Going Beyond: Advice to USDOT on Measuring Transport Fairness


In June, the US Department of Transportation asked for public input on how to assess transportation fairness. TransitCenter has joined hundreds of civic groups, transportation agencies and members of the public in responding.

The status quo must be reformed. While there are policies aimed at preventing discrimination in transportation policy, in practice federal mandates are toothless and the analyzes required shed little light on the problem of inequitable access to good public transit.

In response, transit agencies, advocates and researchers have developed new measures that go beyond federal requirements. USDOT should support, advance and popularize these methods.

Below we summarize our three main points. Our full submission to USDOT can be read here.

Evolving to a System-Wide Standard for Transportation Equity

The Federal Transport Administration currently requires (through its application of Title VI of the Civil Rights Act 1964) that before transport agencies make a “material” change in their tariffs or service, they analyze to show that the change is not having a “disparate impact” on people of color. But these requirements are narrowly defined and too weak to guarantee fair transit.

Title VI analyzes examine discrete changes rather than the system as a whole. They aim to determine whether a proposed change avoids disparate impacts, but say nothing about the extent to which existing transit service is fair.

The FTA has commissioned research that recommends more comprehensive measures; It is time to publish this work and, in collaboration with a wide range of stakeholders, replace the current interpretation of Title VI with respect to transit service and fare changes. Today’s close analyzes measuring the impact of proposed changes should be complemented by a forward-looking standard that measures the equity of a region’s existing transit network and whether that network provides more equitable access over time. time.

Base the analysis on opportunity access metrics

Many equity measures (including some required by Title VI) focus on “who lives near public transport”, but this can be very different from “who benefits from public transport”.

To grasp the latter question, people working in public transport increasingly use opportunity access metrics, which quantify the potential destinations a person can reach or the time it takes to get to types. specific destinations. These measures capture important aspects of how people can – or cannot – use transportation systems in their everyday lives.

The recently released Transit Equity Dashboard by TransitCenter shows how these metrics can help us understand equitable access to public transport – by comparing the efficiency with which the public transport network connects people of different races, ethnicities, incomes and other demographics to jobs, education, healthcare, food and parks. Most of these measures can be replicated by any organization with a high quality General Transit Flow Specification (GTFS) and the ability to analyze census data.

Additional data would provide additional information

Several other types of data would allow agencies to more fully measure equitable access. Important needs include:

Access to opportunities limited by prices. Many metropolitan areas have a “two tier” transit system consisting of fast and expensive regional transit service and relatively affordable but slow local transit service. In these areas, many low-income people are “billed” for parts of the transit system and do not have as much access to them as more affluent commuters.

The Equity Dashboard calculates these impacts. In the Philadelphia Metropolitan Statistical Area, for example, the average Latinx resident of can access 145,979 potential jobs in 45 minutes using public transportation, but only 81% of jobs using public transportation that cost less than $ 4. $ for a one-way ticket.

However, calculating these metrics is manually intensive, requiring months of “scraping” fare information on transit agency websites and other sources. If the GTFS were improved to better integrate tariffs, agencies would have less of a burden to compile the necessary data.

ADA compliance of transit and pedestrian conditions. Most transportation fairness measures ignore ADA compliance. This is partly due to missing data. Many municipal and regional governments lack comprehensive information on the location of sidewalks, crosswalks, and curbs.

One municipal effort worth replicating is the “Denver Moves” planning process. The City of Denver combined data from city maintenance crews, the Denver Regional Council of Governments, and aerial photographs to conclude that 60% of street miles had sidewalks that met the minimum width (4 feet) required by ADA, while 30% had sidewalks of insufficient width, and 10% were missing sidewalks. Austin, Texas recently completed a similar inventory.

On the transit data side, GTFS allows transit agencies to specify whether a transport stop allows people in wheelchairs to board, but few agencies consistently report this data. Other required data includes the ADA status of transit vehicles and the status of elevators at the transit station.

Qualitative awareness data. Transit agencies regularly conduct public education activities during the development of service changes, capital projects, long-term plans and other initiatives. Typically, this qualitative data is collected and applied to a single project or initiative.

There are risks when agencies duplicate public engagement efforts in the same community. For example, an agency might hold town hall meetings in a neighborhood as part of a long-term planning process, then again for a corridor study, then a third time before a capital project. This approach is expensive and if people are repeatedly asked the same questions without seeing the results of the previous outreach, it can decrease public confidence in the agency.

Transportation agencies should develop cross-team practices to retain and reapply qualitative data from previous outreach that is relevant to the ongoing work of any team – and the federal government should use its grants and research funding to support efforts in this direction.

Transport governance data. The boards of directors of transit agencies have considerable authority. Therefore, improving the practices and, in some cases, changing the structure of the boards of directors of transit agencies is an important step towards improving transit service.

An upcoming TransitCenter analysis shows a pattern of disparities between who sits on the boards of transit agencies and who uses transit. “Who decides” and “who rolls” are often very different. For example, less than 25% of the board members of the Southeastern Pennsylvania Transportation Authority are people of color, even though more than 25% of people in jurisdictions served by SEPTA and more than 50% of riders are not. white.

TransitCenter’s full commentary to USDOT is available here. USDOT said he will will publish a summary of the comments in September, and use them to inform an agency “equity plan” and “strategic plan” in February 2022.


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