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"Title VI Fixed Route Transit Requirements" Video Transcript

Instructor: This video will review specific Title VI requirements and guidelines that apply to Fixed Route Transit Providers.

Fixed route modes of service include, but are not limited to, local bus, express bus, commuter bus, bus rapid transit, light rail, subway, commuter rail, and passenger ferry.

Dorval Carter: Fixed Route Transit Providers play an essential role in helping enhance people’s quality of life. They deliver service to millions, enabling them to get to work, educational facilities, health centers, entertainment, and etcetera. Public transportation is an indispensable service, and to guarantee that these specific fixed route modes of service are equitably provided, FTA requires that providers develop, implement, and monitor service policies for its entire system, including schedules, routes and modes of transit.

Instructor: There are two types of transit providers. There are Large Transit Providers, who operate fifty or more fixed route vehicles in peak service and are located in an urbanized area of 200,000 people or more, and all other operators who don’t meet that threshold. These operators will be referred to as Small Transit Providers in this video series.

The requirements outlined in this video do not apply to closed-door service such as general public paratransit, Americans with Disabilities Act complementary paratransit, vanpools, and non-profits that serve their own clientele.

There are requirements for system-wide standards and policies that apply to both large and small providers, and there are requirements that only apply to the large transit providers.

We will first discuss what applies to both types of providers.

A transit provider must adopt system-wide service policies to ensure service design and operation practices do not result in discrimination. Service policies differ from service standards in that they are not necessarily based on a quantitative threshold.

Per regulations, both large and small transit providers are responsible for setting system-wide service standards and policies.

This is to ensure "routing, scheduling, or quality of service of transportation service including the frequency of service, age and quality of vehicles assigned to routes, quality of stations serving different routes, and location of routes are not determined on the basis of race, color, or national origin.

To fulfill both the service standard and the service policy requirements transit providers must identify Vehicle Load, Vehicle Headway, On Time Performance and Service Availability for each mode of transportation.

Vehicle load can be expressed as the ratio of passengers to the total number of seats on a vehicle. For example, on a 40-seat bus, a vehicle load of a ratio of 1:3 means all seats are filled and there are approximately 12 standees. A vehicle load standard is generally expressed in terms of peak and off-peak times. If a transit provider operates multiple modes of transit, they must describe the specific vehicle load standards for peak and off-peak times for each mode of fixed route transit service.

Vehicle Headways and Service Frequency are general indications of the level of service provided along a route.

Vehicle headway is the amount of time between two vehicles traveling in the same direction on a given line or combination of lines. For example, a shorter headway corresponds to more frequent service. Vehicle headways are measured in minutes. Service frequency on the other hand is measured in vehicles per hour.

A vehicle headway standard is generally expressed for peak and off-peak service as an increment of time. For instance, peak time is every fifteen minutes and off peak is every 30 minutes.

Transit providers may set different vehicle headway standards for different modes of transit service. A vehicle headway standard might establish a minimum frequency of service by area based on population density.

Headway standards are also typically related to vehicle load. For example, a service standard might state that vehicle headways will be improved first on routes that exceed the load factor standard or have the highest load factors.

Another standard policy is monitoring on time performance.

This criterion first must define what is considered to be on time. For example, it may be acceptable if a vehicle completes a scheduled run between zero and five minutes late in comparison to the established schedule.

On time performance can be measured in two ways: against route origins and destinations only or against origins and destinations and specified time points along the route.

Some transit providers set an on time performance standard that prohibits vehicles from running early or ahead of schedule, while others have a standard where vehicles meet their schedule within a specified window of time.

A transit provider needs to calculate the percentage of runs completed system-wide or on a particular route or line within the established acceptable level of performance.

For example, a transit provider might define on time performance as 95% of all runs system-wide or on a particular route or line completed within the allowed on time window.

Service availability is a general measure of the distribution of routes within a transit provider’s service area.

For example, a transit provider might set a service standard to distribute routes such that a specified percentage of all residents in the service area are within a quarter-mile walk of bus service or a half-mile walk of rail service.

An example standard for fixed route service might be the maximum distance between stops or stations. A transit agency may decide local bus stops will be not more than 3 blocks apart.

Consider other criteria when developing your standards, such as population density, the location of employment centers, seasonal activity generators, and etcetera. Urban and rural town’s development patterns and your public needs vary greatly and help define your standards. Public outreach will also help you define your standards. For example, how short or how long of distance between stops will be acceptable.

Transit amenities refer to items of comfort, convenience, and safety that are available to the general riding public.

Providers must set a policy to ensure equitable distribution of transit amenities across the system. Different modes of service may have different policies, which address how these amenities are distributed within a transit system and the manner of their distribution is determined by whether transit users have equal access to these amenities.

These amenities include benches and seats at bus stops and rail stations, bus and rail shelters and canopies. They can also include the provision of information, such as printed signs, system maps, route maps, and schedules. Or electronic signage that depicts when a transit vehicle will next arrive at the station or stop. Amenities also include escalators, elevators, and even waste receptacles.

Vehicle assignment refers to the process by which transit vehicles are placed into service on routes throughout the transit provider’s system.

When you develop your service policy regarding vehicle assignment, keep in mind it should address each mode of transit you operate.

A transit provider may set a policy to assign vehicles such as an articulated bus with more capacity to routes with higher ridership or during peak periods or smaller vehicles that can more easily navigate narrow neighborhood streets.

Surveys must collect information on race, color, national origin, English proficiency, language spoken at home, household income and travel patterns along with information on fare usage by fare type amongst minority users and low-income users.

Many agencies collect this information as part of a customer satisfaction survey. However you may find it necessary to independently to collect information to satisfy Title VI using a more focused survey.

All large transit providers must conduct a demographic analysis of their service area, including demographic maps and charts that have been completed since the last Title VI program submission.

All demographic surveys must be conducted at least once every five years. Once this information is gathered, the transit provider develops a demographic profile comparing minority riders and non-minority riders and trips taken by minority and non-minority riders.

Don’t forget to review your completed Four Factor Analysis and Language Access Plan to identify your translation needs before you conduct your survey.

This next requirement applies only to large transit providers. The FTA requires them to specifically prepare data regarding demographic and service profile maps and charts as well as customer demographics and travel patterns.

Large Transit Providers must prepare demographic and service profile maps and charts. Census data may be used to develop maps and charts until the next Census or a provider may use the American Community Survey data between the Censuses. These maps and charts will help determine to what extent transit service is available to minority populations within the service area.

The following specific maps and charts must be submitted. The first map is a base map of the service area that overlays a Census tract, Census block or block group, traffic analysis zone, transit facilities as well as major activity centers or transit trip generators, and major streets and highways.

Major activity centers and transit trip generators can include the central business district, outlying high employment areas, schools, and hospitals.

This map must overlay with the Census tract, block or block group data depicting minority populations with fixed transit facilities, such as bus shelters, transit stations, and fixed guideways.

The second map highlights the transit facilities recently replaced or improved and facilities planned to be updated in the next five years.

The third map plots the information listed in the base map and also identifies those Census tracts, blocks, block groups, traffic analysis or other geographic zones where the percentage of the total minority population residing in these areas exceeds the average percentage of minority populations for the service area as a whole and a map that overlays minority populations with fixed transit facilities such as bus shelters, transit stations, and fixed guideways. This map will help with the evaluation of the impact of major services changes on minority populations.

Additional maps may be produced that separately highlight the presence of specific minority populations if this information helps determine Title VI compliance and assist persons with Limited English Proficiency.

Large Transit providers must also monitor the performance of their transit system relative to the system-wide service standards and service policies at least once every three years using the following method.

  • The results of a monitoring program of service standards and policies, and any action taken
  • A description of the public engagement process used for setting the major service change policy and disparate impact policy
  • A copy of the board meeting minutes or a resolution demonstrating the governing entity's approval of the major service change policy and disparate impact policy, and
  • The results of an Equity Analysis for any major service changes and/or fare changes implemented since the last Title VI Program submission, along with a copy of the governing entity's approval of the Equity Analysis for any service or fare changes.

Large Transit Providers are required to use the minority transit route definition. A minority transit route is one in which at least one-third of the revenue miles are located in a Census block, Census block group, or traffic analysis zone where the minority population percentage is greater than the minority population percentage found in the service area.

FTA recognizes there exists some flexibility in this requirement, given the diverse nature of the routes large transit providers operate. Large transit providers may decide to supplement ridership and adjust route designations accordingly. For example, a commuter bus starts in the suburbs and heads downtown. It picks up passengers in generally non-minority areas and then travels through predominantly minority neighborhoods but does not pick up passengers who live closer to downtown. This might be more appropriately classified as a non-minority route, even though one-third of the bus route mileage is located in predominantly minority Census blocks or block groups.

On the other hand, a light rail line may carry predominantly minority passengers to an area where employment centers and other activities are located, but the minority population in the surrounding Census blocks or block groups does not meet or exceed the area average. This route may be more appropriately classified as a minority transit route.

So it is important to know the ridership data before making these determinations and include that data in the analyses.

A proper method of monitoring is to select a sample of minority and non-minority routes from all modes of service provided. The sample should include routes that provide service to predominantly minority areas and non-minority areas. The greater the sample size, the more reliable the results.

The transit provider then needs to assess and compare the performance of each minority and non-minority route in the sample against each of the standards and service policies. If the observed service for any route fails to meet the standard or policy, depending on the metric measured, the transit provider needs to analyze why the discrepancy exists, and then take steps to reduce the potential effects.

The transit provider then needs to:

  • Evaluate the amenities policy to ensure amenities are being distributed throughout the transit system in an equitable manner
  • Develop a policy or procedure that determines whether disparate impacts exist on the basis of race, color, or national origin and apply that policy or procedure to the results of the monitoring activities, and
  • Brief and obtain approval from policy officials to implement corrections.

If monitoring reveals that prior decisions resulted in a disparate impact on the basis of race, color, or national origin, then the provider needs to take corrective action to remedy the disparities to the greatest extent possible, and report these impacts and the actions taken.

Lastly the transit provider submits the results of the monitoring program as well as the documentation as part of its Program Plan submission to FTA every three years.

The additional requirements for Fixed Route Transit providers ensure that these systems uphold the protections provided by Title VI.