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Policies Related to Service Planning Added Requirements Under FTA Title VI Circular 4702.1B

RELATED TO AGENDA ITEM 13. Policies Related to Service Planning Added Requirements Under FTA Title VI Circular 4702.1B. October 17, 2013. Title VI - What is i t? . Law prohibiting agencies that receive federal funding from intentional or unintentional discrimination as follows:

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Policies Related to Service Planning Added Requirements Under FTA Title VI Circular 4702.1B

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  1. RELATED TO AGENDA ITEM 13 Policies Related to Service PlanningAdded Requirements Under FTA Title VI Circular 4702.1B October 17, 2013

  2. Title VI - What is it? Law prohibiting agencies that receive federal funding from intentional or unintentional discrimination as follows: “No person in the United States shall, on the grounds 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.” 42 U.S.C § 2000d, etseq

  3. Previous Agency Requirements • FTA TITLE VI CIRCULAR 4702.1A • FTA direct grant recipients that operate 50 or more fixed route vehicles in peak service and serves a population of 200,000 or greater. • At the planning stage of any fare change and any major service change, NCTD must conduct a Service Equity Analysis • Requires the establishment of a threshold to define a “major service change”. • Twenty-Five percent (25%) under former SANDAG Policy 18 - Regional Transit Service Planning and Implementation • Proposed NCTD Board Policy No. 30 willretain the major service change threshold at twenty-five percent (25%) • Requires analysis of low-income populations

  4. Added Agency Requirements • FTA TITLE VI CIRCULAR 4702.1B • Draft policies that include thresholds that define: • Disparate impact (minority population) • Disproportionate Burden (low-income population) • Hold public hearings to engage the public in the decision-making process to develop Disparate Impact and Disproportionate Burden Policies • Apply policies to when conducting Service Equity Analyses

  5. Key Definitions • Definition of Disparate Impact • Facially neutral policy or practice that adversely affects members of a protected class identified by race, color, or national origin; • Definition of a Disproportionate Burden: • Facially neutral policy or practice that disproportionately affects low income populations more than non-low income populations

  6. Proposed Disparate Impact and Disproportionate Burden Policies • Proposed Board Policies set a threshold determining when a change is deemed materially different on protected populations • Disparate Impact Policysets the threshold at 10% between the effects on minorities compared to impacts borne by non-minorities • Disproportionate Burden Policysetsthe threshold at 10% between the effects on low income populations compared to impacts borne by non-low income populations • Differences to be applied using system-wide demographics and ridership information, and/or survey data on routes individually and collectively

  7. Assessing a Disparate Impact • Disparate impact assessment: • Acomparison between the proportion of minority persons adversely affected by the service change and the proportion of non-minority persons who are affected by the service change exceeds the threshold • If a disparate impact is determined: • The transit agency must determine whether there are one or more alternatives that would serve the same legitimate objectives, but with less disproportionate effect on the basis of race, color, or national origin • If no other options are identified… • The transit agency must have a substantial, legitimate justification for making the service change

  8. Assessing a Disproportionate Burden • Disproportionate burden assessment: • The comparison between the proportion of low income persons are adversely affected by the service change and the proportion of non- low income persons who are affected by the service change exceeds the threshold • If a disproportionateburden is determined: • Steps should be taken to avoid, minimize, or mitigate impacts where practicable. • Alternatives available to low income passengers affected by the service change should also be described and provided.

  9. Illustrating The 10% Threshold • Example of Disparate Impact on Minority Population Average Minority % of NCTD Population % of Non- Minority Population Impacted = Benefit % of Minority Population Impacted = Burden 43% 0% ≤ 33% ≥ 53% 100% 10% 10%

  10. Next Steps • Held two public workshops • October 10th: Vista, 3 attendees, 1 comment • October 16th: Oceanside, 1 attendee, 1 comment • Request Board to hold public hearing during Board Meeting on November 21, 2013 • Upon approval of Board Policies, submit to SANDAG for upload into Regional Title VI Program • Apply Board Policies as necessary with major service changes

  11. Recommendation Staff recommends that the Board open a 30-day public hearing for draft Policies 30 through 32

  12. Questions?

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