Title VI - New FTA Requirements and Best Practices

Report
Title VI and Fares
March 18, 2013
Jonathan Ocana
Equal Opportunity Specialist
An Overview
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Title VI Applicability
Public Outreach
Fare Policy
Fare Changes
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Title VI Applicability
– Statute
– Applies to recipients
– “No person in the United States shall, on
the ground 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”
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The Basics
• Public Outreach is required of all recipients
• Fare Policy reserved for transit agencies
meeting the threshold
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Public Outreach
The public participation plan will contain:
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Proactive Strategies,
Procedures, and
Desired Outcomes
Suggested Participation Plan strategies and examples
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Meetings at convenient times and accessible locations
Utilizing different meeting sizes and formats
Alternative advertising platforms
Varying community interaction
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The Purpose of a Fare Equity
Analysis
• A fare equity analysis is 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
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Fare Equity Analysis
• Must be completed by transit providers with
50+ vehicles in peak period in large UZAs
• Applies to all fare changes
– Regardless of amount
– Regardless whether increase or decrease
– Completed during the planning stage
• Evaluate effect on Title VI-protected
populations and low-income populations
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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
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Fare Changes and Special
Projects
• Transit providers that will implement a New
Start, Small Start, or other new fixed guideway
capital project shall conduct a service and fare
equity analysis
• The analysis must be conducted 6 months
prior to beginning revenue operations
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Fare Equity Analysis Framework
• 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
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Survey
Transit providers with 50 or more vehicles in
fixed route service that are located in large
UZAs and that have not conducted passenger
surveys in the last five years will have until
December 31, 2013, to conduct these surveys.
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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; and
– Compare the differences for each particular fare
media
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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.
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Fare Equity 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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Questions?
Direct questions regarding the
Title VI Circular 4702.1B to:
[email protected]
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