Attachment B_October 2024 Title VI Service Change Analysis.pdf

Title VI Service Equity Analysis 
City of Phoenix 
Proposed October 2024 Service Change 
 
 
 
 
 
 
 
 
 
 
 
City of Phoenix Public Transit Department

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
Page 2 of 9 
 
INTRODUCTION 
Title VI of the Civil Rights Acts of 1964 prohibits discrimination on the basis of race, 
color, or national origin in programs and activities receiving federal financial assistance. 
Federal law requires the City of Phoenix to evaluate service changes and proposed 
improvements at the planning and programming stages to determine whether those 
changes have a discriminatory impact. This process will be used to evaluate bus 
services in an objective manner to identify the potential for adverse, disproportionately 
high, or disparate impacts to minority and/or low-income populations. 
The Phoenix Public Transit Department (PTD) manages modification to the region’s 
transit network through service changes. Bus service changes are coordinated 
regionally and occur in April and October each year. Service modifications that are 
considered major service changes require service equity analysis to be conducted and 
considered by the Phoenix City Council before approval.  
SERVICE EQUITY ANALYSIS POLICIES 
This section describes Phoenix’s Title VI Service Equity analysis policy, definition, and 
data analysis procedures. The City of Phoenix Public Transit Title VI Program is posted 
at https://www.phoenix.gov/publictransit/title-vi-notice 
Major Service Change 
The Major Service Change and Service Equity Policy developed jointly by both the City 
of Phoenix and Valley Metro defines a major service change as follows: 
• Adding or eliminating an entire route 
• Expanding or reducing existing revenue miles on a route by more than 25% on 
Weekday, Saturday, or Sunday 
• Expanding or reducing number of route directional miles more than 25%A change 
resulting in a 25% or greater variance from the existing route alignment12 
 
1 A change of 25 percent in weekly route revenue miles and/or route directional miles is the City of Phoenix threshold 
for determining whether a potential transit service change qualifies as a major service change (or “substantial” service 
change), according to the City of Phoenix resolution (1990). This percentage is generally an industry-wide percentage 
threshold used by peer transit systems throughout the United States. The City of Phoenix resolution also specifies that 
a public comment period will be initiated when a change in transit service of 25 percent or more is determined. Valley 
Metro has adopted the same thresholds. 
2 A change of 25 percent in Express/RAPID service route revenue miles and/or route directional miles does not apply 
to the portion of the routes that are on the freeway/highway because there are no stops or service. Only the portion of 
the routes that occurs on surface streets applies to the 25 percent threshold for a major service change.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
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All service change proposals that are determined to be a major service change will 
undergo Service Equity Analysis.  
Adverse Effect 
An adverse effect is defined as a reduction or addition in service that includes but is not 
limited to: changes in span of service, changes to frequency of service; the addition of 
new routes; the elimination of routes or route segments; or the modification of routes or 
route segments.  
Disparate Impact 
When the difference in adverse impacts between minority ridership3 and/or population4  
and non-minority ridership and/or population on the affected service is equal to or 
greater than five percent compared to the transit system’s minority and non-minority 
ridership5 and/or population, there would be a disparate impact. 
Disproportionate Burden 
When the difference in adverse impacts between low-income ridership3 and/or 
population4 and non-low-income ridership and/or population on an affected service is 
equal to or greater than five percent compared to the transit system’s low-income and 
non-low-income ridership5 and/or population, there would be a disproportionate burden 
impact.  
Should Valley Metro or the City of Phoenix find any disparate impact or disproportionate 
burden is found during the service equity analysis, steps will be taken to avoid, 
minimize, or mitigate the impacts.  
Equity Analysis Data Sources 
The following table identifies the data source for the service equity analysis depending 
on the type of service change being proposed.  
 
 
3 The determination of the transit system and an affected route’s minority and/or low-income ridership will be derived 
from the most recently completed, statistically valid regional on-board origin/destination survey. 
4 The determination of the potential ridership for service expansion or the addition of a new service will be derived from 
the most recent American Community Survey data for the census tract or census block group surrounding the expanded 
route or new route.  
5 The transit system’s ridership is separated into Local Bus Service (local fixed bus routes, key local service, light rail, 
streetcar and circulator bus service) and Express/RAPID Service (commuter bus service). The affected service would 
be compared to the overall transit system’s ridership by Local Bus Service or Express/RAPID Bus Service.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
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Category 
Action 
Sub Action 
Evaluation Method 
Service Level6 
Change 
Reduction 
Not Applicable 
O/D7 Data 
Expansion 
Not Applicable 
Route Length 
Reduction 
Not Applicable 
O/D Data 
Expansion 
Not Applicable 
Census Data 
Route 
Alignment 
Change 
Reduction 
Not Applicable 
O/D Data 
Expansion 
Not Applicable 
O/D Data and 
Census Data 
Modification 
Eliminated 
Segment(s) 
O/D Data and 
Census Data 
Segment(s)  
to New Areas 
Census Data 
Elimination 
Not Applicable 
O/D Data 
New Route 
New Route 
Not Applicable 
Census Data 
Fare Media 
Access 
Modifications 
Not Applicable 
O/D Data 
Census Data 
 
Transit System Minority/ Low-Income Population Benchmarks 
 
 
 
6 Service Level- Refers to the span of service, days of operations, trips and headways (service frequencies) 
for a transit route or the regional transit system. 
7 Origin/Destination Survey Data 
Service Type
Minority
Low-Income
(150%)
Local Bus
53%
22%
Circulator
58%
26%
Express/RAPID Bus
49%
20%
Service Type
Minority
Low-Income
Local Bus
65%
51%
Circulator
72%
63%
Express/RAPID Bus
38%
19%
Service Equity Analysis Service Area - 2022 ACS Data 
Service Equity Analysis - 2023 O/D Data

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
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Description of Proposed October 2024 Changes 
Following is a brief description of the proposed service changes, followed by details of 
current service and the proposed changes. 
 
The Public Transit Department (PTD) is proposing to modify the east end of Route 13 
(Buckeye Road) to terminate at the PHX Sky Train 24th Street Station, near 24th Street 
and Buckeye Road. This modification was requested by the Phoenix Aviation 
Department, which would remove duplicative service with Sky Train service between 
24th Street and Terminal 3, as well as alleviate vehicle congestion on Sky Harbor 
Boulevard. 
In addition, the Gila River Indian Community (GRIC) is requesting Valley Metro to 
extend Route 77 (Baseline Road) west to 83rd Avenue and Sunshine Road to service 
the GRIC Community Service Center. Route 77 operates in, and is funded by, Phoenix, 
Mesa, and Tempe. 
Current Route Description  
Route 13: The route runs on Buckeye Road between 75th Avenue (to the west) and 
former site of Sky Harbor Airport Terminal 2 (to the east). 
 
Route 77: Valley Metro operates the route on Baseline Road between 75th Avenue in 
Phoenix, to the West Mesa Park and Ride at Country Club Drive. 
 
Proposed Changes  
Route 13: Modify the east end of the route to terminate at the PHX Sky Train 24th 
Street Station and remove service on Buckeye Road and Sky Harbor Boulevard 
between 24th Street and Terminal 3. Bus passengers would use the PHX Sky Train to 
access airport terminals. 
 
The PHX Sky Train extension to the Rental Car Center, via the 24th Street Station, was 
opened in December 2022. Since then, Route 13 passengers have the option to either 
alight the bus at 24th Street and use the PHX Sky Train to access airport terminals, or 
they can continue to ride the bus to the end of the route near the former Terminal 2 site 
and walk to the Terminal 3 Sky Train Station to either access Terminal 3 or take the Sky 
Train to Terminal 4. With the proposal to end Route 13 at the 24th Street Sky Train 
Station, riders can continue to make connection via the Sky Train to access Sky Harbor 
Airport Car Rental Center, Terminal 3, and Terminal 4.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
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Route 77: Extend the route westward to 83rd Avenue to serve the GRIC Community 
Service Center. The extension is one mile in each direction, most of it within the 
jurisdiction of the GRIC. If approved, the extension would increase Phoenix revenue 
miles by 0.2 miles, per trip in each direction. 
 
 
 
Public Input Process 
The Public Transit Department uses the locally adopted public outreach process to 
solicit public feedback on proposed service changes. 
 
The public input process takes place from May 6 to June 7, during which time 
Phoenix and Valley Metro staff will begin the public input process and conduct in-
person and virtual outreach utilizing posters and A-Frame signs placed at key areas 
along each route to notify the public of the proposed changes, and direct

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
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passengers to Valley Metro’s website to submit comments. The proposed changes 
are also be advertised via social media, interactive webinars, and a public hearing, 
which is scheduled on Wednesday, May 22 at Valley Metro’s offices, Conference 
Room 10A and online via Webex. 
SERVICE EQUITY ANALYSIS OF OCTOBER 2024 SERVICE CHANGES 
The first step of the Title VI assessment is to measure and document the magnitude of 
service change being proposed to determine if a project qualifies as a “major service 
change”.  
Table 1: Magnitude of Impact- Revenue Miles Change  
 
Table 2: Magnitude of Impact- Directional Miles Change 
 
Table 3: Magnitude of Impact- Major Change Indicators by Individual Projects 
 
Magnitude of Service Change Assessment Findings 
None of the proposed service changes qualifies as a major service change, therefore no 
further analysis is needed.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
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Demographic Maps 
Map 1: October 2024 Service Change and Title VI Populations Route 13

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
January 2024 Proposed Service Changes 
 
Page 9 of 9 
 
Map 2: October 2024 Service Change and Title VI Population Route 77