Meeting_Body
OPERATIONS, SAFETY, AND CUSTOMER EXPERIENCE COMMITTEE
JUNE 18, 2025
Subject
SUBJECT: FOOTHILL EXTENSION TO POMONA LIGHT RAIL PROJECT TITLE VI SERVICE AND FARE EQUITY ANALYSIS
Action
ACTION: APPROVE RECOMMENDATION
Heading
RECOMMENDATION
Title
APPROVE the Foothill Extension to Pomona Operating Plan Title VI Service and Fare Equity Analysis (Attachment A).
Issue
ISSUE
Section 601 of 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, Metro must ensure its programs and activities are conducted consistently with the intent of Title VI. The Foothill Extension to Pomona is a new light rail project involving federal funding that is expected to begin operating in 2025. Consistent with Federal Transit Administration Title VI guidelines and Metro’s Title VI Plan, a Service and Fare Equity (SAFE) Analysis of this new line’s service impacts on minority populations was presented at the public hearing in April 2025. The minority populations as identified in Metro’s Title VI Plan (2022) are Black/African American, American Indian/Alaskan Native, Asian/Pacific Islander, and Latino/Hispanic.
Background
BACKGROUND
Foothill Extension to Pomona Light Rail Project
The Foothill Gold Line Extension Project broke ground in December 2017 and will be integrated with A Line operations consistent with the Metro Board adopted Operating Plan. It is a 9.1-mile, four-station light rail addition to the existing A Line that extends from the current terminus at Azusa (APU/Citrus College Station) east to serve four new stations at Glendora, San Dimas, La Verne, and Pomona.
The project reached substantial completion on January 3, 2025, and the Foothill Gold Line Construction Authority has turned the project over to Metro for training and pre-revenue operations. The remaining project segment from Pomona to Montclair, including the Claremont and Montclair stations, will be built as a separate phase.
Figure 1 - Foothill Extension to Pomona
The A Line (including the four new stations) will operate the following service frequencies:
• 8-minute peak service weekdays
• 10-minute off-peak weekday and daytime weekend service
• 20-minute evening/late-night service
These service levels are consistent with those operated on all Metro light rail lines and are expected to meet passenger demand.
There is no loss of Metro bus or rail service levels with the new Foothill Extension to Pomona Light Rail Project. Fares will be the same as other Metro rail and bus services.
The A Line light rail extension extends beyond Metro’s primary bus service area and falls predominantly within the Foothill Transit bus service region. Several of their bus lines will directly serve the new rail stations, and to further support seamless integration between bus and rail, Foothill Transit will restructure one existing bus route and introduce a new bus route. Foothill Transit bus services will serve this extension as detailed here:
• Foothill Transit Line 291 serves the Metrolink Pomona North Station (site of future A Line Pomona Station);
• Line 492 connects to the future San Dimas Station, and;
• Line 284 operates adjacent to the future Glendora Station;
• Line 197 will be rerouted to serve the future La Verne Station;
• Foothill Transit plans to launch a new Line 295, which will provide service to the new San Dimas Station, Cal Poly Pomona, and Mt. San Antonio College.
These changes aim to enhance connectivity, expand transit options, and improve the overall passenger experience for residents throughout the Greater San Gabriel Valley region. Foothill Transit will help promote the new A line extension and their associated bus services.
Metro’s Title VI Program, which was most recently updated and approved by Metro’s Board in September 2022, requires two analyses to be completed for each new rail line.
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 5%.
Disproportionate Burden
Metro defines low-income riders at $69,350 or less for their household income, which represents the median income of a four-person household in Los Angeles County (California Department of Housing and Community Development’s 2024 State Income Housing Limits). A disproportionate burden will be deemed to exist if an absolute difference between the percentage of low-income population served by the new lines and the overall percentage of low-income persons in the Metro service area is at least 5%.
A finding of a disproportionate burden on a low-income population requires Metro to evaluate alternatives and mitigate burdens where practicable.
Discussion
DISCUSSION
As required under Title VI, Metro has reviewed the minority and low-income populations that will be served by the new Foothill Extension rail line based on 0.5-mile catchments around the new line.
The minority population served by the new Foothill Extension to Pomona rail service comprises 64.3% of the overall population the new line will serve, which is 6.9% lower than the 71.2% average for Metro’s overall service area (see Figure 2, Table 1). However, since the project will provide a benefit to both the corridor and the minority population, and the new service will not reduce other rail or bus services, the improvement is positive and therefore, the community, including the minority population, benefits from the new rail service and the disparate impact does not require mitigation.
Figure 2 - Foothill Extension to Pomona Rail Line - Minority Population
Note: The Metro Service Area information was updated to incorporate this project
Table 1
Note: Data source is the 2023 American Community Survey.
The low-income households served by the new rail service (see Figure 3, Table 2) comprise 38.7% of the households within the catchment area. This is 6.5% lower than the average of 45.2% of low-income households within the Metro Service Area. However, since the project is a benefit to both the corridor and the low-income households the line will serve, the service change is positive, and therefore, the community, including the low-income households, benefits from the new rail service, and the disproportionate burden does not require mitigation.
Figure 3 - Foothill Extension to Pomona - Low Income Population
Table 2
Note: Data source is the 2023 American Community Survey.
Conclusion:
The Service Equity Analysis shows that both the percentage minority and the low-income populations served by the new Foothill Extension to Pomona Light Rail Project are more than 5% different from those of the Metro service area. This means under Title VI guidelines that there is a disparate impact (minority population) and disproportionate burden (low-income population) associated with this new rail project. However, the new Foothill Extension to Pomona Light Rail Project provides high-quality mobility options and benefits to minority populations as well as low-income households that will be served by this new rail corridor. Minorities and low-income riders will be the primary beneficiaries of this project. In addition, benefits do not come at the expense of other transit services. As a result, Metro concludes that any disparate impact or disproportionate burden under Title VI will not require mitigation.
Metro followed the 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.
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 the Foothill Extension to Pomona Light Rail Project. Staff therefore requests for the Metro Board to adopt this analysis in support of the impending introduction of the new light rail service.
Metro conducted a public hearing at 6 p.m. on Monday, April 14, 2025, to present the Title VI Service and Fare Equity Analysis in order to receive public comment. Information regarding the proceedings was shared via public announcements at the January and March 2025 Metro San Gabriel Valley Service Council meetings, posts on Nextdoor and Metro’s blog, The Source, eblasts to San Gabriel Valley stakeholders/project stakeholders, as well as take-one brochures distributed at customer information centers and on board Metro buses serving the nearby area.
The notice of intent to hold the public hearing and information on the methods to submit public comments were published in the following publications and languages:
• Asbarez Armenian Daily News (Armenian)
• Asian Journal (Tagalog)
• Korea Times (Korean)
• La Opinión (Spanish)
• Los Angeles Daily News (English)
• Los Angeles Sentinel (English)
• Mid Valley News (English)
• Nueva Voz (Spanish)
• Pasadena Star News (English)
• Panorama (Russian)
• Rafu Shimpo (Japanese)
• San Gabriel Valley Tribune (English)
• The Wave (English)
• World Journal (Chinese Daily News)
In addition to being accepted during the hearing, public comments were also accepted via email and postal mail. A summary of comments received is included as Attachment B to this report. No comments were received that warranted any changes to the service plan.
Determination_Of_Safety_Impact
DETERMINATION OF SAFETY IMPACT
There is no safety impact as the results of this Title VI analysis for the Foothill Extension rail service plan, which does not alter any element of this project in terms of facilities and fleet designs that will support safe operations when revenue service begins.
Financial_Impact
FINANCIAL IMPACT
The results of this Title VI analysis for the Foothill Extension rail service plan do not alter any element of this project in terms of facilities or services planned to operate when revenue service begins.
Impact to Budget
There is no impact to the approved Metro FY26 budget. The introduction of revenue service on this new rail line extension is included in the Metro FY26 budget, and that budget will not change as a result of this analysis.
Equity_Platform
EQUITY PLATFORM
The Title VI Service and Fare Equity Analysis is a formal consideration of the impact on minority and low-income communities of the service plan for the Foothill Extension to Pomona rail line that is expected to open for service in 2025.
The analysis concludes that while there are disparate impacts and disproportionate burdens under Title VI, this project will provide new high quality mobility options for the communities it will serve. Minority and low-income riders will be beneficiaries of this project.
Efforts to engage the community through the public hearing process were conducted as outlined above.
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.
This item supports Metro’s systemwide strategy to reduce VMT through operational activities that will benefit and further encourage transit ridership, ridesharing, and active transportation. Metro’s Board-adopted VMT reduction targets were designed to build on the success of existing investments, and this item aligns with those objectives.
Metro conducted a preliminary analysis to show that the net effect of this multi-modal item is to decrease VMT. Impacts on VMT for the Foothill Extension to Pomona were analyzed through the Environmental Impact Report process. The result of this analysis was a reduction of 40,074 VMT per day in the study area, and a reduction of 370,805 VMT per day for the region for the build condition (2035) as compared to the no-build option for this project. This impact conclusion is based on the SEIR 2 for the project <https://foothillgoldline.org/wp-content/uploads/2022/07/Foothill-Gold-Line-Final-SEIR-3_FINAL_071822.pdf> (see Section 3.1.24 Long Term Impacts, Table 3-1 Summary of Vehicle Miles Traveled).
*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
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.
Alternatives_Considered
ALTERNATIVES CONSIDERED
The alternative to the recommendation would be not to approve the Title VI analysis for the Foothill Extension to Pomona Rail Line. This would delay the opening of the line for revenue service, as it is a federal requirement before opening the project for revenue service.
Next_Steps
NEXT STEPS
Once adopted, this analysis completes the requirement for a Title VI Service and Fare Equity Analysis for the Foothill Extension to Pomona Light Rail Project, which is expected to open later in 2025 once all pre-revenue system testing and service operations are completed.
Attachments
ATTACHMENTS
Attachment A - Foothill Extension to Pomona Operating Plan Title VI Service and Fare Equity Analysis
Attachment B - Public Hearing Comments
Prepared_by
Prepared by: Joe Forgiarini, Senior Executive Officer, Service Development, (213) 418-3400
Reviewed_By
Reviewed by: Conan Cheung, Chief Operations Officer, (213) 418-3034
