IndyGo Proposed Title VI Policies

1. IndyGo Proposed Title VI Policies

2. Purpose of Meeting • Education, Transparency, Public Feedback • Agenda • Introduction to Title VI • Federal Transit Administration Circular • Title VI Definitions and Concepts • Proposed IndyGo Title VI Policies • IndyGo 2013 Service Improvements • Service Equity Analysis Results

3. Outreach Efforts • Bus On-Board Announcements • Flyers Placed in Strategic Locations • Targeted Phone Calls and Emails • Organizations Contacted • Faith-Based • Civic Organizations • Neighborhood Associations • Media

4. 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.” • Overlap with Environmental Justice under National Environmental Policy Act (NEPA) • Low-income impact evaluation

5. Federal Transit Administration Circular • FTA Circular 4702.1B released October 2012 • Submit Title VI Program every three years • Service and Fare Equity Analyses • Transit providers required to define: • Major Service Change Policy • Disparate Impact Policy • Disproportionate Burden Policy • Public Engagement

6. Minority and Low-Income Definitions Minority: • American Indian/ Alaska Native • Asian • Black or African American • Hispanic or Latino • Native Hawaiian/ Pacific Islander. Low-Income: • Household income is at or below the poverty guidelines set by the Department of Health and Human Services (DHHS). Source: FTA Circular 4702.1B

7. What is a Disparate Impact? What is a Disproportionate Burden? Disparate Impact: “A facially neutral policy or practice that disproportionately affects members of a group identified by race, color, or national origin.” Disproportionate Burden: “A neutral policy or practice that disproportionately affects low-income populations more than non-low-income populations.” Source: FTA Circular 4702.1B

8. Proposed Major Service Change Policy A major service change shall be defined as any proposed change that meets one or more of the following criteria: • An increase or decrease in fare. • A service change that will impact 25 percent or more of the transit route miles on an existing route. • A service change that will impact 25 percent or more of the total passengers on an existing route. • An implementation of a new route.

9. Minor Service Change Example Proposed change impacts 2 miles of 10 mile route (20%). Service Equity Analysis not required. Existing Service: 2 mi. 2 mi. 2 mi. 2 mi. 2 mi. Proposed Service:

10. Major Service Change Example Proposed change impacts 4 miles of 10 mile route (40%). Service Equity Analysis required. Existing Service: 2 mi. 2 mi. 2 mi. 2 mi. 2 mi. Proposed Service:

11. Proposed Disparate Impact Policy A determination of disparate impact shall be made if the effects of a major service change borne by the minority population, both adverse and beneficial, are not within 20 percent of the effects borne by the non-minority population.

12. Example: Service Improvement

13. Proposed Disproportionate Burden Policy A determination of disproportionate burden shall be made if the effects of a major service change borne by the low-income population, both adverse and beneficial, are not within 20 percent of the effects borne by the non-low-income population.

14. Example: Service Reduction

15. Why Not Zero Percent Difference? • Nearly every change will have a small difference in degree of impact • Imperfect tools for measuring impact • Data is not always current • Title VI requires quantitative as well as qualitative evaluation • Proposed Title VI policies intended as safeguards to provide balance

16. Consistent with Other Providers Similar disparate impact and disproportionate burden policies are in place in: • Washington, D.C. • Los Angeles, CA • Memphis, TN • Denver, CO • Minneapolis-St. Paul, MN

17. Finding of Disparate Impact • Avoid, Minimize, Mitigate • Revise and Reevaluate • Transit provider may proceed with a change that causes disparate impact only if: • There is a substantial legitimate justification for the proposed service change. • There are no alternatives that would have a less disparate impact and still accomplish the legitimate service change goals.

18. 2013 Service Improvements

19. Route 30 Route 11 Route 10 Route 8

20. 2013 Service Improvements Average Service Level Change by Population Group

21. Title VI Approval Process • June 24-25: Public Meetings for Proposed Policies • July 10: Public Comment Period Closes • Late July: Public Feedback Review and Policy Revision • August: Proposed Title VI Policies, Service Equity Analysis, and Title VI Program submitted to IndyGo Board for Review and Approval • October: Title VI Program Submitted to FTA

22. Comments/Questions IndyGo Proposed Title VI Policies