Memorandum
Date May 19, 2016
TO Boston Region Metropolitan Planning Organization
FROM Karl H. Quackenbush
CTPS Executive Director
RE Work Program for: MBTA 2017 Triennial Title VI Report
Review and approval
That the Boston Region Metropolitan Planning Organization, upon the recommendation of the Massachusetts Bay Transportation Authority and the Massachusetts Department of Transportation, vote to approve the work program for the MBTA 2017 Triennial Title VI Report presented in this memorandum
Technical Support/Operations Analysis Projects
11408
[Massachusetts Bay Transportation Authority
Project Supervisor: Miles Walters
Massachusetts Department of Transportation, Office of Diversity and Civil Rights
Project Supervisor: John Lozada
Principal: Annette Demchur
Manager: Nicholas Hart
Future MBTA Contract
The MPO staff has sufficient resources to complete this work in a capable and timely manner. By undertaking this work, the MPO staff will neither delay the completion of nor reduce the quality of any work in the UPWP.
Every three years, the Massachusetts Bay Transportation Authority (MBTA) is required to submit a report to the Federal Transit Administration (FTA) Office of Civil Rights detailing the MBTA’s efforts to comply with Title VI of the Civil Rights Act of 1964. The purpose of this Title VI report is to ensure that, as a recipient of federal funds, the MBTA provides a comparable level and quality of transportation services to all customers without regard to race, color, or national origin. The requirements for demonstrating compliance with Title VI are outlined in FTA Circular 4702.1B.
The most recent triennial Title VI report was provided by the MBTA to the FTA in 2014. For years in which the MBTA does not submit a triennial report, the FTA requires the Authority to complete annual Title VI monitoring and internal reporting to identify and address problems early and to ensure ongoing Title VI compliance. Under the MBTA’s monitoring schedule, data collection and analysis are completed annually for some service indicators, and every two years for others. When possible, the results of biennial monitoring are folded into subsequent triennial Title VI reports for the FTA. The most recent triennial report outlined an ongoing process of Title VI data collection and analysis; documented the results of current assessments of compliance; and indicated responsive action that would be taken with respect to Title VI concerns in the interim years (2015 and 2016) before the 2017 report.
CTPS has performed data collection and analysis for MBTA Title VI reporting since the 1980s and has been responsible for producing the MBTA’s 2005, 2008, 2011, and 2014 Title VI triennial reports for submittal to the FTA. CTPS has also completed annual internal reports for the MBTA since 2005 and quarterly reports for the FTA, as required. This work program represents a continuation of CTPS’s involvement in the MBTA’s Title VI monitoring efforts. It outlines the monitoring that will be completed for both the 2017 Triennial Title VI Report and the 2016 annual monitoring, which will provide some of the data for the analyses that will be reported in the triennial report.
The primary objective of this study is to produce a report that meets all of the requirements set forth in FTA Circular 4702.1B so that the FTA can make a determination about the MBTA’s compliance with Title VI regulations. To do so, CTPS will work closely with the MBTA to collect and analyze transit service data as they relate to minority populations within the MBTA’s service area. CTPS will provide ongoing technical support to the MBTA’s Title VI Working Group and will produce a final report for submittal to the FTA by June 1, 2017. This report will address all of the general reporting requirements (for which most of the documentation will be provided by the MBTA), as well as the required program-specific elements, which will be evaluated in the context of this work program, and will include:
In addition to the general reporting requirements, FTA Title VI Circular 4702.1B, dated October 1, 2012, sets forth a specific set of reporting requirements for transit providers who operate 50 or more fixed-route vehicles in peak service and that are located in an Urbanized Area (UZA) with a population of 200,000 or greater. Therefore, as one of these transit providers, the MBTA is required to collect and report data through a series of demographic and service profile maps and charts; monitor and report transit service through comparative analysis based on the MBTA’s systemwide service standards and service policies; and evaluate major service and fare changes with regard to equity.
The production of demographic and service profile maps and charts relies heavily on up-to-date data coverages of MBTA transit routes and amenities in the geographic information system (GIS) database maintained by CTPS. These coverages, which have been updated using 2010 census data, allow CTPS to designate the transit routes that serve, and the transit amenities that are located in, predominantly minority areas.
CTPS will collect the data needed for the comparative analysis of transit service according to the MBTA level-of-service monitoring schedule. Certain indicators are monitored annually, while others are monitored every two years. The analyses conducted for the 2017 Triennial Title VI Report will utilize the most recent data available for each of the indicators.
CTPS will produce the following maps, overlays, and summary statistics for the MBTA service area by census tract using demographic data from the 2010 census and 2014 American Community Survey (ACS) databases. CTPS will also provide narrative explanations of the maps. This task will consist of the following steps:
Base maps, demographic maps, and all required map overlays, as well as summary statistics and written descriptions and interpretations of the maps and overlays
Most of the level-of-service analyses associated with Title VI reporting rely on up-to-date data coverages of MBTA transit routes and amenities in the GIS database maintained by CTPS. These coverages allow CTPS to designate amenities as being located in, and routes as serving, predominantly minority or nonminority areas as defined by FTA Title VI guidelines.
For the level-of-service analysis, CTPS will first document the MBTA’s standards and policies for the service indicators specified in the Title VI Circular. CTPS will use existing documentation when available and will work with the applicable MBTA departments to document additional standards and policies, as necessary. At this time CTPS is working with the MBTA to develop new customer-centric standards.
For each of the service indicators specified in the Title VI Circular, CTPS will either directly collect the data required for performing the required level-of-service analyses described in Subtask 2.3 below or will work with the applicable MBTA departments to obtain the necessary data. Data collection activities that are not described here will be completed by the MBTA departments specified, and the results will be provided to CTPS for inclusion in the final triennial report.
For each of the service indicators specified in the Title VI Circular, CTPS will use the data discussed in Subtask 2.2 to assess the performance of all services by applying the service standards and policies documented in Subtask 2.1 and to compare the performance of the services provided to predominantly minority areas with the performance of services provided to nonminority areas. If the assessment shows that there is a disparate impact on the basis of race, color, or national origin, CTPS will work with the MBTA to determine why the disparity exists, and will assist in developing corrective actions to remedy the disparity to the greatest extent possible. CTPS will include in the final report a discussion of any corrective actions.
Summaries from the MBTA’s service standards and policies, maps displaying the distribution of transit amenities and transit accessibility, tables and charts displaying collected data and results from level-of-service analyses, and written descriptions of all procedures and findings
Since the submittal of the MBTA’s 2014 Triennial Title VI Report, CTPS has conducted numerous service and fare equity analyses, including those for the 2014 MBTA fare restructuring, 2015 MBTA Late-Night Service termination and mitigation, 2015–16 MBTA Youth Pass Pilot, and the 2016 MBTA fare restructuring. Documentation of these completed service and fare equity analyses and any additional service or fare equity analyses that may be performed before completion of the work outlined in this work program will be included in the MBTA’s 2017 Triennial Title VI Report.
Documentation of any service or fare equity analyses that have been completed between the submittal of the MBTA’s 2014 and 2017 Triennial Title VI reports
In addition to the program-specific data collection and analysis requirements outlined above, the Title VI Circular also includes a number of general reporting requirements that are completed by departments within the MBTA. These include, for example, public notification of protection under Title VI, Title VI complaint procedures and forms, a policy for providing access for limited-English-speaking populations based on the US Department of Transportation’s limited-English-proficiency (LEP) guidance on inclusive public-participation processes; a breakdown of minority representation on planning and advisory bodies; and equity analyses of the locations of any proposed transit facilities. The MBTA will provide CTPS with most all of the documentation related to these general reporting requirements and CTPS will incorporate the documentation into the MBTA 2017 Triennial Title VI Report.
Documentation in the 2017 Triennial Title VI Report of the fulfillment of other FTA general reporting requirements
CTPS will participate as a member in the MBTA’s Title VI Working Group in a technical-support role throughout development of the 2017 Triennial Title VI Report. CTPS will circulate draft sections of the report for review and comment by the Working Group as they become available.
Technical support to the MBTA’s Title VI Working Group
In addition to the summary statistics, maps, and documentation produced in Tasks 1–3, CTPS will assemble and format all of the documentation provided by individual MBTA departments to produce the MBTA’ s Triennial Title VI Report for submittal to the FTA, which is due June 1, 2017. CTPS will produce the final report in a format that is accessible to people with disabilities and is acceptable to the FTA, including a cover with a graphical design and graphical presentations of materials contained in the report, as appropriate. Subsequent to this submission, CTPS will provide follow-up assistance to MBTA staff to respond to issues raised by the FTA in its review of the MBTA’s 2017 Title VI Program.
MBTA 2017 Triennial Title VI Report for the FTA
CTPS staff will provide ongoing technical assistance to the MBTA to address Title VI issues, as necessary.
Technical support provided to the MBTA, as necessary
It is estimated that this project will be completed 12 months after work commences. The proposed schedule, by task, is shown in Exhibit 1.
The total cost of this project is estimated to be $161,511. This includes the cost of 60.5 person-weeks of staff time, overhead at the rate of 102.7 percent, and travel. A detailed breakdown of estimated costs is presented in Exhibit 2.
KQ/AD/NH/nh
Task |
Month | |||||||||||
---|---|---|---|---|---|---|---|---|---|---|---|---|
1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | 10 | 11 | 12 | |
1.
Produce Demographic and Service Maps and Charts |
From month 1 to 4.
| |||||||||||
2.
Monitor the Level of Service |
From month 1 to 8.
| |||||||||||
3.
Document Service and Fare Equity Analyses |
From month 6 to 8.
| |||||||||||
4.
Document Other General Reporting Requirements |
From month 4 to 8.
| |||||||||||
5.
Provide Technical Support to the MBTA's Title VI Working Group |
From month 1 to 13.
| |||||||||||
6.
Assemble the MBTA 2017 Triennial Title VI Report |
From month 8 to 10.
| |||||||||||
7.
Provide Ongoing Technical Support to the MBTA |
From month 1 to 13.
|
Task |
Person-Weeks | Direct Salary |
Overhead (102.70%) |
Total Cost |
||||||
---|---|---|---|---|---|---|---|---|---|---|
M-1 | P-5 | P-4 | P-3 | P-2 | Temp | Total | ||||
1.
Produce Demographic and Service Maps and Charts
|
0.8 | 2.0 | 0.4 | 1.6 | 0.0 | 0.0 | 4.8 | $7,723 | $7,932 | $15,655 |
2.
Monitor the Level of Service
|
1.6 | 0.0 | 0.0 | 6.0 | 1.4 | 13.0 | 22.0 | $18,560 | $19,061 | $37,621 |
3.
Document Service and Fare Equity Analyses
|
2.8 | 0.4 | 1.4 | 1.4 | 0.0 | 0.0 | 6.0 | $9,409 | $9,663 | $19,072 |
4.
Document Other General Reporting Requirements
|
2.0 | 1.0 | 1.0 | 2.0 | 0.0 | 0.0 | 6.0 | $9,272 | $9,523 | $18,795 |
5.
Provide Technical Support to the MBTA's Title VI Working Group
|
4.0 | 0.0 | 0.0 | 2.4 | 0.0 | 0.0 | 6.4 | $10,032 | $10,302 | $20,334 |
6.
Assemble the MBTA 2017 Triennial Title VI Report
|
6.0 | 1.0 | 1.0 | 3.0 | 0.0 | 0.0 | 11.0 | $17,650 | $18,127 | $35,777 |
7.
Provide Ongoing Technical Support to the MBTA
|
2.7 | 0.0 | 0.0 | 1.6 | 0.0 | 0.0 | 4.3 | $6,787 | $6,971 | $13,758 |
Total
|
19.9 | 4.4 | 3.8 | 18.0 | 1.4 | 13.0 | 60.5 | $79,433 | $81,578 | $161,011 |