City of Fresno Department of
Transportation/Fresno Area Express
Title VI Fare Equity Analysis:
Reduced Fares for Students
November 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 ensurin g 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 is proposing a fare change that would provide reduced fares to students beginning in January 2023; students with a valid ID will be able to purchase a single ride ticket for $0.75 or a 31-day pass for $22.00. Under the current fare structure, there is no student category, and students are required to pay full fares.
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 2022. FAX has also recently completed three other Title VI analyses, including for a series of service changes in 2020, an analysis of a fare reduction in 2021, and an analysis of a pilot program consisting of free fares for Reduced Fare passengers subsidized by Kaiser in 2022. This Title VI analysis will apply Title VI policies in a manner consistent with these earlier analyses.
Existing Conditions
The existing fare structure is detailed in Table 1.
Table 1: Existing Fare Structure
Fare Price
Fixed-Route Buses
Base Fare $1.00
Seniors, Medicare cardholders, and persons with
disabilities1
Free2
Children Under 12 Free
Military and Veterans, with valid ID Free
Transfers Free3
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
The free fares for seniors, Medicare cardholders and persons with disabilities (the “Reduced Fare” category) is a temporary measure, funded by a grant from Kaiser Permanente Fresno . Once the Kaiser grant funds are expended, fares will revert to the fare structure detailed in Table 2, unless the Kaiser grant is extended, or another funding source is obtained.
1 Reduced fare is available to seniors 65 and older with a valid ID, Medicare cardholders, and persons with disabilities with a valid ID.
2 The free fares for the “Reduced Fare” category is a temporary measure, funded by a grant from Kaiser Permanente Fresno.
3 Transfers must be requested at time of purchase and permit unlimited transfers for up to 90 minutes. 3 Table 2: Fare Structure without Kaiser Grant Subsidy for Reduced Fares 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.
Proposed Fare Changes
Under the proposed fare changes, FAX would offer a new category of fares for students , adding a new single-ride fare and a new 31-day pass. Handy Ride fares are unchanged by the proposed fare structure.
Table 3 details the proposed fare structure while the Kaiser grant is available.
Table 3: Proposed Fare Structure with Kaiser Grant Subsidy for Reduced Fares Fare Price
Fixed-Route Buses
Base Fare $1.00
Student* $0.75
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 – Student* $22.00
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.
4 Once the Kaiser grant funds are expended, fares will change to the fare structure detailed in Table 4.
Table 4: Proposed Fare Structure Without Kaiser Grant Subsidy for Reduced Fares Fare Price
Fixed-Route Buses
Base Fare $1.00
Student* $0.75
Seniors, Medicare cardholders, and persons with
disabilities*
$0.50
Children Under 12 Free
Military and Veterans, with valid ID Free
Transfers Free**
31-Day Pass – Regular $36.00
31-Day Pass – Student* $22.00
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
* Requires valid ID.
** Transfers must be requested at time of purchase and permit unlimited transfers for up to 90 minutes.
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 result 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, alternatives must be evaluated, and mitigation strategies offered to prevent or mitigate any potential burden.
In this case, FAX is proposing to add a new fare category for students, rather than changing the fares within current categories. Therefore, the analysis needs to answer whether the new fare category causes a disparate impact or disproport ionate burden by providing reduced fares to populations that are disproportionately non-minority or non-low income.
Analyzing the impact of reduced fares for students is complicated from a Title VI perspective. As a significant portion of those who benefit are under the age of 18, demographic data is limited. When analyzing the impact of the fare change on minority populations, some data is available. The major school district, university, and colleges in Fresno, including Fresno Unified School District, Fresno State University, Fresno City College, and Clovis Community College, all report demographic data for their student bodies, which can be compared to the demographic composition of the FAX service area. Table 5 details the demographic makeup of these sc hools compared to the FAX service area. American Community Survey (ACS) data was used for the service area population.
5 Table 5: Demographic Breakdown
Percent
Minority
Percent Non-
Minority
FAX Service Area 72.4% 27.6%
Fresno Unified School District 91.6% 8.4%
Fresno State University 83.2% 16.8%
Fresno City College 82.0% 18.0%
Clovis Community College 69.4% 30.6%
Fresno Unified School District, Fresno State University, and Fresno City College all have a student body where the proportion of minority populations is much greater than the service area as a whole. Clovis Community College is the exception to this, but it has a smaller student body than the others (Fresno Unified enrolls approximately 73,000 students, Fresno State enrolls approximately 24,000 students, and Fresno City College enrolls approximately 21,000 students , compared to just under 13,000 students at Clovis Community College according to the most recent enrollment data available for each ). In addition, the demographic make-up of Clovis Community College is relatively similar to the service area as a whole.
As a result, the benefits of reduced fares for students will go primarily to populations that are more likely to identify as a minority than the service area, and there is no disparate impact caused by the proposed fare change.
The income analysis is more complicated. Students are a wide range of ages, and there is no reliable income data available for students as a whole. Many students are also dependents, which further complicates analysis; an individual student’s income and access to funds may or may not be reflective of their household income. It is pr obable that the typical student in Fresno is equally or more likely to fall below FAX’s low -income threshold of 150% of the federal poverty line than the typical person living in FAX’s service area. With the lack of available data, it can be assumed that students generally follow similar demographic patterns as the service area population as a whole, and where that pattern does not hold true, that students generally have less access to full- time, high -paying jobs than the service area population. As a result, there is no disproportionate burden caused by the proposed fare change.
Public Outreach
FAX conducted Title VI public outreach prior to City Council action on this Fare Equity Analysis and will conduct an advertising campaign in English and Spanish prior to the implementation of the new fare structure. FAX held a virtual meeting on November 7, 2022, and two pop-up events on November 8, 2022, one at the Manchester Transit Center and on e at the Downtown Transit Center at Courthouse Park, to seek input on the new student fares. Passengers expressed support for the proposed student fares. Should the City Council approve the fare change, FAX will post information on the FAX homepage, directing users to more information on the fares and passes page of the website. FAX will also produce flyers advertising the new student fares in both English and Spanish, to be posted on FAX buses. FAX will conduct additional advertisement via community newspapers and Public Service Announcements in English and Spanish, as well as share information through its newsletter, social media, and community events. The materials used for the outreach efforts prior to City Council action are included in the Appendix. 6 Conclusion
Beginning in January 2023, FAX is proposing to add a new fare category to its fare structure that would provide reduced f ares to students with a valid ID. Although demographic data is limited , no disparate impact or disproportionate burden was found, based on what data is available. As a result, no mitigation measures are necessary. FAX will conduct significant public outreach to inform riders of the program, including outreach in both English and Spanish. FAX is also working directly with schools and universities, allowing them to purchase bulk tickets for their students.
7 Appendix: Outreach Materials
Figure 1: The Proposed Fare Structure
8 Figure 2: Outreach Flyer for Buses
9 Figure 3: Online Outreach Flyer in English
10 Figure 4: Online Outreach Flyer in Spanish
11 Figure 5: Website Advertisement
Figure 6: Advertisement on FAX Homepage
12 Figure 7: FAX Webpage on Student Fare Workshops
Figure 8: Virtual Workshop Presentation
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