Title VI and Public Transit Service and Fare Equity Analyses APTA Marketing Seminar February 2015

Title VI and Public Transit

Service and Fare Equity Analyses

APTA Marketing SeminarFebruary 2015


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

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“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.”


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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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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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

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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


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


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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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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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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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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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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Requirements for Fixed Route Transit Providers

1.

2.

3.

4.

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Service Equity Analysis


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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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


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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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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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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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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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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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

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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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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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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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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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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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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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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


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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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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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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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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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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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


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


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


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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Set System-Wide Standards and Policies


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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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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Collect and Report Data


MWRTA Transit System Map

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GIS Analysis – Transit Network LayerMap existing transit routes on TAZ layer

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GIS Analysis – Low Income Areas

Map of low-income areas

Low-income threshold is 18% of regional population

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GIS Analysis

Transit routes on low-income areas

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Minority threshold of 21% determined by total service area population

GIS Analysis – Minority Areas

Map of minority areas

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GIS Analysis

Transit routes on minority areas

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Evaluate Service and Fare Equity Changes


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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GIS Analysis

Overlay affected routes to identify low-income TAZs

• ¼ mile buffer is used to identify the affected population

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GIS Analysis

Eliminated routes on minority TAZs

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GIS Analysis

Overlay affected route to determine minority TAZs

• ¼ mile buffer is used to identify the affected population

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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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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


Agency Policy

For this example we will use the same disparate impact policy as the previous examples: ± 2%

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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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DataCollect and Report

Data


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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DataEvaluate Service and Fare Equity Changes


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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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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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.”

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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)

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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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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


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


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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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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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


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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Disparate Impact Definition

Facially neutral policy or practice that disproportionately affects members of a protected class identified by race, color, or national origin.

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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

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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 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.

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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

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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%

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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


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


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


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

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Avoid, Minimize and Mitigate

• Partnerships

• Subsidy for bulk pass purchases

• Ticket purchases by CBOs or social service agencies

• Outreach!

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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

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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

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Questions?

Aida B. DouglasAdjunct InstructorNational Transit Institute

98

Documents

Title VI and Public Transit Service and Fare Equity Analyses APTA Marketing Seminar February 2015