IndyGo Proposed Title VI Policies

Education, Transparency, Public Feedback Agenda

◦Introduction to Title VI Federal Transit Administration Circular Title VI Definitions and Concepts

◦Proposed IndyGo Title VI Policies◦IndyGo 2013 Service Improvements Service Equity Analysis Results

Purpose of Meeting

Bus On-Board Announcements Flyers Placed in Strategic Locations Targeted Phone Calls and Emails Organizations Contacted

◦Faith-Based◦Civic Organizations◦Neighborhood Associations◦Media

Outreach Efforts

“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.”

Overlap with Environmental Justice under National Environmental Policy Act (NEPA)◦Low-income impact evaluation

Title VI of the Civil Rights Act of 1964

FTA Circular 4702.1B released October 2012 Submit Title VI Program every three years Service and Fare Equity Analyses Transit providers required to define:

◦Major Service Change Policy

◦Disparate Impact Policy

◦Disproportionate Burden Policy Public Engagement

Federal Transit Administration Circular

Minority: American Indian/ Alaska Native Asian Black or African American

Hispanic or Latino Native Hawaiian/ Pacific Islander.

Minority and Low-Income Definitions

Source: FTA Circular 4702.1B

Low-Income: Household income is at or below the poverty guidelines

set by the Department of Health and Human Services (DHHS).

Disparate Impact:

“A facially neutral policy or practice that disproportionately affects members of a group identified by race, color, or national origin.”

Disproportionate Burden:

“A neutral policy or practice that disproportionately affects low-income populations more than non-low-income populations.”

What is a Disparate Impact?What is a Disproportionate Burden?

Source: FTA Circular 4702.1B

A major service change shall be defined as any proposed change that meets one or more of the following criteria:

1. An increase or decrease in fare.

2. A service change that will impact 25 percent or more of the transit route miles on an existing route.

3. A service change that will impact 25 percent or more of the total passengers on an existing route.

4. An implementation of a new route.

Proposed Major Service Change Policy

Proposed change impacts 2 miles of 10 mile route (20%).Service Equity Analysis not required.

Minor Service Change Example

2 mi. 2 mi. 2 mi. 2 mi. 2 mi.

Existing Service:

Proposed Service:

Proposed change impacts 4 miles of 10 mile route (40%).Service Equity Analysis required.

Major Service Change Example

2 mi. 2 mi. 2 mi. 2 mi. 2 mi.

Existing Service:

Proposed Service:

A determination of disparate impact shall be made if the effects of a major service change borne by the minority population, both adverse and beneficial, are not within 20 percent of the effects borne by the non-minority population.

Proposed Disparate Impact Policy

Example: Service Improvement

A determination of disproportionate burden shall be made if the effects of a major service change borne by the low-income population, both adverse and beneficial, are not within 20 percent of the effects borne by the non-low-income population.

Proposed Disproportionate Burden Policy

Example: Service Reduction

Nearly every change will have a small difference in degree of impact

Imperfect tools for measuring impact Data is not always current Title VI requires quantitative as well as

qualitative evaluation Proposed Title VI policies intended as

safeguards to provide balance

Why Not Zero Percent Difference?

Similar disparate impact and disproportionate burden policies are in place in: Washington, D.C. Los Angeles, CA Memphis, TN Denver, CO Minneapolis-St. Paul, MN

Consistent with Other Providers

Avoid, Minimize, Mitigate Revise and Reevaluate Transit provider may proceed with a change that

causes disparate impact only if:1. There is a substantial legitimate justification for the

proposed service change.

2. There are no alternatives that would have a less disparate impact and still accomplish the legitimate service change goals.

Finding of Disparate Impact

2013 Service Improvements

Route 10

Route 8

Route 11

Route 30

Population Group

Population of Service Change

AreaAverage Percent Service Change Acceptable Range

Minority 238,387 7.5% 6.9% - 10.4%

Non-Minority 249,587 8.6% -

Low-Income 117,795 6.8% 6.7% - 10.1%

Non-Low-Income 370,179 8.5% -

Total 487,974 8.1% -

2013 Service Improvements

Average Service Level Change by Population Group

June 24-25: Public Meetings for Proposed Policies July 10: Public Comment Period Closes Late July: Public Feedback Review and Policy

Revision August: Proposed Title VI Policies, Service Equity

Analysis, and Title VI Program submitted to IndyGo Board for Review and Approval

October: Title VI Program Submitted to FTA

Title VI Approval Process

IndyGo Proposed Title VI Policies

Comments/Questions