Attachment B - October 2022 Title VI Service Equity Analysis

Title VI Service Equity Analysis 
City of Phoenix 
Proposed October 2022 Service Change 
City of Phoenix Public Transit Department 
Attachment B

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
Page 2 of 15 
 
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 
 
 
October 2022 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 
 
 
October 2022 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 
Service Equity Analysis benchmarks based on October 2021 Service Area Census Data 
(2019 ACS): 
Service Type 
Minority 
Low-Income 
Local Bus 
50.17% 
25.74% 
Circulator 
56.82% 
29.29% 
Express/RAPID Bus 
50.40% 
25.10% 
 
Service Equity Analysis benchmarks based on 2019 O/D Data 
Service Type 
Minority 
Low-Income 
Local Bus 
62.2% 
45.0% 
Circulator 
60.1% 
45.8% 
Express/RAPID Bus 
43.5% 
4.9% 
 
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

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
Page 5 of 15 
 
SERVICE EQUITY ANALYSIS OF OCTOBER 2022 SERVICE CHANGES 
Description of Proposed Changes 
In October 2022, Phoenix proposes to extend Route 43 (43rd Ave) by one mile to Lower 
Buckeye Road and increase Route 156 (Chandler Blvd) peak weekday frequency to 
every 15 minutes between 48th Street and Gilbert Road. 
Route 43- 43rd Ave 
 
CURRENT ROUTE 
Route 43 is a local route contracted by the City of Phoenix to operate on 43rd Avenue 
between Union Hills Drive to the north and Buckeye Road to the south. This 15-mile 
route provides connection opportunity with 16 other local routes in the region and one 
circulator route operated by the City of Glendale (GUS2). The route runs in both the City 
of Phoenix and the City of Glendale with a 30-minute frequency daily.  
PROPOSED CHANGES 
In early 2022, PTD received requests from west Phoenix businesses on 43rd 
Avenue to explore options to extend the route further south to provide transit service 
for warehouse workers. After initial evaluation of extension considerations that 
include vehicle availability, bus turn-around routing, and roadway condition, staff has 
determined the extension is feasible. As a result, PTD is proposing to extend Route 
43 one mile south to Lower Buckeye Road that would not only provide transit service 
to businesses between Buckeye Road and Lower Buckeye Road, it would also 
provide another transit connection with Route 28 on Lower Buckeye Road.  
 
Route 156- Chandler Blvd 
 
CURRENT ROUTE 
Route 156 is a local route contracted by the Regional Public Transportation Authority 
(RPTA) to operate on Chandler Blvd. between 48th Street in Phoenix and ASU 
Polytechnic Campus in Mesa. This 21-mile-long route operates in Chandler, Gilbert, 
Mesa, and Phoenix. The route provides connection opportunity with 9 other local routes 
in the region and one circulator route operated by the City of Phoenix (ALEX in 
Ahwatukee). The route operates daily on a 30-minute frequency.  
 
PROPOSED CHANGES 
The City of Chandler is proposing to introduce weekday peak hour 15-minute 
frequency on Route 156 within its jurisdictions. The Phoenix portion of the route is 
the half mile section of Chandler Blvd between 48th Street and the I-10 freeway

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
Page 6 of 15 
 
ramp. To promote regional connectivity and avoid bus trips ending at the city 
boundary, Phoenix is proposing to extend the peak hour frequency improvement to 
the western end of the line at 48th Street on Chandler Blvd.  
 
Public Input Process 
The Public Transit Department will use the locally adopted public outreach process to 
solicit public feedback on proposed service changes. The process opened on May 2, 
2022 and ends June 3, 2022, and includes methods such as: 
• Posting proposed service change details and an online passenger survey. 
• Implementing on-board announcements requesting passenger input on the 
proposed service changes. 
• Posting flyers at impacted stops along affected routes. 
• Joint online public hearing with Valley Metro on May 18, 2022 
Magnitude of Service Change 
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”. As both Route 43 and Route 156 cross jurisdictional boundaries, revenue and 
directional miles are summarized for both total route and Phoenix portion only. 
Table 1: Magnitude of Impact- Major Change Indicators by Individual Projects 
 
Table 2a: Revenue Miles Change (Total Route) 
 
 
Project
Add or 
Eliminate 
Route
Expanding or 
reducing 
existing route 
by more than 
25% of 
Weekday 
route 
revenue 
miles 
Expanding or 
reducing 
existing route 
by more than 
25% of 
Saturday 
routes 
revenue 
miles
Expanding or 
reducing 
existing route 
by more than 
25% of 
Sunday 
route 
revenue 
miles
Expanding or 
reducing 
number of 
route 
directional 
miles more 
than 25%
A change 
resulting in a 
25% or 
greater 
variance from 
the existing 
route 
alignment
Continue to 
Assess 
Mitigation
Route 43
NO
NO
NO
NO
NO
NO
NO
Route 156
NO
NO
NO
NO
NO
NO
NO
Routes Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
43
1,187
  
1,108
  
1,108
  
1,266
  
1,181
  
1,181
  
6.7%
6.6%
6.6%
156
1,416
  
1,191
  
998
      
1,526
  
1,191
  
998
      
7.8%
0.0%
0.0%
Current Revenue Miles
Proposed Revenue Miles
% Difference

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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Table 2b: Revenue Miles Change (Phoenix Only) 
 
Table 3a: Directional Miles Change (Total Route) 
 
Table 3b: Directional Miles Change (Phoenix Only) 
 
Findings 
October 2022 proposed service change does not qualify as a major service change. As 
a result, no further Title VI analysis or mitigation efforts is required.  
 
 
 
 
 
 
 
 
 
 
Routes Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
43
992
      
923
      
923
      
1,071
  
996
      
996
      
8.0%
7.9%
7.9%
156
34
        
29
        
24
        
39
        
29
        
24
        
14.7%
0.0%
0.0%
Current Revenue Miles
Proposed Revenue Miles
% Difference
Routes
Current Directional 
Miles
Proposed 
Directional Miles
% Difference
43
30.0
                          
32.0
                          
6.7%
156
43.0
                          
43.0
                          
0.0%
Routes
Current Directional 
Miles
Proposed 
Directional Miles
% Difference
43
25.0
                          
27.0
                          
8.0%
156
1.0
                            
1.0
                            
0.0%

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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SERVICE EQUITY ANALYSIS FOR PHOENIX OPERATED ROUTE IN OTHER 
JURISDICTIONS 
In addition to Phoenix proposed changes, PTD also conducts service equity analysis 
for proposed service changes on routes operating by Phoenix in another 
jurisdictions: 
 
Route 106- Peoria Road 
 
CURRENT ROUTE 
Route 106 is a local route contracted by the City of Phoenix to operate on Peoria Road 
between Sunnyslope Transit Center in Phoenix and Banner Medical Center Sun City. 
This 21-mile-long route operates in Glendale, Peoria, Phoenix, Sun City and 
Youngtown. The route provides connection opportunity with 14 other local routes in the 
region, one limited route, three express routes and three circulator routes. On 
weekdays, the route operates at a 30-minute frequency except in Sun City and 
Youngtown where the frequency is hourly. On Saturdays, the route operates every 30 
minutes in Phoenix and hourly in Glendale and Peoria. The route does not operate in 
Sun City or Youngtown on Saturdays. On Sundays, the route operates every 30 
minutes in Phoenix and hourly in Glendale. There is no Sunday service in Peoria, 
Youngtown, and Sun City.  
PROPOSED CHANGES 
The City of Peoria is proposing to introduce hourly Sunday service on Route 106 within 
its jurisdiction.  
 
Magnitude of Service Change 
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”. As routes do cross jurisdictional boundaries, revenue and directional miles are 
summarized for both total route and in the jurisdiction with proposed service change 
only.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
Page 9 of 15 
 
Table 4: Magnitude of Impact- Major Change Indicators by Individual Projects- 
City of Peoria 
 
Table 5a: Revenue Miles Change (Total Route) 
 
Table 5b: Revenue Miles Change (Peoria Only) 
 
Table 6a: Directional Miles Change (Total Route) 
 
Table 6b: Directional Miles Change (Peoria Only) 
 
Findings 
The proposed Sunday addition of Route 106 in the City of Peoria does qualify as a 
major service change as there is 100% change of revenue miles on Sunday. The route 
change does impact several areas that include above average minority and low-income 
population. Although any service reduction or deviation in this area would result in 
disparate impact to minority population or disproportional burden on the low-income 
community, the nature of the proposed service change is to add more transit service 
Project
Add or 
Eliminate 
Route
Expanding or 
reducing 
existing route 
by more than 
25% of 
Weekday 
route 
revenue 
miles 
Expanding or 
reducing 
existing route 
by more than 
25% of 
Saturday 
routes 
revenue 
miles
Expanding or 
reducing 
existing route 
by more than 
25% of 
Sunday 
route 
revenue 
miles
Expanding or 
reducing 
number of 
route 
directional 
miles more 
than 25%
A change 
resulting in a 
25% or 
greater 
variance from 
the existing 
route 
alignment
Continue to 
Assess 
Mitigation
Route 106
NO
NO
NO
YES
NO
NO
YES
Routes Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
106
1,266
  
832
      
696
      
1,266
  
832
      
811
      
0.0%
0.0%
16.6%
Current Revenue Miles
Proposed Revenue Miles
% Difference
Routes Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
106
260
      
122
      
-
       
260
      
122
      
115
      
0.0%
0.0% 100.0%
Current Revenue Miles
Proposed Revenue Miles
% Difference
Routes
Current Directional 
Miles
Proposed 
Directional Miles
% Difference
106
41.7
                          
41.7
                          
0.0%
Routes
Current Directional 
Miles
Proposed 
Directional Miles
% Difference
106
8.2
                            
8.2
                            
0.0%

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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where it is currently unavailable. As a result, no disparate impact to minority population 
or disproportional burden to low-income population is found with this service change 
proposal.  
Maps 
Map 1 and Map 2 illustrate the distribution of Title VI populations and the proposed 
October 2022 service changes to Route 43. Map 3 and Map 4 illustrate the distribution 
of Title VI populations and Route 106: Map 5 and Map 6 illustrate the distribution of Title 
VI populations and Route 156:

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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Map 1: October 2022 Service Change and Minority Population Route 43

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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Map 2: October 2022 Service Change and Low-Income Population Route 43

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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Map 3: October 2022 Service Change and Minority Population Route 106 
 
Map 4: October 2022 Service Change and Low-Income Population Route 106

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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Map 5: October 2022 Service Change and Minority Population Route 156

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2022 Proposed Service Changes 
 
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Map 6: October 2022 Service Change and Low-Income Population Route 156