Meeting_Body
EXECUTIVE MANAGEMENT COMMITTEE
JULY 17, 2025
Subject
SUBJECT: TITLE VI EQUITY ANALYSIS POLICIES
Action
ACTION: APPROVE RECOMMENDATION
Heading
RECOMMENDATION
Title
ADOPT Title VI Service and Fare Equity Analysis Policies which include:
• Major Service Change Policy (Attachment A);
• Disparate Impact Policy (Attachment B); and
• Disproportionate Burden Policy (Attachment C).
Issue
ISSUE
Title VI of the Civil Rights Act of 1964 (Title VI) prohibits discrimination based on race, color, and national origin in programs that receive federal funding. The Federal Transportation Administration (FTA) requires transportation agencies to demonstrate their compliance with Title VI by adopting policies with FTA Circular 4702.1B “Title VI Requirements and Guidelines for Federal Transit Administration Recipients,” issued October 1, 2012. FTA requires the Metro Board of Directors to review and approve the Title VI Equity Analysis policies.
Background
BACKGROUND
Section 601 of Title VI states the following:
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.
FTA Circular 4702.1B, revised in 2012, requires transportation agencies to develop policies to assist in the evaluation of impacts to minority and low-income riders when considering service and fare changes. Metro’s Title VI equity policies were adopted pursuant to the Administrative Code under Part 2-50 “Public Hearings”.
The Title VI Equity Analysis policies consist of:
The Major Service Change Policy: This policy defines what constitutes a major service change for the agency which will require a service equity analysis (Attachment A).
The Disparate Impact Policy: Disparate impact refers to a facially neutral policy or practice that disproportionately affects members of a group identified by race, color or national origin, which lacks a substantial legitimate justification, including one or more alternatives that would serve the same legitimate objectives but with less disproportionate effects on the basis of race, color or national origin (Attachment B).
The Disproportionate Burden Policy: Disproportionate burden refers to a neutral policy or practice that disproportionately affects low-income populations more than non-low-income populations (Attachment C).
Metro’s Title VI Obligations when evaluating service and fare changes
Metro will utilize the Board adopted Title VI polices included in the agency’s Board adopted Title VI Program Update when analyzing service and fare changes. The equity analysis will be completed during the planning stages of the proposed changes. The results of the analysis will be approved by the Board and evidence of the Board action will be included in the next Title VI Program Update submitted to FTA. Metro must submit a Title VI Program Update every three years. The Board last approved the Title VI Policies at its September 2022 meeting. The last submitted Title VI Program Update was on September 29, 2022.
Discussion
DISCUSSION
Metro, as a fixed route transit provider that receives Federal financial assistance and operates 50 or more fixed route vehicles in peak service, is required to prepare and submit service and fare equity analysis policies to comply with Department of Transportation (DOT) Title VI regulations. Under FTA Circular 4702.1B Title VI Equity Analysis policies are developed by the agency to ensure minorities and low-income communities are not impacted when it conducts Service and Fare Equity (SAFE) Analyses. There are three policies that must be approved by the Board every three years:
1) The Major Service Change Policy. Metro’s current policy states that a Title VI Equity Analysis will be completed for all Major Service Changes and will be presented to the Board for its consideration and the results will be included in the subsequent Metro Title VI Program Update with a record of action taken by the Board. There are no recommended changes to this Policy for 2025. The full policy is attached as Attachment A.
2) The Disparate Impact Policy. Metro’s current policy states that testing for Disparate Impact evaluates effects on minority riders or populations as compared to non-minority riders or populations. While performing a Title VI Equity Analysis for possible disparate impact, Metro will analyze how the proposed major service change or fare change action could impact minority populations, as compared to non-minority populations. There are no recommended changes to this Policy for 2025. The full policy is attached as Attachment B.
3) The Disproportionate Burden Policy. Metro’s current policy states that testing for Disproportionate Burden evaluates potential effects on low-income riders or populations, which Metro defines in the 2025 program update as $69,350 for a four-member household in Los Angeles County. The line and system level evaluations are identical to those used to determine potential disparate impacts but compare low-income and non-low-income riders or populations rather than minority and non-minority riders or populations. There are no recommended changes to this policy other than the updated increased low-income threshold from $$59,550 to $69,350. Metro’s Disproportionate Burden policy is subject to change pending further FTA guidance. The full policy is attached as Attachment C.
The next Title VI Program Update will be submitted on or before the due date of October 1, 2025.
Determination_Of_Safety_Impact
DETERMINATION OF SAFETY IMPACT
The requested action in this report will have no direct impact on the safety of Metro’s employees or customers.
Financial_Impact
FINANCIAL IMPACT
Adoption of the Title VI Equity Policies has no direct impact upon Metro’s expenditure or revenues. Approval is consistent with the implementation of service included in the adopted FY2026 Budget.
Equity_Platform
EQUITY PLATFORM
Title VI Equity Policies address impacts to Minority Communities and Low-Income Communities as required by FTA Title VI Circular 4702.1B. The FTA encourages agencies to evaluate the impacts of service and fare changes on both minority and low-income communities. While there has been no change to the way impacts to minority communities are analyzed, in January 2025, Metro increased the low-income threshold from $59,550 to $69,350, consistent with the California Department of Housing and Community Development’s (HCD) increased threshold. This new, increased threshold served to expand the population now classified as “low-income,” resulting in a larger share of our customers falling under Title VI protections. This shift reinforces the need to reevaluate service and fare equity analysis to ensure that planned changes do not disproportionately burden these communities. The result is that transit access remains fair, inclusive, and responsive to evolving community needs.
Moreover, although the FTA does not prescribe specific thresholds for identifying disparate impacts or disproportionate burdens, Metro has adopted a more rigorous standard to better address potential inequities. Under Metro’s policies, a 5% absolute difference is used to determine whether a major service or fare change results in a disparate impact on minority populations or a disproportionate burden on low-income populations. This threshold is more stringent than the 10% standard used by some other public agencies, reflecting Metro’s stronger commitment to equity.
Vehicle_Miles_Traveled _Outcome
VEHICLE MILES TRAVELED OUTCOME
VMT and VMT per capita in Los Angeles County are lower than national averages, the lowest in the SCAG region, and on the lower end of VMT per capita statewide, with these declining VMT trends due in part to Metro’s significant investment in rail and bus transit.* Metro’s Board-adopted VMT reduction targets align with California’s statewide climate goals, including achieving carbon neutrality by 2045. To ensure continued progress, all Board items are assessed for their potential impact on VMT.
While this item does not directly encourage taking transit, sharing a ride, or using active transportation, it is a vital part of Metro operations, as it ensures compliance with federal requirements under Title VI of the Civil Rights Act of 1964. Because the Metro Board has adopted an agency-wide VMT Reduction Target, and this item supports the overall function of the agency, this item is consistent with the goals of reducing VMT.
*Based on population estimates from the United States Census and VMT estimates from Caltrans’ Highway Performance Monitoring System (HPMS) data between 2001-2019.
Implementation_of_Strategic_Plan_Goals
IMPLEMENTATION OF STRATEGIC PLAN GOALS
The recommendation supports strategic plan goal # 5, “Provide responsive, accountable and trustworthy governance within the Metro organization” by adhering to civil rights equity requirements mandated by FTA Title VI Circular 4702.1B.
Alternatives_Considered
ALTERNATIVES CONSIDERED
The Title VI Equity Analysis Policies require Board approval before being submitted to FTA. Failure to include Board approved policies in the Title VI Program update may result in non-compliance with FTA program requirements and may result in suspension of federal grants by being non-compliant with civil rights requirements.
Next_Steps
NEXT STEPS
Once approved, Metro’s Title VI Equity Analysis Policies will be included in the Title VI Program Update and will be submitted to FTA before the due date of October 1, 2025.
Attachments
ATTACHMENTS
Attachment A - Major Service Change (2025)
Attachment B - Disparate Impact Policy (2025)
Attachment C - Disproportionate Burden Policy (2025)
Prepared_by
Prepared by: Joanna Lemus, Senior Manager, Civil Rights Programs, (213) 922-4067
Stewart Chesler, Manager, Transportation Planning, Service Development, (213) 922-2826
Joseph Forgiarini, Sr. Executive Officer, Service Development, (213) 418-3400
Althea Bovell, Deputy Chief Civil Rights Programs Officer, (213) 418-3168
Benjamin Alcazar, Senior Director, Civil Rights Programs, (213) 922-2634
Reviewed by: Nicole Englund, Chief of Staff, (213) 922-7950
