Title VI Policies: Major Service Change & Fare Equity Analyses

Title VI of the Civil Rights Act of 1964 states that “no person shall, on the grounds 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.”

CNYRTA (Centro) is committed to the principles embodied in Title VI. Analysis of services provided by the Authority indicates a consistent history of excellent distribution of transit resources for the various populations in its service area. Centro serves a wide range of social, geographic and economic disparity, including most areas with higher populations of minorities, limited English proficiency and low-income populations. No particular group in the Centro service area is excluded from transit services.

Our customers should know that NO SERVICE OR FARE CHANGES ARE CURRENTLY BEING CONSIDERED. However, should changes be considered, Centro will adhere to the following Objectives and Policies:

CNYRTA Title VI Objectives

The Authority FTA Title VI objectives are as follows:

To ensure that transit benefits and related services are equitably distributed without regard to race, color, or national origin.
To ensure that the level and quality of transit services are sufficient to provide equal access and mobility for any person without regard to race, color, or national origin.
To ensure that opportunities to participate in the transit planning and decision making processes are provided to persons without regard to race, color, or national origin.
To ensure that decisions on the location of transit services and facilities are made without regard to race, color or national origin.
To ensure that corrective and remedial action is taken to prevent discriminatory treatment based on race, color or national origin.

1. Major Service Change Policy

CNYRTA will conduct an Equity Analysis to ensure that the impacts of fare changes &/or major service changes are not disproportionately borne by any minority or low-income populations. CNYRTA defines a Major Service Change as a change in any route, other than a school tripper, specialized service or experimental route, that 1) changes the number of service hours operated on any route by 25% or more, or, 2) changes the length of a route by 25% or more.

2. Disparate Impact Policy

Centro defines a disparate impact as an adverse effect of service changes or fare change borne disproportionately by minority populations. Centro’s Policy is that any time there is a difference in adverse impacts between minority and non-minority populations of plus or minus 20% for service changes, or any time there is a difference in adverse impacts between minority and overall populations of plus or minus 20% for fare changes, such difference in adverse impacts are disparate. As an example, if the overall bus ridership on a route proposed for a major service change is composed of 40% minorities and 60% non-minorities, and minorities would bear 70% of the impacts and non-minority riders bearing 30% of the impacts; there is a disparate impact as the minority group bears 30% more than its expected share and non-minorities bear 30% less than their share. When a disparate impact is identified, Centro will consider modification of the proposal in order to avoid, minimize, or mitigate the disparate impact. This Disparate Impact Policy will be applied to all major service changes.

2a. Major Service Change - Analysis Framework

Centro may use any and all datasets available, applicable and appropriate in conducting equity analysis for major service changes. While Centro does not preclude the use of any dataset, ridership data by route and bus trip is the best data available for analysis of equity impacts on the riding public, therefore, when possible, route and trip specific data will be used. Ridership data is obtained through farebox counts, monitoring cameras or Automated Passenger Counters. However, these sources have limitations with respect to equity analysis, therefore, when resources are available, Centro will conduct periodic or “spot” rider surveys by route, which will enable an accurate assessment of impacts on the riding public with regards to race, color, national origin, income level and English proficiency.

Rider surveys can be labor intensive and, therefore, costly. When rider surveys are not readily available and/or cannot be obtained in a timely or cost-efficient manner to complete an equity analysis, data generated by the U.S. Census American Community Survey (ACS) may be combined with Census block level data or the smallest geographic area available. The demographic datasets applicable to race, color, national origin, income and English proficiency of the neighborhoods within those areas will be the datasets used. This method is also appropriate where surveys of existing ridership do not yield a statistically valid assessment, such as when service is proposed for a new corridor or neighborhood not previously served.

2b. Assessing Major Service Changes

Centro will show how the proposed major service change impacts minority and low-income populations at the geographic level by including:

Overlay maps showing proposed service changes as well as demographic data in order to study the affected population
Tables showing impacts associated with each type of route or service change (e.g., routing, frequency, span of service, addition or elimination of routes).

If a disparate impact exists and the proposed service changes must take place despite such impact:

Centro will clearly demonstrate that a substantial legitimate justification for the proposed service changes exists; and
Centro will clearly demonstrate that alternatives were analyzed to determine whether the proposed service changes are the least discriminatory alternative
Centro will take steps to avoid, minimize, or mitigate impacts where practicable.Alternatives available to low-income passengers affected by the service changes will also be considered.
In the case of a proposed service improvement, Centro will analyze accrual of benefits for minority populations as compared to non-minority populations, and low-income populations as compared to non-low-income populations, using the comparison population selected (i.e., ridership or service area).
If a service is proposed to be increased and/or expanded, but minority and/or low-income populations are not expected to benefit from the expansion as much as non-minority and/or non-low-income populations, then Centro will explain any plans to improve service to the minority and/or low-income populations.
Centro will describe any plans to restore service if/when additional funds become available.

2c. Fare Equity Analysis

Centro defines a fare related disparate impact as an adverse effect of a fare change borne disproportionately by minority or low-income populations. A disproportionate impact is present if there is a difference in adverse impacts between minority and overall populations or low-income and overall populations of plus or minus 20%.

When a fare change is proposed, Centro will analyze the fare media usage data generated from ridership surveys indicating whether minority and/or low-income riders are disproportionately more likely to use the payment type or fare media that would be subject to the fare increase or decrease.
Centro will include a profile of fare usage by group – minority, low-income and overall ridership.
If the proposed changes would only affect certain fare media, the analysis should address whether focusing changes on those fare media may lead to a disparate impact or disproportionate burden.
Centro will depict the information in tabular format.The table will depict the fare media comparing the existing cost, the percent change, and the usage of minority groups as compared to overall usage and low-income groups as compared to overall usage.Centro will analyze fare media for minority groups distinct from low-income.
Centro will compare the differences in impacts between minority users and overall users and analyze any alternative fare payment types, or fare media available for people affected by the fare change.The analysis will compare the fares paid by the proposed changes with fares that would be paid through available alternatives.
If Centro determines that a disparate impact exists, a modification to the fare change proposal will be considered to remove the impacts.If the proposal is modified, Centro will analyze the modified proposal to determine whether minority populations will experience disparate impacts.Centro will also explore alternatives, including the timing of implementing the fare increases, providing discounts on passes to social service agencies that serve the impacted populations, and other alternatives as appropriate.

Should you have any questions regarding these Title VI Objectives and Policies, you may contact Centro by email at cnyrta@centro.org, by phone at (315) 442-3400 or by written correspondence addressed to:

Central New York Regional Transportation Authority (Centro)

Title VI

200 Cortland Ave. PO Box 820

Syracuse, NY 13205