will build support for the tough decisions that we need to make. the reason i am concerned about this morning anything else we don't get enough money to run the transportation system from the federal government, the state government and from within the city and county. the only thing that we have to control the resources is how to use the streets and the longer we wait and the longer it takes to do projects like this the more we just throw away money we could be saving biincreased efficiencies and we don't need to do that and disband 29 or go through stop reductions. these are i think things we are forced to do because we don't have the resources and this will increase the operations and help us deliver the service that every san franciscan deserves. thank you for your good work. >>i appreciate it.

>>i will echo what director ramos said. we talk about this a lot and we as a city and county and as a transit agency have control over the streets and we need to take advantage of that to make the system run better and this say fabulous step in the right direction and we are looking forward to this project moving forward. it's going to be fabulous. >> thank you. >> moving on to the next item, item 12 and changing the definition and disparate impact policies. directors no members of the public have identified -- >> have members of the board had a chance to look at this and presentation. are you interested to have a presentation for everybody? >> i have one question but other than that i don't think we need -- >> director reiskin -- >> i think it's fairly significant. we covered this at the policy and governance committee but i think it's

worth the time to maybe quickly hit the highlights and a little bit speak to the process that got us to this point. >> okay. very good. >> good afternoon. >> hi everyone. i am julie kirb balm and the operations planning operations manager. on our title six program i work closely with kathleen who is in the regulatory affairs group and oversees the title six program. i can go through the material briefly, but what i am bringing to you is a set of policies around how we evaluate service and fare changes, in particular our proposed service definition and our disparate impacts and disproportionate burden policies. for those of you not familiar title six is a civil rights act of 1964 addressing

discrimination and most aspects of life in the u.s. and specifically states that no person in the united states shall on the groupeds of race, color or national origin excluded from participating in, denied the of benefits of or subject to discrimination of any activity receiving federal funds. and as an agency that receives federal funds from fta they monitor our transit providers for compliance and in particular they issued a new circular with guidelines and part of why we're here is to meet the requirements in that new guidelines. a strong title six program ensures that public services including transportation are provided in a non discriminatory manner and

provides opportunity for public decision making without regard to race, or national origin and color and provides access to service for lgbt population. it's critical and noncompliance can cause federal funding to be conditioned or with held. fta has recognized the mta's title six program as a strong program. they will send peer agencies to us for example to discuss and review some of these issues. the specific things we're here today to talk about is the major service change definition and determines when analysis for service change is needed and our disparate impact and disproportionate policies which [inaudible] proposed major service changes or fare changes would adversely affect majority and low income populations and

what alternatives need to be considered or impacts mitigated. i want to point out this is one small aspect of the overall title six program which we update every three years. we will be bringing that update to you this fall and it includes a number of topics, one of which is how our service is performing against our service standards, so one of the things that we will look at for example is crowding. are we seeing minority routes more crowded than non majority routes? if so how are we addressing that? so these are specifically today talking about fare and service changes, but we evaluate our service through an equity lens in a number of different ways.

in preparing for this work we spent a tremendous amount of time at the staff level really trying to digest this technical and complex project and i was particularly in support in addition to kathleen and helen quam and paul and at the staff level dove into all aspects of this material. we provided draft and comments on the circular itself and participated in title six webinars as well as regional workshops to try to understand how our peer properties are addressing this issue. every large agency in the country is bringing these policies to their board for adoption. we also arrange for interviews and we learned a lot from chicago and los angeles and examples of majority /minority cities so that was helpful and we conducted a multilingual

outreach process and shaped and formed our proposals and to the citizens' advisory council twice and muni advisory council. we connected two public workshops as well as made -- took comments via both email and 311. we also reached out directly to about 30 community based organizations and transportation advocacy groups who focus on equity issues to let them know this work was under way. it's a fairly -- as i said a fairly abstract topic so we felt those conversations were really important to engage key stakeholders in the process. as i alluded to san francisco is a minor /majority city with 58%

of residents being minority according to the census. for low income population we have flexibility how we define low income. our recommendation to the board is we use 200% of the federal poverty level which is also consistent with how we define qualifications for our life line pass. that ends up being 31% of san francisco households meet that definition. we average between two and three people per household which is by that definition 31 to $38,000 so that just gives you a scale of the income we're talking about. for the analysis to date we have focused on using census data looking at the demographics of the routes that the neighborhoods they travel through and complemented with

an on board survey and give information about who is using our service and one of the things we will be doing once that work is completed and doing the data collection and now doing data entry is see how closely the demographics of the ridership matches the demographics of the neighborhoods that the routes go through. i am really supportive of the cac's recommendation at the staff level we review the thresholds when we have this survey data available and we will certainly follow up on that. this is a map here that shows all of the census tracks that have a higher percentage minority than 58%. as you can see in the map it's primary clustered in the southern part of the city as well as the sunset portions of the richmond and mission, treasure island and as well as areas in the western edition and north of market.

the second map shows census tracks that are low income which means they have more households than the 31% city wide average. again we see the southeast corridor emerge as well as the outer sunset, the mission and portions of north and south of market in addition to treasure island. the way that we use the census data is by looking at the -- for every census block group we determine what percentage of the population is majority as a percent of the total population. then this is the route here. we look at every stop and we draw a quarter mile radius around our surface stops and half mile radius around the subway stops. then we look at every census block group that intersects

that radius, whether wholly or partially included in it. we add up all of the demographics of those particular block groups and that gives us the demographics of the route. in san francisco our routes -- particularly the cross town routes tend to be very long, so unlike some cities where their routes are very segregated or they will have very minority or non minority routes our routes tend to be more evenly balanced because of the diversity of neighborhoods that they travel through. in terms of service and fare changes any fare change that is in place for more than six months requires an equity analysis and that is regardless of the dollar amount we're considering for the change. for a service change though there

is acknowledgment by fta they don't want this high level of scrutiny get in the way of service and schedule changes part of the regular business so they allow us to design what is a major service change so once we determine that then also requires that we evaluate the impacts in minority and low income communities. through that analysis we are trying to determine if there is a disparate impact on these communities? if we determine there isn't then the analysis is complete. if there is the circular gives clear guidance on the next steps which include evaluating alternatives, mitigations, or explaining the rational depending on the type of impact or burden we

identify. this is primarily focused on route changes so for example if we are changing a route or eliminating a segment of a route. frequency changes which is modifying how often the bus arrives to pick up customers and span of changes and has to do with the hours of operation on i route. our proposed definition of a major service change is a change in transit service that is in effect for more than 12 months period and any of the criteria is met. a schedule change or series of changes resulting in this amount or more or rolling or 24 month period. schedule change in the route with 25 trips or more a day and add or eliminate a route. change in revenue hours on route of 25% or more. a change in daily span of service of three hours or more and 25% or more where the route moves more than a quarter of a

mile. corridors served by multiple routes will looked at this with route miles. what i mean by that is for example if we are -- we did this in 2009. we restructured the 10 and the 12 and there was a segment in pacific hites that used to be served by the 12 in peak periods between -- on pacific between fillmore and van ness. that service was completely replaced by the 10 and we didn't think it was a service change because there was no disruption of service to the customers even though had a new name and capital projects are part of the service definition regardless whether the proposed change meets the criteria above. in developing this definition we were trying to find a delicate

balance between ongoing system maintenance and addressing important equity issues. we consider the needs of minority and low income populations when we make any change, and this is really identifying the point at which we go through the much more formal process and circular work. the challenge is if you make the definition too narrow you really risk locking in the existing service and not able to make incremental changes but at the same time you want to make sure you're capturing important equity issues. we did make several changes to this definition based on the public process. one of the key things was that we added this rolling 24 month period to the system changes. what the concern was in the public process was that we would make a 2% change one year and then a 1% change six

months later and a 3% change six months after that, and that we would be stringing together these smaller changes and not ever reach this larger threshold. that certainly would never be the intent of me or my staff but we felt it was important in the policy to call out that concern, so what this would mean is if we were considering a 3% change and a 2% change already put in place within the last 24 months we would evaluate the full 5% proposal and not just the 3% proposal. we also had originally had the span of service before hours, and one of the things we heard in the public process was four hours seemed too high so we reduced it to three hours. we didn't reduce it as far as the cac recommended and one hour and we

received comments to do two hours and again we felt it was very close to what we consider more of a minor service change. we also received questions on why this policy does not specifically call out stock consolidation? and there again our stock removal policy is guided by our service standards where we look at stop spacing based not only space between stops but transfer points and grades, so when we make proposals to remove stops they're within that standard which we felt was not considered a major service change, but that doesn't mean it's not an important policy issue and one of the things we tried to explain throughout the outreach process is that this was not our only avenue for looking at different service changes, and

that it's important that we particularly consider the needs of our vulnerable users when we're making service decisions. the other two things that we have before you today are our disparate impact policy and our disproportionate burden policy. disparate impact policy determines when the adverse effect of a service change are borne disparately by minority populations and our policy rear view mirrors that the changes or major packet of. >> >> changes and have disparate impact on minority populations if a percentage impacted by the change and system wide is 8% or more and i can walk you through some of the examples and i know that's a heavy policy. we recommend the same policy of 8%

threshold for low income populations and here is an example of how it works. here are fictitious changes here. and system wide 58% minority and if we were looking at changes for the frequency routes and only went through neighborhoods 40% minority that would be considered a disparate impact even though we're not reducing service. we're adding service and in a way minority populations benefit more than non minority populations. a second example is shown that we are reducing frequency and heavily minority more so the 58% minority city wide and again that is considered a disparate impact. i think that the nuance of the threshold is shown in the third example. in the third

example we're eliminating a set of routes and those routes run through neighborhoods that are 63% minority and while that is more than our city wide average of 58% because it's below that threshold of 8% it would not be considered a disparate impact. my second example here talks about the cumulative nature of these changes. you may have noticed we talked both individual change and a set of changes in the disparate impact definition. in this example if we were only making changes to route a which is 70% minority it would be considered a disparate impact, but because we're balancing those changes with similar changes to route b we look at those cumulatively, and because those routes collectively go through neighborhoods are 62% minority and within the policy threshold that is not considered a

disparate impact. sorry to make you guys do a lot of math, but this is kind of the nature of these thresholds as we're trying to find really the point at which there's a significant difference between the routes we're changing and city average. the last example is here and this is fictitious data we will have real data as soon as the survey is analyzed but in this example if we make changes to the cash fare and used by this amount of people and 160,000 are minority and because of the percent and the 8% threshold this isn't considered a disparate impact. alternatively if we were making changes to

the youth pass and in this example it's used by 75% minority that is considered a disparate impact but if we're making changes to the two at the same time we would look at them collectively and collectively they would be found to have a disparate impact because the percent minority using the two pass types are more than our city wide average plus the threshold. the threshold -- developing the thresholds as i said they need to be sensitive enough to distinguish between differences and disparate impact on minority and non minority populations. we essentially set the threshold at 15% and brought them down to 8% based on analysis of all of the spectrum of minority and

low income populations on each of our routes. we also compared ourselves to peers as a second check to make sure we were on the lower end of the spectrum in terms of these thresholds. the comments from the public process are summarized in your calendar item but there was really a range. there were people that attended to talk about specific route and service -- route and fare concerns, and we listened and tried to communicate those in the calendar item. there were also comments that we received as i said about the system wide over time issue as well as span. there was also the recommendation made that we reevaluate that the thresholds every three years as part of the title six program update which we agree is sound practice. the thresholds are intended to apply for the entire three year period because fta doesn't want you to

be changing the rules of the game in the middle of your program update but as we get familiar with the thresholds we do equity and analysis we will learn over time so we think that's a sound recommendation. we also -- an issue came up at both the public process as well as in the written comments asking if we could extend these programs to seniors or people with disabilities? and at the staff level we really understand these concerns and think it's really important that all of our service and fare policies are sensitive to the needs of seniors and needs of people with disabilities. title six however is not the right policy tool for that. it's very specific and narrowly focused and i think it's important that we sort of acknowledge the limitations of it as a tool to understand these issues. in terms of next steps if you approve these policies

today all future fare and service equity analysis will use these definitions including any dialogue we have around service increases or decreases or fare increases or decreases as part of the upcoming budget dialogue they anticipate will start this fall. the title six program update as i said is happening this fall as well and we will be bringing that to you in november or late october for your approval. we're also really excited as i said to get the demographic data to really find out if the demographics of the neighborhood is indicative or reflective of the dem graph ikts of the routes. in some cities it is and some cities it isn't. for example los angeles is 70% minority but the ridership is 85% minority so you can certain

see variations and i expect that we will see some variation here. i'm happy to answer any questions. >> thank you very much. anyone from the public wish to speak to us? >> one person turned in a speaker card. herbert wiener. >> let's hear from mr. wiener. >> herbert wiener impaled stakeholders and also senior citizen. one question i have about this i really feel that seniors and handicapped and severely ill should be considered part of minority because basically they're a significant part of the population, and they can also be adversely impacted. now, if you adopt this this would possibly be a legal basis and criteria for provekz of services to minorities and i feel that seniors and the disabled should be considered part of that, and

if you don't decide to innercorporate seniors and the disabled maybe the government does and this could be a point of legal contest. the second thing is in respect to minorities throughout the richmond district there are asian speaking people. they are not -- many don't speak english and they have been severely impacted by the transit effectiveness projected and one stopped at park presidio and my understanding you're going to curtail the service further and like the ft. sutter run and the trolleys are still there and basically a violation of civil rights with the transit effectiveness project. it really is wrong headed. it's based on supply and demand. it's not based on moral principles and sufficient rights and that is fundamentally wrong

and i think. >> >> will be contested in the future, if not by me by someone else and it will come down hard on you and you will pay the consequences. >> thank you very much. anyone else care to speak? there is another slip over there. is that the same one, same item? oh okay. thank you. we have heard from the public. members of the board. good presentation. >> yeah good presentation. thank you very much. i did have one question. i know we do the a letter from the bcdc asking that question about seniors and i understand in your presentation you said this is actually not the appropriate tool to address the question of seniors and people with disabilities and i'm sorry did you say which one is the correct tool and i missed it? or is that something we approach on a granduear level. >> exactly. through our

service standards so for stops for example and one of the things the standards speaks to is go to a shorter stop spacing with grades or considering the adjacent land uses. it's part of the information that staff will prepare for you as you make decisions about service changes and it's also built into the outreach process, so for example we are looking to do a pilot of service improvements on fulton as part of the transit effectiveness project and one of the things we're doing is working closely with the senior center that's on fulton and 38th to make sure that our stop proposals work for their needs so we try to address a number of levels, both through your lens as you make policy decisions,

but also through outreach and technical length as well. >> thank you. that's the only question i had. >> can i ask given the concerns that has been raised i see this as an exercise in community engagement and awareness building. you know one of the other things that was articulated in the letter from the bcdc they see stop consolidation as a way to speed up service or i can't remember -- reduce run times and i don't know that's necessarily the intent of the stop consolidation. from what i understand the intent is really make the system more efficient and to conserve resources so we can protect service that is threatened because of the current cost of operations, and i'm concerned that there's a