Attachment B - October 2026 Title VI Service Change Analysis.pdf

Title VI Service Equity Analysis 
City of Phoenix 
October 2026 Service Change 
City of Phoenix Public Transit Department 
ATTACHMENT B

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 2 of 14 
 
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 2026 Proposed Service Changes 
 
Page 3 of 14 
 
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 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 2026 Proposed Service Changes 
 
Page 4 of 14 
 
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 - Census ACS Data 
Service Equity Analysis - 2023 O/D Data

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 5 of 14 
 
Description of Proposed October 2026 Changes 
Microtransit Implementation: 
 
Three microtransit zones were identified in the Project EASE grant application. Each 
zone is planned to operate with four microtransit vehicles and will cover approximately 
12–16 square miles. The size and boundaries of each zone were designed to balance 
service coverage with operational efficiency. 
 
The North Phoenix Zone is generally bounded by Union Hills Drive to the south, Happy 
Valley Road to the north, 51st Avenue to the west, and 16th Street to the east. 
Implementation of this zone will be coordinated with the launch of enhanced all-day I-17 
RAPID service, which will provide direct connections to Downtown Phoenix from the 
Happy Valley Park-and-Ride and the Bell/I-17 (Deer Valley) Park-and-Ride. 
 
The West Phoenix Zone is generally bounded by McDowell Road to the south, 
Camelback Road to the north, 75th Avenue to the east, and 107th Avenue to the west. 
This zone will be implemented alongside enhanced all-day I-10 West RAPID service, 
offering direct connections to Downtown Phoenix from the Desert Sky Transit Center 
and the 79th Avenue/I-10 Park-and-Ride. 
 
The South Phoenix Zone is generally bounded by Dobbins Road to the south, 
Broadway Road to the north, 59th Avenue to the west, and Central Avenue to the east. 
This zone will connect directly to the Valley Metro Light Rail B Line at the Central and 
Baseline Park-and-Ride, providing seamless access to the regional rail network. 
Each pilot microtransit zone is designed to operate daily from 6 a.m. to 8 p.m. 
 
RAPID Service Enhancement: 
 
Current Route Description 
I-17 RAPID: The I-17 RAPID is an express bus route connecting north Phoenix with 
Downtown Phoenix along the I-17 freeway corridor. Current service operates inbound to 
Downtown Phoenix during weekday morning peak hours (5 a.m. to 8 a.m.), and 
outbound during weekday afternoon peak hours (3 p.m. to 6 p.m.) to the Thelda 
Williams Transit Center, the Bell/I-17 Park-and-Ride, and the Happy Valley Park-and-
Ride. 
 
I-10 West RAPID: The I-10 West RAPID is an express bus route connecting west 
Phoenix with Downtown Phoenix along the I-10 freeway corridor. Current service 
operates inbound to Downtown Phoenix during weekday morning peak hours (5 a.m. to 
8 a.m.), and outbound during weekday afternoon peak hours (3 p.m. to 6 p.m.) to the 
79th Avenue/I-10 Park-and-Ride and the Desert Sky Transit Center. 
 
Proposed RAPID Changes 
PTD proposes improving both routes to operate bi-directionally Monday through Friday 
by adding reverse-commute trips during peak hours and extending service into off-peak

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 6 of 14 
 
periods. Once implemented, each route will operate in both directions from 5 a.m. to 7 
p.m. on weekdays. Existing peak-hour frequent service will remain in place to 
accommodate high-demand travel periods. 
 
In addition to I-17 and I-10 West RAPID, PTD also proposed schedule changes to other 
RAPID routes (SR 51 RAPID, I-10 East RAPID, South Mountain East RAPID, and 
South Mountain West RAPID) that were shared for public comment in the effort to 
improve on-time performance and service efficiency.  
 
Public Outreach 
The Public Transit Department used the locally adopted public outreach process to 
solicit public feedback on proposed service changes.  
The public input process took place from May 11, 2026, through June 16, 2026. During 
the public comment period, Phoenix and Valley Metro staff conducted outreach utilizing 
the Valley Metro website, Valley Metro App, City newsletters, social media, and on-
board bus public messaging announcements to notify passengers of the proposed 
changes and directed passengers to visit Valley Metro’s website to submit comments.  
The proposed service change information was also presented by city staff to the 
following Village Planning Committees where the village would be impacted by the 
proposed service change: 
• May 4, 2026- Deer Valley Village 
• May 11, 2026- Laveen Village 
• May 12, 2026- South Mountain Village 
• May 13, 2026- Maryvale Village 
• May 19, 2026- Estrella Village 
A hybrid public hearing was held on May 27 at Valley Metro’s offices, Conference Room 
10A and virtually, for the public to attend and provide comments.  
SERVICE EQUITY ANALYSIS OF OCTOBER 2025 PROPOSED 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”.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 7 of 14 
 
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 
Microtransit service implementation qualifies as add a new route. I-17 RAPID and I-10 
West RAPID’s revenue mile increase are greater than 25% of existing service on 
weekdays. Therefore, all proposed projects will proceed to step 2 to be assessed for 
possible disparate impact to minority population and/or bestowing disproportionate 
burden on low-income populations.  
Routes Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
I17 RAPID
864
       
-
     
-
     
1,318
  
-
       
-
       
53%
I-10 West RAPID
255
       
-
     
-
     
536
      
-
       
-
       
110%
North Microtransit
-
        
-
     
-
     
New
New
New
100%
100%
100%
South Microtransit
-
        
-
     
-
     
New
New
New
100%
100%
100%
West Microtransit
-
        
-
     
-
     
New
New
New
100%
100%
100%
Current Revenue Miles
Proposed Revenue Miles
% Difference
Routes
Current Directional 
Miles
Proposed 
Directional Miles % Difference
I17 RAPID
44
44
0%
I-10 West RAPID
26
26
0%
North Microtransit
N/A
N/A
N/A
South Microtransit
N/A
N/A
N/A
West Microtransit
N/A
N/A
N/A
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
I17 RAPID
No
Yes
No
No
No
No
Yes
I-10 West RAPID
No
Yes
No
No
No
No
Yes
North Microtransit
Yes
Yes
Yes
Yes
Yes
Yes
Yes
South Microtransit
Yes
Yes
Yes
Yes
Yes
Yes
Yes
West Microtransit
Yes
Yes
Yes
Yes
Yes
Yes
Yes

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 8 of 14 
 
Step 2- Disparate Impact and Disproportionate Burden Determination 
The second step of the service equity assessment will evaluate each major service 
change to determine if it would have a disparate impact on minority populations and/or 
cause disproportionate burden on low-income populations. 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.  
Table 4: Route Service Area Title VI Populations by Census Block Group* 
 
Table 5. Route Rider Population from 2023 Valley Metro Origin and Destination 
Survey 
 
Step 2- Disparate Impacts and Disproportionate Burden findings and mitigation strategy  
Route
Percent Minority 
Population
Percent Low Income 
Population
All Local
52.8%
22.0%
North Microtransit Zone
37.4%
18.4%
South Microtransit Zone
80.1%
24.0%
West Microtransit Zone
82.8%
26.0%
Above system average by five percent
Route
Percent Minority 
Population
Percent Low Income 
Population
RAPID/Express
49.2%
20.0%
I-17 RAPID
63.8%
32.5%
I-10 West RAPID
84.6%
36.6%
Above system average by five percent
* Population within 3/4 mile buffer of route.
* Population within 3/4 mile buffer of route.
Route
Percent Minority 
Population
Percent Low 
Income 
Population
All RAPID/Express
37.5%
18.5%
I-17 RAPID
45.1%
30.9%
I-10 West RAPID
66.7%
32.0%
* 2023 Valley Metro Origin and Destination Study
Above system average by five percent

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 9 of 14 
 
North Microtransit Zone 
Findings: Based on census data, areas proposed to be covered by the North 
microtransit zone are 37.4% minority, which is less than the regional local route average 
of 52.8%. Should the proposed service change negatively impact riders, it would not 
qualify as having a disparate impact on minority populations. The same area is 18.4 
low-income, which is less than the regional local route average of 22%. Should the 
proposed service change negatively impact riders, it would not qualify as causing 
disproportional burden on low-income populations 
Mitigation Requirements: The proposed microtransit zone in north Phoenix would 
provide additional transit options for riders on top of existing transit service. Since the 
proposed change is a positive change for transit passengers, no mitigation efforts are 
necessary. 
South Microtransit Zone 
Findings: Based on census data, areas proposed to be covered by the South 
microtransit zone are 80.1% minority, which is more than five percent above the 
regional local route average of 52.8%. Should the proposed service change negatively 
impact riders, it would qualify as having a disparate impact on minority populations. The 
same area is 24% low-income, which is less than five percent above the regional local 
route average of 22%. Should the proposed service change negatively impact riders, it 
would not qualify as causing disproportional burden on low-income populations 
Mitigation Requirements: The proposed microtransit zone in South Phoenix would 
provide additional transit options for riders on top of existing transit service. Since the 
proposed change is a positive change for transit passengers, no mitigation efforts are 
necessary. 
West Microtransit Zone 
Findings: Based on census data, areas proposed to be covered by the West 
microtransit zone are 82.8% minority, which is more than five percent above the 
regional local route average of 52.8%. Should the proposed service change negatively 
impact riders, it would qualify as having a disparate impact on minority populations. The 
same area is 26% low-income, which is less than five percent above the regional local 
route average of 22%. Should the proposed service change negatively impact riders, it 
would not qualify as causing disproportional burden on low-income populations 
Mitigation Requirements: The proposed microtransit zone in West Phoenix would 
provide additional transit options for riders on top of the existing transit service. Since

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 10 of 14 
 
the proposed change is a positive change for transit passengers, no mitigation efforts 
are necessary. 
I-17 RAPID 
Findings: According to the most recent origin/destination survey, current I-17 RAPID 
passengers are 45% of the minority, which is more than five percent above the regional 
average of 37.5% for RAPID routes. Should the proposed service change negatively 
impact riders, it would qualify as having a disparate impact on minority populations. I-17 
RAPID passengers are 30.9% low-income, which is more than five percent above the 
regional average of 18.5% for RAPID routes. Should the proposed service change 
negatively impact riders, it would qualify as causing a disproportional burden on low-
income populations.  
Mitigation Requirements: The proposed service change on I-17 RAPID is to keep 
existing service and add more trips bi-directionally on weekdays. Since the proposed 
change is a positive change for transit passengers, no mitigation efforts are necessary.   
I-10 West RAPID 
Findings: According to the most recent origin/destination survey, current I-10 West 
RAPID passengers are 66% minority, which is more than five percent above the 
regional average of 37.5% for RAPID routes. Should the proposed service change 
negatively impact riders, it would qualify qualifies as having a disparate impact on 
minority populations. I-10 West RAPID passengers are 32% low-income, which is more 
than five percent above the regional average of 18.5% for RAPID routes. Should the 
proposed service change negatively impact riders, it would qualify as causing a 
disproportional burden on low-income populations.  
Mitigation Requirements: The proposed service change on I-10 West RAPID is to keep 
existing service and add more trips bi-directionally on weekdays. Since the proposed 
change is a positive change for transit passengers, no mitigation efforts are necessary.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 11 of 14 
 
Demographic Maps 
Map 1: October 2026 Service Change and Title VI Populations- RAPID

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
Page 12 of 14 
 
Map 2: October 2026 Service Change and Title VI Populations- North Microtransit 
Zone

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
October 2026 Proposed Service Changes 
 
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Map 3: October 2026 Service Change and Title VI Populations- West Microtransit 
Zone

Title VI Analysis  
City of Phoenix Public Transit Department 
October 2026 Proposed Service Changes 
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Map 4: October 2026 Service Change and Title VI Populations- South Microtransit 
Zone