Draft Title VI Analysis

As part of the annual Service Plan, Sound Transit conducts a service equity analysis, also known as a Title VI evaluation analysis, to ensure that changes to transit service are consistent with Title VI policies defined by the Federal Transit Administration (FTA) and Board policies defined by the Sound Transit Board of Directors. The FTA is responsible for ensuring that federally supported transit services and related benefits are distributed by applicants and recipients of FTA assistance in a manner consistent with Title VI, Section 601 of the Civil Rights Act of 1964, which states: 

No person in the United States shall, on the grounds 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.

In response to the COVID-19 pandemic, Sound Transit has made emergency reductions and changes to most of its services. This includes some routes that serve many transit-dependent riders. Download a chart for a summary or check out the draft 2021 SIP for more details.

Download the chart

Policies and Definitions

The section below describes Sound Transit's approved policies for conducting and identifying major service changes, as well as for assessing their impacts on Title VI populations.

Service Standards and Performance Measures

Service standards and performance measures are a set of guidelines that are used to design, evaluate and modify transit service. The standards and measures establish baselines to obtain optimum efficiency and effectiveness in the system on a short-term basis, while maintaining or improving the quality of service. Planning and day-to-day management of transit service is based on the established service standards and performance measures. The guidelines provide a multi-step process to identify the level and type of service that should be provided, as well as a process to implement any changes needed to meet established priorities. The Service Standards and Performance Measures defines the criteria for making major or administrative service changes, as well as guidelines and driving factors for the type of changes needed to ensure Sound Transit services are meeting the demand for regional transit in the Puget Sound area.

Major Service Change

Resolution R2013-18, adopted by the Sound Transit Board of Directors in 2013, established policies for conducting equity analyses of major service changes and assessing the impacts on minority and low income populations. This policy defines a major service change as follows:

  • A major service change is any single change in service on an individual bus or rail route that would add or eliminate more than 25 percent of the route's weekly platform service hours,
  • Move the location of a stop or station by more than a half mile.
  • Closing or removing a stop or station without replacement within a half mile.

Adverse Effects

The adopted Sound Transit major service change policy, described above, also defines potential adverse effects of major service changes and thresholds for determining whether the proposed service change would have a disparate impact on minority populations and/or a disproportionate burden on low-income populations. The definitions are as follows:

  • A potential adverse effect is defined as a geographical or time-based addition or reduction in service which includes but is not limited to: changes to span of service, changes to frequency of service, or elimination of routes or route segments.
  • A disparate impact occurs when the minority percentage of the population adversely affected by a major service change is greater than the average minority percentage of the population of Sound Transit's service area.
  • A disproportionate burden occurs when the low income percentage of the population adversely affected by a major service change is greater than the average low income percentage of the population of Sound Transit's service area.

Per Sound Transit's policy, if any disparate impact or disproportionate burden is found during the service equity analysis, Sound Transit will consider steps to avoid, minimize, or mitigate the adverse impacts and reanalyze the modified changes to determine if the impacts are removed or lessened.

Definitions and Data Analysis

The following sections describe the data definitions and methodologies used by Sound Transit to develop estimates for Title VI populations within the Sound Transit service area.

Demographic Analysis Methodology and Title VI Data Definitions Sound Transit uses census demographic data to identify Title VI communities (Minority, Low Income, & Limited English Proficiency) for service equity analysis and calculates the system-wide or mode specific average representation of these communities within the general population. Only Minority or Low Income status are used to determine if a disparate impact or disproportionate burden must be mitigated or analyzed. However, identifying Limited English Proficiency (LEP) residents helps Sound Transit to ensure that outreach efforts reach diverse customers.

Sound Transit uses the 2010 designated Census Tracts as the geographic basis for assessing the Title VI populations. Sound Transit uses the most recent five-year demographic estimates available from American Community Survey (ACS). The ACS dataset identifies Minority, Low Income and LEP populations as follows:

  • Minority: Persons who self-identify as being one or more of the following ethnic groups: American Indian and Alaska Native, Asian, Black or African American, Hispanic or Latino, Native Hawaiian and Other Pacific Islander.
  • Low income: Persons whose household income is below the federal poverty level.
  • Limited English Proficiency (LEP): Persons who identify a language other than English as their primary language and are not fluent in English. 

Visit the Title VI program page for more information on Sound Transit's Title VI program.