Service & Fare Equity Policy

Purpose

The Federal Transit Administration requires that transit agencies evaluate the impact of significant changes to its transit service as well as any changes to fares or fare media to ensure that such changes do not disproportionally impact minorities or low-income riders. The purpose of this policy is to: (1) define what constitutes a “major service change”; (2) determine what constitutes a “disparate impact” on minority riders and a “disproportionate burden” on low-income riders, based on FTA Circular 4702.1B; (3) specify the steps that METRO will take to notify and solicit comments from the public regarding proposed fare changes and major service changes; and (4) explain how METRO will analyze such changes to determine whether a disparate impact or disproportionate burden would be created under Title VI of the Civil Rights Act of 1964 and Executive Order 12898.

Scope

This policy applies to METRO, its fixed-route bus and rail services, fare media, and the fares charged for fixed-route bus and rail services. All proposed fare increases and decreases will be analyzed, with the exception of temporary and promotional fare reductions lasting six or fewer months.

Provisions

Definitions

A “major service change” is defined as:

  • Any change of more than 25 percent of the revenue hours on a given transit route (bus or rail) or route branch, for any weekday, Saturday or Sunday service.
  • Any change to the span of service of two or more hours on a given transit route (bus or rail) for any weekday, Saturday or Sunday service.
  • Any new transit route being introduced.

Fixed-route bus service is defined as one that is operated along a prescribed route according to a fixed schedule.

A route branch is defined as one of two or more route segments served by a single route.

The span of service is defined as the time from the start of the first trip to the start of the last trip on a given route.

Low income for service changes is defined as households having an annual income less than or equal to the poverty threshold updated annually by the U. S. Census Bureau.

Low income for fare changes is defined as households having an annual income less than or equal to the poverty guidelines issued annually by the U. S. Department of Health and Human Services.

Analysis – Major Service Change

For all routes with proposed changes that fall within the definition of a “major service change,” METRO staff will analyze anticipated travel time changes for low income and minority populations to determine whether a disparate impact or disproportionate burden will likely result. This analysis will be conducted for each of the routes as follows:

  1. Peak hour, peak direction travel times will be compared from the two bus stops with the highest boarding activity to the end point of the route.
  2. If the increase in travel time from the proposed “major service change” is more than fifteen minutes, and that travel time change would disproportionally affect minority riders, then the proposed route change would lead to a disparate impact. If the travel time change would disproportionately affect low-income riders, then the proposed route change would lead to a disproportionate burden.
  3. If a particular local route or service is discontinued and there is no alternative service within one-quarter mile of the two bus stops noted above, then the route elimination would lead to a disparate impact if the route’s riders are disproportionally minorities. If the route’s riders are disproportionately low-income, then the route elimination would lead to a disproportionate burden.
  4. For all routes where a disparate impact is identified, METRO staff will analyze reasonable alternatives to mitigate the anticipated impact to minority riders. However, if these alternatives have a greater negative impact than the recommended change, and METRO has demonstrated a legitimate business need in the public’s interest, then the recommended change can still be implemented. Otherwise, METRO will implement one of the reasonable alternatives identified or withdraw that route change from consideration.
  5. For all routes where a disproportionate burden is identified, METRO will take steps to avoid, minimize, or mitigate the burden on low-income riders where practicable. METRO will describe alternatives available to those low-income riders affected by the route change to avoid or mitigate the anticipated burden.

Analysis – Fare or Fare Media Changes

  • For all proposed increases and decreases in the cost of fixed-route fares or fare media that are intended to be permanent, METRO staff will analyze the usage of the fares or fare media to determine whether a disparate impact or disproportionate burden could occur. Usage of the fare media will be examined by analysis of data from ridership surveys, and the potential impacts to minority
    and low-income riders will be calculated and compared to the potential impacts to
    non-minority and non-low-income riders. If a proposed fare change would require minority riders to bear adverse effects that are more than 20 percent greater than the adverse effects borne by non-minority riders, then the fare change would lead to a disparate impact
  • If a proposed fare change would require low-income riders to bear adverse effects that are more than 20 percent greater than the adverse effects borne by non-low-income riders, then the fare change would lead to a disproportionate burden
  • If a disparate impact is identified, METRO staff will analyze reasonable alternatives to determine whether an alternative would serve the same objectives but with a lesser impact on minority riders. However, if the analysis shows that the alternatives have a greater negative impact than the proposed fare change, and if METRO has demonstrated a legitimate business need that is in the public’s interest, the recommended change can still be implemented. Otherwise, METRO will implement one of the reasonable alternatives identified or withdraw the fare change from consideration
  • If a disproportionate burden is identified, METRO will take steps to avoid, minimize, or mitigate the burdens on low-income riders where practicable. METRO will describe alternatives available to those low-income riders affected by the fare change

Publicizing a Major Service Change or Fare Change

When METRO proposes a “major service change” or fare change, a public hearing will be scheduled and advertised in such a manner as to inform the public of the proposed changes, and provide an opportunity for public comment on those changes. To ensure that customers with limited English proficiency will have the opportunity to actively participate in the process, all advertising will be prepared consistent with METRO’s current Language Assistance Plan. The official legal notice will be placed in the major metropolitan newspaper with the largest distribution (currently the Houston Chronicle) at least fourteen days prior to the date of the public hearing. Other English and non- English language newspapers having a significant community distribution will be utilized within those particular communities where the proposed service or fare changes are expected to have considerable impact. This determination will be made by an analysis of ethnicity and language data available from the U.S. Census Bureau using standard

GIS (Geographic Information Systems) software. Additionally, METRO will publicize the public hearing by:

  • Displaying posters at affected transit centers, Park & Ride lots, and METRORail stations;
  • Placing flyers on METRO buses and rail cars; and
  • Placing relevant information on the METRO website.

METRO will also solicit public comments from stakeholder and community groups by sending email blasts about the public hearing, summarizing the proposed changes and specifying the methods for providing comments. Finally, METRO may publicize the public hearing and provide a summary of the proposed changes by using social media channels such as Facebook, Twitter and blogs.

Exceptions

  • Fares charged for demand-response service
  • Temporary or promotional fares lasting six or fewer months

Related Policies or Guidelines
None.

Record of Revisions

Revision No: 1
Date
:
Reason for Revision:
Revised to reflect requirements of finalized Title VI circular, and to add fare and fare media change references.
Supersedes: Major Service Change Policy