FTA Seeks Input on Equity Analysis

FTA issued a request for information in November on Title VI implementation. In their dozen questions a few focus on equity analysis. In my comments (below) I offered input on the use of zero auto ownership (ZAO) and multi-variable analysis to help better guide transit service route changes or service frequency changes to ensure that impacts or benefits are equitable and essential transit services are protected. If you are interested in equity analysis, please offer FTA your insights by January 3, 2022 as they have extended the comment period through the holiday period.

Letter to FTA Administrator Nuria Fernandez:

I would ask FTA to establish desired outcomes related to service equity rather than to stipulate means and methods of analysis. So many transit providers do not have the resources of the top 10 MSAs in the United States. They would benefit more from efforts of FTA to provide clear guiding principles that are desired/required for using federal funds. And then offer simple-to-apply case studies where these principles have been used in practical, pragmatic, and cost-effective fashion. This could be done through funding of pilot or demonstration projects showing how the means and methods of analysis can be applied in a real, first-hand user basis to the benefit of communities of concern. This would help agencies and districts more than prescriptive regulations regarding analysis, steering clear of one-size fits all approaches (which can border on proprietary practices). FTA has leaned in on the regulatory approach for 50 years. Emphasizing outcomes and incentives rather than compliance with rule making would be welcome now.

This is particularly true today as analysis methods and big data sources are evolving yearly if not daily. During COVID they have accelerated. While census data sets can be helpful, multivariable analysis is more readily available with GIS. With regard to question 6 asking about population data or ridership data – the real question is whether either of them by themselves actually constitute equity analysis? Since much of the American Community Survey (ACS) can be GIS based, it would seem population or ridership data by themselves are not adequate. If the guiding principle is greater equity in route or fare decision making, simple multi-variable tools would be a great help. Using FTA research funds to pilot some example equity analysis approaches that can readily be accessed by all transit districts and agencies seems very possible today with GIS, big data sources, census AND ACS type data.

Related to question 7, access to transit and service coverage only tells a small part of the story. Using parcel level data sets, much more can be learned by multivariable GIS analysis of route access and frequency today various essential needs. Things like jobs (within for example 45 minutes), grocery access within 15 minutes, accessibility to medical, school, recreation and/or activity centers should be part of equity analysis rather than simple service coverage.

Related to question 6, using GIS across a transit service area to group data on auto ownership, income and race (and where possible verified with ridership data) should be considered in equity analysis. The multi-variable approach may better be able to demonstrate where any service change may or may not affect underrepresentation of population. For example, looking in silos at auto ownership, income and race only tells pieces of the story. Access or service coverage tells even less. Auto ownership and income can be a key determinate in essential transit services and whether transit service changes would impact those populations. However, looked at in isolation the enormous difference between car-less and car-free can be lost and lead inequitable decisions. By layering analysis through GIS using readily-defined zones (census or TAZ) with available auto ownership, income, age and race data, essential transit route coverage and its equitable application can be differentiated. Simple criteria (<$50,000 household incomes, zero auto ownership, race) can be combined analytically. These are readily available data sets from ACS and census sources and can be confirmed through ridership survey data sets (when available). When service reductions or enhancements are a part of the investment strategy of both local and federal funding, the impact to lower income, car-less households should always be assessed to optimize transit services.

Rule making should focus on the desired outcome rather than greater regulation of analysis. Therefore, I would ask FTA prioritize setting clear guiding principles and obtaining practical case study go-bys for local districts and agencies. Establishing the guiding principles associated with any equity analysis allows analysts to create timely solutions for the future rather than the past, right-sized to the transit authority.?Working collaboratively with partner transit district/agencies to pilot them in real-life, with a keen focus on labor efficiency, FTA can provide valued services for use across the country. The outcome would be practical case studies that flexibly apply to each circumstance leading to innovation, adaptation and better outcomes which may be shared.?