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Message from the RTA Chairwoman 06-13

Message from the Chairwoman of the RTA

On March 26, 2013, the Board of Commissioners of the Regional Transit Authority approved the agency’s Title VI Policy. Title VI of the Civil Rights Act of 1964 prohibits discrimination and provides that "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."

Beyond equality, new Title VI mandates for public transit agencies require the RTA to promote "equity" in the provision of public transit services and to prevent unintentional discrimination -- the disparate impacts on low-income communities and communities of color that are unintended consequences of changes in transit service plans or policies that are seemingly neutral. Title VI requires that the RTA conduct an equity analysis for every major service change and any change in the fares for public transit.

For all routes with proposed major service changes RTA must conduct a social equity analysis to:

1) determine the benefits to and potential negative impacts on minority and low-income populations;

2) quantify expected effects (positive or negative); and

3) determine the appropriate course of action to prevent, minimize or mitigate any negative or disproportionate impacts on minority and low-income communities.

In addition to equity analyses conducted when changes are proposed, the RTA must look at the equity of transit services on an annual basis and compare the level of service for minority and low-income citizens, with services to non-minority communities. Such service standards as on-time performance, overcrowding, access, ridership and access to amenities must be examined every year to determine if there are any disparate impacts in low-income and minority communities. The annual equity analysis will involve:

• Selection of a sample of minority, low-income and non-minority bus and streetcar routes;

• Assessment of the performance of each minority, low-income and non-minority route in the sample for each RTA service standard;

• Comparison of the services provided for each route;

• Determination of whether or not the minority and/or low-income routes in the sample fail to meet the service standard;

• Determination of the reason the route failed to meet the standard;

• Development of a corrective action plan; and

• Evaluation of the distribution of transit amenities to determine if amenities are distributed equitably throughout the system.

And like equity analyses conducted on a project-by-project basis, the annual analysis must be conducted in full view of the public with specific and meaningful efforts to maximize the engagement of minority and low-income citizens in the public participation process.

Title VI was amended by Executive Order to include persons with Limited English Proficiency (LEP) to prevent discrimination based a person’s ability to read, write, speak or understand English. As such, the RTA’s Title VI program includes a Limited English Proficiency plan for non-English speakers, requiring that all applications for services, notices of rights, complaints and appeal forms and processes, notifications of award, denial, loss or decrease in benefits and feedback forms and processes be made available in Spanish and Vietnamese.

The RTA’s Title VI plan also includes policies for Environmental Justice relative to infrastructure and capital projects. The policy requires that the agency identify and address any and all disproportionate high and adverse human health or environmental impacts on low-income communities and communities of color. Moreover, we have defined health and environmental impacts to include impacts on community cohesion. As such, in addition to issues of pollution, traffic congestion, or relocation, we must also ensure that when we enter a community with a major capital project, we leave that community in tact – that our infrastructure not divide a neighborhood, enhancing instead the quality of life for the citizens who live there.

Changes to Title VI requirements call for more aggressive outreach efforts to ensure maximum feasible participation of minority and low-income citizens and we have strengthened our policy for citizen engagement to ensure that all decisions are in the full view of the citizens we serve. At the RTA, our commitment to equity is institutionalized in our policies for service delivery so as we move forward every citizen in every community can be assured equitable access to public transportation.

Barbara C. Major


Regional Transit Authority Board of Commissioners

Reprinted from letter for Tribune, May 2013

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