Notice | The Davison Index thedavisonview MASS TRANSPORTATION AUTHORITY PUBLIC HEARINGS ON TITLE VI of the Civil Rights Act of 1964 Policies The Mass Transportation Authority will hold two public hearings on Thursday August 2, 2018, at 12:00 noon and 6:00 p.m. at the Mass Transportation Authority Administration and Training Center, 1401 S. Dort Hwy, Flint, MI 48503. The purpose of the Public Hearing is to introduce policy changes. In accordance with FTA Title VI Circular 4702.1B Title VI requirements, MTA Flint is proposing adoption of a Major Service/Fare Change Policy, a Disparate Impact Policy and a Disproportionate Burden Policy. The purpose of these policies is to establish the definition of a major service change and establish thresholds for determining when a potential disparate impact or disproportionate burden may occur and require a Title VI analysis. The revised policy is as follows: Flint Mass Transportation Authority Title VI of the Civil Rights Act of 1964 Policies The Federal Transit Administration (FTA) Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients,” effective October 1, 2012, requires that all FTA recipients operating 50 or more fixed route vehicles during peak service and serving a population of 200,000 or greater must evaluate service changes and their corresponding impacts on transit services. The required policies are subdivided into three categories: • Major Service Change Policy • Disparate Impact Policy • Disproportionate Burden Policy MAJOR SERVICE CHANGE POLICY The FTA requires funding recipients to prepare and submit service and fare equity analyses for public comment in consideration of proposed major service or fare changes. The purpose of this policy is to establish thresholds that define a “major service change”, and the definition of an adverse impact created by a “major service change”. The MTA Operating Procedure #AP-500 (Rev. #2), dated September 6, 2011, complies with this policy requirement. As contained within this policy, a major service change is defined by MTA as meeting one of the following criteria: 1. 25 percent or more of the number of round trip route miles of a regularly scheduled primary route; or 2. 25 percent of more of the daily revenue vehicle miles of a regularly scheduled primary route; or 3. 25 percent or more the scheduled service hours operated in a Your Ride service area. 4. All proposed fare changes excluding ride free promotional events, and temporary fare reductions that are mitigating measures for other actions. 5. All promotional fare reductions remaining in effect after 12 months. If a proposed major service change falls within one of the five categories above, the MTA will conduct a Title VI service and/or fare equity analysis for review and consideration by the Board of Directors and the public prior to implementing changes. An adverse effect is defined as a major geographical or time-based reduction in service which may include, but is not limited to, span of service changes, frequency changes, route segment elimination, re-routing, or route elimination. The MTA shall consider the degree of adverse effects in the form of an equity analysis when planning major service changes. The following types of service changes are exempt: • Minor route alignment, frequency, span, or time point adjustments; • Routing or bus stop changes due to temporary road detours caused by construction, maintenance, closures, emergencies, labor disruptions or strikes, fuel shortages, or safety concerns; • Any temporary service addition, change, or discontinuation of a route with less than twelve months of operation; • Changes on special service routes serving sporting events, special events, or service contracted through other cities or agencies; • Any service change that does not meet the definition of a major service change described above. DISPARATE INCOME POLICY The purpose of this policy is to establish a threshold which identifies when adverse effects of a major service or fare change are borne disproportionately by minority populations. For the purpose of this policy, a minority population is defined as any readily identifiable group of minority persons who live in geographical proximity, and if circumstances warrant, geographically dispersed/transient populations (such as migrant workers or Native Americans) who will be similarly affected by a proposed program, policy, or activity. A Major Service Change to a single route will be considered to have a potential Disparate Impact if the percentage of impacted minority population in the service area of the route exceeds the percentage of the minority population of the MTA Flint fixed route service area as a whole by at least 10 percent. To determine the system-wide impacts of a Major Service Change on more than one route, the percentage of MTA’s minority population that is impacted is compared to the percentage of MTA’s non-minority population that is impacted. If the percentage of the minority population impacted is at least 20 percent greater than the percentage of the non-minority population impacted, the overall impact of changes will be considered disparate. Should a proposed major service change result in a disparate impact, the MTA will consider modifying the proposed change to avoid, minimize, or mitigate the disparate impact of the change. If MTA finds potential disparate impacts and then modifies the proposed changes in order to avoid, minimize, or mitigate potential disparate impacts, MTA will reanalyze the proposed changes in order to determine whether the modifications actually removed the potential disparate impacts of the changes. If MTA chooses not to alter the proposed changes, MTA may implement the service or fare change if there is substantial legitimate justification for the change and MTA can show that there are no alternatives that would have less impact on the minority population and still accomplish program goals. DISPROPORTIONATE BURDEN POLICY The purpose of this policy is to establish a threshold which identifies when adverse effects of a major service or fare change are borne disproportionately by low-income populations. For purposes of this policy, low-income population is defined as any readily identifiable group or households who are at or below 150 percent of the U.S. Department of Health and Human Services Poverty Guidelines. The MTA defines a “disproportionate burden” as occurring when the low-income population adversely affected by a major service or fare change is 15 percent more than the average low-income population of MTA’s service area. Similar to the approach in identifying a potential disparate impact, should a proposed major service or fare change result in a disproportionate burden, MTA will consider modifying the proposed change to avoid, minimize, or mitigate the disproportionate burden of the change. If MTA finds potential disproportionate burdens and then modifies the proposed changes in order to avoid, minimize, or mitigate potential disproportionate burdens, MTA will reanalyze the proposed changes in order to determine whether the modifications actually removed the potential disproportionate burdens of the changes. If MTA chooses not to alter the proposed changes, MTA may implement the service or fare change if there is substantial legitimate justification for the change and MTA can show that there are no alternatives that would have less impact on low-income population and still accomplish program goals. Persons unable to attend the public hearing may submit comments in writing via mail or fax. Those submitting comment should identify themselves by name and address. Written testimony postmarked no later than August 1, 2018 should be addressed to: MTA, 1401 S. Dort Highway, Flint, MI 48503 Attention: Title VI Policy Changes. Individuals may also fax comments to (810) 767-6580.