Attachment B - Title VI Service Equity Analysis July 2025 Service Change

Title VI Service Equity Analysis 
City of Phoenix 
July 2025 Service Change 
City of Phoenix Public Transit Department 
Attachment B

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 2 of 13 
 
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 
 
 
July 2025 Proposed Service Changes 
 
Page 3 of 13 
 
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 
 
 
July 2025 Proposed Service Changes 
 
Page 4 of 13 
 
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 
 
 
July 2025 Proposed Service Changes 
 
Page 5 of 13 
 
Description of Proposed July 2025 Changes 
The Public Transit Department (PTD) is proposing to modify the local bus service on 
Central Avenue in connection with the upcoming five-mile South Central Light Rail 
extension on Central Avenue from downtown Phoenix to Baseline Road. The proposed 
service change on Central Avenue would combine Route 0 and Route 0A back into a 
single bus route. In addition, service frequency on the combined route would be 
modified in anticipation of riders shifting transit modes to use Light Rail for travel from 
South Phoenix.  
 
Current Route Description  
Route 0 (Central Ave): Route 0 operates on Central Avenue between Sunnyslope 
Transit Center (to the north) and downtown Phoenix at Van Buren Street (to the south).  
 
Route 0A (South Central Shuttle): Route 0A operates on Central Avenue between 
Van Buren Street (to the north) and Dobbins Road (to the south).  
 
Proposed Service Changes 
Route 0 (Central Ave): Combine route with Route 0A and modify the weekday route 
frequency from every 20 minutes to every 30 minutes. The combined route eliminates 
duplicative service with the introduction of light rail service to South Phoenix. 
 
Route 0A (South Central Shuttle): Combine route with Route 0 and modify the 
weekday route frequency from every 15 minutes to every 30 minutes. The combined 
route eliminates duplicative service with the introduction of light rail service to South 
Phoenix. 
 
Prior to October 2020, the local bus service on Central Avenue was served by a single 
Route 0 that operated between Sunnyslope Transit Center and Dobbins Road seven 
days a week.  
 
In October 2020, the local bus service on Central Avenue was split into two routes in 
coordination with light rail construction activities on Central Avenue. The Route 0 
segment north of Van Buren Street continued to operate as Route 0 and maintained its 
pre-light rail construction frequency of every 20 minutes. The Route 0 segment south of 
Van Buren Street was split into a new Route 0A that was scheduled to run every 15 
minutes on weekdays between Van Buren Street and Baseline Road. The Route 0A 
segment south of Baseline Road is scheduled to run every 30 minutes.   
 
The proposed change would once again merge the two routes back together with the 
completion of the South-Central Light Rail extension project. PTD anticipates that 
demand for Route 0 service would be reduced on Central Avenue as transit riders in

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 6 of 13 
 
South Phoenix choose to ride light rail on Central Avenue once the rail line extension is 
operational. While Route 0’s proposed frequency adjustment north of Van Buren from 
every 20 minutes to every 30 minutes is unrelated to the South-Central Light Rail 
project, recent passenger load analysis indicates that a frequency reduction would not 
cause crowding issues on Route 0.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 7 of 13 
 
Public Outreach 
The Public Transit Department will use the locally adopted public outreach process to 
solicit public feedback on proposed service changes.  
The public input process would takes place from March 3 to April 4, during which time 
Phoenix and Valley Metro staff will seek public input on the proposed service changes 
by conducting in-person and virtual outreach activities, utilize posters and A-Frame 
signs placed at key areas along each route to notify the public of the proposed changes, 
and direct passengers to visit Valley Metro’s website to submit comments. The 
proposed changes are also to be advertised via social media, interactive webinars, and 
a public hearing.  
SERVICE EQUITY ANALYSIS OF JULY 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”.  
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 
Routes Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Weekday
Saturday
Sunday
Route 0
946
       
627
    
627
    
1,273
  
1,207
  
1,207
  
35%
93%
93%
Route 0A
991
       
609
    
609
    
-
       
-
       
-
       
-100%
-100%
-100%
Route 0/0A Corridor
1,937
   
1,235
 
1,235
 
1,273
  
1,207
  
1,207
  
-34%
-2%
-2%
Current Revenue Miles
Proposed Revenue Miles
% Difference
Routes
Current Directional 
Miles
Proposed 
Directional Miles % Difference
0
16.8
                        
32.7
                    
94.6%
0A
16
                           
-
                      
-100%
0/0A Corridor
33
                           
33
                       
-2%

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 8 of 13 
 
 
Magnitude of Service Change Assessment Findings 
Routes 0 and 0A merger with frequency reduction represent a Major Service Change as 
the revenue miles will change by over 25%. The proposed project will proceed to step 2 
to be assessed for possible disparate impact to minority population and/or bestowing 
disproportionate burden on low-income populations.  
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 
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
0
No
Yes
Yes
Yes
Yes
Yes
Yes
0A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
0/0A Corridor
No
Yes
No
No
No
No
Yes
Route
Percent Minority 
Population
Percent Low Income 
Population
All Local
52.8%
22.0%
Route 0
45.0%
23.2%
Route 0A
75.2%
35.2%
Above system average by five percent
* Population within 3/4 mile buffer of route.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 9 of 13 
 
 
Step 2- Disparate Impacts and Disproportionate Burden findings and mitigation strategy  
Route 0 findings: According to the most recent origin/destination survey, current Route 
0 passengers are 74% minority, which is more than five percent above the regional 
average of 65% for local routes. The proposed service change on Route 0 qualifies as 
having a disparate impact on minority populations. Route 0 passengers are 74% low 
income, which is more than five percent above the regional average of 51%. The 
proposed service change on Route 0 qualifies as causing a disproportional burden on 
low-income populations.  
Route 0 Mitigation: Current passenger loads on Route 0 indicate there are adequate 
seating capacity at 20-minute weekday frequency. Transit service volume and capacity 
chart on Route 0 based on Fall 2024 passenger data calculated at the 90th percentile 
indicates expected passenger loads are typically well below bus capacity. When 
lowering route seat capacity by reducing service to every 30 minutes on weekdays, 
assuming the same passenger demand, there would still be more than enough transit 
capacity to handle expected passenger loads.  
 
Route
Percent Minority 
Population
Percent Low 
Income 
Population
All Local
64.7%
50.9%
Route 0
74.1%
74.2%
Route 0A
73.2%
62.9%
* 2023 Valley Metro Origin and Destination Study
Above system average by five percent

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 10 of 13 
 
 
When examining the location where Route 0 currently is seeing higher transit demand, it 
is highest at route segment between Thomas Road and Camelback Road, which is 
influenced by the presence of Central High School located between Indian School Road 
and Camelback Road. This section of the route is also serviced by Valley Metro’s Light 
Rail B Line. Valley Metro B line is expected to be improved to operate every 12 minutes 
from the existing 15-minute frequency on weekdays. With the expected improvement on 
the nearby light rail line, transit passenger crowding on Central Avenue should be 
mitigated.  
 
Route 0A findings: According to the most recent origin/destination survey, current 
Route 0A passengers are 73% minority, which is more than five percent above the 
regional average of 65% for local routes. The proposed service change on Route 0A 
qualifies as having a disparate impact on minority populations. Route 0A passengers 
are 62% low income, which is more than five percent above the regional average of 
51%. The proposed service change on Route 0A qualifies as causing a disproportional 
burden on low-income populations.

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 11 of 13 
 
Route 0A Mitigation: Current passenger loads on Route 0A indicate there are 
adequate seating capacity at 15-minute weekday frequency. Transit service volume and 
capacity chart on Route 0A based on Fall 2024 passenger data calculated at the 90th 
percentile indicates expected passenger loads are typically well below bus capacity.  
 
Without accounting for the expected implementation of Valley Metro’s South Central 
Rail extension, when just lowering route seat capacity by reducing service to every 30 
minutes on weekdays, assuming the same passenger demand, there will be crowding 
issues around 6:00 a.m. where standing load is expected. Around 1:00 p.m., Route 0A 
is expected to be overcapacity where passengers will need to wait for the next bus.  
 
Phoenix public transit is expecting much of the transit passenger demand on Central 
Avenue south of Van Buren Street to shift over to Valley Metro’s B Line when South

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 12 of 13 
 
Central Rail extension is complete. On top of the 30-minute frequency of the combined 
Route 0 on Central Avenue on weekdays, Valley Metro B line will operate every 12 
minutes on weekdays connecting South Central communities to the rest of the regional 
transit network. With the expected new light rail service on Central Avenue, transit 
passenger crowding on Central Avenue south of Van Buren Street should be mitigated.  
Valley Metro Two-line System Map

Title VI Analysis  
 
 
City of Phoenix Public Transit Department 
 
 
July 2025 Proposed Service Changes 
 
Page 13 of 13 
 
Demographic Maps 
Map 1: July 2025 Service Change and Title VI Populations Route 0 and 0A