City of Fresno Department of
Transportation/Fresno Area Express
Title VI Fare Equity Analysis:
Free Fares for Reduced Fare Riders, funded
by Kaiser Permanente Fresno until Funds are
Expended
August 2022
Prepared By:
1 Overview
In compliance with Title VI of the Civil Rights Act of 1964, the Federal Transit Administration (FTA) requires all transit agencies that receive federal funding to monitor the performance of their systems, ensuring services are made available and/or distributed equitably. One component of ensuring compliance is performing an equity analysis for all fare changes and any major service changes to determine its impact on minority (race, color, or national origin) and low-income populations.
Fresno Area Express (FAX) is the primary fixed -route transit operator in Fresno and is operated and administered by the City of Fresno, California. FAX implemented a pilot fare change on July 1, 2022, eliminating fares for seniors 65 years old and older with a valid ID; Medicare cardholders; and persons with disabilities with a valid ID. Under the fare structure prior to July 1, these riders were eligible for a reduced fare of $.50. This measure is temporary, funded by a $500,000 grant from Kaiser Permanente Fresno, and will end when the grant funding has been expended.
This Title VI analysis will:
• Evaluate how the proposed fare changes may impact low-income and minority populations, and • Identify strategies to avoid, minimize, or mitigate any disproportionate burdens, disparate impacts, or any potentially negative outcomes.
Relevant Policies
This fare equity analysis was completed in accordance with FTA regulations outlined in FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients.” The circular requires this analysis to ensure or minimize any disparate impact on minority populations or disproportionate burden on low-income populations.
Disparate Impact Definition
Refers to a facially neutral policy or practice that disproportionately affects members of a group identified by race, color, or national origin, where the recipient’s policy or practice lacks a substantial legitimate justification and where there exists one or more alternatives that would serve the same legitimate objectives but with less disproportionate effect on the basis of race, color, or national origin. (FTA C 4702.1B, Chap. I-2)
Disproportionate Burden Definition
Refers to a neutral policy or practice that disproportionately affects low-income populations more than non-low-income populations. A finding of disproportionate burden requires the recipient to evaluate alternatives and mitigate burdens where practicable. (FTA C 4702.1B, Chap. I-2) The circular requires that there be a fare equity analysis completed for any change in fares or in fare media. Each transit agency is responsible for establishing what differential is considered a disparate impact or disproportionate burden.
Disparate Impact Policy
A disparate impact exists if a major service change, fare change, or fare media change requires a minority population to bear adverse effects by 20 percent or more than the adverse effects borne by the general population in the affected area.
2 Disproportionate Burden Policy
A disproportionate burden exists if a major service change, fare change, or fare media change requires a low-income population to bear adverse effects by 20 percent or more than the adverse effects borne by the general population in the affected area.
FAX’s Title VI Program was adopted in 2019. FAX has also recently completed four other Title VI analyses, one for the Faster FAX network in 2016, one for a proposed smart card in 2018, one for a series of service changes in 2020, and an analysis of a fare reduction in 2021. This Title VI analysis will apply Title VI policies in a manner consistent with these earlier analyses.
Existing Conditions
The existing fare structure prior to July 1st is detailed in Table 1. Once the Kaiser grant funds are expended, fares will revert back to this fare structure.
Table 1: Existing Fare Structure
Fare Price
Fixed-Route Buses
Base Fare $1.00
Reduced Fare* $0.50
Children Under 12 Free
Military and Veterans, with valid ID Free
Transfers Free**
31-Day Pass – Regular $36.00
31-Day Pass – Reduced $18.00
10-Ride Card - Regular $9.00
10-Ride Card – Reduced $4.50
Handy Ride
Base Fare (single ride) $1.25
Handy Ride Pass $36.00
* Reduced fare is available to seniors 65 and older with a valid ID, Medicare cardholders, and persons with disabilities with a valid ID.
** Transfers must be requested at time of purchase and permit unlimited transfers for up to 90 minutes.
Temporary Pilot Fare Changes
FAX has removed fares for passengers eligible for reduced fares , while Kaiser grant funding remains available. The pilot fare structure is detailed in Table 2. 3 Table 2: Pilot Fare Structure
Fare Price
Fixed-Route Buses
Base Fare $1.00
Seniors, Medicare cardholders, and persons with
disabilities*
Free
Children Under 12 Free
Military and Veterans, with valid ID Free
Transfers Free**
31-Day Pass – Regular $36.00
31-Day Pass – Reduced Free
10-Ride Card - Regular $9.00
10-Ride Card – Reduced Free
Handy Ride
Base Fare (single ride) $1.25
Handy Ride Pass $36.00
* Requires valid ID.
** Transfers must be requested at time of purchase and permit unlimited transfers for up to 90 minutes.
The pilot fare structure further simplifies FAX’s fare structure, effectively reducing the number of fare categories to two. Riders now either qualify for free fares through a variety of categories or pay the base fare. Handy Ride fares are unchanged by the pilot fare structure.
Fare Equity Analysis
At its core, a fare equity analysis demonstrates that a transit agency has considered the consequences of a proposed policy that is facially neutral but may resul t in a disparate impact on minority riders or a disproportionate burden for low-income riders. The FTA’s recommended methodology for performing a fare equity analysis begins with determining the number and percent of users of each fare type and evaluating the differences between minority users and non-minority users and low-income and non-low- income users. Next, the analysis should evaluate the impacts of the proposed changes to determine if there is a disparate impact or disproportionate burden. Finally, a lternatives must be evaluated, and mitigation strategies offered to prevent or mitigate any potential burden.
FAX is proposing to reduce fares for a limited time due to a grant from Kaiser Permanente Fresno which will subsidize fares for the mentioned groups. This may not seem like an obvious equity concern. However, the FTA Circular requires that all fare changes be analyzed to ensure that benefits are not disproportionately given to non-minority and non-low-income individuals.
Free fares for riders eligible for reduced fares is complicated from a Title VI perspective. The populations impacted by this pilot program are diverse, and there is little demographic data available for some of them. Although FAX has conducted customer surveys that have been used i n previous Title VI analys es, the level of detail collected by those surveys was not enough to properly analyze the impact of the pilot program. The surveys did ask questions about age and income, but the age brackets were not spaced in a manner to be usef ul for this analysis . Additionally, the customer surveys did not collect data about disability status or Medicare cardholders.
American Communities Survey (ACS) data is similarly limited. Although ACS contains some data on some of these populations, it is not sufficiently detailed for the purposes of this analysis; ACS does have data by 4 age, for example, but does not provide crosstab ulations for income and household sizes, necessary information to determine low-income status. Similar issues exist with minority status.
For reference, maps depicting minority, low -income, senior, and disabled populations in Fresno are included in Appendix A. In general, areas with above average disability correlate with low -income and minority populations. There is less correlation between seniors and areas with low -income and minority populations.
Seniors, Medicare cardholders, and persons with disabilities already have a benefit over other riders, and reduced fares are frequently provided for seniors, Medicare cardholders, and persons with disabilities by transit agencies all over the country. These benefits are widely accepted , and the FTA does not provide guidance on how much these fares can be reduced by.
Additionally, eliminating and lowering fares for seniors, Medicare cardholders, and persons with disabilities has been used to encourage riders that are eligible for paratr ansit services but able to access and use fixed route services instead, as the cost to transit agencies to provide paratransit services is significantly higher than the cost to provide service on fixed route services.
The benefits also do not discriminate on basis of race or income; everyone over the age of 65 can take advantage of the free fares, and everyone needs to meet the same criteria to be eligible for Medicare cards or disability. As a result, the pilot fare program does not result in a disparate i mpact or disproportionate burden, and mitigation measures do not need to be considered for these changes.
Public Outreach
FAX conducted public outreach prior to the implementation of the pilot program, undertaking an extensive advertising effort in English and Spanish. FAX posted information about the fare change on the FAX homepage, directing users to more information on the fares and passes page of the website. A flyer advertising the fare program in both English and Spanish was posted on FAX buses. To ensure the broadest reach, FAX ran ads in The Advocate newspaper in English and the Vida En La Valle newspaper in Spanish on June 29, 2022. FAX also advertised the program at major transit centers and on some highly trafficked bus shelters. FAX shared information regarding the fare changes through its newsletter and social media.
FAX’s marketing campaign is detailed in Appendix B.
Conclusion
On July 1, 2022 FAX initiated a pilot program financed by Kaiser Permanente Fresno that allows reduced fare riders – seniors, Medicare cardholders, and persons with disabilities – to ride for free until the funding is expended . Although specific data on these populations was unavailable, no disparate impact or disproportionate burden was found, due to the fact that these populations already receive reduced fares, and that no one is excluded from these populations based on race or income. FAX conducted significant public outreach to inform riders of the program, including outreach in Spanish. FAX should continue to conduct outreach, especially in low-income and minority neighborhoods to ensure those that are eligible for the program take advantage of it.
5 Appendix A: Maps
Map 1: Areas with Above Average Disability Population
6 Map 2: Areas with Above Average Minority Population
7 Map 3: Areas with Above Average Low-Income Population
8 Map 4: Areas with Above Average Senior Population
i
Appendix B: Informational and Outreach Materials
Flyers in English and Spanish were posted onto the FAX web site home page informing passengers of new fares:
When the ‘Attention FAX: Reduced Fare Riders’ image was clicked on the website, it opened to the Fares and Passes section of the website, shown below. The messaging related to the Kaiser Grant is shown in the second sub -section within the screenshot below.
ii
The flyers were also made available in English and Spanish as PDF files for online distribution.
iii
A third flyer was created in both English and Spanish for off-line distribution and posted onto all FAX buses.
iv
Advertisements were run in The Advocate newspaper in English and in the Vida En La Valle newspaper in Spanish. Both were run as quarter page ads on June 29, 2022.
v
Kiosk insert placed at Manchester Transit Center kiosk in English and Spanish:
vi
Kiosk insert placed at A, B, and L Shelters at Courthouse Park in Downtown Fresno in English and Spanish:
vii
Reduced Fare instructions in English were placed on the “Fares” page of the FAX web site and made available to English- speaking transit riders at MTC.
viii
ix
Reduced Fare instructions in English were placed on the “Fares” page of the FAX web site and made available to English- speaking transit riders at MTC.
x
Two banners were hung in the breezeway at the Manchester Transit Center.
Stickers were placed on the fare boxes of FAX buses
xi
A Flyer of Current Fare Structure with information about Kaiser Grant Subsidy was posted onto the “Fares” page of the FAX web site.
xii
A poster was displayed in the Bus Drivers room at FAX advising them about the Kaiser Program subsidy.
xiii
The June 2022 “What’s New At FAX” newsletter included an article announcing the Kaiser grant providing free fares for Reduced Fare Riders for a limited time (English).
Posted on the FAX website in English a nd Spanish and sent to subscribers of the FAX email newsletter containing 322 subscribers.
xiv
The June 2022 “What’s New At FAX” newsletter included an article announcing the Kaiser grant providing free fares for Reduced Fare Riders for a limited time (English).
Posted on the FAX website in English and Spanish
xv
Social Media posts were posted onto Facebook, Instagram, and Twitter
xvi
E-mail was sent to FAX Stakeholders on June 30, 2022:
Dear FAX Stakeholders:
Generous Kaiser grant provides free fares for Reduced Fare Riders for a limited time In May 2022, Kaiser Permanente Fresno awarded grant funds to FAX to subsidize fares for Reduced Fare riders. Reduced Fare riders include Seniors 65 or older with ID, Medicare card holders, and persons with disability placards. This project is supported by Kaiser Permanente Northern California Community Benefit Programs. This program will continue until grant funds are expended.
WHAT THIS MEANS AND HOW TO USE THE PROGRAM
Beginning July 1, 2022, qualifying Reduced Fare riders can board any FAX Fixed Route bus at no cost to the rider. This means that Reduced Fare riders can ride for FREE, and will no longer need to purchase tickets or passes, until the grant funds expire. (Handy Ride is not included.) *Riders must show identification at the time of boarding. *Acceptable types of I.D. are:
• FAX issued identification cards
• Medicare card and proper identification
• Driver’s License or State issued I.D. card (DMV)
• DMV Parking Placard with registration form
We ask you to help us inform all FAX riders that you encounter. For assistance, please call 559-621-RIDE.
Thanks to Kaiser Permanente Fresno for this kind gesture!
Una generosa subvención de Kaiser proporciona tarifas gratuitas para pasajeros con tarifa reducida por tiempo limitado En mayo de 2022, Kaiser Permanente Fresno otorgó fondos de subvención a FAX para subsidiar las tarifas de los pasajeros con tarifa reducida. Los pasajeros de tarifa reducida incluyen personas mayores de 65 años con identificación, titulares de tarjetas de Medicare y personas con carteles de discapacidad. Este proyecto cuenta con el apoyo de los Programas de Beneficios Comunitarios del Norte de California de Kaiser Permanente. Este programa continuará hasta que se agoten los fondos de la subvención.
QUÉ SIGNIFICA ESTO Y CÓMO UTILIZAR EL PROGRAMA
A partir del 1 de julio de 2022, los pasajeros de tarifa reducida que califiquen pueden abordar cualquier autobús de ruta fija de FAX sin costo alguno para el pasajero. Esto significa que los pasajeros con tarifa reducida pueden viajar GRATIS y ya no necesitarán comprar boletos o pases hasta que expiren los fondos de la subvención. (Handy Ride no está incluido). *Los pasajeros deben mostrar una identificación al momento de abordar. *Tipos aceptables de I.D. son:
• Tarjetas de identificación emitidas por FAX
• Tarjeta de Medicare e identificación adecuada
• Licencia de conducir o identificación emitida por el estado. tarjeta (DMV) • Placa de estacionamiento del DMV con formulario de registro Le pedimos que nos ayude a informar a todos los usuarios de FAX que encuentre. Para obtener ayuda, llame al 559 -621- RIDE.
¡Gracias a Kaiser Permanente Fresno por este amable gesto! xvii
Jeff
Jeff Long
Senior Regional Planner
Department of Transportation
Phone: 559.621.1436
Email: [email protected]
2223 G Street
Fresno, CA 93706
www.fresno.gov/transportation
Serving our community through safe,
Sustainable, and reliable transportation.