Updates to Sound Transit's Title VI Policy

Introduction 

Sound Transit is proposing updates to policies that support providing service in a nondiscriminatory manner. As system expansion grows regional transit over the next few years, significant changes to service will occur. We want to use this opportunity to update our policies to reflect our evolving transit system. Before presenting proposed updates to the Sound Transit Board of Directors, we are sharing a draft with passengers and the public. The following page provides an overview of Title VI, our existing policies and our proposed changes. 

Title VI and why it’s important at Sound Transit 

When we consider making significant changes to our transit service, our fares or the location of a new maintenance facility, we follow Federal Transit Administration requirements to make changes in a nondiscriminatory manner. The FTA requires all transit agencies to measure if impacts of potential changes disproportionately affect minority and low-income populations. Equity is core to our values and a key element of future system expansion. In addition to our obligation under Title VI, Sound Transit’s Equity and Inclusion Policy ensures that equity is central to our programs and planning. 

Overview of Title VI equity analysis 

In order to conduct an equity analysis, we first determine the population within the service area affected by the potential change. Using census data, we calculate the percentage of people within this affected service area who self-identify as people of color, and how many people live in households earning below 200% of the federal poverty line. (See map below.) 

The equity analysis then compares the percentage of Title VI-protected populations in the affected service area to the average percentage of Title VI-protected populations across the Sound Transit District to determine if the service change has the potential to cause a potential disparate impact or disproportionate burden.  

  • A Disparate Impact is defined as, “A facially neutral policy or practice that disproportionately affects members of a group identified by race, color or national origin.”  

  • A Disproportionate Burden is defined as, “A policy or practice that disproportionately affects low-income populations more than non-low-income populations.” 

Proposed updates to two key agency policies that support Title VI  

In 2013 Sound Transit established policies for conducting equity analyses of Major Service Changes and Fare Changes impacting people of color or low-income populations (R2013-18 and R2013-19). The policies establish when an equity analysis is required and sets thresholds to identify potential situations where changes may disproportionately affect people of color and low-income populations. 

This year we’re proposing a new policy that would consolidate, update and replace R2013-18 and R2013-19. The new policy will better reflect our growing region and network of transit services. Future system expansion will bring significant changes as we open new Link and Stride stations and adjust existing bus service to improve community connections with new stations. The updated policies will better prepare the agency for evaluating potential changes in the next few years.  

Before presenting proposed updates to the Sound Transit Board of Directors, we are sharing a draft with passengers and the public. A complete draft document is available in the documents section of this page. 

Here’s what we’re proposing to update 

We started by researching how other transit agencies across the nation approach their policies to identify best practices. After the review, we updated our approach to how we determine significant changes to service and the way we define potential equity impacts. We also added a new level of analysis to better evaluate systemwide effects of multiple service changes together. We’ve included a brief summary below. For a complete table comparing existing and proposed changes, click here

Proposed changes  

Update the service data used to define a major service change to "revenue service hours." This update will allow us to better measure changes in the amount of service delivered to riders. What we call “revenue service hours” is the time that buses and trains carry riders. Our existing policy measured “platform service hours,” which included time that buses and trains were traveling to/from maintenance bases in addition to time carrying riders.  

Reduce the distance we can move a bus stop from half a mile to a quarter mile before causing a major service change. Our research found a quarter of a mile is more in line with peer transit agencies evaluation of changes to bus service. This update would help highlight changes to rider experience and access when evaluating potential stop location changes. This update also recognizes the variety of areas served by ST Express across the region. 

Align the threshold for evaluating potential service changes with industry standards. With our current policy, when evaluating a potential major service change, any percentage of Title VI protected populations above the district average identifies a potential equity impact. In practice, we call this a “0% threshold.” As an example, a service area with Title VI protected populations just 1% higher than the district average is treated the same as a service area that has Title VI protected populations that are 15% higher than the district average. This makes it challenging to highlight equity impacts and compare between different changes to prioritize serving Title VI protected populations.  

In our research, we did not find any of our peer transit agencies using a “0% threshold” to identify potential equity impacts. As a result, we are proposing that a potential equity impact occurs when the service area has Title VI protected populations that are 5% higher than the Title VI protected populations across the district. A “5% threshold” is more in-line with peer transit agency best practices.  

Add a new systemwide analysis to determine cumulative impacts of past and potential service changes. 

Our current policy does not evaluate how the cumulative effect of multiple changes benefit or impact Title VI protected populations over time. Adding a new systemwide analysis would expand our existing individual route analysis to consider the total effects of multiple service reductions and/or multiple service improvements. 

In the proposed policy, we would review all changes in the past two years together with potential future changes. We would combine all service changes in two categories, service reductions and service increases. Next, we would measure how these combined changes impact Title VI protected populations compared with non-Title VI protected populations. To identify when a potential equity impact occurs, we proposed a threshold of 20 percent, consistent with peer transit agencies we researched. This threshold is different from the 5% used for the individual change because it measures multiple changes together. 

For service improvements, a potential equity impact occurs when Title VI protected populations benefit from service improvements 20% or less than non-Title VI protected populations.  

For service reductions, a potential equity impacts occurs when Title VI protected populations experience impacts from service reductions 20% or more than non-Title VI protected populations. 

Update fare change evaluation to be consistent with new systemwide analysis threshold of 20% to identify impacts for fare changes. Similar to the service change analysis, our current threshold is 0% and doesn't match the complexities of our growing service or reflect the systemwide impact of potential fare changes.  

Process timeline and next steps 

After the public engagement period concludes in May, Sound Transit’s sub-areas, which include King, Pierce and Snohomish counties, will review the proposed DIDB Policy. It will then move forward to the full Sound Transit Board for approval, followed by submittal to the Federal Transit Administration as part of Sound Transit’s 2022 Title VI program update. 

Timeline 

  • Fall 2021: Research of peer transit agency’s Title VI policies. 

  • March 2022: Draft of updated ST policy development. 

  • April-May 2022: Release draft policy for public review and input. 

  • May 2022 Review input and refine draft policy. 

  • July 2022: Present draft policy update for adoption to Sound Transit Board of Directors. 

  • August 2022: Submit updated policy with the Sound Transit Triennial Title VI Program. 

Future plans

While the Title VI Program provides a solid foundation to ensure nondiscrimination in our practices, we know that equity encompasses so much more. Over the next three years, Sound Transit is committed to developing a more comprehensive equity assessment of service and fare changes that will deepen our understanding of these impacts beyond just demographic comparisons and will be inclusive of other historically excluded communities who currently do not receive protection under Title VI. We will develop our approach to assessing equity of future system changes in partnership with, and informed by, our community partners, passengers and the communities we serve. 

Overview of new proposed policy

The table below outlines the components of the current policies and the proposed changes.

Download proposed policy changes

Current Proposed Justification for the change

Measures platform service hours. 
(Identified as the hours vehicles are in service picking up passengers and the time they are out of service and cannot.) 

Measure revenue service hour, only. 
(The time when vehicles are in-service and able to pick up passengers.) 

By measuring revenue hours only, we will more transparently show how our service affects our passengers. 
Major service change = moving the location of a bus stop by more than a 1/2 mile

Major service change = moving the location of a bus stop by more than a 1/4 mile
(*Rail remains the same at ½ mile.)  

A quarter of a mile is easier to access by different modes than a ½ mile. The standard is also more in line with peer transit agencies.  
Major service change = closing or eliminating a stop or station without a replacement within 1/2 mile for bus and rail

Change to 1/4 mile for bus
(*Rail remains the same at ½ mile.)  

See above. 
0% threshold to determine Disparate Impact and Disproportionate Burden for all major service and fare changes. 
 

5% threshold for major service changes to a single line or route. 

A disparate impact or disproportionate burden occurs when the percentage of the adversely affected minority or low-income population in the service area of the line or route exceeds the percentage of the minority or low-income population within the Sound Transit district by at least 5% (e.g. 15% of the low-income population is adversely effected compared to 10% of the non-low-income population). 

0% threshold doesn't allow for nuance in the data and potentially implies there is an impact where there isn't. In revising our standards, Sound Transit looked at adopted Title VI policy from peer agencies including, New York City Transit, LA Metro and Tri-County Metropolitan Transportation District of Oregon (TriMet), among others.  

Five percent is in-line with peer-transit agencies/industry standards. 

20% threshold for major service changes that are systemwide. 

Systemwide service reductions 
A disparate impact or disproportionate burden occurs when the percentage of the minority or low-income population adversely affected is 20% or greater than the percentage of the non-minority or non-low-income population adversely affected (e.g. 12% compared of the minority population is adversely effected compared to 10% of the non-minority population is adversely effected).  

Systemwide service additions 
A disparate impact or disproportionate burden occurs when the percentage of the minority or low-income population benefited is 20% or less than the percentage of the non-minority or non-low-income population benefited (e.g. 8% of minority population receives benefits compared to 10% of non-minority population receives benefits)  

Collective service reductions include both service reductions under consideration and implemented service reductions in the past two years, both major and minor service changes. 

Systemwide changes will help show us if the relative benefit and or impacts on the entire system are disproportionately affecting a particular region or transit corridor. 

By applying a scan over the course of two years that includes minor changes not subject to Title VI analysis, we can better understand the accrual of both transit benefits and potential impacts on protected Title VI populations. 

20% threshold for all fare changes. 

A disparate impact or disproportionate burden occurs when the percentage of the minority or low-income population affected by the increase is 20% or greater than the percentage of the non-minority or non-low-income population adversely affected (e.g. minority population affected is 24% compared to non-minority population affected is 20%).