Published on February 27, 2014
County of Fairfax, Virginia Fairfax County DOT Title VI Program Disparate Impact, Disproportionate Burden, and Major Service Change Proposed Policies Department of Transportation
County of Fairfax, Virginia Presentation Overview • • • • • • Title VI of the Civil Rights Act of 1964 FTA Circular 4701.2B Required Policies Proposed Policy Methodology Proposed Draft Policies Sample Application of Policies Submit Your Comments Department of Transportation 2
County of Fairfax, Virginia Title VI of the Civil Rights Act of 1964 “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” Department of Transportation 3
County of Fairfax, Virginia Required Policies Federal Transit Administration Circular 4701.2B requires that Fairfax County DOT set the following policies to prevent discrimination from occurring in transit service changes and transit fare changes: – Major Service Change – Disparate Impact (Minority Status) – Disproportionate Burden (Low-Income) Department of Transportation 4
County of Fairfax, Virginia Major Service Change Methodology Key Considerations: – Peer transit system policies – Data availability and ease of application – Fairfax Connector system structure • Short, frequent routes • Long, peak-period routes Department of Transportation 5
County of Fairfax, Virginia Proposed Draft Policies Major Service Change A major service change is defined as either an increase or a decrease of 25 percent or more in either daily revenue service hours, revenue service miles, or both for the individual route being modified. Department of Transportation 6 Definitions Revenue Service Hours: The number of hours a bus operates while carrying paying passengers. Revenue Service Miles: The number of miles a bus operates while carrying paying passengers.
County of Fairfax, Virginia Disparate Impact Methodology Department of Transportation 7
County of Fairfax, Virginia Proposed Draft Policies Disparate Impact To determine whether a major service change or a fare change will cause a disparate impact, the percentage of population affected that is minority will be compared to the proportion of the total minority population served by Fairfax Connector. A disparate impact occurs when the difference between the system wide percentage of minority riders and the percentage of minority riders affected by a proposed service change or fare change is 10 percent or greater. Department of Transportation 8
County of Fairfax, Virginia Disproportionate Burden Methodology Low Income Households are defined as those below 50% area median income. Department of Transportation 9
County of Fairfax, Virginia Proposed Draft Policies Disproportionate Burden To determine whether a major service change or a fare change will cause a disproportionate burden, the percentage of the population affected that is low-income will be compared to the proportion of the total low-income population served by Fairfax Connector. A disproportionate burden occurs when the difference between the system wide percentage of low-income riders and the percentage of low-income riders affected by a proposed service change or fare change is 10 percent or greater. Department of Transportation 10
County of Fairfax, Virginia Sample Application of Policies: Disparate Impact Routes A, B, C are proposed for elimination Minority Population (living within 1/4 Total Population Route (living within 1/4 mile) mile) A 11,007 16,958 B 21,310 39,511 C 4,491 9,245 Percent Minority 64.9 53.9 48.6 System Percent Disparate Minority Difference Impact? Yes 49.1 15.8 No 49.1 4.8 No 49.1 -0.6 FCDOT’s proposed elimination of Route A would result in a disparate impact as the population served is more than 10 percent above the system average for minority population served. Department of Transportation 11
County of Fairfax, Virginia Sample Application of Policies: Disproportionate Burden Routes E, D, F are proposed for elimination Low-Income Total Households Percent System Households (living within 1/4 LowPercent Disproportionate mile) Income Low-Income Difference Route (living within 1/4 mile) Burden D 8,301 31,560 26.3 5.0 21.3 Yes E 1,542 25,243 6.1 5.0 1.1 No F 606 28,630 2.1 5.0 -2.8 No FCDOT’s proposed elimination of Route D would result in a disproportionate burden as the population served is more than 10 percent above the system average for low-income households served. Department of Transportation 12
County of Fairfax, Virginia Sample Application of Policies: Fare Equity Fictional Fare Increase Proposal Disparate Impact or LowAll Disproportionate Income Riders Burden 25% 55% No 35% 15% Yes - both No 2% 5% No 1% 2% No No 17% 13% No 20% 10% Yes - both 100% 100% Usage by Group* Current Proposed Absolute Percent Base Fare Change Change Minority Fares Fares SmarTrip $1.60 $1.80 $0.20 11% 30% Cash $1.80 $2.20 $0.40 19% 25% Express Fare (394 & 395) SmarTrip $3.65 $4.00 $0.35 9% 2% Cash $4.00 $4.35 $0.35 8% 3% Base Senior and Disabled Fare SmarTrip $0.80 $0.90 $0.10 11% 15% Cash $0.90 $1.05 $0.15 15% 25% Total 100% *These are fictional figures created for use in this example only. The proposed fare increase would result in a disparate impact for minority riders, seniors and the disabled paying cash and a disproportionate burden for low-income riders, seniors and the disabled paying cash. Department of Transportation 13
County of Fairfax, Virginia Finding of Disparate Impact If an analysis results in a finding of disparate impact, Fairfax County DOT must: – Avoid, minimize, or mitigate the impact – Can only implement the change if: • Substantial legitimate justification exists • There are no alternatives meeting the same legitimate objectives Department of Transportation 14
County of Fairfax, Virginia Finding of Disproportionate Burden If an analysis results in a finding of disproportionate burden, Fairfax County DOT must: – Avoid, minimize, or mitigate the impact where practical – Describe alternatives available Department of Transportation 15
County of Fairfax, Virginia Submit Your Comments • Public Comment Period from February 28, 2014 to March 30, 2014 – Email: email@example.com Please include “Title VI” in the subject line – Mail: Fairfax County DOT ATTN: Title VI 4050 Legato Road, 4th Floor Fairfax, Virginia, 22033 Must be postmarked by March 30, 2014 Department of Transportation 16
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