Meeting_Body
EXECUTIVE MANAGEMENT COMMITTEE
AUGUST 18, 2022
Subject
SUBJECT: TITLE VI EQUITY ANALYSIS POLICIES
Action
ACTION: APPROVE RECOMMENDATION
Heading
RECOMMENDATION
Title
ADOPT Title VI Equity Analysis Policies presented in Attachments A, B and C.
Issue
ISSUE
Title VI of the Civil Rights Act of 1964 (Title VI) prohibits discrimination on the basis of 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 in compliance 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 of the Civil Rights Act of 1964 (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 into the Administrative Code under Part 2-50 "Public Hearings".
The Title VI Equity Analysis policies consist of:
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)
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 and the policy lacks a substantial legitimate j...
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