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Title VI Review Process For Major Services Changes

Title VI of the 1964 Civil Rights Act states that “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.” Title VI bars intentional discrimination as well as disparate impact discrimination (i.e., a neutral policy or practice that has a disparate impact on protected groups).

Chapter V part 4 of the Federal Transit Administration Circular 4702.1A, requires transit agencies serving large urbanized areas to evaluate significant system-wide service and fare changes at the planning and programming stages to determine whether proposed changes would have a discriminatory impact. For service changes, this requirement applies to “major service changes” only and the recipient should establish guidelines or thresholds for what it considers a “major service change” to be.

Metro must ensure that there is Title VI consideration whenever there is a change in service that could impact minority communities. Metro must describe significant service changes relating to hours or days of operation, headways or fares, etc., and provide an analysis of the effect that any proposed changes may have on minority, low-English proficiency (LEP), and low-income communities. The Metro Transit Service Policy provides a delineation of that service review. Service changes covered by this policy are those indicated as “Major Adjustments of Transit Service” under Board Policy (Chapter 2-50 Public Hearings of the Administrative Code). Major service adjustments are generally those that constitute an aggregate change of 25 percent or more in route miles or hours when compared on a daily basis. This includes system wide route restructuring, or adding and deleting service.

All major service changes will be screened to determine if they have a disproportionate impact on minority, poor and LEP communities (target populations). The routing of those services, for which major changes are recommended, will be overlaid on top of GIS demographic information to determine if the route serves a large share of the target population(s). If it does, than the impacts of the change will be determined, and if they are significant, mitigation may be recommended, alternative services identified, and the change could be withdrawn. If the route does not serve a large share of the target populations, no further review will be required.