File #: 2021-0736   
Type: Public Hearing Status: Consent Calendar
File created: 11/9/2021 In control: Board of Directors - Regular Board Meeting
On agenda: 3/24/2022 Final action:
Title: APPROVE the Crenshaw and Regional Connector Operating Plans Title VI Service and Fare Equity Analysis.
Sponsors: Operations, Safety, and Customer Experience Commit
Indexes: 7th Street/Metro Center Station, Airport Metro Connector (AMC) Station Project, Alignment, Aviation/LAX Station, Budgeting, Crenshaw Station, Federal Transit Administration, Light rail transit, Little Tokyo/Arts District Station, Los Angeles International Airport, Metro Equity Platform, Metro Rail A Line, Metro Rail C Line, Metro Rail E Line, Metro Rail K Line, Metro Rail L Line, Minorities, Mitigation, Plan, Program, Project, Public Hearing, Regional Connector Transit Corridor Project, Revenue Service, Service Authority For Freeway Emergencies, Surveys, Third rail, Title VI Requirements
Attachments: 1. Attachment A - Public Hearing Comments
Related files: 2022-0270

Meeting_Body

EXECUTIVE MANAGEMENT COMMITTEE

MARCH 17, 2022

Subject

SUBJECT:                     CRENSHAW AND REGIONAL CONNECTOR RAIL PROJECTS TITLE VI SERVICE AND FARE EQUITY ANALYSIS

 

Action

ACTION:                     APPROVAL

 

Heading

RECOMMENDATION

 

Title

APPROVE the Crenshaw and Regional Connector Operating Plans Title VI Service and Fare Equity Analysis.

 

Issue
ISSUE

 

Title VI of the Civil Rights Act of 1964 states, “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.”

 

As a recipient of federal funding, LA Metro is required by the Federal Transit Administration (FTA) to ensure its programs and activities are conducted consistent with the intent of Title VI. The Crenshaw and Regional Connector rail projects are new rail alignments involving federal funding expected to begin operation in 2022. Consistent with Federal Transit Administration Title VI guidelines and Metro’s Title VI Plan, a Service and Fare Equity (SAFE) Analysis of the impacts of service on these two new lines on minority populations is required six months ahead of the start of revenue service.

 

 

Background

BACKGROUND

 

Crenshaw Rail Project:

The Crenshaw Rail Project is an 8.5-mile extension of C Line (Green) light rail from Aviation/Imperial to the Exposition Line at Exposition/Crenshaw (Figure 1), including eight new stations as well as a new Airport Metro Connector station that will provide a direct connector to the new LAX airport people mover system. The Crenshaw Line will be integrated with C Line (Green) operations consistent with the Metro Board adopted Operating Plan.

 

 

Figure 1 - Crenshaw Rail Project

 

 

 

Due to the construction of the Airport Metro Connector station, the Crenshaw rail service will be opened in three stages:

1)                     2022: Westchester/Veterans - Expo/Crenshaw (7 stations); bus bridge  Westchester/Veterans station and Aviation/LAX station on the C Line (Green). 

 

 

2)                     Late 2023: Implement Board 2018 Motion; Full Crenshaw Rail service, integrated with the C Line (Green), with two services:

a.                     Norwalk C Line (Green) - Expo Crenshaw station

b.                     Willowbrook/Rosa Parks C Line (Green) - Redondo Beach C Line (Green)

 

3)                     Late 2024: Same service patterns as for Phase 2 above with the addition of the Airport Metro Connector station. 

 

Service frequencies in all phases above, up to 6-minute peak, 12- minute midday and weekends, 20-minute evenings, consistent with the rest of the Metro light rail network.  

 

Regional Connector Rail Project:

The Regional Connector Rail Project is a 1.9-mile underground light-rail system with three new stations, connecting Metro Gold Line to 7th Street/Metro Center Station.

 

Once operations commence, A Line (Blue), E Line (Expo) and L Line (Gold) operations will be reconfigured from 3-line operation to a Board approved 2-line regional operation:

•                     A Line (Long Beach - Azusa)

•                     E Line (Santa Monica - Eastside)

 

Figure 1 - Regional Connector Rail Project

 

Peak service on both the A Line and E Line will be 6-minute, with 12-minute midday and weekend and 20 min evenings, consistent with the rest of the Metro light rail network.

 

Summary:

There is no loss of rail service levels with either the new Crenshaw nor Regional Connector rail services. Fares for the reconfigured light rail services will be the same as for other Metro rail and bus services.  There will be no bus service changes being made due to either of these new rail services.

 

 

Discussion
DISCUSSION

 

Metro’s Title VI Program, which was updated and approved by Metro’s Board in October 2019, requires two analyses to be completed for each new rail line. The SAFE analysis is the second requirement by Title VI presented in this report. The analysis and results represent the service operating plan and fare related impacts from these two projects. The results provide data that will show the impact of minority populations and low-income households by these projects. The impact is measured by Disparate Impact and Disproportionate Burden. The terms Disparate Impact and Disproportionate Burden reflect that notably larger than system average minority population or low-income households are served by or impacted by these projects.  Metro used our Title VI Plan as a greater than 5% difference from the system average to measure these impacts.

 

Disparate Impact

 

A disparate impact will be deemed to have occurred if the absolute difference between the percentage of minority population served by the new lines and the overall percentage of minority riders in the Metro service area is at least five percent.

 

Disproportionate Burden

 

Based on 200% of the Federal Poverty Level in 2019 for a three-person household, Metro defines low-income riders at $41,500 or less annual household income in the Metro service area of Los Angeles County. A disproportionate burden will be deemed to exist if an absolute difference between the percentage of low-income households served by the new lines and the overall percentage of low-income households in the Metro service area is at least five percent.

 

A finding of a disparate impact on a minority community requires Metro to evaluate alternatives and mitigate burdens where practicable.

 

Crenshaw Rail Service Plan Title VI Service and Fare Equity Analysis:

 

As required under Title VI, Metro has reviewed the minority and low-income populations that will be served by the new Crenshaw rail line based 0.5-mile catchments around the new line. The relevant data is shown in Table 1 below.

 

Table 1

 

Population

Minority Population

Minority Percent

Households

Low Income Households

Low Income Household Percent

Crenshaw Rail Project

   177,720

   159,028

89.5%

      68,026

     30,375

44.7%

Metro Service Area

9,417,605

6,634,742

70.5%

3,176,713

1,089,941

34.3%

Difference Comparison

 

 

19.0%

 

 

10.3%

 

Note:  The Metro Service Area information is from the October 2019 Title VI Update Report to the Metro Board.  The source of data is 2017 American Community Survey.

 

The minority population served by the new Crenshaw rail service (see Figure 2) comprises 89.5 percent of the overall population the new line will serve, which is 19 percent higher than the 70.5 percent average for Metro’s overall service area. However, the project is a benefit to both the corridor and the minority population the new line will serve. Therefore, by adding a new rail service and not reducing other rail or bus services, the disparate impact is positive for the minority population and does not require any review of alternative options for mitigation. 

 

 

Figure 2 - Crenshaw Rail Line - Minority Population

 

The Low-income households served by the new Crenshaw rail service (see Figure 3) comprise 44.7 percent of the households. This is 10.3 percent higher than the Metro Service Area average of 34.3% for low-income households.  However, the project is a new rail line that will provide beneficial new transit service for the corridor minority population and low-income households.  Therefore, the disproportionate burden is positive for the low-income population and does not require any review of alternative options for mitigation. 

 

 

Figure 3 - Crenshaw Rail Line - Low Income Population

 

 

 

Regional Connector Rail Service Plan Title VI Service and Fare Equity Analysis:

 

As required under Title VI, Metro has reviewed the minority and low-income populations that will be served by the new Regional Connector rail line based on being within 0.5 miles of the alignment. The relevant data is shown in Table 2 below.

 

Table 2

 

Population

Minority Population

Minority Percent

Households

Low Income Households

Low Income Household Percent

Regional Connector Rail Project

   88,478

   64,918

80.7%

      37,922

     20,375

53.7%

Metro Service Area

9,417,605

6,634,742

70.5%

3,176,713

1,089,941

34.3%

Difference Comparison

 

 

10.2%

 

 

19.4%

Note:  The Metro Service Area information is from the October 2019 Title VI Update Report to the Metro Board.  The source of the data is the 2017 American Community Survey.

 

The minority population served by the new Regional Connector Stations (see Figure 4, 0.5-mile catchment) will comprise 80.7 percent of the overall population the new line will serve,10.2 percent higher than the 70.5 percent average for Metro’s overall service area. However, the project benefits both the corridor and the minority population the new line will serve. Therefore, the disparate impact is positive for the minority population and does not require any review of alternative options for mitigation. 

 

Figure 4 - Regional Connector Rail Line - Minority Population

 

The Low-income households that will be served by the new Regional Connector Stations (see Figure 5, 0.5-mile catchment) comprise 53.7 percent of the households. This is 19.4 percent higher than the Metro Service Area average of 34.3% for low-income households.  However, the project is a benefit to both the corridor and the low-income households the line will serve.  Therefore, the disproportionate burden is positive for the low-income population and does not require any review of alternative options for mitigation. 

 

 

 

 

 

 

 

 

 

 

Figure 5 - Regional Connector Rail Line - Low Income Population

 

 

Conclusion:

 

The Service Equity Analysis shows that both Minority and Low-Income populations are impacted based on Metro’s threshold of at least 5%, which both exceed. However, the new Crenshaw and Regional Connector rail service each add service to the network and provide new high quality mobility options, benefiting minority populations and low-income households that these new corridors will serve.

Both projects add service to the network, hence the term “benefits”.  Metro will not reduce bus or other rail service to implement these two new rail lines. Both projects follow the established Metro systemwide fare structures. As a result, Metro concludes any disparate impact or disproportionate burden under Title VI are positive and will not require mitigation.

Metro followed requirements of FTA Circular 4702.1B and met the legal test for disparate impact as follows:

 (1) Metro has a substantial legitimate justification for the proposed service changes as it works to expand access to high quality rail service and facilities across the Metro service area; and (2) Metro has no alternatives that would have a less disparate impact on minority riders but would still accomplish the transit provider’s legitimate program goals with the opening of Crenshaw and Regional Connector rail services. Staff is therefore requesting the Metro Board adopt this analysis in support of the impending introduction of Crenshaw and Regional Connector rail service.

Metro conducted public hearings virtually at 10 am Saturday February 12, and 6 pm Tuesday February 15, 2022, to present the Title VI Service and Fare Equity Analysis and receive public comment. A summary of comments received is included as Attachment A to this report.

 

The notice of intent to hold these public hearings was published in the following publications:

•                     Asian Journal (LA.)

•                     Korea Times

•                     La Opinión

•                     Los Angeles Sentinel

•                     Press Telegram

•                     Pasadena Star News

•                     Rafu Shimpo (Japanese)

•                     San Gabriel Valley Tribune

•                     Southwest Wave

•                     South Bay Daily Breeze

•                     Watts Times

•                     World Journal (Chinese Daily News)

 

Information regarding the proceedings was also shared via public announcements at the January and February Metro Regional Service Council meetings, posts on Nextdoor and Metro’s blog, The Source, eblasts to Service Council stakeholders and project stakeholders, and take one brochures distributed aboard Metro buses.

 

Financial_Impact
FINANCIAL IMPACT

The results of this Title VI analysis for the Crenshaw and Regional Connector rail service plans does not alter and element of these projects in terms of facilities or services planned to operate when revenue service begins.

 

Impact to Budget

 

There is no impact to the approved Metro FY22 budget. The introduction of revenue service on these two new rail lines will be included in the Metro FY23 budget request and that request will not change as a result of this analysis.

 

Equity_Platform

EQUITY PLATFORM

 

The Title VI Service and Fare Equity Analysis is required to consider the impact of the future service plans for the Crenshaw and Regional Connector rail lines on minority and low-income communities. A separate Title VI analysis was conducted in project development to assess and address design, construction, and property impacts from these two projects. This analysis only addresses service and fare equity.

 

The analysis concludes that these projects impact a larger number of minority populations and low-income households than system average. However, the project impacts are benefits in the form of new high-quality transit service for the communities they will serve, with no loss in other transit service or options, and at the same affordability levels as other Metro transit services.

 

Implementation_of_Strategic_Plan_Goals

IMPLEMENTATION OF STRATEGIC PLAN GOALS

 

The recommendation supports strategic plan goal #1: Provide high quality mobility options that enable people to spend less time traveling. The service changes also respond to the sub-goal of investing in a world class bus system that is reliable, convenient, safe, and attractive to more users for more trips.

 

Next_Steps
NEXT STEPS

 

This analysis once adopted completes the requirement for a Title VI Service and Fare Equity Analysis at least six months in advance of revenue service commencing for the Crenshaw and Regional Connector rail lines which are expected to open later in 2022.

 

Attachments

ATTACHMENTS

 

Attachment A - Public Hearing Comments

 

Prepared_by

Prepared by: Joe Forgiarini, Acting Senior Executive Officer, Service Development, Scheduling, and Analysis (213) 418-3400

 

Reviewed_By

Reviewed by: Conan Cheung, Acting Chief Operations Officer, Bus Operations (213) 418-3034