Big Blue Bus_Title VI Report_9.26.22 draft FINAL — Santa Monica City Council, October 25, 2022

Big Blue Bus
Title VI Report
October 2022
Table of Contents
Table of Contents ..................................................................................................................................................... 1 1 Overview ............................................................................................................................................................. 3

1.1 Background .............................................................................................................................................. 3

1.2 Mission Statement and Goals ............................................................................................................... 4 Mission Statement ............................................................................................................................................ 4 Vision .................................................................................................................................................................... 4 Core Values ........................................................................................................................................................ 5

1.3 Notice of Rights Under Title VI ............................................................................................................... 5

1.4 Title VI Rights Claims & Complaints ..................................................................................................... 5 Procedure for Filing a Title VI Complaint ..................................................................................................... 6

1.5 FTA Certification and Assurances ....................................................................................................... 7

1.6 Racial Breakdown of Non-Elected Advisory Councils .................................................................... 7

1.7 Subrecipient Monitoring ......................................................................................................................... 7

1.8 Limited English Proficiency Plan ........................................................................................................... 7

1.9 Title VI Analysis of New Facilities .......................................................................................................... 8 2 Service Design Standards ............................................................................................................................... 9

2.1 Service Area.............................................................................................................................................. 9

2.2 Service Availability and Demographics ............................................................................................ 10

2.3 Service Frequency ................................................................................................................................ 10

2.4 Span of Service ....................................................................................................................................... 13

2.5 Stop Spacing and Placement ............................................................................................................. 15 3 Service Policies ................................................................................................................................................ 16

3.1 Transit Amenities ................................................................................................................................... 16

3.2 Vehicle Fleet ........................................................................................................................................... 16

3.3 Vehicle Assignment .............................................................................................................................. 17

3.3 Vehicle Amenities .................................................................................................................................. 18

3.4 Vehicle Load ........................................................................................................................................... 18

3.4 Security .................................................................................................................................................... 20

3.5 Information Dissemination .................................................................................................................. 20 4 Service Quality Standards ............................................................................................................................ 22

4.1 On-time Performance ......................................................................................................................... 22 5 Current Activities ............................................................................................................................................ 24

5.1 Community Outreach .......................................................................................................................... 24

5.2 Service Changes .................................................................................................................................... 24

5.3 Fares ......................................................................................................................................................... 26

5.4 Federally Assisted Projects ................................................................................................................. 28 6 Appendix ................................................................................................................................................. 29

1 Overview
City of Santa Monica’s Department of Transportation, operating as Big Blue Bus (BBB) operates more than 50 fixed-route peak vehicles and is located in an urbanized area of more than 200,000 people and is therefore subject to the requirements set forth in the Federal Transit Administration’s (FTA) Circular 4702.1B and Title VI of the Civil Rights Act of 1964:
“No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal assistance.” Every three years, Big Blue Bus submits a Title VI Program to the FTA documenting compliance with the established Title VI requirements. In accordance with this submittal, Big Blue Bus has issued the following update, contained herein, to its Title VI Program.

The service design standards lay out how Big Blue Bus service should be designed and operated, for existing as well as new services. The service performance standards describe how Big Blue Bus analyzes its routes to ensure the highest possible level of performance in terms of service effectiveness, efficiency, and quality for customers. The service evaluation process presents Big Blue Bus’s strategy for analyzing, updating, and communicating its service plans to ensure that it continues to provide service that stays relevant to the needs of the City and its residents, employees, and visitors.

Big Blue Bus is committed to
the enforcement of USDOT’s
Title VI regulations which
state that no person or group
of persons shall be
discriminated against with
regard to the routing,
scheduling, or quality of
service of transportation
provided on the basis of
race, color, or national origin.

1.1 Background
Operated by the City of Santa Monica and governed by its seven-member elected City Council, the Big Blue Bus service area encompasses 58 square miles in the Westside region of Los Angeles County. The City of Santa Monica has provided transit service in the area since the launch of Santa Monica Municipal Bus Lines in 1928.

Presently, BBB operates 21 fixed routes with a fleet of 195 buses. It serves over 900 bus stops, 360 of which are in the City of Santa Monica. Service types are divided into three categories: Rapid service, Local service, and Commuter/Express service.

Average daily weekday ridership is approximately 25,000 boardings per day.

According to a 2021 Big Blue Bus Customer Survey, the majority of BBB riders (73%) identify as a minority, and 59% of BBB riders are considered low-income with an annual household income of less than $35,000.

BBB also provides demand response and door-through-door services for seniors and people with disabilities through MODE (Mobility on Demand Everyday), in partnership with the City's Community and Cultural Services Department. MODE serves over 1,400 enrolled members, providing over 2,500 trips each month.

Compliance with Title VI regulations is overseen by the Director of Department of Transportation, who reports to the City Manager. Additional City departments, including the City Attorney’s Office and Human Resources Department, assist the Transportation Department with Civil Rights compliance.

1.2 Mission Statement and Goals
BBB’s Strategic Plan, mission statement, goals, values, and standards serve as guiding principles for daily administrative functions and transit operations.

Mission Statement
BBB is dedicated to contributing to the region’s mobility, economic vitality, sustainability, and enhanced quality of life through the delivery of safe, reliable, economical, accessible and customer-focused mass transportation services.

Vision
BBB is a leading resource for innovative and environmentally friendly transportation options with a team of employees committed to continuous improvement and excellent service.

Core Values

1.3 Notice of Rights Under Title VI
BBB is committed to ensuring that no person is excluded from participation in, or denied the benefits of services on basis of race, color, and national origin as protected by the Civil Rights Act of 1964, as amended.

No person or group of persons will be discriminated against with regards to fares, routing, scheduling or quality of transportation service that BBB furnishes, on the basis of race, color, or national origin.

In addition, the frequency of service, age and quality of BBB vehicles assigned to routes, and location of routes will not be determined on the basis of race, color, national origin, sex, age or disability.

This information can be accessed via BBB’s website at:
https://www.bigbluebus.com/titlevi. Additionally, this information is posted in BBB’s Transit Store and on all BBB buses. See appendix for a copy of the public notice.

1.4 Title VI Rights Claims & Complaints
The City Attorney’s Office tracks and monitors any Title VI allegations of discrimination on the basis of race, color, or national origin with respect to service or other transit benefits. The City will continue to provide FTA information upon request. Two formal complaints or lawsuits alleging discrimination on the basis of race, color, or national origin with respect to service or other transit benefits were received.

Service
• Safe
• Reliable
• Sustainable
• Accessible
• Customerfocused
• Responsive
People
• Diverse
• Ethical
• Honest
• Responsible
• Creative
• Learning
• Resourceful
Culture
• Collaborative
• Constructive
• Engaging
• Inclusive
• Respectful
• Reflective

Date of
Alleged
Incident Summary Status Action Taken
Lawsuits
Bullard v. City of
Santa Monica,
22STCV11354, filed
4/4/22
2/20/21 Race: Plaintiff alleged
bus driver verbally
abused her including
use of a racial slur.

Litigation
is
pending.

Closure letter provided to
complainant. Referred to
Operations to take
appropriate action if
required.

Complaints
Gorg-Carter Kent 8/12/22 Race, Color, National
Origin: Complainant
alleged bus driver
refused to allow him
on bus based on
race, color, national
origin and other
protected classes.

Complaint
closed.

Closure letter provided to
complainant. Referred to
Operations to take
appropriate action if
required.

BBB’s Customer Service Division is responsible for receiving, filing, monitoring, and reporting informal customer complaints, including discriminatory complaints.

Monthly reports are generated to evaluate trends and address issue areas.

Procedure for Filing a Title VI Complaint
If any person feels he or she has been discriminated against on the basis of race, color or national origin by the City of Santa Monica Big Blue Bus, he or she may file a Title VI complaint by completing and submitting the Title VI Complaint Form. BBB investigates complaints received no more than one hundred and eighty (180) days after the alleged incident. The complaint may be submitted by mail, email, or in person, or it could be submitted directly with the Federal Transit Administration Region IX or Federal Transit Administration Office of Civil Rights.

The complaint may be filed in writing, in person, or by telephone. The complaint should include the following information:
 Name, address and how to contact complainant (e.g. telephone number, email address, etc.)  How, when, where and why complainant believes they were discriminated against. Include the location, names and contact information of any witnesses.

Complaint Assistance: A City of Santa Monica Big Blue Bus Customer Service Representative will assist with writing a complaint if the complainant is unable to do so.

See appendix for complete complaint procedure and complaint form.

1.5 FTA Certification and Assurances
BBB certifies, through the annual Certifications and Assurances, compliance with Title VI. The City Manager and City Attorney certify annually to the FTA Certifications & Assurances in accordance with the Federal Register and FTA Master Agreement.

1.6 Racial Breakdown of Non-Elected Advisory Councils
Big Blue Bus has a goal of providing customer-driven transit service, and particularly values the views and concerns of the large percentage of minority and low-income populations that utilize our system on a daily basis.

BBB reports directly to one governing body:
 Santa Monica City Council – Made up of seven members, elected at-large for staggered four-year terms, the City Council selects one of its members to serve as Mayor and another to serve as Mayor Pro Tempore.

As all individuals are elected into office, a racial breakdown of the advisory body is not required.

1.7 Subrecipient Monitoring
BBB does not have any subrecipients and in turn, does not perform any subrecipient monitoring.

1.8 Limited English Proficiency Plan
BBB is committed to the development of a Limited English Proficiency (LEP) Plan to ensure full dissemination, access, and participation by all persons where English may not be their first language. An LEP Plan has been developed in association with this document.

See appendix for the Limited English Proficiency Plan.

1.9 Title VI Analysis of New Facilities
BBB has not constructed a new facility, such as vehicle storage facility, maintenance facility, operation center, etc., at this time nor is planned in the near future.

Therefore, an equity analysis, regarding new facilities, was not performed. 2 Service Design Standards
Service design standards refer to how transit service is designed, implemented, and operated on the street, from route alignment and stop spacing to frequency and span of service. Results from monitoring service, the demographic data is consulted to perform a service equity analysis prior to service changes.

2.1 Service Area
The Big Blue Bus service area encompasses approximately 58 square miles that covers Santa Monica and surrounding areas in the Westside region of Los Angeles County, including: Pacific Palisades, West Los Angeles, Brentwood, Westwood, University of California Los Angeles (UCLA), Cheviot Hills, Mid-City, Westchester, Inglewood, Marina del Rey, Venice, and Playa Vista. BBB service also provides connections to the LA Metro rail network, Metrolink, Amtrak, and Los Angeles International Airport.

The BBB service area includes any Census block group that falls within a 1/2 mile of a fixed-route. The block group is the smallest geographical unit for which the Census Bureau publishes sample data and results in a more accurate analysis. A minority or low-income route is considered to be any route with a ½ mile population above the service area average for these two categories.

For the purposes of this evaluation, the minority population has been defined in accordance with FTA Circular 4702.1B and includes the following persons:
1) American Indian and Alaska Native;
2) Asian;
3) Black or African American;
4) Hispanic or Latino;
5) Native Hawaiian or other Pacific Islander
BBB’s current service area encompasses 550 block groups with 40.9% of all persons identifying as a minority race and 28.6% of all persons considered to be low-income.

The low-income population has been defined as any individual with an annual household income of less than $35,000. In addition, 11.1% of all households within the BBB service area have a limited proficiency in English.

The appendix includes a collection of BBB service area maps, identifying Census Block Groups with a population of minority persons, low-income persons, and limited English households that are above the corresponding service area averages.

2.2 Service Availability and Demographics
BBB provides service to all riders regardless of race, color, or national origin.

BBB routes are categorized as follows:

Table 1: Service Categories
Category Network Role Bus Routes
Rapid Provides high frequency, limited-stop
service between Santa Monica and
neighboring destinations of strong regional
importance.

R3, R7, R12
Local Serves the greater Santa Monica area,
providing service along major and
secondary corridors and serving larger local
destinations and intermodal connections.
1, 2, 3, 5, 7, 8, 9, 14, 15,
16, 17, 18, 41-42, 44
Commuter Augments the local network with additional
peak hour service to key destinations.

R10, 43, E7
Demand
response
Connections to, complements, and
encourages fixed-route transit.

MODE

2.3 Service Frequency
BBB’s adopted frequency standards and goals guide service investment and allocation decisions to ensure a high quality of service for all riders.  Rapid routes should operate at 20 minutes or better, with a goal of 6-10 minutes (weekdays) and 30 minutes or better, with a goal of 10-15 minutes (weekends). Whenever possible, Rapid services should operate more frequently than Local service on the same corridor, to allow maximum customer convenience and greater access to the faster, more efficient service option.
 Local routes should operate at 30 minutes or better, with a goal of 10-15 minutes (weekdays) and 30 minutes or better, with a goal of 15-20 minutes (weekends). Local routes on major corridors (especially those without Rapid options) may warrant much more frequent service (15 or 10 minutes).  Commuter route frequency should be tailored to demand volumes but should operate 30 minutes or better, with a goal of 10-15 minutes to allow spontaneous use where supported by ridership.

Table 2 shows current headways for all routes broken, down by weekday time periods, Saturdays, and Sundays.

Table 2: Service Frequency (minutes)
Route AM
Peak
Midday
PM
Peak
Evening Saturday Sunday
1 – Mains St & Santa
Monica Blvd 10-11 10-11 10-11 20 12-15 15
2 – Wilshire Blvd 20 20 20 20 20 20
3 – Lincoln Blvd 15 12 15 20 15 15
R3 – Lincoln Blvd Rapid 12 - 12 - - -
5 – Olympic Blvd –
Century City 60 60 60 60 - -
7 – Pico Blvd 14 14 14 20 15 15
R7 – Pico Blvd Rapid 14 14 14 - - -
E7 – Pico Boulevard
Express 20 20 20 20 - -
8 – UCLA/Westwood &
Ocean Park Blvd 20 30 20 30 30 30
9 – Pacific Palisades 15-20 30 20 30 30 40
R10 – Downtown LA
Freeway Express 60 - 60 - - -
R12 – UCLA/Westwood
& Overland Ave 10-12 12 10-12 20 22 22
14 – Bundy Dr &
Centinela Ave 15 20 15 20 20 28
15 – Barrington Ave 50-
60 50 50 50-60 - -
16 – Wilshire Blvd/Bundy
Dr – Marina del Rey 25 25 25 - - -
17 – UCLA – VA Medical
Center - Palms 15 20 20 30 28-30 28-30
18 – UCLA – Abbot
Kinney – Marina del Rey 30 30 30 30 30 30
41 – 17th St Station – SMC
- Montana 20 20 20 - 30 -
42 – 17th St Station –
SMC - Montana 20 20 20 - - -
43 – 26th St & San
Vicente Blvd 30 - 30 - - -
44 – 17th St Station –
SMC – Ocean Park 13 13 13 - - -
In Table 3, minority and low-income routes are compared to non-minority and nonlow-income routes. Each category presents frequency in minutes during weekday time periods, Saturdays, and Sundays. Using the ½ mile buffer of all fixed-route service, the same three routes exceed the service area average for both the minority and low-income designations. These routes are Route 7, Rapid 7, Express 7, and Rapid 10. All other routes are considered non-minority and non-low-income routes.

Table 3: Service Frequency Comparison
Service Category AM
Peak Midday
PM
Peak
Evening Saturday Sunday
Minority and LowIncome Route
Frequencies

8.0 8.0 8.1 8.1 15.0 15.0
Number of Minority
Routes Operating
(4) (3) (4) (3) (1) (1)
Non-Minority and NonLow-Income Route
Frequencies

17.6 18.3 18.2 20.4 24.0 24.9
Number of NonMinority and Non-LowIncome Routes
Operating
(17) (16) (17) (9) (9) (9)

2.4 Span of Service
The BBB span of service standards guide how many hours a specific route will operate during each day of service. Span of service is designated into two categories: 1) High ridership corridors that carry over 2,500 average daily riders, and 2) Low ridership corridors that include all other routes.  High ridership corridors should have a weekday span starting from 5am-6am to midnight and a weekend span starting from 6am-7am to midnight  Low ridership corridors should have a weekday span starting from 5am-6am to 9pm and a weekend span starting from 6am-7am to 9pm
 Commuter service spans should be tailored to demand patterns  Span of service may need to be adjusted on certain routes depending on the operating hours of connecting services, or, if there is an over capacity in service during the off-peak hours, where two routes are operating similar services
In Table 4, the average start and end times, along with the span of service, are compared between minority and non-minority routes, and low-income and nonlow-income routes for each service day type. As previously stated, three BBB routes are considered both minority routes and low-income routes. These routes are Route 7, Rapid 7, Express 7, and Rapid 10. All other routes are considered nonminority and non-low-income routes.

Table 4: Comparison of Service Start Times and Spans
Day of
Service Service Category
No. of
Lines in
Service
Avg. Time
Service
Begins
Avg. Time
Service
Ends
Avg. Span
of Service
(hours)
Weekday
Minority and lowincome routes 4 5:38 AM 9:23 PM 15.75
Non-minority and
non-low-income
routes
17 6:05 AM 9:17 PM 15.21
Saturday
Minority line and
low-income
routes
1 5:30 AM 12:00 AM 18.5
Non-minority and
non-low-income
routes
9 6:29 AM 10:13 PM 13.11
Sunday
Minority and lowincome routes 1 6:05 AM 12:00 AM 17.9
Non-minority and
non-low-income
routes
9 6:56 AM 9:40 PM 14.73

2.5 Stop Spacing and Placement
This standard involves how far apart bus stops are spaced. Big Blue Bus stop spacing standards differ by service type, with Rapid stops spaced further apart than Local stops.
 Rapid Bus Stop Spacing – Rapid bus routes on corridors also served by Local routes should have stops spaced a minimum of ½ mile apart, and should be placed at major destinations, intersections, and transfer points. Rapid stop placement should be determined based on overall spacing as well as ridership.
 Local Bus Stop Spacing – For Local services, stop spacing from 1000 feet up to ¼ mile (roughly 1,300 feet) is desirable. Local service on small streets can sustain the most closely-spaced stops (since trip distances are usually short) while Local stops on major arterial streets risk introducing unnecessary delay if stops are spaced closer than 1,000 feet. Existing stop with continuously low usage will be subject to review for consolidation with other stops or removal in order to increase service speed and reliability.
 Commuter Service Stop Spacing - Commuter services can either use Local or Rapid type stopping patterns depending on the type of service and passenger needs.
3 Service Policies

3.1 Transit Amenities
Transit agencies must maintain standards for the distribution of transit amenities.

BBB has significant authority over bus stop improvements and amenities within the City of Santa Monica while bus stops located in neighboring cities and jurisdictions are often subject to external policies that BBB must adhere to. Transit amenities are allocated based on ridership activity (total number of average daily weekday boardings) and are equitably distributed to reflect the systemwide demographics of Big Blue Bus.

Table 5 outlines BBB’s amenity policy for distribution of resources based on stoplevel boardings.

Table 5: BBB Amenity Thresholds
Average Daily
Boardings
Bus Stop
Classification Amenities Provided
All Stops All stops Public information kiosk
5 or more off-peak
boardings
Low volume or
more
Above plus lighting
50 or more
boardings
Medium volume or
more
Above plus shelter or shade and
seating
100 or more
boardings
High volume or
more
Above plus real-time signage
900 or more
boardings Very high volume Above plus multiple shelters or extra-large shelter

3.2 Vehicle Fleet
BBB maintains a 100% alternative fuel vehicle fleet, which includes CNG and battery-electric buses.

Table 6: BBB Vehicle Fleet
Bus Series
Number
Year
Built
Make Model # of
Buses
Seats
Fleet
Type
Fuel
1827 2019 GILLIG G28D 1 39 40’ Electric
1808-1826 2018 GILLIG G31D 19 39 40’ CNG
1801-1807 2018 GILLIG G31E102N2 7 26 30’ CNG
1707-1725 2017 GILLIG G31D102N4 19 39 40’ CNG
1706 2017 GILLIG G27D102N4 1 39 40’ CNG
1701-1705 2016 GILLIG G27D102N4 5 39 40’ CNG
1600-1603 2015 GILLIG G27E102N2 4 26 30’ CNG
1500-1510 2015 GILLIG G27D102N4 11 39 40’ CNG
1560 -1566 2015 NEW FLYER XN60 7 56 60’ CNG
1345 - 1357 2014 GILLIG G27D102N4 13 39 40’ CNG
1301-1344 2013 GILLIG G27D102N4 44 39 40’ CNG
1300 2012 GILLIG G27D102N4 1 39 40’ CNG
5300 - 5320 2011 NABI 60BRT-14.02 21 51 60’ CNG
3868 - 3876 2011 NABI 40LFW-14.01 9 36 40’ CNG
2905 - 2914 2011 EL DORADO EZR II- BRT 32' 10 29 32’ CNG 2900 - 2904 2010 EL DORADO EZR II- BRT 32' 5 29 32’ CNG 2101 - 2118 2021 GILLIG G28D 18 39 40’ Electric

3.3 Vehicle Assignment
BBB assigns vehicles based on service category and vehicle capacity. Prior to a service change, scheduling staff make vehicle recommendations by block. A block consists of the routes that make up an operator’s daily work assignment. Dispatch staff assigns vehicles, accounting for vehicle availability, maintenance holds, and operational needs. Due to the interlining of routes throughout the BBB system, a vehicle is likely to operate on several different routes throughout the day. The average age of the BBB fleet is 8.7 years old with new buses replaced when they have exceeded their useful life.

There are currently three vehicle types in the BBB fleet (30’-32’, 40’, 60’).

Table 7 shows the type of vehicles that are assigned by route and the number of vehicles operating during peak service.

Table 7: BBB Vehicle Assignment
Route
Ridership
exceeds
percent
minority
ridership
systemwide
Ridership
exceeds
percent lowincome
ridership
systemwide
Fleet Type
Number of
Peak
Vehicles
Route 1 No No 40’ 15
Route 2 No No 40’ 5
Route 3 No No 40’ or 60’ 11
Rapid 3 No No 40’ or 60’ 8
Route 5 No No 40’ 3
Route 7 Yes Yes 40’ 12
Rapid 7 Yes Yes 40’ or 60’ 8
Express 7 Yes Yes 40’ or 60’ 7
Route 8 No No 40’ 6
Route 9 No No 40’ 5
Rapid 10 Yes Yes 40' 2
Rapid 12 No No 40’ 6
Route 14 No No 40’ 8
Route 15 No No 40’ 1
Route 16 No No 30’ 4
Route 17 No No 40’ 7
Route 18 No No 30’ or 40’ 6
Route 41 No No 30’ or 40’ 2
Route 42 No No 30’ or 40’ 2
Route 43 No No 30’ 2
Route 44 No No 40’ 4

3.3 Vehicle Amenities
All fleet vehicles are ADA compliant, with wheelchair lifts/ramps and kneeling capabilities. Other vehicle amenities include air conditioning and bike racks. Fleet vehicles also have design and operational elements to assist visually-impaired or hearing-impaired passengers, including: similar seating configurations, voice annunciators on the bus and at bus stops, and new shelter signage to improve readability and information access for riders with disabilities.

3.4 Vehicle Load
Vehicle loads are monitored by the Planning division, which reviews customer feedback regarding overload conditions and hosts quarterly service review sessions with Motor Coach Operators to identify overcrowded trips. Planning staff then review the ridership data and, if warranted, may schedule additional trips to address overloaded trips at the next available service change.

Table 8: Vehicle Load by Route
Route
Ridership
exceeds
percent
minority
ridership
systemwide
Ridership
exceeds
percent lowincome
ridership
systemwide
Average Load
Route 1 No No 12
Route 2 No No 9
Route 3 No No 12
Rapid 3 No No 11
Route 5 No No 5
Route 7 Yes Yes 14
Rapid 7 Yes Yes 12
Express 7 Yes Yes 0
Route 8 No No 11
Route 9 No No 10
Rapid 10 Yes Yes 13
Rapid 12 No No 11
Route 14 No No 9
Route 15 No No 4
Route 16 No No 3
Route 17 No No 8
Route 18 No No 8
Route 41 No No 4
Route 42 No No 0
Route 43 No No 4
Route 44 No No 1

Table 9: Vehicle Load Comparison

Minority
and LowIncome
Routes
NonMinority
and NonLowIncome
Routes
Differenc
e:

Minority
to NonMinority
+/ (-)
Average
Load 13.0 9.3 3.7

3.4 Security
BBB takes various measures to ensure the safety and security of all riders, including:
equipping all vehicles with radios and digital video recorders, committing transit security funds to contract out security services, assigning transit supervisors to provide systemwide security, and establishing security protocols at the BBB operations and maintenance facility.

3.5 Information Dissemination
BBB strives to keep all riders informed of day-to-day service operations as well as any service changes that may affect their commutes. In making information available through printed materials, online, over the phone, in person, and in multiple languages, the staff is committed to ensuring that all riders can access the necessary information.

Customer service staff can also provide transit information to individuals who do not have access to the internet. Many staff members are multi-lingual and can provide trip-planning assistance for non-English speaking riders. There is a separate information line for riders who are hearing impaired, and improvements to BBB’s website to assist visually-disabled users have been made. BBB also works with the City’s Community and Cultural Services Department senior and disabled groups to ensure dissemination of information and address access issues for all types of riders.

Printed material of service changes is available in the form of “take-one” cards on board buses. City public libraries and public facilities also maintain transit information racks. The BBB website, www.bigbluebus.com, offers a trip planner, up- to-date route and schedule information, information for passengers with disabilities, and any service changes or facility improvements. Users can also subscribe to an email list whereby BBB can directly contact them with transit updates.

In terms of language access, BBB ensures that service improvements, along with route and policy changes, are published in multiple languages in local area publications. Most information is available in Spanish, and can be obtained in additional languages upon request.

Public notice of Title VI is posted on BBB’s website at www.bigbluebus.com and posted on each of our buses for fixed route.
4 Service Quality Standards

4.1 On-time Performance
On-time performance reflects both the quality and reliability of service. A vehicle is considered on-time if it runs no more than one (1) minute early and no more than five (5) minutes late compared to the scheduled time at each timepoint. Early arrivals at the final timepoint are considered on-time. BBB’s current goal is to have 85% of arrivals on time. This standard is evaluated quarterly and included in the Planning Department’s Performance Report. On-time performance is collected by route and aggregated across the fiscal quarters. The average performance represents data from July 2021 to June 2022 (Table 11). In Table 10, on-time performance is compared between minority and non-minority lines, and poverty and non-poverty lines.

Table 10: On-time Performance Comparison

Minority
and LowIncome
Routes
NonMinority and
Non-LowIncome
Routes
Difference:

Minority to
NonMinority
+/ (-)
Average Ontime
Performance

66.4% 73.8% 7.4%
Table 11: On-time Performance by Route
Route
Ridership
exceeds
percent
minority
ridership
systemwide
Ridership
exceeds
percent lowincome
ridership
systemwide
Average OnTime
Performance
Route 1 No No 76.2%
Route 2 No No 71.3%
Route 3 No No 68.7%
Rapid 3 No No 58.3%
Route 5 No No 68.8%
Route 7 Yes Yes 67.4%
Rapid 7 Yes Yes 61.7%
Express 7 Yes Yes
Route 8 No No 73.2%
Route 9 No No 71.9%
Rapid 10 Yes Yes 70.2%
Rapid 12 No No 85.6%
Route 14 No No 71.6%
Route 15 No No 80.9%
Route 16 No No 70.3%
Route 17 No No 65.1%
Route 18 No No 75.2%
Route 41 No No 80.8%
Route 42 No No 79.7%
Route 43 No No 83.6%
Route 44 No No 86.0%

5 Current Activities

5.1 Community Outreach
Public hearings, community workshops, school and city-sponsored fairs/festivals are held throughout the year as forums for distributing information and collecting input to identify travel needs and to solicit comments on proposed service changes and improvements. At least one series of outreach meetings are conducted annually. Receiving input from community stakeholders on a frequent basis allows BBB to implement a “market driven” planning approach to provide the best possible service for passengers.

BBB has standardized policies and procedures for conducting public hearings and these are provided in the appendix. Generally, any activity that results in an increase or decrease in route revenue miles or route miles that are equal to or greater than twenty-five percent (25%) of the existing service, the introduction of a new route, elimination of an existing route, or a permanent change in fare structure would require outreach, a public hearing, and City Council approval.

Efforts are made to encourage participation by minorities in hearings and outreach events. Notices for hearings are published in a range of publications including newspapers for Spanish-speaking residents.

See appendix for a list of community outreach.

5.2 Service Changes
In response to the COVID-19 pandemic, Big Blue Bus implemented a series of service changes.

Service changes between 2020-2022, by route, include:
 Route 1
o Weekday, Saturday, Sunday service mostly remained the same except cuts to early and late-night trips
 Route 2
o Weekday service frequency was changed to 20 minutes
 Route 3
o Weekday, Saturday, Sunday service mostly remained the same except cuts to early and late-night trips
 Rapid 3
o Weekday service was temporarily suspended at the onset of the pandemic but has been reinstated. Service levels are at pre-covid levels
 Route 5
o Weekday span of service shortened. Weekday frequency changed to every 60 minutes
 Route 7
o Weekday, Saturday, Sunday service mostly remained the same except cuts to early and late-night trips
 Rapid 7
o Weekday service was temporarily suspended at the onset of the pandemic but has been reinstated. Service levels are at pre-covid levels
 Express 7
o Introduced limited stop Express 7 service on Pico Blvd every 20 minutes  Route 8
o Weekday frequency changed to every 20-30 minutes during AM and PM peak periods
 Route 9
o Weekday frequency changed to every 20-30 minutes during AM and PM peak periods
 Rapid 10
o Weekday service changed to only three AM peak-hour trips and three PM peak hour trips
 Rapid 12
o Weekday frequency changed to 10-12 minutes
 Route 14
o Weekday frequency changed to 15-20 minutes
o Select trips extended to Inglewood with plans to extend all trips to Inglewood late 2022
 Route 15
o Weekday frequency changed to every 50-55 minutes all day  Route 16
o Weekday frequency changed to every 25 minutes all day  Route 17
o Weekday frequency changed to every 15-20 minutes during peak hours
o New routing through Westwood and new northern terminus at UCLA Macgowan Hall
 Route 18
o Weekday frequency changed to 30 minutes all day
 Route 41
o Weekday service improved to every 20 minutes all day
o Sunday service suspended
 Route 42
o Service suspended since onset of COVID-19 pandemic
 Route 43
o No change
 Route 44
o Service suspended since onset of COVID-19 pandemic and low inperson enrollment at Santa Monica College See Appendix for service equity analysis.

5.3 Fares
An analysis of the revised fare structure found that the changes would not result in an adverse disparate impact on the minority population or an adverse disproportionate burden on the low-income population. See Appendix for fare equity analysis. The fare structure, effective in 2022, is as follows:

Table 12: Fare Structure
For the latest fare information, please visit Fare Information - Big Blue Bus

5.4 Federally Assisted Projects
BBB federally-funded projects include the ongoing bus replacement program and the future implementation of a bus shelter program in the City of Santa Monica portion of the service area. Figure 12, below, shows active federal grants.

Table 13: Active Federal Grants

Grant Description Total Grant
Amount
CA-90-Y770 Bus Stop Improvements $ 4,200,000
CA-90-Z102 Bus Replacement, Expo Study, Bus Stop
Amenities
$15,636,765
CA-2016-103 Bus Stop Improvement, Expo Study $2,180,000 CA-2020-174 Bus Replacements, Bus Stop Enhancement
(7th Street) $16,048,887
CA-2021-159 CRRSAA – Operating Assistance $22,247,777

6 Appendix

6.1 Appendix A
Title VI Notice to the Public

6.2 Appendix B
Complaint Form and Internal Procedures

Service Alerts (/Newsr Route 9: Detour in Santa Monica 1/17-1/30 ( oom/Content.aspx?type=Alerts) /Newsroom/Se The City of Santa Monica's Big Blue Bus (BBB) is committed to ensuring that no person is excluded fro participation in, or denied benefits of, its services on the basis of race, color or national origin, as protec by Title VI of the Civil Rights Act of 1964, as amended.

No person or group of person will be discriminated against with regard to fares, routing, scheduling or q of transportation service that BBB furnishes on the basis of race, color or national origin.

If you believe you have been discriminated against on the basis of race, color or national origin by the C Santa Monica's Big Blue Bus, you may file a Title VI complaint by completing and submitting the Civil R Complaint form. The City of Santa Monica's Big Blue Bus investigates complaints received no more tha 180 days after the alleged incident.

To request additional information regarding Title VI, please contact: [email protected] (mailto:[email protected]).

In addition to Title VI of the Civil Rights Act of 1964, BBB also prohibits discrimination based on sex, ag disability, religion, medical condition, marital status or sexual orientation.

If you believe you have been discriminated against on the basis of race, color, or national origin, sex, a disability, religion, medical condition, marital status or sexual orientation by the City of Santa Monica's B Blue Bus you may file a Civil Rights complaint by completing and submitting the Civil Rights Complaint Form. The City of Santa Monica Big Blue Bus investigates complaints received no more than 180 days the alleged incident.

How to File a Complaint
You may file a signed, written complaint within one hundred and eighty (180) days of the date of allege discrimination. The complaint should include the following information:

Your name, address and how to contact you (e.g. telephone number, e-mail address, etc.) How, when, where and why you believe you were discriminated against. Include the location, nam and contact information of any witnesses.

Complaint Assistance: A City of Santa Monica Big Blue Bus Customer Relations representative will ass with writing a complaint if the complainant is unable to do so.

See below for complete complaint procedure and printable complaint form.

Civil Rights Complaint Form (/uploadedFiles/Content/About_BBB/Civil Rights Complaint Form_8.10.17.pdf)
The complaint may be filed the following ways:

By mail:

Bridget Cade, Administrative Services Officer
City of Santa Monica Big Blue Bus
P.O. Box 2200
Santa Monica, CA 90407-2200
By email:
[email protected] (mailto:[email protected])
By telephone:
310-451-5444
In person:
1444 4th St., Santa Monica, CA 90401 (https://www.bigbluebus.com/About-BBB/Main-Office.aspx) M - F: 7:30 a.m. - 5:30 p.m.

Sat.: 12 p.m. - 6 p.m. (only phone assistance available) You may also file a complaint directly with either of the two following agencies:

Federal Transit Administration Region IX (http://www.fta.dot.gov/about/region9.html) Civil Rights Officer
201 Mission Street, Suite 1650
San Francisco, CA 94105-1839
Federal Transit Administration Office of Civil Rights (https://www.transit.dot.gov/regulations-and-guidan /civil-rights-ada/civil-rightsada)
Attention: Title VI Program Coordinator
East Building, 5th Floor - TCR
1200 New Jersey Avenue SE
Washington, DC 20590
About BBB
Working Together (/About-BBB/Partnerships/Working-Together.aspx) Santa Monica College (/About-BBB/Partnerships/Santa-Monica-College.aspx) Ride Blue. Go Green. (/About-BBB/Ride-Blue--Go-Green-.aspx) Our Buses (/About-BBB/Our-Buses.aspx)
Our History (/About-BBB/Timeline/Historical-Info/Our-History.aspx) Civil Rights (/About-BBB/Civil-Rights.aspx)
For App Developers (/About-BBB/For-App-Developers.aspx) DBE Goal (/About-BBB/DBE-Goal.aspx)
We're Going Zero Emissions! (/About-BBB/We-re-Going-Zero-Emissions!.aspx) Top of Page
Email address Sign Up
Customer Service: (310) 451-5444
1444 4th Street, Santa Monica, California 90401
(/About-BBB/Main-Office.aspx)
Copyright © 2020 Big Blue Bus All Rights Reserved
Privacy Policy (http://www.smgov.net/privacy/) |
Accessibility Policy (http://www.smgov.net/accessibility/) | Disclaimer (http://www.smgov.net/disclaimer/)
(/)
(http://smgov.net/)

_____________________________________ ________________________

CIVIL RIGHTS TICKET PROCESSING
STEP 1 – MEMBER OF (OR AFFILIATED WITH) A PROTECTED CLASS? Race, Color, National Origin, Sex, Age, Disability, Religion, Medical Condition, Marital Status, Sexual Orientation
If Yes ‐ Move to next step.

If No ‐ Do NOT escalate through Civil Rights process.
‐ Utilize standardized response to customer.

STEP 2 ‐ ALLEGED DISCRIMINATION ON BASISS OF MEMBERSHIP OR AFFILIATION WITH A PROTECTED CLASS?
Customer must state that he/she felt discriminated (treated differently) because of his/her protected status.

If Yes ‐ Move to next step.

If No ‐ Do NOT escalate through Civil Rights process.
‐ Utilize standardized response to customer.

STEP 3 – EVIDENCE OF BIAS?
Did BBB employee distinguish the person as a part of a protected class? ‐ Did driver do something that shows that the treatment was biased because of the customers protected class?
This might mean our employee making a comment, pointing the person out as different, making general comments about people in a protected class, or changing tone, attitude OR gestures when talking to someone in a protected class or about someone in a protected class.

Customers can’t claim bias because they are in a protected class and the driver is rude to them.

Example – Customer who is wheelchair bound is passed up. If the driver did not see him/her, there is no evidence of biased treatment.
o Ask patron if driver pulled into bus stop, if so, you could say that after driver pulled over he saw the person and took off b/c of disability.

If Yes ‐ Move to next step.

If No ‐ Do NOT escalate through Civil Rights process.
‐ Utilize standardized response to customer.

STEP 4 – EVIDENCE OF UNFAIR TREATMENT?
Is person claiming that they were treated differently than others around them in a way that denotes a lack of fairness?
If Yes – ESCALATE THROUGH CIVIL RIGHTS PROCESS
If No ‐ Do NOT escalate through Civil Rights process.

Utilize standardized response to customer.

NON‐CIVIL RIGHTS CASE EXAMPLES
PASS‐UP
‐ Someone is a member or affiliate of a protected class, and suffers poor treatment, but there is nothing to make one believe that the poor treatment is due to their being a member or affiliate of a protected class.

Example: A foreign born person is standing with a mixed group of 20 people and is dressed similarly. A bus drives by, and does not pick any of them up. Even though the person is part of a protected class (national origin), there is little evidence in what is presented that protected class status played a part in the pass up. This is not a civil rights complaint.

PREFERENTIAL TREATMENT DESIRED
‐ Someone is a member or affiliate of a protected class and is treated equal to those around him or her, and thinks the protected class should indicate preferential treatment. For example, a person with disabilities is sitting in a wheelchair at the bus stop in a group of 20 people. A driver pulls up and says that he can only take ten people due to overcrowding. He takes the ten people closest to the door and then shuts the door and leaves. The person left behind in the wheelchair feels that they were discriminated against, but states that many others were left behind as well due to the overcrowding. This is not a civil rights complaint.

NON‐PROTECTED CLASS – DISCRIMINATION CLAIM
‐ Someone is, or is not, a member or affiliate of a protected class and feels discriminated against for reasons not related to protected class status. For example, a man is standing at a bus stop and the bus pulls up. As the door opens, the passenger notices the driver has a bag of donuts and says “I hate donuts” to the driver. The driver shuts the door and drives away. The man feels discriminated against for hating donuts. This is not a civil rights complaint.

TITLE VI POLICY
‐ The City of Santa Monica's Big Blue Bus (BBB) is committed to ensuring that no person is excluded from participation in, or denied benefits of, its services on the basis of race, color or national origin, as protected by Title VI of the Civil Rights Act of 1964, as amended. ‐ No person or group of people will be discriminated against with regard to fares, routing, scheduling or quality of transportation service that BBB furnishes on the basis of race, color or national origin. ‐ If you believe you have been discriminated against on the basis of race, color or national origin by the City of Santa Monica's Big Blue Bus, you may file a Title VI complaint by completing and submitting the Civil Rights Complaint form. The City of Santa Monica's Big Blue Bus investigates complaints received no more than 180 days after the alleged incident.

CIVIL RIGHTS PROCEDURE
‐ In addition to Title VI of the Civil Rights Act of 1964, BBB also prohibits discrimination based on sex, age, disability, religion, medical condition, marital status or sexual orientation. ‐ If you believe you have been discriminated against on the basis of race, color, or national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation by the City of Santa Monica's Big Blue Bus you may file a Civil Rights complaint by completing and submitting the Civil Rights Complaint Form. The City of Santa Monica Big Blue Bus investigates complaints received no more than 180 days after the alleged incident.

CUSTOMER RESPONSE
Dear BBB Rider,
Big Blue Bus has a civil rights policy that ensures that no person is excluded from participation in, or denied benefits to, its services on the basis of race, color, national origin, sex, age, disability, religion, medical condition, marital status, or sexual orientation. It appears from the evidence that you provided that the issues you raised do not involve a civil rights complaint, but do in fact constitute a complaint nonetheless. Please note that Big Blue Bus will be conducting an investigation into the claims you made to determine subsequent steps.

Thank you for being a loyal Big Blue Bus customer and for the feedback provided.

Sincerely,

DATE: 2/20/2018
CATEGORY: Standard Operating Procedures
SUBJECT: Processing Santa Monica Works Tickets for Bus Operator Concerns
WRITTEN BY: Kennisha Williams
What To Do When – Processing SMW Tickets for Bus Operator Concerns Background
Our operators' primary responsibility is to transport riders to their destinations in a reasonably safe, secure, and comfortable manner. Big Blue Bus strives to ensure that our customers are served well and served courteously. Occasionally, passengers encounter unpleasant experiences during their ride on BBB and leave feedback through the Santa Monica Works system. Each complaint against an operator is reviewed and taken very seriously to ensure that BBB is providing the highest quality of service for our riders.

Persons Involved
 Customer Service Assistant
o Creates SMW ticket on customer’s behalf.
 Customer Service Assistant assigned to Concerns Category o Receives notification of ticket via email.
o Runs playback to substantiate incident
o Forwards to Operations for investigation
18-001

o Responds to Customer acknowledging receipt of ticket, apologizing for incident and notifying of the completion of investigation
 Operations Supervisor / Jesse Gurrola and Ricardo Juarez o Investigates the claim
o Determines if claim is an incident or non-incident
o Takes action with driver
 HR / Bridget Cade
o Receives special case tickets that violate ADA and other Civil Rights o Views DVR and awaits outcome of Operations investigation o Personally responds to customer via written letter, email, or phone conversation Steps in Process

1. Confirm/Enter the following information:
o Date
o Time
o Issue Type
 Discourteous Operator Behavior
 i.e. the driver was rude
 Unsafe Bus Operation
 i.e. the driver ran a red light
 Other
 i.e. customer paid for a day pass but received a transfer o Route number
o Operator ID
o Bus number
o Day of the week
o Direction of travel

2. Take information received from customer and plug it into Transit Master Playback (TMPB) to confirm/substantiate claim

o Does the information that customer provided match what is shown in TMPB?  Yes – the incident is substantiated
 No – the incident is unsubstantiated
o Note: TMPB can also help fill in any of the aforementioned information the customer did not or could not provide

3. Once incident is substantiated, send email to customer apologizing for incident and informing him/her that the ticket has been forwarded to Operations for further review.

4. Click ‘For Operations’ box

5. Click Update & Exit
o Ticket is then re-assigned to Supervisors Jesse Gurrola and Ricardo Juarez o Jesse, Ricardo, and Operations team investigates the issue which includes reviewing DVR footage and takes appropriate action with driver
 Note: Appropriate action can be that the driver was coached and counseled about the incident or the driver may receive a Record of Event (R.O.E). This internal information remains confidential and is never disclosed to the customer o Jesse or Ricardo updates internal notes of the ticket and unchecks ‘For Operations’ box to re-assign back to Customer Service

6. Connect with customer notifying him/her that investigation is complete and the appropriate action against the operator has been taken and close the ticket.

6.3 Appendix C
Limited English Proficiency Plan

Limited English Proficiency Plan – BIG BLUE BUS 1
Santa Monica
Big Blue Bus
Limited English
Proficiency
Plan
Limited English Proficiency Plan – BIG BLUE BUS 2
Limited English Proficiency Plan – BIG BLUE BUS Contents i Contents
Santa Monica Big Blue Bus
Limited English Proficiency Plan . . . . . . . . . . . . . 1 Introduction.......................................................................................1 Purpose of the LEP Plan....................................................................2 Determination of Need......................................................................2 Language Assistance Plan..............................................................10 Limited English Proficiency Plan – BIG BLUE BUS ii
LIMITED ENGLISH PROFICIENCY PLAN – BIG BLUE BUS 1
Santa Monica
Big Blue Bus
Limited English
Proficiency Plan
Introduction
The City of Santa Monica is 8.6 square miles and is
bordegZd by the City of Los Angeles and the Pacific Ocean.

The Transit Services Division, the Big Blue Bus (BBB), is a line depart-ment of the City and has operated transit service since 1928. Transit services extend well beyond the city limits through-out the Westside of Los Angeles County
covering a reserve service area of 52 square miles. BBB is a local fixed-route transit operator serving the City of Santa Monica and ad-jacent Westside communities
including: Pacific Palisades, West Los Angeles, Brentwood, Westwood, University of Cali-fornia Los Angeles (UCLA), Cheviot Hills, South Robertson, Mid-City, Westchester,
Marina del Rey, Venice, and Playa Vista, and providing
regional connections to downtown Los Angeles, Los
Angeles International Airport, LA Metro Blue, Red, Purple, Gold, and Green Line rail stations, Union Sta-tion,
Metrolink, and Amtrak inter-city rail services.

BBB currently operates a fleet of 195 vehicles. The 20 bus routes include fixed-route local, limited-stop (Rapid), freeway express, commuter transit, and regularly-scheduled circulators that target particular community needs. There are over 1,100 bus stops in the BBB service area, including approximately 360 within the City of Santa Monica.

Limited English Proficiency Plan – BIG BLUE BUS 2
BBB provides transportation for over 70,000 passengers per day and has constant interactions with individuals with varying degrees of ability to speak and/ or understand English. For this reason, BBB has
developed this Implementation Plan for a Language
Assistance/Limited English Proficiency Plan.

Purpose of the LEP Plan
On August 11, 2000, President William J. Clinton
signed Executive Order 13166, “Improving Access to
Services for Persons with Limited English Proficiency,” which stated that recipients of Federal financial assistance must take reasonable steps to ensure
meaningful access to their programs and activities for
individuals who are limited-English proficient (LEP).

The U.S. Department of Transportation handbook,
titled “Implementing the Department of Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP)
Persons: A Handbook for Public Transportation Providers (April 13, 2007)” (hereinafter “Handbook”), further expanded on the 2000 Executive Order by
stating that Title VI of the Civil Rights Act of 1964,
42 U.S.C. 2000d et seq., and its implementing regulations, provide that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or otherwise subjected to discrimination
under any program or activity that receives Federal
financial assistance (Handbook, page 5).

The Handbook further adds that Title VI prohibits
conduct that has a disproportionate effect on LEP
persons because such conduct constitutes national
origin discrimination (Handbook, page 5).

LEP individuals, as defined by the 2010 United States
Census, are any individuals who speak a language
at home other than English as their primary language and who speak or understand English “not well” or “not at all.” Individuals who have a limited
ability to read, write, speak, or understand English
are considered LEP individuals. In Los Angeles
County, according to the 2010 U.S. Census records,
approximately 26.4 percent of the County’s residents
describe themselves as not able to communicate in
English very well. This is equivalent to 2.4 million
potential BBB passengers countywide who do not
communicate well in English.

BBB will take reasonable steps to ensure that all
persons have meaningful access to its programs,
services, and information at no additional cost. For
many LEP individuals, public transit is a principal
mode of transportation. It is therefore extremely important that BBB is able to communicate effectively with all its riders, both LEP and non-LEP individuals
alike. This provides safer, more reliable, and more
convenient and accessible service for all the agency’s
customers. For these reasons, BBB is committed to
taking the following steps to ensure meaningful access for LEP individuals to this agency’s services.

This plan will demonstrate the efforts that BBB has
undertaken to make its service as accessible as
possible to all persons irrespective of their ability
to communicate in English. Additionally, BBB welcomes any comments or suggestions that would further improve the effectiveness of this Plan and/
or our ability to communicate more effectively with
our customers.

Determination of Need
In order to develop this policy, Big Blue Bus has followed the U.S. Department of Transportation (USDOT) four-factor LEP analysis which considers the following factors:

1. The number proportion of LEP persons in the
service area who may be served or are likely to
encounter a BBB program, activity, or service.

2. The frequency with which LEP persons come
in contact with BBB programs, activities,
or services.

3. The nature and importance of programs,
activities or services provided by BBB to the
LEP population.

Limited English Proficiency Plan – BIG BLUE BUS 3

4. The resources available to BBB and overall
cost to providing LEP assistance.

This analysis helps determine whether BBB’s work
is sufficient to ensure that service is accessible to
all those who rely upon fixed-route service for their
transportation needs. This plan will also include information on future goals and tasks for BBB to pursue to improve its accessibility to LEP persons.

FACTOR 1: The Number and Proportion
of LEP Persons Served or Encountered
in BBB’s Service Area
An analysis of U.S. Census data provides a profile of
LEP individuals in Los Angeles County. This data is
used to determine the approximate number of LEP
persons age 5 years or older. Table 1 shows the number and percent of persons who speak English “less than very well,” by language spoken at home, and
who are age five and older in Los Angeles County.

As indicated, 43.0 percent of the population speaks
only English, while 26.4 percent of the population is
considered limited English proficient. The remaining 36.4% speaks another language and English “very well.”
The most commonly encountered LEP persons in the
BBB service area speak Spanish. Spanish speakers
represent 39.5 percent of the total population of Los
Angeles County. 18.2 percent of the residents of Los
Angeles County are Spanish-speaking and limited
English proficient.

Because Spanish is the most commonly spoken
language (outside of English) used in Los Angeles
County, BBB has developed much of its public literature to be printed in English and Spanish. BBB has also worked to hire individuals for the Transit
Store who are capable of communicating effectively
in both English and Spanish.

8.2 percent of the total population of Los Angeles County is limited English proficient and speaks neither English nor Spanish. The most commonly
spoken languages after English and Spanish are:

Chinese (3.9%), Tagalog (2.4%), Korean (2.0%), and
Armenian (2.0%).

Language Estimate % of Total Population
over 5 yrs old
Total 9,240,851 100%
Speak only English 3,977,701 43.04%
Speak another language and English “very well” 2,825,094 30.58% Speak English “less than very well” 2,438,056 26.38%
Spanish or Spanish Creole 3,651,208 39.51%
Speak English “very well” 1,966,044 21.28%
Speak English “less than very well” 1,685,164 18.24%
French 41,043 0.44%
Speak English “very well” 34,564 0.37%
Speak English “less than very well” 6,479 0.07%
Table 1: Language Spoken at Home by Ability to Speak English for Population 5 Years and Over Limited English Proficiency Plan – BIG BLUE BUS 4
Language Estimate % of Total Population
over 5 yrs old
French Creole 3,027 0.03%
Speak English “very well” 2,697 0.03%
Speak English “less than very well” 330 0.00%
Italian 14,833 0.16%
Speak English “very well” 11,684 0.13%
Speak English “less than very well” 3,149 0.03%
Portuguese or Portuguese Creole 12,217 0.13%
Speak English “very well” 9,686 0.10%
Speak English “less than very well” 2,531 0.03%
German 23,351 0.25%
Speak English “very well” 20,302 0.22%
Speak English “less than very well” 3,049 0.03%
Yiddish 2,890 0.03%
Speak English “very well” 2,453 0.03%
Speak English “less than very well” 437 0.00%
Other West Germanic languages 5,751 0.06%
Speak English “very well” 4,593 0.05%
Speak English “less than very well” 1,158 0.01%
Scandinavian languages 4,777 0.05%
Speak English “very well” 4,119 0.04%
Speak English “less than very well” 658 0.01%
Greek 5,900 0.06%
Speak English “very well” 3,670 0.04%
Speak English “less than very well” 2,230 0.02%
Russian 49,168 0.53%
Speak English “very well” 22,401 0.24%
Speak English “less than very well” 26,767 0.29%
Polish 6,579 0.07%
Speak English “very well” 4,888 0.05%
Speak English “less than very well” 1,691 0.02%
Serbo-Croatian 6,744 0.07%
Speak English “very well” 5,848 0.06%
Speak English “less than very well” 896 0.01%
Other Slavic languages 6,184 0.07%
Speak English “very well” 4,449 0.05%
Speak English “less than very well” 1,735 0.02%
Armenian 179,073 1.94%
Speak English “very well” 88,939 0.96%
Speak English “less than very well” 90,134 0.98%
Limited English Proficiency Plan – BIG BLUE BUS 5
Language Estimate % of Total Population
over 5 yrs old
Persian 75,700 0.82%
Speak English “very well” 46,416 0.50%
Speak English “less than very well” 29,284 0.32%
Gujarati 12,660 0.14%
Speak English “very well” 8,714 0.09%
Speak English “less than very well” 3,946 0.04%
Hindi 20,849 0.23%
Speak English “very well” 16,504 0.18%
Speak English “less than very well” 4,345 0.05%
Urdu 10,602 0.11%
Speak English “very well” 6,647 0.07%
Speak English “less than very well” 3,955 0.04%
Other Indic languages 25,037 0.27%
Speak English “very well” 13,916 0.15%
Speak English “less than very well” 11,121 0.12%
Other Indo-European languages 12,880 0.14%
Speak English “very well” 7,889 0.09%
Speak English “less than very well” 4,991 0.05%
Chinese 355,907 3.85%
Speak English “very well” 142,941 1.55%
Speak English “less than very well” 212,966 2.30%
Japanese 53,725 0.58%
Speak English “very well” 27,670 0.30%
Speak English “less than very well” 26,055 0.28%
Korean 183,117 1.98%
Speak English “very well” 72,116 0.78%
Speak English “less than very well” 111,001 1.20%
Mon-Khmer, Cambodian 30,372 0.33%
Speak English “very well” 12,124 0.13%
Speak English “less than very well” 18,248 0.20%
Hmong 1,380 0.01%
Speak English “very well” 988 0.01%
Speak English “less than very well” 392 0.00%
Thai 23,817 0.26%
Speak English “very well” 8,128 0.09%
Speak English “less than very well” 15,689 0.17%
Laotian 4,142 0.04%
Speak English “very well” 2,105 0.02%
Speak English “less than very well” 2,037 0.02%
Limited English Proficiency Plan – BIG BLUE BUS 6
Language Estimate % of Total Population
over 5 yrs old
Vietnamese 76,387 0.83%
Speak English “very well” 29,321 0.32%
Speak English “less than very well” 47,066 0.51%
Other Asian languages 24,074 0.26%
Speak English “very well” 15,209 0.16%
Speak English “less than very well” 8,865 0.10%
Tagalog 224,629 2.43%
Speak English “very well” 148,856 1.61%
Speak English “less than very well” 75,773 0.82%
Other Pacific Island languages 24,993 0.27%
Speak English “very well” 17,785 0.19%
Speak English “less than very well” 7,208 0.08%
Navajo 36 0.00%
Speak English “very well” 0 0.00%
Speak English “less than very well” 36 0.00%
Other Native North American languages 424 0.00%
Speak English “very well” 404 0.00%
Speak English “less than very well” 20 0.00%
Hungarian 6,220 0.07%
Speak English “very well” 3,822 0.04%
Speak English “less than very well” 2,398 0.03%
Arabic 38,866 0.42%
Speak English “very well” 23,870 0.26%
Speak English “less than very well” 14,996 0.16%
Hebrew 21,907 0.24%
Speak English “very well” 17,604 0.19%
Speak English “less than very well” 4,303 0.05%
African languages 17,496 0.19%
Speak English “very well” 12,966 0.14%
Speak English “less than very well” 4,530 0.05%
Other unspecified languages 5,185 0.06%
Speak English “very well” 2,762 0.03%
Speak English “less than very well” 2,423 0.03%
Limited English Proficiency Plan – BIG BLUE BUS 7
In order to ensure that LEP populations have sufficient access to BBB’s transit systems, it is important to determine where LEP populations are located and
concentrated. Identifying census tracts where the
proportion of LEP persons exceeds the proportion
of LEP persons in the population as a whole is an
important part of this analysis. Figure 1, attached at
the end of the document, shows the concentration of
LEP populations in the census tracts served by Big
Blue Bus, indicating that BBB adequately serves all
areas of high LEP concentrations.

FACTOR 2: Frequency of
Contact of LEP Individuals
With BBB’s Programs,
Activities, and Services
The Federal guidance for this factor recommends
that agencies should, as accurately as possible,
assess the frequency with which they have contact
with LEP individuals from different language groups.

The idea is that the more frequent the contact with a
particular LEP language group, the more likely enhanced services will be needed. In the case of Big Blue Bus, such in-person contact may take place by
an LEP individual telephoning the customer service
center or by interacting with a motor coach operator
or Transit Store personnel.

In August 2013, an LEP survey was distributed to
BBB bus drivers and customer representatives in
order to obtain information about frequency of contact with LEP individuals. Of the total 33 surveys sent, 27 were completed by bus drivers, and 6 were
completed by customer representatives for a 100
percent response rate.

Following are the highlights of the survey results:
• On average, staff assist LEP customers on a daily basis, with a range of 5 to 100 times per week. • Spanish was reported as being by far the most
frequent language encountered by staff. 32 of 33
respondents stated Spanish as the most frequent
language they encounter. Every three years a
Line by Line analysis is completed that includes
gathering demographic information on riders.

The last Line by Line completed in 2011 shows
that 35 percent of riders identify as Hispanic.
• Farsi is the language encountered second most
regularly and was reported as being encountered
up to 80 times in one week. Although Persians
comprise less than one percent of the Los Angeles County population, they are concentrated more heavily within Santa Monica.
• Korean, Japanese, Chinese, and Armenian were
reported as being encountered with a frequency
of an average of 5 times per week.
• French, Italian, Arabic, Vietnamese, Russian,
and Tagalog were reported as being encountered, but with little frequency. • 58 percent of respondents reported that they
are able to speak another language, and 52 percent of respondents are qualified to translate another language. Reported languages spoken
by staff are: Spanish, Farsi, Tagalog, Korean,
and Malayalam.

As demonstrated by the survey results, BBB bus
drivers and customer service representatives have
frequent contact with LEP individuals. These staff
members take several steps to ensure LEP individuals receive high-quality service. Bus drivers try their best to communicate with LEP individuals by using
maps or sign language. They frequently ask other
passengers on the bus for assistance with specific
languages. Customer service representatives treat
customers of all languages with the same attention
and care and do their best to direct LEP individuals
to representatives who speak their language.

Limited English Proficiency Plan – BIG BLUE BUS 8
FACTOR 3: The Nature or Importance
of BBB Services, Programs, or
Activities Provided to LEP Individuals
A LEP person’s inability to effectively use public
transportation may adversely affect his or her ability
to obtain health care, education, or access to employment. While public transit is not an essential service, such as police, fire, and medical emergency
service, public transit is a key means of achieving
mobility for many LEP persons.

According to the 2011 American Community Survey
data, in Los Angeles County 13.8 percent of LEP persons aged 16 years or older claimed public transit as their primary means of transportation to work,
compared with 4.2 percent of English speakers.

Recent immigrants to the United States use public
transit at higher rates than native-born adults, regardless of their English proficiency. Therefore, LEP persons generally rely more heavily on public transit
as their primary means of transportation than the
general population.

Language Spoken Population Percent of
Working
Population
Percent of Population
that Takes Public
Transportation
Public transportation 314,747 7.31% 100.00%
Speak only English 76,052 1.77% 24.16%
Speak Spanish: 203,085 4.72% 64.52%
Speak English “very well” 55,656 1.29% 17.68%
Speak English “less than very well” 147,429 3.43% 46.84% Speak other languages: 35,610 0.83% 11.31%
Speak English “very well” 44,929 1.04% 14.27%
Speak English “less than very well” 47,482 1.10% 15.09% Table 2 – Those Who Take Public Transportation to Work by Ability to Speak English Table 3 – Means of Transportation to Work by Ability to Speak English Mode to Work English-SpeakingPercent of English SpeakersLEP Population Percent of LEP Population
Total population 1,826,767 100.00% 1,200,337 100.00%
Car, truck, or van 1,550,841 84.90% 911,154 75.91%
Public transportation 76,052 4.16% 166,118 13.84%
Walked 46,791 2.56% 42,768 3.56%
Taxicab, motorcycle,
bicycle, etc… 37,252 2.04% 29,110 2.43%
Worked at home 115,831 6.34% 51,187 4.26%
Limited English Proficiency Plan – BIG BLUE BUS 9
FACTOR 4: The Resources Available to
BBB And The Costs of Providing LEP
Assistance
BBB is committed to ensuring that resources are
used to reduce the barriers that limit access to its
information and services by LEP persons.

Current language assistance measures
used by BBB:

1. Four of the six Customer Service staff members are bi-lingual in English and Spanish.

They are certified by way of a language test and
are well-equipped to help LEP customers.

2. BBB offers translators at various community
meetings held throughout the year.

3. Telephone access offers connections to a
Spanish-speaking representative during normal business hours.

4. Voice announcements regarding safety policies
on the bus are spoken in English and Spanish.

5. Schedules, service change announcements,
and interior cards containing fare and safety
policies are printed in both English and Spanish. Additional materials are translated upon request.

Community Outreach

1. BBB works actively with community groups,
centers for individuals with disabilities, Senior
Centers, and other organizations where participants may benefit from fixed-route transportation services.

2. Staff members attend meetings to provide
detailed information about BBB and answer
questions from the public at identified community outreach locations.

3. Community outreach locations include:
a. City of Santa Monica Main Library
b. Ken Edwards Center
c. UCLA Ackerman Student Union
d. Santa Monica College
e. Neighborhood associations
f. Seniors and Disability Commissions
g. Cinco de Mayo Festival
h. Alt Car Expo
i. SM Festival
j. Special outreach at high volume transfer
points, for example, Pico Rimpau Center
k. Two Hispanic stores that sell fare media for
BBB – Envios Montalban and Chita Store
BBB is committed to improving LEP access to information and services. A Transit Community Relations Coordinator staff person working in the Government
Limited English Proficiency Plan – BIG BLUE BUS 10
and Community Relations Division has responsibility
over translation services and oversees the portion of
the budget dedicated to translation of communications. Additionally, the Government and Community Relations Division recommended that the Operations
Division include provision of services to LEP patrons
as part of their bus operator training. The Operations
Division is in the process of reviewing options for the best way an operator can assist LEP patrons in order
to develop a training module. The Government and
Community Relations Division is also reviewing options on how to best assist LEP patrons who do not speak English or Spanish and the best ways to train
Customer Service staff to assist these customers.

Language Assistance Plan
In developing a Limited English Proficiency Plan,
FTA guidance recommends the implementation of a
Language Assistance Plan, which includes the following five elements:
• Identifying LEP individuals who need language assistance. • Providing language assistance measures.
• Training staff.
• Providing notice to LEP persons of available
non-English assistance.
• Monitoring and updating the LEP Plan.
1) Identifying LEP Individuals Who
Need Language Assistance
DOT Guidance: “There should be an assessment of
the number or proportion of LEP individuals eligible
to be served or encountered and the frequency of
encounters pursuant to the first two factors in the
four-factor analysis.”
The analysis under Factors 1 and 2 found that roughly

2.4 million LEP persons reside in Los Angeles County,
comprising 26.4 percent of the population.

81.8 percent of all residents speak either English or
Spanish. Therefore, BBB publishes important public
documentation in English and Spanish to address
the community need.
2) Providing Language
Assistance Measures
DOT Guidance: “An effective LEP plan would likely
include information about the ways in which language assistance will be provided.” As noted under Factor 4, BBB has many systems in
place to provide LEP persons with non-English assistance. To reiterate, BBB offers translation services, Spanish-speaking customer representatives, written materials printed in Spanish, and safety
policy announcements in Spanish.

BBB is in the process of creating a new web site featuring some key information translated to Spanish and informing customers that translation services
are available. More information in Spanish will be
available as the web site is updated in the future.

BBB will ensure that marketing materials for upcoming projects are printed in both English and Spanish.

On on-board printed materials with pertinent rider
information, BBB will post information in English,
Spanish, Farsi, Korean, Japanese, Chinese, and Armenian directing riders to a phone number whereby they can seek additional assistance with the language of their choice.

In order to ensure that it best serves the needs of
its LEP patrons, BBB will research language access
services provided by other public agencies.
3) Training Staff
DOT Guidance: “Staff members should know their obligations to provide meaningful access to information and services for LEP persons. An effective LEP plan
would ensure that staff knows about LEP policies and
procedures and that staff having contact with the public is trained to work effectively with interpreters.” Limited English Proficiency Plan – BIG BLUE BUS 11
BBB will implement this element of the Language
Assistance Plan by (1) identifying agency staff likely
to come into contact with LEP individuals; (2) identifying existing staff training opportunities and providing regular re-training for staff for dealing with LEP individual needs; and (3) designing and implementing LEP training for agency staff.

Customer Service Staff have been trained on how
to handle LEP customers, and Spanish-speaking
customer service representatives are available
via phone or at the counter when the store is open
for business.
4) Providing Notice to LEP Persons
DOT Guidance: “Once an agency has decided, based
on the four factors, that it will provide language services, it is important that the recipient notify LEP persons of services available free of charge.”
BBB can notify LEP persons by posting signs in intake areas or entry points, stating in outreach documents that language services are available, and using an automated telephone voice mail system with different language options.

BBB currently notifies LEP persons about existing
services through community outreach efforts. BBB
staff brings Spanish-speaking representatives when
they present at schools, festivals, libraries, and cultural centers about BBB’s service offerings. 5) Monitoring and Updating
the LEP Plan
DOT Guidance: “Recipients should, where appropriate,
have a process for determining, on an ongoing basis,
whether new documents, programs, services, and activities need to be made accessible for LEP individuals, and they may want to provide notice of any changes in
services to the LEP public and to employees.”
The BBB LEP Plan will need to be updated at the
very latest once every three years upon updates to
the existing census records for Los Angeles County.

In order to evaluate the effectiveness of the LEP Plan, BBB will closely monitor the activity and experience of LEP patrons. BBB will track both call-in and walk-in patrons to determine the number of patrons
requiring referrals to outside translation services.

BBB will continue to evaluate complaints regarding
language access and ensure that the Government
and Community Relations Manager receives these
complaints. Finally, BBB will monitor traffic to the
Spanish language web page and feedback about its
effectiveness. Closely examining all these factors
will allow BBB to ensure it provides the best service
possible to LEP patrons.

BBB understands the value that fixed-route service
can play in the lives of individuals who rely on this
service. Therefore, management is open to suggestions from customers of the service, BBB staff, other transportation agencies, and the general public.

Limited English Proficiency Plan – BIG BLUE BUS 12
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a BBB Route passing within 1/2 mile
of any part of a tract.

Census Tracts Where the LEPPopulation is Above the
BBB Service Area Average
Source: Census 2011 ACS 5-year SurveyOn Average, 22.0% of the Population residing in the Big Blue Bus Service Area* exhibits
Limited English (Language) Proficiency (LEP)
Census Designation: "Speaks English Less Than 'Very Well'" ßß EXPO - beginning 2015
LA METRO Rail M!(
Big Blue Bus NetworkBBB (I-10 Freeway Segment)
City of Santa Monica
Map 1: Population Exhibiting Limited English Proficiency

6.4 Appendix D
Demographic Maps
 Minority Population by Census Block Group. Highlights all block groups where the minority population percentage is higher than the service area average of 40.9%
 Low-Income Population by Census Block Group. Highlights all block groups where the low-income population is higher than the service area average of

28.6%
 Limited English Household by Census Block Group. Highlights all tracts where the percentage of limited English households is higher than the service area average of 11.1%

6.5 Appendix E
Big Blue Bus Service, Design, Performance, and Evaluation Guidelines Big Blue Bus
Service, Design, Performance, and
Evaluation Guidelines
October 9, 2018
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24 6.6 Appendix F
Big Blue Bus Title VI Standards and Polices
Big Blue Bus
Title VI Standards and Policies
Page | 1
Table of Contents
Overview ............................................................................................................................................................................. 2 Service Design .................................................................................................................................................................. 2 Service Standards and Policies ................................................................................................................................... 3 Vehicle Load ................................................................................................................................................................. 3 Vehicle Headway ......................................................................................................................................................... 4 On-time Performance ............................................................................................................................................... 4 Service Availability ...................................................................................................................................................... 5 Transit Amenities ........................................................................................................................................................ 5 Vehicle Assignment ................................................................................................................................................... 6 Monitoring Transit Service .......................................................................................................................................... 7 Service and Fare Equity Policies................................................................................................................................. 8 Major Service Change Policy .................................................................................................................................. 8 Disparate Impact Policy ............................................................................................................................................ 9 Disproportionate Burden Policy ............................................................................................................................ 9 Public Input & Review ................................................................................................................................................... 9 Conclusion ...................................................................................................................................................................... 11 Page | 2
Overview
Big Blue Bus is the primary transit provider for the City of Santa Monica and surrounding Westside region, providing Local and Rapid service to major destinations including UCLA, the Rimpau Transit Center, the Culver City Expo Line station, the Wilshire/Western Purple Line station, the Aviation/LAX Green Line station, and downtown Los Angeles.

Big Blue Bus operates more than 50 fixed-route peak vehicles and is located in an urbanized area of more than 200,000 people and is therefore subject to the requirements set forth in the Federal Transit Administration’s (FTA) Circular 4702.1B.

Pursuant to the requirements of FTA C 4702.1B, Big Blue Bus must establish and monitor system performance under quantitative service standards and qualitative service policies. In addition, Big Blue Bus must establish service and fare equity policies to evaluate the impacts of a major service change on minority and low-income populations.

Every three years, Big Blue Bus submits a Title VI Program to the FTA documenting compliance with the established Title VI requirements. In accordance with this submittal, Big Blue Bus will monitor and evaluate system performance relative to the service standards and policies, contained herein, no less than every three years.

Service Design
Big Blue Bus fixed-route services are grouped into three service categories for the purposes of setting service standards and policies. The majority of these services are Local routes, which operate on a set schedule and make frequent local stops. Big Blue Bus also operates several Rapid routes (limited-stop or express) with fewer stops and higher speeds. Lastly, Big Blue Bus operates limited Commuter routes, which supplement the other two services by providing service during the peak periods.

Service categories may have different standards and expectations based on the types of markets served and the operating protocols required. Wherever necessary, the service standards are shown by service category.

Big Blue bus is committed to the enforcement of USDOT’s Title VI regulations, which state that no person or group of persons shall be discriminated against with regard to the routing, scheduling, or quality of transit service on the basis of race, color, or national origin.

Page | 3
*Bus routes are current as of 2018
Service Standards and Policies
The FTA requires that all fixed-route transit providers develop service standards and policies to provide a context for the monitoring and assessment of transit service. These standards and policies are used to compare the services provided in minority areas with the services provided in non-minority areas. Service standards and polices include:
 Service Standards
o Vehicle Load
o Vehicle Headway
o On-time Performance
o Service Availability
 Service Policies
o Transit Amenities
o Vehicle Assignments
Vehicle Load
Vehicle load is the ratio of passengers to the number of seats on a vehicle, relative to the vehicle’s maximum load point. For example, on a 40 seat bus, a vehicle load of 1.5 or 150% means all seats are filled and there are 20 standees.

Vehicle overcrowding is dependent upon ridership activity and the seating capacity of each vehicle assigned to the route. Big Blue Bus operates three vehicle sub-groups each with varying capacities. To account for the difference in seating, the vehicle load will be measured as an average from the maximum load point.

Service Category Network Role Bus Routes*
Rapid Provides high-frequency, limited-stop service
between Santa Monica and neighboring
destinations of strong regional importance.

R3, R7, R10, R12, R20
Local Serves the greater Santa Monica area, providing
service along major and secondary corridors and
serving larger local destinations and intermodal
connections.
1, 2, 3, 4, 5, 7, 8, 9, 12,
14, 41, 44
Commuter Augments the local network with additional
peak hour service to key destinations.
6, 13
Page | 4
Vehicle Load Standard
Service Category Maximum Load Standard
Rapid (non-freeway), Local, Commuter Maximum of 150% or more of the seated capacity at the maximum load point on all trips
Rapid (on-freeway) Maximum of 100% or more of the seated capacity at the maximum load point on all trips
 Vehicle load standards are consistent for the peak and off-peak periods Vehicle Headway
Vehicle headway is defined as the amount of scheduled time between two vehicles traveling in the same direction on the same route.

Vehicle headways determine how long customers must wait for bus service. Higher frequencies result in reduced wait times, which make the service more attractive to potential riders. At the same time, higher frequencies can significantly increase costs by requiring additional buses and drivers. Frequent service, which enables customers to use the service “spontaneously” without consulting the bus schedule, is defined as 15 minute headways or better.

Vehicle Headway Standard
Service Category Maximum Headway Standard
Rapid 15 minute service or better throughout the day*
Local 30 minute service or better throughout the day
Local on Rapid Corridor 20 minute service or better throughout the day Commuter Per trip basis
* Rapid (on-freeway) service may operate less frequently during the off-peak period  Whenever possible, Rapid services should operate more frequently than Local service on the same corridor, to allow maximum customer convenience and greater access to the faster, more efficient service option
 Local service on major corridors, especially those without Rapid service, may warrant more frequent service of 15 minutes or better
 Commuter service is tailored to ridership activity and may have inconsistent headways On-time Performance
On-time performance is a measure of service reliability that determines the percentage of buses that arrive or depart within a certain amount of time before or after the published schedule. Ontime performance reflects the quality of service and influences a customer’s choice to use transit.

Page | 5
On-time Performance Standard
A vehicle is considered on-time if it runs no more than one (1) minute early and no more than five (5) minutes late compared to the scheduled time at each timepoint. Early arrivals at the final timepoint will be considered on-time.

Big Blue Bus maintains a systemwide on-time performance goal of eighty-five percent (85%) ontime, which allows for some level of service variability while maintaining the reasonable expectation of reliability for customers.

Service Availability
Service availability is a measure of transit accessibility based on the distribution of routes and the placement of stops within a transit provider’s service area. Stops spaced further apart allow for faster bus speeds and reduce customer travel times but also require customers to walk further to access the service. Stop spacing standards differ by service category.

Service Availability Standard
Rapid Service Stop Spacing
Rapid bus routes on corridors also served by Local routes should have stops spaced a minimum of 2,640 feet (1/2 mile) apart, and should be placed at major destinations, intersections, and transfer points. Rapid stop placement should be determined based on overall spacing as well as ridership demand.

Local Service Stop Spacing
For Local services, stop spacing from 1,000 feet up 1,300 feet (1/4 mile) is desirable. Local stops on major arterial streets risk introducing unnecessary delay if stops are spaced closer than 1,000 feet. Existing stops with continuously low usage will be subject to review for consolidation with other stops or removal in order to increase service speed and reliability.

Commuter Service Stop Spacing
Commuter services may use either Local or Rapid stop spacing patterns depending on the type of service, passenger needs, and areas served.

Transit Amenities
Transit amenities refer to items of comfort, convenience, and safety that are available to transit passengers. These items include, but are not limited to, shelters, seating, signage, and trash receptacles. Transit amenities must be equitably distributed on a systemwide basis.

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Transit Amenities Policy
Big Blue Bus has significant authority over bus stop improvements and amenities within the City of Santa Monica. Bus stops located in neighboring cities and jurisdictions may be subject to external policies. Transit amenities will be allocated based on ridership activity (total number of average daily boardings) and will be equitably distributed to reflect the systemwide demographics of Big Blue Bus. Ridership activity levels are classified as follows:

Average Daily Boardings Bus Stop Category Amenities Provided 49 or less Low Volume Public information kiosk
50-99 Medium Volume Above plus shelter and seat
100-999 High Volume Above plus real time signage
1,000 or more Very High Volume Above plus multiple shelters or extra-large shelter
Vehicle Assignment
Vehicle assignment refers to the process by which transit vehicles are placed into service. Big Blue Bus presently maintains a fixed-route fleet with three vehicle sub-groups: articulated 60-foot motor coaches, 40-foot motor coaches, and 32-foot motor coaches. All vehicles are maintained and operate from a single depot.

Vehicle Assignment Policy
Vehicles are assigned based on service category and vehicle capacity. Vehicle assignments are as follows:

Articulated 60-foot Motor Coaches
The articulated 60-foot coaches are assigned to Rapid services that have higher ridership activity.

Given that there are not enough articulated buses to supply all of the assignments for Rapid service, some 40-foot coaches are also assigned to Rapid service. Rapid routes with the highest average passenger loads are assigned the 60-foot articulated coaches due to the greater seating capacity. Within Rapid service, buses are assigned among routes to maintain fleets on each route with an average age that does not exceed the systemwide average. 40-foot Motor Coaches
The 40-foot motor coaches make up over half of the Big Blue Bus fleet. These buses are primarily assigned to Local service, as well as to some Rapid service as noted above. Within routes with 40- foot bus assignments, buses are assigned among routes to maintain fleets on each route with an average age that does not exceed the systemwide average.

Page | 7
32-foot or smaller Motor Coaches
The 32-foot or smaller motor coaches are assigned to routes with lower ridership activity and/or to routes that use local streets. Some of the 32-foot coaches may also be assigned to routes that primarily use 40-foot coaches, specifically at times when ridership is expected to be light, such as nights or weekends. Within routes with a mix of 40-foot and 32-foot bus assignments, buses are assigned among routes to maintain fleets on each route with an average age that does not exceed the systemwide average.

The low number of vehicles in the 32-foot or smaller sub-group, and the propensity to replace the whole fleet at once, means that there is less opportunity to assign a variety of vehicles in order to maintain fleets on each route with an average age that does not exceed the systemwide average. Buses on routes with exclusive use of 32-foot or smaller motor coaches are currently younger than the systemwide average and will age on that route until they are replaced with new vehicles, or until the sub-group is large enough to enforce an average age policy.

Monitoring Transit Service
Big Blue Bus will monitor and evaluate transit performance relative to the service standards and policies, contained above, no less than every three years.

Big Blue Bus will use the FTA minority transit route definition to implement this monitoring program. A minority transit route is one in which at least one-third of the revenue miles are located in a Census block or Census block group where the minority population percentage exceeds average minority population in the Big Blue Bus service area. This method of analysis may be supplemented with on-board passenger survey data, as available, to adjust route designations accordingly.

Big Blue Bus will evaluate the results of the monitoring program to determine if a disparate impact exists as a result of prior policy actions and decision-making. Big Blue Bus will take steps to remedy any potential disparity where the monitored service fails to meet the established service standards or policies.

The results of the monitoring program will be submitted to the Santa Monica City Council and the FTA as part of the triennial Title VI Program submittal.

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Service and Fare Equity Policies
In accordance with FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients,” effective October 1, 2012, transit providers, operating 50 or more fixed route vehicles during peak service and serving a population of 200,000 or greater, must evaluate prior to implementation, any and all proposed changes that exceed the transit provider’s major service change threshold to determine whether those changes will have a discriminatory impact.

To comply with this requirement, transit providers must adopt the following three policies:
 Major Service Change Policy
 Disparate Impact Policy
 Disproportionate Burden Policy
The Major Service Change Policy defines what actions constitute a major change and are therefore subject to a service or fare equity analysis. The Disparate Impact Policy establishes a threshold for determining when adverse impacts of a proposed change are borne disproportionately by the minority population. The Disproportionate Burden Policy establishes a threshold for determining when adverse impacts of a proposed change are borne disproportionately by the low-income population.

The low-income population is defined as all persons living at or below the U.S. Federal Poverty Guidelines as established annually by the U.S. Department of Health & Human Services. Big Blue Bus intends to use rider demographic data rather than Census data for this calculation because the percent low-income population in the service area is close to the fifteen percent (15%) threshold established in the Disproportionate Burden Policy.

Major Service and Fare Change Policy
Proposed changes that qualify as a major service change include changes to existing routes that result in an increase or decrease in route revenue miles or route miles that are equal to or greater than twenty-five percent (25%) of the existing service, as happening one-time or cumulatively throughout the year. A major service change also includes the introduction of a new route and the elimination of an existing route.

All fare and fare media changes will be subject to a fare equity analysis which will include an analysis of adverse impacts.

Changes that are exempt from this policy include the introduction or elimination of a limited-term route that will be, or has been, operated for no more than twelve (12) months, promotional or temporary fare reductions lasting no longer than six (6) months, and occasional “free ride” days.

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Disparate Impact Policy
A disparate impact occurs when the percent minority population adversely impacted by a major service change is fifteen percent (15%) higher than the average minority population of the Big Blue Bus service area, or when the percent non-minority population beneficially impacted by a major service change is fifteen percent (15%) higher than the average non-minority population of the Big Blue Bus service area.

A disparate impact analysis on routes with a major service change will be examined on a cumulative basis by evaluating all route changes together.

Disproportionate Burden Policy
A disproportionate burden occurs when the percent low-income population adversely impacted by a major service change is fifteen percent (15%) higher than the average low-income population of the Big Blue Bus service area, or when the percent non-low-income population beneficially impacted by a major service change is fifteen percent (15%) higher than the average non-lowincome population of the Big Blue Bus service area.

A disproportionate burden analysis on routes with a major service change will be examined on a cumulative basis by evaluating all route changes together.

If a disproportionate burden exists as a result of the proposed changes, Big Blue Bus may take steps to avoid, minimize, or mitigate the impact of the proposed change on the low-income population.

Public Input & Review
A major service change will be subject to a public hearing and adoption by the Santa Monica City Council. Public input will be actively sought in regard to the proposed changes prior to the public hearing. Customers, stakeholders, and the general public will be invited to provide comment through at least one of the following methods: the Big Blue Bus website, public meetings, through surveys, or at public hearings with the Santa Monica City Council.

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Public Notification
When required, the public comment process will begin with the publishing of a legal notice seven (7) calendar days in advance of the public hearing date in the local newspapers of general circulation. This notice will set a specific place, date, and time for one or more public hearings.

Written comments will also be accepted on the proposed changes seven (7) calendar days beyond initial publishing of the legal notice. Legal notices will inform the public of the proposed actions that initiated the public comment process. Press releases will also be prepared and sent to the local media.

In addition to the public hearing process, Big Blue Bus employs various outreach methods including:
 Publication on website
 Information posted on buses
 Public meetings in various parts of the Big Blue Bus service area  Notices to public officials, key stakeholders, and community groups  Targeted surveys to riders of affected services
 E-communications to self-identified Big Blue Bus passengers (those who provide contact information)
 “Ambassador” personnel stationed at key bus stops and transit hubs to discuss service changes with customers
Scheduling Public Hearings
The public hearing(s) will be scheduled and conducted by the City of Santa Monica City Council at a time, date, and place to be designated. The facility utilized for public hearings will be accessible to persons with disabilities. Special arrangements will be made for vision or hearing impaired persons if requested at least three days prior to the meeting.

Procedure for Conducting Public Hearing
Forms will be available to attendees to register their presence and desire to speak. Public hearings will begin with a reading of the public notice, purpose, and proposed action that necessitated the public hearing. After an explanation of the proposed action is completed, the public will be invited to offer their comments. The City Council will determine the amount of time the public has to comment during the public hearing. After all registered persons have commented, a final opportunity will be offered for any additional public comment. This offering will precede the close of the public hearing.

Documentation of Public Hearing
Official records of public hearings on service or fare adjustments will be generated by:
 Affidavits of newspaper publications of public notices Page | 11
 Press releases conveying information on upcoming public hearings  Tape recordings and transcripts of proceedings
Addressing Public Comments Received
All relevant comments received verbally or in writing at a public hearing, or as otherwise conveyed to Big Blue Bus prior to the established deadline, will be entered into the public record of the comment process. Subsequent to the public comment period, staff will evaluate and analyze all relevant comments received and prepare a written report for consideration by the Santa Monica City Council.

City Council Notification
The City Council will be notified by the City Manager of all written public comment solicitations in advance of all scheduled public hearings on fare and service adjustments. A summary of public feedback received will be provided to the City Council along with staff recommendation for final disposition of the issues. Upon review by the City Council, the City Manager will be directed accordingly to proceed with or amend the recommended service and/or fare adjustments.

Conclusion
Big Blue Bus is committed to the enforcement of USDOT’s Title VI regulations and will provide the most effective and efficient transit service possible, with full accountability to those it serves.

Through the use of the established service standards and policies, Big Blue Bus will ensure that no person or group of persons shall be discriminated against with regard to the routing, scheduling, or quality of transit service on the basis of race, color, or national origin.

6.7 Appendix G
Big Blue Bus Public Participation Plan and Hearing Procedures for Major Service or Fare Changes

1. Background
Santa Monica’s Big Blue Bus (BBB) is required by the Federal Transit Act, as amended through 1992, to establish a policy which defines a process to solicit and consider public comment prior to raising fares or implementing a major change of transit services.

2. BBB Policy
a. It shall be the BBB’s policy that public comments be solicited prior to:
i. Any permanent fare or fare media change.
ii. A twenty-five percent (25%) or more change in the number of daily transit revenue vehicles miles of a route; i.e., the total number of miles operated by all vehicles in revenue service for a particular day of the week on an individual route.
iii. A twenty-five percent (25%) or more change in the number of transit route miles of a route, i.e., the total mileage covered during one round trip by a vehicle in revenue service on a particular route.
iv. Proposed introduction or elimination of a new route that will be, or has been, operated for more than twelve (12) months. b. It shall be the BBB’s policy that the following shall be exempt from public comment and public hearing:
i. A minor change in fare or service. Examples would be temporarily reduced, experimental or promotional fares, minor reroutes or minor temporary reroutes due to street
construction(s) or minor schedule changes.
ii. Experimental, seasonal or emergency fare changes expected to exist fewer than six (6) months in service. If these changes ultimately continue to remain in effect for more than six (6) months, they will be the subject of public comment and public hearing.

3. Public Notification
When required, the public comment process will begin with the publishing of a legal notice seven (7) calendar days in advance of the public hearing date in the local newspapers of general circulation. This notice will set a specific place, date, and time for one or more public hearings. Written comments will also be accepted on the proposed changes seven (7) calendar days beyond initial publishing of the legal notice. Legal notices will inform the public of the proposed actions that initiated the public comment process. Press releases will also be prepared and sent to the local media.

In addition to the public hearing process, Big Blue Bus employs various outreach methods including:
 Publication on website
 Information posted on buses
 Public meetings in various parts of the Big Blue Bus service area  Notices to public officials, key stakeholders, and community groups  Targeted surveys to riders of affected services
 E-communications to self-identified Big Blue Bus passengers (those who provide contact information)
 “Ambassador” personnel stationed at key bus stops and transit hubs to discuss service changes with customers
All printed public information is bilingual at minimum which includes anything related to service (major and minor) changes, fare changes, policy updates, promotions, etc. All information on board our buses and at our bus stops is bilingual, including schedules and maps found in the Little Blue Book and System Map, maps and info at bus stops.

All notifications for public meetings are bilingual and ensure that language services are available upon request. Bilingual staff are present at the event in case the need arises. In addition, trained customer service staff is bilingual and language translation services are available to accommodate any other languages.

4. Scheduling Public Hearings
The public hearing(s) will be scheduled and conducted by the City of Santa Monica City Council at a time, date, and place to be designated. The facility utilized for public hearings will be accessible to persons with disabilities. Special arrangements will be made for vision or hearing impaired persons if requested at least three days prior to the meeting.

5. Procedure for Conducting Public Hearing
Forms will be available to attendees to register their presence and desire to speak.

Public hearings will begin with a reading of the public notice, purpose, and proposed action that necessitated the public hearing. After an explanation of the proposed action is completed, the public will be invited to offer their comments. The City Council will determine the amount of time the public has to comment during the public hearing. After all registered persons have commented, a final opportunity will be offered for any additional public comment. This offering will precede the close of the public hearing.

6. Documentation of Public Hearings
Official records of public hearings on service or fare adjustments will be generated by:
 Affidavits of newspaper publications of public notices  Press releases conveying information on upcoming public hearings  Tape recordings and transcripts of proceedings

7. Addressing Public Comments Received
All relevant comments received verbally or in writing at a public hearing, or as otherwise conveyed to Big Blue Bus prior to the established deadline, will be entered into the public record of the comment process. Subsequent to the public comment period, staff will evaluate and analyze all relevant comments received and prepare a written report for consideration by the Santa Monica City Council.

8. City Council
The City Council will be notified by the City Manager of all written public comment solicitations in advance of all scheduled public hearings on fare and service adjustments. A summary of public feedback received will be provided to the City Council along with staff recommendation for final disposition of the issues. Upon review by the City Council, the City Manager will be directed accordingly to proceed with or amend the recommended service and/or fare adjustments.

6.8 Appendix H
Community Outreach
Big Blue Bus hosted the following Public Hearings in February 2022, on proposed fare adjustments:

Thursday, February 10 | 5:30-7:30pm
Santa Monica Main Library
Martin Luther King Jr. Auditorium
601 Santa Monica Blvd.

Santa Monica, 90401
All printed public information is bilingual at minimum which includes anything related to service (major and minor) changes, fare changes, policy updates, promotions, etc. All information on board our buses and at our bus stops is bilingual, including schedules and maps found in the Little Blue Book and System Map, maps and info at bus stops.

6.10 Appendix J
Fare Equity Analysis
Big Blue Bus
Title VI Fare Equity Analysis
Elimination of on-board cash fares and
magnetic fare cards
July 2021
July 2021

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Table of Contents
Table of Contents..........................................................................................................................................1 Purpose .........................................................................................................................................................2 Executive Summary.......................................................................................................................................2 Background ...................................................................................................................................................3 Fare Structure ...............................................................................................................................................3 Fare Utilization..............................................................................................................................................4 Proposed Fare Media Changes.....................................................................................................................5 Methodology.................................................................................................................................................5 Data Sources.............................................................................................................................................5 Definitions.................................................................................................................................................6 Title VI Policies..........................................................................................................................................6 Fare Equity Disparate Impact Policy .....................................................................................................6 Fare Equity Disproportionate Burden Policy ........................................................................................6 Fare Equity Analysis......................................................................................................................................7 Disparate Impact Analysis.........................................................................................................................7 Disparate Impact Findings.....................................................................................................................7 Disparate Impact Conclusion ................................................................................................................8 Disproportionate Burden Analysis............................................................................................................8 Disproportionate Burden Findings........................................................................................................8 Disproportionate Burden Conclusion ...................................................................................................9 Conclusion.....................................................................................................................................................9 Further Actions ...........................................................................................................................................10 Appendix .....................................................................................................................................................11

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Purpose
In the summer of 2021, Big Blue Bus (BBB) will pilot the introduction of a purely contactless fare system.

As a result, BBB is proposing a fare media change that will result in the elimination of on-board cash fares and the elimination of magnetic fare cards. During this pilot period, riders will only be able to pay their fare using either the regional TAP fare payment system or mobile ticketing. Cash and magnetic fare cards will no longer be accepted on-board. Riders will have a variety of options for obtaining TAP fares, and cash paying customers who are unbanked or underbanked will be able to replenish their TAP balances using ticket vending machines, available along every BBB bus route, or at the nearly 900 retail TAP vendor locations located across Los Angeles County. Smartphone users will be able to choose between TAP or mobile ticketing, depending on their preferences. The Contactless Fare Pilot is set to begin on July 5, 2021 and will run for six months ending on January 5, 2022.

The proposed fare media change is subject to a fare equity analysis as defined by BBB’s Major Service and Fare Change Policy. The fare equity analysis, contained herein, is required to ensure compliance with the Federal Transit Administration (FTA) Title VI regulations as defined by FTA Circular 4702.1B. The purpose of this analysis is to determine whether the proposed changes result in a disparate impact on the basis of race, ethnicity, or national origin, or a disproportionate burden on the defined low-income population.

Executive Summary
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in any program or activity that receives Federal funds or other Federal financial assistance. In compliance with this law, Big Blue Bus has conducted a Title VI analysis on the proposed fare media changes. The following analysis has found that the proposed changes will not result in an disparate impact on the minority population, or a disproportionate burden on the low-income population, as the changes do not exceed the adopted fifteen percent (15%) threshold as defined by Big Blue Bus policy.

While the impacts of the proposed changes do not exceed the established thresholds, BBB has and will continue to take action to lessen the challenges of adaptation to contactless fares. For example, BBB has hired a designated Contactless Fare Pilot Customer Service Associate on a one-year limited term appointment to coordinate the efforts to assist people in the transition to contactless fares. BBB has also embarked on an extensive communications effort on contactless fares, including how to get them, and promoting the benefits to passengers which include lower fares, faster boarding and travel times, and the opportunity to bypass cash and the associated risks to health.

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Background
Prior to 2015, all BBB customers paid their fare with either cash or magnetic fare cards. These two fare systems have significant downsides for both customers and BBB. Cash fare payment is much slower, on average, than other fare payment methods, due to the time required to physically insert the necessary bills and coins into the farebox. Over the course of 40 people boarding a bus, and using cash to pay their fare, the trip can require up to 13 additional minutes dedicated exclusively to the cash payment process.

The resulting delay in service has a substantial negative impact on rider experience, on-time performance, and operating costs across the system making transit a less attractive mode of transportation.

Contactless fare payment options have several benefits. They can reduce dwell times, improve on-time performance, and will ultimately result in faster travel times for passengers riding the bus. They also operate separately from the farebox and are, therefore, not susceptible to farebox malfunctions which result in lost revenue.

Additionally, cash and the farebox are known vectors for disease transmission, not only for passengers, but also for the driver, and staff that are assigned to count and process cash. While magnetic fare cards are significantly faster than cash, and eliminate the process of counting cash, passengers are still required to touch the farebox when paying. Magnetic fare cards also possess two additional negative qualities which are a high failure rate and the inability to integrate them into the regional fare card system for Los Angeles County.

Due to the pandemic, BBB suspended fare collection on March 20, 2020 to slow the spread of disease.

This led BBB staff to reexamine strategies for shifting more passengers to contactless fare media and a goal was set to pilot the elimination of on-board cash fares and magnetic fare cards soon after the fare collection resumed on February 14, 2021.

Fare Structure
BBB fares vary based on rider classification and fare category. Rider classifications include: Regular (age 19-61), Youth (age 5-18), Senior (age 62+)/Disabled/Medicare, and Child (age 4 and under). Fare categories include: Single Trip, Day Pass, 7-Day Pass, 13 Ride Pass, 30-Day Pass, Annual Pass, and EZ Pass.

Fares can be paid either on-board with cash or prior to boarding with TAP or mobile ticketing. Fare prices vary based on rider classification, fare category, and method of payment. Customers with a valid Access ID and children ages 4 and under ride for free.

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Fare Category
Regular Fares S/D/M Fares
On-Board
Cash Fare
TAP & Mobile
Ticket Fare
On-Board
Cash Fare
TAP & Mobile
Ticket Fare
Single Trip $1.25 $1.00 $0.50 $0.40
Day Pass - $4.00 - $1.50
7-Day Pass - $14.00 - -
13 Rides Pass - $14.00 - $6.00
30-Day Pass - $50.00 - $24.00
Annual Pass - $500.00 - -
EZ Pass - $110.00 - $42.00
Interagency Transfer - $0.50 - $0.25
Youth 30-Day Pass - $19.00 - -
Figure 1: Existing BBB Fare Structure as of March 2021
Fare Utilization
During the period of COVID-19 fare suspension, BBB took several measures to further attract, and encourage, riders to use contactless fare payment options when fare collection resumed in the future.

BBB worked closely with Santa Monica College (SMC) to shift their riders from magnetic fare cards to contactless fares, moving 12.2% of pre-COVID ridership to contactless fares in the process. BBB further reduced the base fare on TAP and mobile ticketing from $1.10 to $1.00 and introduced a new low Senior/Disabled/Medicare (S/D/M) fare on TAP and mobile ticketing of $0.40 (versus $0.50 cash S/D/M fare). BBB also enabled S/D/M riders to self-declare eligibility for a mobile ticket reduced fare, rather than having to go to the store to certify eligibility prior to obtaining the discount.

BBB also began offering Low Income Fare is Easy (LIFE) applications at the Transit Store. The LIFE program provides free fares to low-income riders using contactless fares (TAP). Lastly, in preparation for the contactless fare pilot, BBB hired a Customer Service Associate to work specifically on assisting vulnerable populations in adapting to contactless fares.

When fare collection resumed on February 14, 2021, cash ridership, as a percentage of total ridership, was significantly higher than it was before fare collection was suspended. Ridership on UCLA and SMC passes previously made up 23% of the total systemwide ridership. It was determined that in the absence of those rider populations, at institutions closed due to the pandemic, a large number of contactless fare riders had been removed from the system, leaving behind a majority of cash riders. Additionally, surveying completed in March 2021 showed that 74% of the new riders that began to use the system in the last year were using cash to pay their fare versus 52% of the riders who had been riding longer.

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Fare Media Type FY 2019-2020 March 2021 Survey Difference Cash on Bus 32.8% 56.9% 24.1%
Magnetic Fare Card 15.2% 0.0% -15.2%
Smartphone App 1.5% 1.5% 0.0%
TAP Card 44.8% 35.8% -9.0%
Other (UCLA, SMC, Access) 5.7% 5.8% 0.1%
Figure 2: Fare Utilization Comparison
As of March 2021, fare payment by contactless fare media had sunk from 46.3% prior to the COVID-19 suspension of fares to 37.3% after fare collection resume in February 2021. During this same period, cash usage increased from 32.8% to 56.9%. The customer profile is now more low-income and more minority, compared to pre-COVID ridership, and these groups are more likely to use cash as their fare payment option.

Proposed Fare Media Changes
The proposed fare media changes include: 1) the elimination of on-board cash fares and, 2) the elimination of magnetic fare cards. The proposed changes are expected to shift riders to pre-paid, contactless fare media options, which include TAP cards and mobile ticketing apps. Increased contactless fare adoption will benefit all BBB riders through reduced dwell times, improved on-time performance, and faster travel times.

Methodology
Data Sources
The fare equity analysis was completed using passenger survey data collected from the March 2021 Big Blue Bus Passenger Survey.

The following information was obtained from the passenger survey for use in the fare equity analysis:
• Method of fare payment
• Fare category
• Rider race/ethnicity
• Household income
• Household size
Rider demographics were combined with the method of fare payment to determine the systemwide, minority, and low-income fare utilization for all methods of payment. The resulting comparison of fare utilization between minority and non-minority riders, and low-income and non-low-income riders, will establish whether the proposed changes result in a disparate impact or disproportionate burden as defined by BBB’s adopted policies.

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Definitions
In performing the fare equity analysis, minority riders are defined as survey respondents who completed the race/ethnicity question and marked any category besides White-alone. Low-income riders are defined as survey respondents who completed the household income and household size questions and are deemed eligible to participate in the Low-Income Fare is Easy (LIFE) program.

The household income limits established by the LIFE program are the same guidelines that BBB uses to determine which riders define the low-income population.

Low-Income Fare is Easy (LIFE)
Household Income Limits
Persons per
Household Annual Income
1 $39,450 or less
2 $45,050 or less
3 $50,700 or less
4 $56,300 or less
5 $60,850 or less
6 $65,350 or less
Figure 3: 2021 LIFE Household Income Limits
Title VI Policies
As required by the FTA Title VI regulations, the public was engaged in the development of BBB’s disparate impact and disproportionate burden policies. These two policies will determine if the proposed fare media changes result in a disparate impact or disproportionate burden.

Fare Equity Disparate Impact Policy:
“A disparate impact occurs when the percent minority population adversely impacted by a major service change is fifteen percent (15%) higher than the average minority population of the Big Blue Bus service area, or when the percent non-minority population beneficially impacted by a major service change is fifteen percent (15%) higher than the average non-minority population of the Big Blue Bus service area.

If a disparate impact exists as a result of the proposed changes, Big Blue Bus will determine whether there are alternatives that would serve the same legitimate objectives but with less disparate impact on the minority population. If there are no viable alternatives, Big Blue Bus must have a substantial legitimate justification for making the proposed change.”
Fare Equity Disproportionate Burden Policy:
“A disproportionate burden occurs when the percent low-income population adversely impacted by a major service change is fifteen percent (15%) higher than the average low-income population of the Big Blue Bus service area, or when the percent non-low-income population beneficially impacted by a major service change is fifteen percent (15%) higher than the average non-low-income population of the Big Blue Bus service area.

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If a disproportionate burden exists as a result of the proposed changes, Big Blue Bus may take steps to avoid, minimize, or mitigate the impact of the proposed change on the low-income population.” Fare Equity Analysis
The proposed fare media changes represent an adverse change to current cash or magnetic fare card riders. As such, the following analyses, disparate impact and disproportionate burden, must determine whether the minority and low-income populations will be unfairly impacted by the proposed changes by 15% or greater compared with the non-minority and non-low-income populations.

Disparate Impact Analysis
There were 550 respondents that completed the race/ethnicity question in the March 2021 survey. Of these responses, 84% of all riders were identified as minority riders (riders that selected a race other than White-alone).

Figure 4: Systemwide Ridership by Race
Disparate Impact Findings
• Minority riders comprise 84% of systemwide riders
• On-board cash fares account for 49.6% of all boardings making it the most popular fare choice amongst minority (59.2%) and non-minority (44.9%) riders • The next most popular fare choice is TAP, which accounts for 29.5% of all boardings • Minority riders are 14.3% more likely to use cash compared with non-minority riders • Minority riders are 0.1% less likely to use magnetic fare cards compared with non-minority riders Fare Media Type
Non-Minority
Riders
Minority
Riders
Non-Minority
Percent
Minority
Percent
Difference
Access TAP Card 12 20 13.5% 4.3% -9.1%
Cash on Bus 40 273 44.9% 59.2% 14.3%
Smartphone App 2 6 2.2% 1.3% -0.9%
TAP Card 35 162 39.3% 35.1% -4.2%
Figure 5: Fare Utilization Comparison by Race
84%
16%
0% 20% 40% 60% 80% 100%
Minority Riders
Non-Minority Riders
Percent of All Riders
2021 Passenger Survey - Ridership by Race

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Fare Media Type
(pre-COVID)
Non-Minority
Riders
Minority
Riders
Non-Minority
Percent
Minority
Percent Difference
Magnetic Fare
Card 2 11 3.1% 3.0% -0.1%
Other Fare
Media 63 358 96.9% 97.0% 0.1%
Figure 6: Fare Breakdown by Race
Disparate Impact Conclusion
Based on the 15% threshold, established in the Disparate Impact Policy, minority riders would not experience a disparate impact as a result of the proposed fare media change. Minority riders are 14.3% more likely to use on-board cash fares and 0.1% less likely to use magnetic fare cards compared with nonminority riders. Although adversely impacted by the change, the impact does not exceed the 15% threshold as established by BBB's Disparate Impact Policy.

Disproportionate Burden Analysis
There were 382 respondents that completed the household income and household size questions in the March 2021 survey. Of these total responses, 87% of all riders were identified as low-income riders(riders whose reported household income met the established thresholds of the LIFE program).

Figure 7: Systemwide Ridership by Income
Disproportionate Burden Findings
• Low-income riders comprise 87% of systemwide riders
• On-board cash fare is the most popular fare choice amongst low-income riders (48.2%) • TAP card is the most popular fare choice amongst non-low-income riders (47.1%) • Low-income riders are 14.4% more likely to use cash compared with non-low-income riders • Low-income riders are 3.3% less likely to use magnetic fare cards compared with non-low-income riders
87%
13%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Low-Income Riders
Non-Low-Income Riders
Percent of All Riders
2021 Passenger Survey - Ridership by Income

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Fare Media Type Non-Low-Income
Riders
Low-Income
Riders
Non-Low-Income
Percent
Low-Income
Percent Difference
Access TAP Card 3 22 5.9% 6.6% 0.8%
Cash on Bus 21 184 41.2% 55.6% 14.4%
Smartphone App 3 4 5.9% 1.2% -4.7%
TAP Card 24 121 47.1% 36.6% -10.5%
Figure 8: Fare Utilization Comparison by Income
Fare Media Type
(pre-COVID)
Non-Low-Income
Riders
Low-Income
Riders
Non-Low-Income
Percent
Low-Income
Percent Difference
Magnetic Fare Card 2 7 5.9% 2.6% -3.3%
Other Fare Media 32 263 94.1% 97.4% 3.3%
Figure 9: Fare Breakdown by Income
Disproportionate Burden Conclusion
Based on the 15% threshold, set in the Disproportionate Burden Policy, low-income riders would not experience a disproportionate burden as a result of the proposed fare media change. Low-income riders are 14.4% more likely to use on-board cash fares and 3.3% less likely to use magnetic fare cards compared with non-low-income riders. Although adversely impacted by the change, the impact does not exceed the 15% threshold as established by BBB's Disproportionate Burden Policy.

Conclusion
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in any program or activity that receives Federal funds or other Federal financial assistance. In compliance with this law, Big Blue Bus has conducted a Title VI analysis on the proposed fare media changes. This analysis has found that, based on the adopted 15% threshold, the proposed changes will not result in a disparate impact on the minority population or a disproportionate burden on the low-income population.

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Further Actions
While the impacts of the proposed changes do not exceed the established 15% threshold, there are some opportunities to lessen the challenges of adaptation to contactless fares, and to empower riders to make the shift on their own, prior to the start of the pilot project.

Encouraging most customers to convert to contactless fares before the start of the pilot rather than when the pilot begins will mitigate some of the impacts. In support of this goal, BBB has hired a designated Contactless Fare Pilot Customer Service Associate on a one-year limited term appointment to coordinate the efforts to assist people in the transition to contactless fares. BBB has also embarked on an extensive communications effort on contactless fares, including how to get them, and promoting the benefits to passengers.

In order to convert the greatest number of customers to contactless fares, beginning April 19, 2021, BBB began to distribute free 30-Day passesto customers. These passes are available on a free TAP card through the Transit Store and on mobile ticketing through the Token Transit and Transit App mobile ticketing platforms. There is a limit of one pass per customer and they are available only through July 15, 2021.

There is no cost to participate and no one is excluded.

The introduction of this program is an opportunity to educate BBB customers on the benefits of contactless fare options, and to address any concerns or questions that they may have.

Using the information gleaned from this Title VI analysis, BBB will continue to work with vulnerable populations to address concerns, remove barriers, craft communication, and create programs that empower riders to embrace contactless fares. With over 1,000 TAP reload locations, online options, unbanked options, and opportunities to participate in contactless fares on an anonymous basis, BBB is intent on making contactless fares work for all customers. The savings in travel time will be of significant benefit to all riders, and the opportunity to bypass cash and the associated risks to health will be a benefit to both customers and staff.

BBB is committed to caring for the most vulnerable through this process and learning as we go, to ensure a fair and equitable system that benefits everyone. For a list of communication and outreach efforts to encourage the use of contactless fares, see Appendix 2.1 - Communication & Outreach Timeline.

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Appendix

1.1 Big Blue Bus – March 2021 Passenger Survey Results

1. Enter Survey Invitation Code____________

2. Are you at least 14 years old?
a. Yes >> 550 of 550 (100%)
b. No >> 0 of 550

3. How many days a week do you ride on BBB buses?
a. Less than 1 day/week >> 81 of 550 (14.7%)
b. 1 to 3 days >> 196 of 550 (35.6%)
c. 4 to 5 days >> 158 of 550 (28.7%)
d. 6 days or more >> 115 of 550 (20.9%)

4. BBB route(s) you ride on a weekly basis
(Select All That Apply)
a. 1 Santa Monica Blvd. >> 204 of 550 (37.1%)
b. 2 Wilshire Blvd. >> 59 of 550 (10.7%)
c. 3 Lincoln Blvd. >> 212 of 550 (38.5%)
d. 5 Olympic Blvd. >> 11 of 550 (2.0%)
e. 7 Pico Blvd. >> 203 of 550 (36.9%)
f. 7 Rapid Pico Blvd. >> 75 of 550 (13.6%)
g. 8 Ocean Park >> 31 of 550 (5.6%)
h. 9 Pacific Palisades >> 143 of 550 (26.0%)
i. 10 Rapid Downtown LA >> 6 of 550 (1.0%)
j. 12 Westwood/UCLA/Culver City >> 18 of 550 (3.3%)
k. 14 Bundy Dr. >> 30 of 550 (5.5%)
l. 15 Barrington Ave. >> 2 of 550 (0.3%)
m. 17 UCLA - VA Medical – Palms >> 18 of 550 (3.3%)
n. 18 UCLA - Abbot Kinney >> 63 of 550 (11.5%)
o. 41 - 17th St. - SMC – Montana >> 5 of 550 (0.9%)
p. 43 - 26th St. & San Vicente Blvd. >> 6 of 550 (1.0%)

5. Did you ride BBB before the COVID-19 pandemic?
a. Yes, started riding before March 20th, 2020. >> 434 of 550 (78.9%) b. No, started riding after March 20th, 2020. >> 116 of 550 (21.1%)

6. Before the COVID-19 pandemic, How did you USUALLY pay for your BBB fare? a. Cash on the bus >> 220 of 434 (50.7%)
b. BBB Paper Pass (magnetic) >> 6 of 434 (1.4%)
c. TAP card >> 165 of 434 (38.0%)
d. Access TAP card >> 30 of 434 (6.9%)
e. 7-Day BBB Paper Pass >> 7 of 434 (1.6%)

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f. Santa Monica College Pass >> 2 of 434 (0.5%)
g. UCLA Pass >> 2 of 434 (0.5%)
h. Smartphone app (Transit app, Token Transit app) >> 2 of 434 (0.5%) i. BBB employee/retiree/dependent pass >> 0 of 434

7. Before the COVID-19 pandemic, where did you usually purchase your Paper Pass? a. On the bus >> 3 of 13 (23.1%)
b. BBB Transit Store >> 9 of 13 (69.2%)
c. Santa Monica public library >> 1 of 13 (7.7%)

8. How do you usually pay for your BBB fare now?
a. Cash on the bus >> 313 of 550 (57.0%)
b. TAP card >> 197 of 550 (35.8%)
c. Smartphone app (Tap, Transit app, Token Transit app) >> 8 of 550 (1.5%) d. Access TAP card >> 32 of 550 (5.8%)
e. BBB employee/retiree/dependent pass >> 0 of 550
f. Paper pass that I had left over. >> 0 of 550

9. Which Smartphone App do you usually use to pay your BBB fare? a. TAP app >> 3 of 8 (37.5%)
b. Transit app >> 2 of 8 (25.0%)
c. Token Transit App >> 2 of 8 (25.0%)
d. Other >> 1 of 8 (12.5%)

10. Where do you typically get your BBB fare products (tickets/passes)? (Select All That Apply)
a. A ticket vending machine (TAP Stored Value) >> 43 of 119 (36.1%) b. TAP website or TAP call center >> 10 of 119 (8.4%)
c. TAP retail location (Ralph’s, 7-Eleven, etc.) >> 3 of 119 (2.5%) d. TAP app >> 7 of 119 (5.9%)
e. BBB Transit Store >> 15 of 119 (12.6%)
f. Smartphone app (Token Transit app, Transit app) >> 6 of 119 (5.0%) g. Pass is provided by Employer or School >> 0 of 119
h. Pass is provided by Access or Social Service Agency >> 35 of 119 (29.4%) i. No answer provided >> 128 of 237

11. Do you usually pay your fare with a Senior, Disabled or Medicare discount? a. Yes >> 117 of 544 (21.5%)
b. No >> 427 of 544 (78.5%)
c. No answer provided >> 6 of 550

12. Which fare(s) do you normally choose now (only for S/D/M riders)? (Choose One or Two)
a. TAP Single Ride >> 18 of 63 (28.6%)
b. Day Pass >> 5 of 63 (7.9%)

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c. 13-Rides Pass >> 1 of 63 (1.6%)
d. 30-Day Pass >> 18 of 63 (28.6%)
e. EZ Pass >> 27 of 63 (42.9%)
f. Cash (S/D/M) >> 54 of 117

13. Which fare(s) do you normally choose now (only for non-S/D/M)? (Choose One or Two)
a. TAP Single Ride >> 60 of 174 (34.5%)
b. Day Pass >> 8 of 174 (4.6%)
c. 7-Day Pass >> 30 of 174 (12.2%)
d. 13-Rides Pass >> 7 of 174 (4.0%)
e. 30-Day Pass >> 31 of 174 (17.8%)
f. EZ Pass >> 19 of 174 (10.9%)
g. Youth 30-Day Pass >> 3 of 174 (1.7%)
h. BBB Annual Pass >> 1 of 174 (0.6%)
i. Blue to Business Pass >> 0 of 174
j. Access TAP Card >> 11 of 174 (6.3%)
k. TAP Interagency Transfer >> 1 of 174 (0.6%)
l. UCLA Pass >> 7 of 174 (4.0%)
m. SMC Pass >> 0 of 174
n. TAP U-Pass >> 1 of 174 (0.6%)
o. TAP E-Pass >> 2 of 174 (1.1%)
p. Cash (regular) >> 259 of 433

14. Thinking about one-way trips on the Big Blue Bus, how often do you transfer to or from Big Blue Bus from or to another bus or rail provider?
a. Never >> 272 of 550 (49.5%)
b. Rarely >> 80 of 550 (14.5%)
c. Sometimes >> 105 of 550 (19.1%)
d. Usually >> 48 of 550 (8.7%)
e. Always >> 45 of 550 (8.2%)

15. When you transfer to other transit providers (not BBB), do you use TAP Stored Value to purchase the discounted $0.50 Interagency Transfer?
a. Yes >> 61 of 278 (21.9%)
b. No >> 217 of 278 (78.1%)

16. Do you have a smartphone?
a. Yes >> 487 of 550 (88.5%)
b. No >> 63 of 550 (11.5%)

17. Does your phone have a data plan to access the internet? a. Yes >> 462 of 487 (94.9%)
b. No >> 25 of 487 (5.1%)

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18. Do you access the Internet on your phone using Wi-Fi? a. Yes >> 5 of 25 (20.0%)
b. No >> 20 of 25 (80.0%)

19. Do you have a credit card, bank debit card, or pre-paid card to make purchases? a. Yes >> 371 of 550 (67.5%)
b. No >> 179 of 550 (32.5%)

20. Are you eligible for reduced bus fares under any of the categories below? (Select All That Apply)
a. Senior >> 115 of 567 (20.3%)
b. Disabled >> 34 of 567 (6.0%)
c. Medicare recipient >> 4 of 567 (0.7%)
d. Youth (5 to 18 years of age) >> 1 of 567 (0.2%)
e. No – Not Eligible for discounts >> 413 of 567 (72.8%)

21. What is your gender?
a. Female >> 342 of 550 (62.2%)
b. Male >> 206 of 550 (37.5%)
c. Non-binary >> 2 of 550 (0.4%)

22. In which age category do you belong?
a. 16-17 years >> 4 of 550 (0.7%)
b. 18-24 >> 49 of 550 (8.9%)
c. 25-34 >> 106 of 550 (19.3%)
d. 35-44 >> 105 of 550 (19.1%)
e. 45-54 >> 117 of 550 (21.3%)
f. 55-61 >> 86 of 550 (15.6%)
g. 62 and Older >> 83 of 550 (15.1%)

23. Select the group(s) that best describe you.
(Select All That Apply)
a. Hispanic/Latino/Latinx >> 328 of 550 (59.6%)
b. White >> 108 of 550 (19.6%)
c. Black/African American >> 96 of 550 (17.4%)
d. Asian/Pacific Islander >> 28 of 550 (5.1%)
e. Native American >> 13 of 550 (2.4%)
f. Other >> 9 of 550 (1.6%)

24. How many people currently live in your home (including you)? _____________ a. 1 >> 140 of 545 (25.7%)
b. 2 >> 122 of 545 (22.4%)
c. 3 >> 109 of 545 (20.0%)
d. 4 >> 95 of 545 (17.4%)
e. 5 >> 56 of 545 (10.3%)

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f. 6 >> 15 of 545 (2.8%)
g. 7 >> 5 of 545 (0.9%)
h. 8 >> 1 of 545 (0.2%)
i. 9 >> 1 of 545 (0.2%)
j. 10 >> 1 of 545 (0.2%)

25. Thinking about all the people who earn money in your home – If their annual incomes were combined, approximately how much money is earned per year (i.e., annual household income)? a. Less than $20,000 >> 156 of 380 (41.0%)
b. $20,000 – $39,999 >> 142 of 380 (37.4%)
c. $40,000 – $59,999 >> 56 of 380 (14.7%)
d. $60,000 – $79,999 >> 20 of 380 (5.3%)
e. $80,000 – $99,999 >> 4 of 380 (1.0%)
f. More than $100,000 >> 4 of 380 (1.0%)
g. No answer provided >> 170 of 550

26. How proficient are you in English?
a. I speak little to no English >> 80 of 549 (14.6%)
b. I speak some English >> 142 of 549 (25.9%)
c. I speak English very well >> 327 of 549 (59.5%)
d. No answer provided >> 1 of 550

27. What is your home zip code? __________________
(Top five shown below)
a. 90405 – Sunset Park SM >> 48 of 545 (8.8%)
b. 90011 – Historic South-Central LA >> 32 of 545 (5.9%) c. 90401 – Downtown SM >> 28 of 545 (5.1%)
d. 90019 – Rimpau LA >> 24 of 545 (4.4%)
e. 90404 – Mid-City SM >> 23 of 545 (4.2%)
f. No answer provided >> 5 of 550

2.1 Communication & Outreach Timeline
General Ongoing Contactless Payment Promotion (BBB Customers)

1. English & Spanish Contactless Landing Page (bigbluebus.com/contactless) – 2/1 and updated 4/5

2. English & Spanish Contactless Extended Car Cards on Buses – 2/1

3. GTFS-RT Message – 2/1 and updated 4/5

4. Real-time Sign Message – 2/1 and updated 4/5

5. English & Spanish Contactless Digital Screen Ads at GoSaMo Center – 2/1 and updated 4/5

6. English & Spanish Onboard Audio Announcements for Contactless Payments – 4/11

7. English & Spanish Onboard Headsign Ads for Contactless Payments – 4/11

8. English & Spanish Social Media Posts – 2/1 and 4/5

9. LIFE Program Application Distribution English & Spanish at Transit Store – 3/29

10. English On-Hold Audio Announcements for BBB Call Center – 4/30

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Free 30-Day Pass Promotion Soft-Launch (Existing Mobile Ticket Customers)

1. English & Spanish Transit App Banner – 4/19

2. English & Spanish Transit App Landing Page – 4/19

3. Token Transit Email & Push Notification – 4/19

4. English & Spanish Senior TAP Card Applications on Buses – 4/22

5. English & Spanish Onboard Audio Announcement for Senior TAP Card Applications – 4/25 Free 30-Day Pass Promotion Hard-Launch (TAP & New Mobile Ticket Customers)

1. English & Spanish Promotion Landing Page (bigbluebus.com/quitcash) – 5/10

2. Email Blast #1 to MODE Members – 5/10

3. English & Spanish CSA Verbal Notification at Transit Store – 5/10

4. Walk-in & Appointment Only Decals at Transit Store – 5/10

5. Provide one-on-one education in English & Spanish at Transit Store – 5/10

6. Virtual Presentation to WISE Members – 5/12

7. English & Spanish Letter to MODE Members (Batch #1) – 5/12

8. English & Spanish Transit App Banner – 5/12

9. Token Transit Push Notification – 5/12

10. English & Spanish SMS to Swiftly Real-Time Subscribers – 5/12

11. Email Blast #1 to BBB Customers – 5/17

12. English & Spanish Digital Screen Ads at GoSaMo Center – 5/17

13. English & Spanish Letter to MODE Members (Batch #2) – 5/17

14. Phone Greeting for BBB & MODE Call Center – 5/17

15. English & Spanish GTFS-RT Message – 5/17

16. Real-time Sign Message – 5/17

17. English & Spanish Letter to MODE Members (Batch #3) – 5/24

18. English & Spanish Bilingual Flyer on Buses – 5/24

19. English & Spanish Extended Car Cards on Buses (Pass Promotion) – 5/24

20. English & Spanish Car Cards on Buses (LIFE) – 5/24*

21. English & Spanish Audio Announcements – 5/24

22. English & Spanish Bilingual Farebox Slot Sign – 5/24

23. English & Spanish Headsigns – 5/24

24. Press Release – 5/24

25. Community Partner/Stakeholder Notification – 5/24

26. English & Spanish Paid and Organic Social Media Posts – 5/24

27. English & Spanish Website Homepage Graphics – 5/24
Contactless Payment Ongoing Communication

1. Upgrade TAP vendor location digital map (75 new locations) – May 2021

2. Create English & Spanish print version of BBB-specific TAP vendor directory (100 locations) – June 2021

3. Partner with WISE and Healthy Aging for monthly Senior Workshops – May 2021 – ongoing

4. Partner with Santa Monica Public Library on Appy Hour Workshops – TBD

5. Develop next phase of contactless messaging in anticipation of July 5 transition – May-June 2021

6. Outreach at High-Volume Bus Stops – May-July 2021
Big Blue Bus
Title VI Fare Equity Analysis
Simplified fare structure
December 2021

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Table of Contents
Table of Contents..........................................................................................................................................1 Purpose .........................................................................................................................................................2 Executive Summary.......................................................................................................................................2 Background ...................................................................................................................................................3 Fare Structure ...............................................................................................................................................3 Fare Utilization..............................................................................................................................................4 Proposed Fare Media Changes.....................................................................................................................4 Methodology.................................................................................................................................................5 Data Sources.............................................................................................................................................5 Definitions.................................................................................................................................................6 Title VI Policies..............................................................................................................................................6 Fare Equity Disparate Impact Policy .....................................................................................................6 Fare Equity Disproportionate Burden Policy ........................................................................................7 Fare Equity Analysis......................................................................................................................................7 Disparate Impact Analysis.........................................................................................................................7 Disparate Impact Findings.....................................................................................................................7 Disparate Impact Conclusion ................................................................................................................8 Disproportionate Burden Analysis............................................................................................................9 Disproportionate Burden Findings........................................................................................................9 Disproportionate Burden Conclusion .................................................................................................10 Conclusion...................................................................................................................................................11 Appendix .....................................................................................................................................................12

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Purpose
In the summer of 2021, Big Blue Bus implemented a purely contactless fare system as part of a six-month pilot program. As a result, BBB eliminated all on-board cash fares and BBB magnetic fare cards. During this pilot period, riders have only been able to pay their fare using either the regional TAP fare payment system or mobile ticketing. Cash and magnetic fare cards are no longer accepted on-board. Six-months later, BBB is now planning to fully adopt the changes made during the contactless pilot and is also proposing new changes to simplify the existing fare structure.

The newly proposed changes are subject to a fare equity analysis as defined by BBB’s Major Service and Fare Change Policy. The fare equity analysis, contained herein, is required to ensure compliance with the Federal Transit Administration (FTA) Title VI regulations as defined by FTA Circular 4702.1B. The purpose of this analysis is to determine whether the proposed changes result in a disparate impact on the basis of race, ethnicity, or national origin, or a disproportionate burden on the defined low-income population.

This analysis found that some of the proposed changes exceed BBB’s disparate impact and disproportionate burden thresholds and, as such, require additional analysis to determine how the minority and low-income populations will be impacted by the changes. This additional analysis found that most of the proposed changes will benefit the minority and low-income populations. Only one proposed change, the elimination of the existing 13 Ride Pass, would result in a disparate impact. As a result, BBB has proposed a new 10 Ride Pass, as a replacement fare product for the existing 13 Ride pass, to mitigate the impact.

As defined by BBB policy, the changes being proposed will not result in a disparate impact on the minority population or a disproportionate burden on the low-income population.

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Background
Due to COVID-19, BBB suspended fare collection on March 20, 2020 to slow the spread of disease. This led BBB staff to reexamine strategies for shifting more passengers to contactless fare media. Contactless fare payment options have several benefits. They can reduce dwell times, improve on-time performance, and will ultimately result in faster travel timesfor passengers riding the bus. Contactless fares also operate separately from the on-board farebox and are, therefore, not susceptible to farebox malfunctions which result in lost revenue. A goal was set to pilot the elimination of on-board cash fares and the elimination of magnetic fare cards soon after the fare collection resumed on February 14, 2021. On July 12, 2021, BBB eliminated on-board cash fares and magnetic fare cards as part of a six-month pilot program.

A follow-up passenger survey was conducted in September 2021 to gauge customer reaction to the contactless pilot program, the results of which can be found in the “Appendix” section of this report. Of all surveyed riders, only 13.8% indicted that the contactless fare program affected them either “Negatively” or “Somewhat negatively”. The majority of riders, 79.1%, selected the neutral option that the program affected them “Neither negative nor Positive”. While 64.4% of riders wanted BBB to return to accepting cash fare payments, 64.2% would not use cash again, 27.4% would use cash for some trips, and 8.4% would use cash for most trips. As such, BBB does not intend to return to collecting on-board cash fares and plans to fully adopt the changes made during the contactless pilot.

With the information gained through the contactless fare pilot and corresponding passenger surveys, BBB is now planning to simplify the existing fare structure through several proposed changes. These changes seek to: 1) reduce the number of available fare options through the elimination of existing fare products, 2) adjust pricing to encourage a higher rate of adoption of BBB’s pass products.

Fare Structure
BBB fares vary based on rider classification and fare category. Rider classifications include: Regular (age 19-61), Youth (age 5-18), Senior 62+/Disabled/Medicare (shown as S/D/M), and Child (age 4 and under).

Current fare categories include: Single Trip, Day Pass, 7-Day Pass, 13 Ride Pass, 30-Day Pass, and Annual Pass. Fare prices vary based on rider classification and fare category. Customers with a valid Access ID ride for free and children ages 4 and under ride for free as well, which will expand to age 5 and under in the proposed changes.

Fare Category Regular Fare S/D/M Fare
Single Trip $1.10 $0.50
Day Pass $4.00 $1.50
7-Day Pass $14.00 -
13 Ride Pass $14.00 $6.00
30-Day Pass $50.00 $24.00
Annual Pass $500.00 -
Youth 30-Day Pass $19.00 -
Figure 1: Existing BBB Fare Pricing as of December 2021

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Fare Utilization
When fare collection resumed on February 14, 2021, cash ridership, as a percentage of total ridership, was significantly higher than it was before fare collection was suspended. Ridership on UCLA and SMC passes previously made up 23% of the total systemwide ridership. In the absence of those rider populations, at institutions closed due to the pandemic, a large number of contactless fare riders had been removed from the system, leaving behind a majority of cash riders. When BBB conducted the March 2021 Passenger Survey, 57.0% of riders indicted that they used cash to pay their fares on-board. BBB subsequently eliminated on-board cash fares as part of the contactless fare pilot program and cash riders had to migrate to one of BBB’s alternative fare payment options. The most popular fares, according to the recent September 2021 Passenger Survey, are the Single Trip fare, “Other” fares (UCLA, SMC, ACCESS), and the 30-Day Pass, in that order.

Fare Category Number of Riders Percent of All Riders
Single Trip 283 46.7%
Day Pass 33 5.5%
7-Day Pass 50 8.2%
13 Ride Pass 15 2.5%
30-Day Pass 76 12.5%
Annual Pass 0 0%
Youth 30-Day Pass 35 5.8%
Metro EZ Pass 15 2.5%
Other 99 16.3%
Total 606 100%
Figure 2: BBB Fare Utilization Comparison from September 2021 Survey Proposed Fare Media Changes
The newly proposed fare changes include: 1) the elimination of the Day Pass, 7-Day Pass, and Annual Pass, 2) the elimination and replacement of the 13 Ride Pass with a new 10 Ride Pass, 3) an decrease of $0.10 for the Single Trip (Regular) fare, 4) a decrease of $20.00 for the 30-Day Pass (Regular), 5) a decrease of $4.00 for the 30-Day Pass (S/D/M), 6) the introduction and acceptance of the Metro Day Pass, 7) the introduction of free BBB-to-BBB transfers for riders using the Single Trip fare or 10 Ride Pass.

The proposed changes are intended to simplify the existing fare structure through the elimination of underutilized fare products. The Day Pass, 7-Day Pass, and Annual Pass, which are proposed for elimination, account for 13.7% of all rides. These riders are expected to shift to the existing Single Ride fare, 30-Day Pass, or BBB’s new 10 Ride Pass. Simplifying the fare structure will reduce customer confusion and makes it easier for customers to select the fare best suited to their transportation needs. Other proposed changes include price changes for certain fares and the introduction of two new fare products.

These changes will align prices across the fare product spectrum and expand BBB’s current offerings for customers that transfer between BBB-to-BBB buses or BBB-to-Metro buses or trains.

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Fare Category
Regular Fares S/D/M Fares
On-Board
Cash Fare
TAP & Mobile
Ticket Fare
On-Board
Cash Fare
TAP & Mobile
Ticket Fare
Single Trip Eliminated
July 2021
Decrease $0.10
($1.00)
Eliminated
July 2021
No Change
($0.50)
Day Pass -
Eliminated
($4.00) -
Eliminated
($1.50)
7-Day Pass -
Eliminated
($14.00) - -
10 Ride Pass -
New
($9.00) -
New
($4.50)
13 Ride Pass -
Eliminated
($14.00) -
Eliminated
($6.00)
30-Day Pass -
Decrease $20.00
($30.00) -
Decrease $4.00
($20.00)
Annual Pass -
Eliminated
($500.00) - -
Youth 30-Day Pass -
No change
($19.00) - -
Metro Day Pass -
New
($7.00) -
New
($2.50)
Metro EZ Pass -
No change
($110.00) -
No change
($42.00)
Interagency Transfer -
No change
($0.50) -
No change
($0.25)
BBB to BBB Transfer -
New
(Free with fare) -
New
(Free with fare)
Figure 3: Proposed Changes to BBB Fare Structure (change in red / new price in parentheses) Methodology
Data Sources
The following fare equity analysis was completed using passenger survey data collected from the September 2021 Passenger Survey.

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between minority and non-minority riders, and low-income and non-low-income riders, will establish whether the proposed changes result in a disparate impact or disproportionate burden as defined by BBB’s adopted policies.

The household income limits established by the LIFE program are the same guidelines that BBB uses to determine which riders define the low-income population.

Low-Income Fare is Easy (LIFE)
Household Income Limits
Persons per
Household Annual Income
1 $39,450 or less
2 $45,050 or less
3 $50,700 or less
4 $56,300 or less
5 $60,850 or less
6 $65,350 or less
Figure 4: 2021 LIFE Household Income Limits
Title VI Policies
As required by the FTA Title VI regulations, the public was engaged in the development of BBB’s disparate impact and disproportionate burden policies. These two policies will determine if the proposed fare media changes result in a disparate impact or disproportionate burden.

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Fare Equity Disproportionate Burden Policy:
“A disproportionate burden occurs when the percent low-income population adversely impacted by a major service change is fifteen percent (15%) higher than the average low-income population of the Big Blue Bus service area, or when the percent non-low-income population beneficially impacted by a major service change is fifteen percent (15%) higher than the average non-low-income population of the Big Blue Bus service area.

If a disproportionate burden exists as a result of the proposed changes, Big Blue Bus may take steps to avoid, minimize, or mitigate the impact of the proposed change on the low-income population.” Fare Equity Analysis
The fare equity analysis will determine whether the minority and low-income populations will be unfairly impacted by the proposed changes. Changes that result in a 15% difference between the impacted minority and low-income populations and their corresponding systemwide percentages will require further analysis to determine if there is a disparate impact or disproportionate burden.

Disparate Impact Analysis
There were 592 respondents that completed the race/ethnicity question in the September 2021 survey.

Of these total responses, 74.5% of all riders were identified as minority riders.

Figure 5: Systemwide Ridership by Race
Disparate Impact Findings
• Minority riders comprise 74.5% of all systemwide riders • The elimination of the 13 Ride Pass exceeds the 15% Disparate Impact threshold • The decreased price of the 30-Day Pass (S/D/M) exceeds the 15% Disparate Impact threshold • All other proposed changes are below the 15% threshold

74.5%

25.5%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Minority Riders
Non-Minority Riders
Percent of All Riders
September 2021 Survey - Ridership by Race

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Fare Media Type
Proposed
Change
NonMinority
Riders
Minority
Riders
NonMinority
Percent
Minority
Percent
Minority
vs. NonMinority
Difference
Minority vs.

Systemwide
Difference
Day Pass Eliminate 10 23 30.3% 69.7% +39.4% -4.8%
7-Day Pass Eliminate 12 38 24.0% 76.0% +52.0% +1.5%
Annual Pass Eliminate 0 0 0% 0% 0% 0%
13 Ride Pass Replace 1 14 6.7% 93.3% +86.6% +18.8%
Single Ride
(Regular)
Decrease
of $0.10 54 188 22.3% 77.7% +55.4% +3.2%
30-Day Pass
(Regular)
Decrease
of $20.00 12 53 18.5% 81.5% +63.0% +7.0%
30-Day Pass
(S/D/M)
Decrease
of $4.00 6 5 54.4% 45.5% -8.9% -29.0%
Figure 6: Fare Utilization Comparison by Race
Disparate Impact Conclusion
Based on the 15% threshold, established in the Disparate Impact Policy, the elimination of the 13 Ride Pass would result in a disparate impact. Minority riders constitute 93.3% of all riders using the 13 Ride Pass, a difference of +18.8% compared with the systemwide minority percentage. To mitigate this impact, BBB will introduce a new 10 Ride Pass as a replacement for the 13 Ride Pass. The 10 Ride Pass will be priced at $9.00 (Regular) and $4.50 (S/D/M) and will have a price per ride of $0.90 (Regular) and $0.45 (S/D/M). This pricing is considered a beneficial change over the existing 13 Ride Pass which had a price per ride of $1.08 (Regular) and $0.46 (S/D/M). All riders using the 10 Ride Pass will pay less per ride compared with the 13 Ride Pass. The introduction of the 10 Ride Pass will benefit minority riders to a higher degree than non-minority riders and is considered an adequate measure to mitigate the disparate impact finding.

The only other proposed change that exceeds the 15% threshold is the decreased price for the 30-Day Pass (S/D/M). Minority riders constitute 45.5% of all riders using the 30-Day Pass (S/D/M), a difference of -29.0% compared with the systemwide minority percentage. Since this proposed change results in a price decrease, it is considered a beneficial change that benefits non-minority riders to a higher degree than minority riders. However, the 30-Day Pass (S/D/M) accounts for only 1.8% of total BBB rides and, given that both non-minority and minority riders will benefit from the price decrease, the proposed change is not considered a disparate impact on the minority population.

The introduction and acceptance of the Metro Day Pass on BBB buses is considered a new fare product.

The Metro Day Pass is priced at $7.00 (Regular) and $2.50 (S/D/M). While BBB is planning to eliminate the BBB Day Pass, the Metro Day Pass is not considered a direct replacement for that fare product. Instead, the Metro Day Pass is targeted to infrequent riders, such as tourists, who might purchase this pass from one of Metro’s ticket vending machines. Acceptance of the Metro Day Pass will prevent BBB from turning away these potential riders that may not have access to BBB’s fare products. Since this is a new fare product, its introduction will not result in a disparate impact on the minority population.

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The introduction of free BBB-to-BBB transfers with paid fare is also a new fare product. Current riders must pay the full Single Trip fare when transferring from one BBB bus to a second BBB bus. Customers using any of BBB’s current pass products (Day Pass, 7-Day Pass, 30-Day Pass, Annual Pass) do not pay an additional fee to transfer buses since the pass products provide unlimited riding within their allotted time period. Enabling free BBB-to-BBB transfers will benefit Single Trip and 10 Ride Pass riders that transfer between two BBB routes on a one-way journey as those riders will no longer pay an additional fare to ride a second BBB bus. Minority riders make up 77.7% of all Single Trip (Regular) riders and 72.7% of all Single Trip (S/D/M) riders, which is +5.0% higher and -1.8% lower, respectively, than the systemwide minority percentage of 74.5%. Of the 264 riders that selected the Single Trip fare, 118 indicated that they transfer from one BBB bus to another BBB bus “Sometimes”, “Usually”, or “Always”. Of these 118 riders, 96 are minority riders or 81.4%, which is +6.9% higher than the systemwide minority percentage. As such, the introduction of free BBB-to-BBB transfers will benefit minority riders to a higher degree than non-minority riders and will not result in a disparate impact on the minority population.

All other proposed changes are below the 15% threshold and will not result in a disparate impact.

Disproportionate Burden Analysis
There were 385 respondents that completed the household income and household size questions in the September 2021 survey. Of these total responses, 86.5% of all riders were identified as low-income riders (riders whose reported household income met the established thresholds of the LIFE program).

Figure 7: Systemwide Ridership by Income
Disproportionate Burden Findings
• Low-income riders comprise 86.5% of systemwide riders • The decreased price of the 30-Day Pass (Regular) exceeds the 15% Disproportionate Burden threshold
• All other proposed changes are below the 15% threshold

86.5%

13.5%
0% 20% 40% 60% 80% 100%
Low-Income Riders
Non-Low-Income Riders
Percent of All Riders
Septmeber 2021 Survey - Ridership by Income

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Fare Media Type
Proposed
Change
NonLowIncome
Riders
LowIncome
Riders
Non-LowIncome
Percent
LowIncome
Percent
Low
Income vs.

Non-LowIncome
Difference
Low-Income
vs.

Systemwide
Difference
Day Pass Eliminate 4 16 20.0% 80.0% +60.0% -6.5%
7-Day Pass Eliminate 5 35 12.5% 87.5% +75.0% +1.0%
Annual Pass Eliminate 0 0 0% 0% 0% 0%
13 Ride Pass Replace 1 9 10.0% 90.0% +80.0% +3.5%
Single Ride
(Regular)
Decrease
of $0.10 17 144 10.6% 89.4% +78.8% +2.9%
30-Day Pass
(Regular)
Decrease
of $20.00 12 30 28.6% 71.4% +42.8% -15.1%
30-Day Pass
(S/D/M)
Decrease
of $4.00 0 7 0% 100% +100% +13.5%
Figure 8: Fare Utilization Comparison by Income
Disproportionate Burden Conclusion
The only proposed change that exceeds the 15% threshold is the decreased price for the 30-Day Pass (Regular). Low-income riders constitute 71.4% of all riders using the 30-Day Pass (Regular), a difference of -15.1% compared with the systemwide low-income percentage. Since this proposed change results in a price decrease, it is considered a beneficial change that will benefit non-low-income riders to a higher degree than low-income riders. Given that both non-low-income and low-income riders will benefit from the price decrease, the proposed change is not considered a disproportionate burden on the low-income population.

As stated in the Disparate Impact analysis, the introduction and acceptance of the Metro Day Pass on BBB buses is considered a new fare product. The Metro Day Pass is priced at $7.00 (Regular) and $2.50 (S/D/M).

While BBB is planning to eliminate the BBB Day Pass, the Metro Day Pass is not considered a direct replacement for that fare product. Instead, the Metro Day Pass is targeted to infrequent riders, such as tourists, who might purchase this pass from one of Metro’s ticket vending machines. Acceptance of the Metro Day Pass will prevent BBB from turning away these potential riders that may not have access to BBB’s fare products. Since this is a new fare product, its introduction will not result in a disproportionate burden on the low-income population.

As also stated in the Disparate Impact analysis, the introduction of free BBB-to-BBB transfers with paid fare is also a new fare product. Current riders must pay the full Single Trip fare when transferring from one BBB bus to another. Customers using any of BBB’s current pass products (Day Pass, 7-Day Pass, 30- Day Pass, Annual Pass) do not pay an additional fee to transfer buses since the pass products provide unlimited riding within their allotted time period. Enabling free BBB-to-BBB transfers will benefit Single Trip and 10 Ride Pass riders that transfer between two BBB routes on a one-way journey. Low-income riders make up 89.4% of all Single Trip (Regular) and 100% of all Single Trip (S/D/M) riders, which is +2.9% higher and +10.6% higher, respectively, than the systemwide low-income percentage of 86.5%.

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Of the 179 riders that answered the income question and selected the Single Trip fare, 89 indicated that they transfer from one BBB bus to another BBB bus “Sometimes”, “Usually”, or “Always”. Of these 89 riders, 82 are low-income riders or 92.1%, which is +5.6% higher than the systemwide low-income percentage. As such, the introduction of free BBB-to-BBB transfers will benefit low-income riders to a higher degree than non-low-income riders and will not result in a disproportionate burden on the lowincome population.

All other proposed changes are below the 15% threshold and will not result in a disproportionate burden.

Conclusion
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in any program or activity that receives Federal funds or other Federal financial assistance. In compliance with this law, Big Blue Bus has conducted a Title VI analysis on the proposed fare changes. This analysis has found that the proposed changes will not result in a disparate impact on the minority population or a disproportionate burden on the low-income population.

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Appendix

1.1 Big Blue Bus – September 2021 Passenger Survey Results

1. Are you at least 14 years old?
a. Yes >> 592 of 592 (100%)
b. No >> 0 of 592

2. How many days a week do you ride on BBB buses?
a. Occasionally (less than 1 day per week) >> 50 of 592 (8.5%) b. 1 to 3 days >> 211 of 592 (35.6%)
c. 4 or 5 days >> 289 of 592 (48.8%)
d. 6 or more days >> 42 of 592 (7.1%)

3. BBB route you ride on a weekly basis
(Select all that apply)
a. 1 Santa Monica Blvd. >> 164 of 1,060 (15.5%)
b. 2 Wilshire Blvd. >> 70 of 1,060 (6.6%)
c. 3 Lincoln Blvd. >> 143 of 1,060 (13.5%)
d. Rapid 3 Lincoln Blvd. >> 47 of 1,060 (4.4%)
e. 5 Olympic Blvd. >> 9 of 1,060 (0.8%)
f. 7 Pico Blvd. >> 175 of 1,060 (16.5%)
g. Rapid 7 Pico Blvd. >> 76 of 1,060 (7.2%)
h. Express 7 Pico Blvd. >> 23 of 1,060 (2.2%)
i. 8 Ocean Park >> 24 of 1,060 (2.3%)
j. 9 Palisades >> 136 of 1,060 (12.8%)
k. Rapid 10 Downtown Express >> 5 of 1,060 (0.5%)
l. Rapid 12 Westwood Blvd. >> 37 of 1,060 (3.5%)
m. 14 Bundy Dr. – Centinela Ave. >> 32 of 1,060 (3.0%)
n. 15 Barrington Ave. >> 4 of 1,060 (0.4%)
o. 16 Marina del Rey >> 8 of 1,060 (0.8%)
p. 17 UCLA – VA >> 21 of 1,060 (2.0%)
q. 18 Abbott Kinney >> 59 of 1,060 (5.6%)
r. 41 17th St. >> 17 of 1,060 (1.6%)
s. 43 26th St. >> 10 of 1,060 (0.9%)
t. 44 SMC Bundy Campus >> 0 of 1,060
--FARE PURCHASE AND PAYMENT METHODS--

4. Before BBB stopped accepting cash and tokens (July 12th, 2021), how did you normally pay for your BBB fare?
(Rank top two)
a. Paid cash on the bus >> 178 of 670 (26.6%)
b. TAP card (Regular, Reduced Fare, ACCESS, UCLA or SMC TAP cards) >> 388 of 670 (57.9%)
c. TAP App on a mobile device (smartphone or Apple Watch) >> 62 of 670 (9.3%) d. Smartphone App (Transit app, Token Transit app) >> 31 of 670 (4.6%) e. Paper pass Bought on the bus >> 2 of 670 (0.3%)
f. Paper Pass Bought at the BBB Transit Store >> 9 of 670 (1.3%)

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g. BBB employee/retiree/dependent pass >> 0 of 670

5. Now, how do you usually pay for your BBB fare?
a. TAP card (Regular, Reduced Fare, ACCESS, UCLA or SMC TAP cards) >> 432 of 592 (73.0%)
b. TAP app on a mobile device (smartphone or Apple Watch) >> 114 of 592 (19.3%) c. Smartphone app (Transit app, Token Transit app) >> 43 of 592 (7.3%) d. I usually don’t pay >> 3 of 592 (0.5%)

6. Why don’t you usually pay the fare on BBB?
(Select all that apply)
a. I don’t have a TAP card >> 1 of 3
b. I don’t have a smartphone >> 0 of 3
c. I don’t have a credit card >> 0 of 3
d. Because I can ride without paying >> 1 of 3
e. Other >> 1 of 3

7. Where do you typically obtain your BBB fare products? (Select all that apply)
a. TAP - Ticket Vending Machine >> 259 of 761 (34.0%)
b. TAP - Website or call center >> 48 of 761 (6.3%)
c. TAP - Retail location (Ralph’s, 7-11, CVS, Walgreens, Check Cashing, etc.) >> 100 of 761 (13.1%)
d. BBB Transit Store >> 81 of 761 (10.6%)
e. Smartphone app (Token Transit app, Transit app) >> 43 of 761 (5.7%) f. TAP app on a mobile device (smartphone or Apple Watch) >> 168 of 761 (22.1%) g. My pass is provided by my employer or school >> 34 of 761 (4.5%) h. My pass is provided by Access or another social service agency >> 28 of 761 (3.7%)

8. Which BBB fare(s) do you normally choose now?
(Select one or two)
a. TAP (stored value) single ride >> 264 of 606 (43.6%) b. TAP UCLA BruinGo! quarterly pass >> 4 of 606 (0.7%)
c. TAP UCLA Co-pay Pass >> 14 of 606 (2.3%)
d. TAP E-Pass >> 8 of 606 (1.3%)
e. TAP U-Pass >> 11 of 606 (1.8%)
f. TAP Interagency Transfer >> 3 of 606 (0.5%)
g. Access TAP Card >> 48 of 606 (7.9%)
h. Single ride on mobile phone >> 19 of 606 (3.1%)
i. 1 Day Pass >> 33 of 606 (5.4%)
j. 7-Day Pass >> 50 of 606 (8.3%)
k. 30-Day Pass >> 76 of 606 (12.5%)
l. 13 Rides Pass >> 15 of 606 (2.5%)
m. Youth 30-Day Pass >> 35 of 606 (5.8%)
n. BBB Annual Pass >> 0 of 606
o. EZ Pass >> 15 of 606 (2.5%)
p. Employer-provided pass >> 2 of 606 (0.3%)
q. Santa Monica College pass >> 9 of 606 (1.5%)

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--TRANSFER TRIPS WITHIN BBB AND TO/FROM BBB—

9. Thinking about 1-way trips on the Big Blue Bus, how often do you transfer from Big Blue Bus to another Big Blue Bus (Blue to Blue)?
a. Never >> 223 of 592 (37.7%)
b. Rarely >> 92 of 592 (15.5%)
c. Sometimes >> 143 of 592 (24.2%)
d. Usually >> 86 of 592 (14.5%)
e. Always >> 48 of 592 (8.1%)

10. Thinking about 1-way trips on the Big Blue Bus, how often do you transfer to or from Big Blue Bus to another bus or rail systems (Blue to/from Orange LA Metro Bus, Green Culver CityBus, etc.)]
a. Never >> 201 of 592 (34.0%)
b. Rarely >> 98 of 592 (16.6%)
c. Sometimes >> 133 of 592 (22.5%)
d. Usually >> 104 of 592 (17.6%)
e. Always >> 56 of 592 (9.5%)

11. When you transfer to other transit providers (not BBB), do you use TAP Stored Value to purchase the discounted $0.50 Regular or $0.25 Senior/Disabled Interagency Transfer?
a. Yes >> 307 of 592 (51.9%)
b. No >> 84 of 592 (14.2%)
c. Don’t transfer >> 201 of 592 (34.0%)

12. What is the main reason you don’t use TAP Stored Value to pay for your transfer? a. Not aware of the transfer discount >> 29 of 84 (34.5%) b. I pay with a pass or passes on BBB and other transit agencies >> 44 of 84 (52.4%) c. Because Metro isn’t charging a fare currently >> 9 of 84 (10.7%) d. Because I don’t use TAP to pay my fare >> 2 of 84 (2.4%)

13. Are you aware that single rides cost less when using TAP or a mobile ticket than they did when using cash?
a. Yes >> 459 of 592 (77.5%)
b. No >> 133 of 592 (22.5%)
--CONTACTLESS FARE PERCEPTIONS--

14. How has the contactless fare program (no cash use on board) affected you? a. Negatively >> 28 of 592 (4.7%)
b. Somewhat negatively >> 54 of 592 (9.1%)
c. Neither negative nor Positive >> 468 of 592 (79.1%)
d. Somewhat positively >> 23 of 592 (3.9%)
e. Positively >> 19 of 592 (3.2%)

15. Please describe any positive or negative impacts you have experienced as a result of the contactless fare program?

Page 15 ends

16. The goal of contactless payments on buses is to move buses faster, make fare payment more sanitary, and reduce the fare price for each ride. Understanding these goals, should BBB return to accepting cash fare payments?
a. Yes >> 381 of 592 (64.4%)
b. No >> 142 of 592 (24.0%)
c. I don’t know >> 69 of 592 (11.6%)

17. If BBB goes back to accepting cash, will you start using cash again? a. Yes, for most trips >> 50 of 592 (8.4%)
b. Yes, for some trips >> 162 of 592 (27.4%)
c. No >> 380 of 592 (64.2%)

18. What can BBB do to improve the contactless fare program? --SMARTPHONE AND CREDIT ACCESS--

19. Do you have a smartphone?
a. Yes >> 512 of 592 (86.5%)
b. No >> 80 of 592 (13.5%)

20. Does your phone have a data plan?
a. Yes >> 498 of 592 (84.1%)
b. No >> 14 of 592 (2.4%)
c. No smartphone >> 80 of 592 (13.5%)

21. If your phone does not have a data plan, do you access the Internet on your phone using Wi-Fi? a. Yes >> 10 of 14 (71.4%)
b. No >> 4 of 14 (28.6%)

22. Do you have a credit, debit, or pre-paid card to make purchases? a. Yes >> 530 of 592 (89.5%)
b. No >> 62 of 592 (10.5%)

23. Would you be interested in using mobile ticketing (smartphone app) if you could load value to your phone at the BBB Transit Store using cash?
a. Yes >> 363 of 592 (61.3%)
b. No >> 135 of 592 (22.8%)
c. No answer >> 94 of 592 (15.9%)
--REDUCED FARE OPTIONS--

24. Are you aware that there are reduced fares available for seniors (62+), people with Disabilities, Medicare recipients, and/or youth?
a. Yes >> 519 of 592 (87.7%)
b. No >> 73 of 592 (12.3%)

25. Which of the reduced fares are you receiving, if any? (Select all that apply)
a. Senior (62+) >> 66 of 550 (12.0%)

Page 16 ends

b. Disabled/Medicare recipient >> 37 of 550 (6.7%)
c. Youth (5-18 years of age) >> 40 of 550 (7.3%)
d. Low-Income (LIFE) >> 8 of 550 (1.5%)
e. Not Receiving a discount >> 384 of 550 (69.8%)
f. I don’t know >> 15 of 550 (2.7%)

26. What reduced fares might you qualify for?
(Select all that apply)
a. Senior (62+) >> 6 of 457 (1.3%)
b. Disabled/Medicare recipient >> 2 of 457 (0.4%)
c. Youth (5-18 years of age) >> 4 of 457 (0.9%)
d. Low-Income (LIFE) >> 0 of 457
e. None of the above >> 423 of 457 (92.6%)
f. I don’t know >> 22 of 457 (4.8%)

27. Before BBB stopped accepting cash and tokens, did you receive the senior or disabled/Medicare reduced fare by paying $0.50 with cash? a. Yes >> 95 of 109 (87.2%)
b. No >> 14 of 109 (12.8%)
--LIFE PROGRAM--

28. Are you aware of the free or reduced fare available for low-income riders through the LIFE program?
a. Yes >> 110 of 592 (18.6%)
b. No >> 481 of 592 (81.3%)
c. No answer >> 1 of 592 (0.2%)

29. Are you currently receiving the LIFE program reduced fare? a. Yes >> 29 of 592 (4.9%)
b. No >> 77 of 592 (13.0%)
c. I don’t know >> 4 of 592 (0.7%)
d. No answer >> 482 of 592 (81.4%)

30. Are you eligible for reduced fares based on household income? a. Yes >> 121 of 592 (20.4%)
b. No >> 440 of 592 (74.3%)
c. I don’t know >> 30 of 592 (5.1%)
d. No answer >> 1 of 592 (0.2%)
--DEMOGRAPHICS--

31. What is your gender?
a. Male >> 230 of 592 (38.9%)
b. Female >> 360 of 592 (60.8%)
c. Non-binary >> 2 of 592 (0.3%)

32. In which age category do you belong?
a. 14-17 >> 44 of 592 (7.4%)

Page 17 ends

b. 18 to 24 >> 87 of 592 (14.7%)
c. 25-34 >> 106 of 592 (17.9%)
d. 35-44 >> 121 of 592 (20.4%)
e. 45-54 >> 117 of 592 (19.8%)
f. 55-61 >> 38 of 592 (6.4%)
g. 62 and Older >> 79 of 592 (13.3%)

33. Select the group(s) that best describe you
(Select all that apply)
a. Hispanic/Latino/Latinx >> 284 of 604 (47.0%)
b. White >> 148 of 604 (24.5%)
c. Black/African-American >> 103 of 604 (17.1%)
d. Asian/Pacific Islander >> 58 of 604 (9.6%)
e. Native American >> 0 of 604
f. Other >> 11 of 604 (1.8%)

34. How many people currently reside in your household?

35. What is your annual household income?
a. Less than $25,000 >> 98 of 592 (16.6%)
b. $25,000 – $34,999 >> 129 of 592 (21.8%)
c. $35,000 – $49,999 >> 112 of 592 (18.9%)
d. $50,000 – $74,999 >> 36 of 592 (6.1%)
e. $75,000 – $99,999 >> 8 of 592 (1.4%)
f. More than $100,000 >> 2 of 592 (0.3%)
g. Decline >> 207 of 592 (35.0%)

36. How proficient are you in English?
a. I speak little to no English >> 20 of 592 (3.4%)
b. I speak some English >> 153 of 592 (25.8%)
c. I speak English very well >> 419 of 592 (70.8%)

37. What is your home zip code?

Santa Monica City CouncilOctober 25, 2022

Santa Monica City Council
October 25, 2022