1. Title VI Program Overview
Benjamin Limmer
Valley Metro
Corridor & Facility Development Manager
Phoenix, AZ

2. Title VI - Disclosure
Title VI prohibits discrimination by recipients of federal financial assistance on the basis of race, color, or national origin, including the denial of meaningful access for limited English proficient (LEP) persons.

3. FTA Title VI Program New Requirements
• New Circular (4702.1B) effective Oct. 1, 2012
• New Requirements
- Title VI compliant form
- Governing Board/Council approval
- Racial & ethnic diversity of non-elected committee and council members
- Monitoring subrecipients
The new FTA Title circular went into effect on October 1, 2012 and requires all transit agencies to update their Title VI Program by their triennial review with the FTA.
All transit providers are now required to develop a Title VI compliant form and have it available to the public to fill out and submit.
The Title VI program must now be approved by the providers governing board or council and a copy of the minutes.
Provide a table depicting the racial and ethnic diversity of the non-elected committee and council members.
Primary recipients (City of Phoenix) must provide the FTA with a description on how they monitor subrecipients.
A Title VI analysis must be performed for all new facilities such as storage facilities, maintenance facility, operation center, etc.

4. FTA Title VI Program New Requirements
- Analysis on facilities (e.g., storage facility)
- Major Service Change and Fare Equity Policies
- Service and Fare equity analysis on New Starts and other fixed guideway systems
Transit providers of fixed route service with more than 50 vehicles and in an area greater than 200,000 people are required to develop Major Service Change and Fare Equity Policies to determine if there are any impacts to minority or low-income riders. These policies sets a threshold for when there is a Major Service Change and a threshold to determine when a fare adjustment will have an effect to a minority and/or low-income riders.
These policies must be approved prior to any service or fare changes after April 1, 2013.
The new circular also now requires that a Title VI analysis be conducted on service and fare changes for new starts and other fixed guideway systems 6 months prior to the beginning of revenue service.

5. Valley Metro Title VI Program
• City of Phoenix – primary/designated recipient
• Region adopted City of Phoenix Title VI program
• City of Phoenix and Valley Metro to update program for region based on new circular
The City of Phoenix is the primary / designated recipient in the region for federal funds from the FTA.
Valley Metro and all the other subrecipients in the region has adopted Phoenix’s Title VI program this past year
Valley Metro and the City of Phoenix will be working on updating their Title VI program to be in compliance with the new FTA circular.

6. Title VI Proposed Policies
- Major Service Changes
- Fare Equity
• Process
- Drafted polices in coordination with City of Phoenix
- Gathered community input

7. Major Service Change Policy
- Establish a threshold of when a service change is considered a major change
- Recommended 25% threshold
% of minority/low-income population of proposed service change
% of minority/low-income population of system
Title VI Impact

8. Fare Equity Policy • Fare Equity Policy
- Any proposed fare change requires Title VI analysis
- Establish a threshold for comparing the impacts a proposed fare change has on its riders
- Comparison ensures riders are being charged equitably based on the ridership demographics of the services they use
- Recommended threshold of 4%
All fare changes undergo a Title VI analysis

9. Fare Equity Policy Example: Proposed Local Fare 5% Increase
Local Riders = 50% Minority
Proposed Express Fare 20% Increase
Express Riders = 30% Minority
Increase on Predominately Minority Fares (5%) < Increase on Predominately Non-Minority Fare (20%)
All fare changes undergo a Title VI analysis
5%-20%=
-15%
4% Policy
No Title VI Impact

10. Title VI for Capital Projects
• Public outreach to engage Environmental Justice (EJ) populations throughout project development
• Title VI/EJ analysis is conducted per FTA guidance
• Analysis looks at how project impacts EJ populations
As I mentioned in a few minutes ago all capital projects seeking federal funds must complete a NEPA document as well as conducting a Title VI analysis on potential impacts to minority and low-income populations.
All analysis is done following the FTA guidance and is reviewed and approved by the FTA.