impacts to riders, i.e. internal cost-containment
strategies
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Conclusions
• What are your conclusions as to the
impact of proposed service changes on L-I
and minority populations?
• If disparate impact:
– Meets a substantial need that is in the public
interest
– Alternative strategies have more severe
adverse effects than preferred alternative
– 1 & 2 not a pretext for discrimination
– & considered alternatives & mitigation
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• Is it always the case that, if a transit agency raises
fares such that the percent increase is the same for
all fares, then the increased fares are equitable?
Yes?
No?
2008 Customer Satisfaction Survey (Systemwide)
Weekday
Ethnicity by Fare Type
Weighted by originating rides
Count
Fare type
FR Cash
FR Day Metro Pass
Express Bus Cash
Express Bus Day Pass
Rail Cash 1-Zone
Rail Cash 2-Zone
Rail 1-Zone Day Pass
Rail 2-Zone Day Pass
Cash Single Ride Student
Seniors
Disability Fare card
Active Duty/Military
Disability Fare Card (ADA
certified)
Dillo
STS
Adult 31 31-Day R Pass
Student 31-Day R Pass
Adult 7-Day R Pass
Dillo Monthly Pass
Express & Rail Adult 31-Day
Pass (all zones)
Express & Rail Reduced fare
31-day rolling Pass (all
zones)
Non-minority
149,131
158,451
5,198
2,166
Ethnicity
M inority
302,021
290,456
1,047
1,047
28,395
9,321
17,681
29,280
9,321
9,321
335,544
130,489
511,225
192,661
6,498
3,140
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11,262
1,396
Example Fare Data:
Is there a disparate impact?
Fare Type
Cash 1-ride
Day Pass
Monthly Pass
NonMin
149,131
158,451
511,225
Minority
302,021
290,456
355,544
TOTAL
686,930
1,122,250
Cost/Ride
$1.00
$1.25
$0.75
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Compare & Mitigate
Proposed Fare Changes
• Analysis should compare the fares that
would be paid under the change with fares
that would be paid under available
alternatives.
• Describe actions to avoid, minimize, or
mitigate any adverse effects of proposed
fare changes on minority and low-income
populations.
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Service & Fare Equity Analysis
Summary Points


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
Evaluate changes during planning
Determine if discriminatory impact
Compare “apples-to-apples”
Explain methodology
Use graphics
Describe actions to mitigate
Remember! Compare Apples to Apples,
Oranges to Oranges
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