http://www.bart.gov/news/articles/2013/news20130605.aspxThe federal transportation administration released new, slightly different guidelines for public transportation providers. Basically what they say is that the civil rights office of each Public Transit Agency has to make up some criteria to test whether proposed route changes or fare increases disproportionally affect minority riders. For instance, if a transit agency were to cancel a bus line (and replace it with nothing) where 35% of the riders were black, but the overall ridership of the transit system was 12% black, then that service change would be have a disproportionate impact on black riders by 35-12=23% NOW, if the public wanted to sue the agency to stop the discontinuation of the bus line, but the agency's guidelines said the disproportionate impact had to be greater than, say, 25%, then the lawsuit would fail. The FTA mandates the creation of some guidelines, but doesn't say what should be in them.
Another example would be fare increases. If a transit agency increases regular fare by 10%, but senior fares by 50%, and 21% of seniors are some certain race, as opposed to 6% of the general population being that race, that would be a disproportionate impact of 15%.
The FTA notes that low-income people are not a protected class for the federal civil rights laws, but, (progressively) it encourages Transit Agencies to include low-income populations as a protected class in their guidelines because minorities are generally over represented in the lower incomes.
In the fare raising example above therefore, if seniors are not disproportionately some particular race, but if they are disproportionally poor, a transit agency could create guidelines that would recognize that.
So if 13% of the general transit population earns 200% or less of the national poverty level, but 20% of the senior population earns that or less, than that would be a disproportionate impact of 7%.
If the transit agency prohibited disparate impacts of more than 5% (for instance) that change would be a no go.
First of all, the policy needs more examples of how to find
disparate impacts, like the example on pg 45 of FTA C 4702.1B, or the
examples in appendix K. Second of all, the BART DIDB Policy should
explicitly take into account the relative nature of the price of a fare
(relative, that is, to the rider's overall income) and therefore the
relative nature of a fare increase.
For instance, if you earn $10/ hour, then a dollar is
equivalent to 6 minutes. If you earn $30/ hour, than a dollar is 2
minutes. That means if fares increase by, say, $10/ month, (5% of a
monthly BART bill of $200) and you earn $10/ hour, then your fare
increase is equivalent to an hour of your time. If you earn $30/ hour,
the fare increase is 20 minutes. Measured in dollars, the increases
appear to be the same for the two riders, but measured in man-hours, the
poorer rider is facing an increase that is 300% bigger than the fare
increase for the less poor rider. That is a disparate impact, so the
policy should reflect that.
Thanks for your attn in this matter.