Meeting_Body
EXECUTIVE MANAGEMENT COMMITTEE
FEBRUARY 21, 2019
Subject
SUBJECT: ADMINISTRATIVE CODE AMENDMENTS - OFFICE OF CIVIL RIGHTS
Action
ACTION: APPROVE RECOMMENDATION
Heading
RECOMMENDATION
Title
APPROVE amendment of Title 2, Chapter 2-50 of the Los Angeles County Metropolitan Transportation Authority (“Metro”) Administrative Code, concerning Title VI Requirements and Public Hearings, as set forth in Attachment A. The amended Administrative Code will become effective March 1, 2019.
Issue
ISSUE
Approval of the above recommendation will conform Metro’s Administrative Code to the guidance provided by the Federal Transit Administration in regards to fare changes and will correct the language concerning the procedure by which disparate impact and disproportionate burden are calculated for fare and service changes.
Background
BACKGROUND
The Federal Transit Administration has issued a new interpretation of its guidance concerning fare equity analysis as it relates to fare changes when the price of the product is not determined by Metro. The Office of Civil Rights Department believes it prudent to align Metro’s Administrative Code with this new interpretation. An amendment is also sought to correct errors in language identifying the procedure used to calculate disparate impact and disproportionate burden for fare and service changes.
Discussion
DISCUSSION
Proposed amendments to the Administrative Code are set forth in Attachment A to this Board Report to adjust two sections:
1. Section 2-50-010 Fare Changes
This section is being amended as a result of a new interpretation of the Title VI guidance received from the Federal Transit Administration. The change will eliminate the requirement to conduct a Title VI and Environmental Justice analysis for fare products where the price of the product is not determined by Metro. This includes instances such as where the employer determines the price of the pass being sold to employees or post-secondary universal passes where the educational institution or student body establishes the final price of the product.
2. Section 2-50-020 Definitions
This change corrects an error in the original text and brings the text in alignment with the actual procedure that is used to calculate disparate impact and disproportionate burden for fare and service changes.
Financial_Impact
FINANCIAL IMPACT
Amendment of the Administrative Code would have no financial impact to the agency.
Implementation_of_Strategic_Plan_Goals
IMPLEMENTATION OF STRATEGIC PLAN GOALS
The recommendations put forward support the Strategic Plan Goal # 1: Provide high quality mobility options that enable people to spend less time traveling. The recommendation will assist Metro in achieving its goals of establishing a transportation system pricing framework that is equitable, reduces negative effects and ensures access to a variety of transportation options for everyone.
Alternatives_Considered
ALTERNATIVES CONSIDERED
Not implementing the recommended amendments would place Metro out of compliance with the Federal Transit Administration’s guidance concerning fare changes and would allow errors in Metro’s Administrative Code concerning the procedure to calculate disparate impact and disproportionate burden for fare and service changes to remain unchanged.
Next_Steps
NEXT STEPS
Following Board approval of the recommended amendments to the Administrative Code, the Office of Civil Rights Department will ensure that a fare equity analysis is prepared for all fare changes in accordance with the guidance provided by the Federal Transit Administration.
Attachments
ATTACHMENTS
Attachment A - Code Amendments for Fare Changes and Definitions.
Prepared_by
Prepared by: Jason Lombardi, Ethics Officer, (213) 922-2982
Reviewed_By
Reviewed by: Karen Gorman, Chief Ethics Officer, (213) 922-2975
Reviewed by: Daniel Levy, Chief Civil Rights Programs Officer, (213) 418-3169
