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45 never made precipitously. A series of steps are involved, with the Assistant County Attorney responsible for including meetings with experts and constituents, public transit," or that the agency's "legal staff specifically outreach efforts to all interest groups, and the inclusion of focused on regulatory and compliance issues." beneficiaries at important stages of the planning process. Some of the responses were more detailed and thus Along with this, quantitative measures involving census more indicative of what transit agencies consider to be and demographic data are included in the decision- making process very early on such that any effects of ser- best practices. For example, Capital District Transit vice or fare change are mitigated. For example, whenever Authority, Albany, New York, stated that it has a "for- route changes are planned, a "demographic profile" of the mal process...for consideration of service changes that affected area(s) is taken by using GIS analytical tech- is laid out in [its] Strategic Business Plan"; that routes niques and applying walking-distance buffers around and corridors identified for a reduction in service are routes to obtain a demographic "snapshot" of the route in based primarily on low ridership levels; and that con- question at the block-group and block level; this gives us sideration is given to existing service "heavily used by invaluable information about the demographic makeup of the elderly, disabled, or low-income passengers." this area, including information regarding low-income Another agency reported that and minority percentages of residents. Whenever possi- ble, numerous scenarios of change are offered; this is done [It discusses] all ramifications which would arise from to minimize the overall effect of change by allowing us to any service reduction or fare increase. The issues that are choose the least onerous of scenarios with the minimal typically included in [the] discussion are [the] effect on impact upon the region in question. So, modeling of riders of service reduction and/or [a] fare increase. We change scenarios is done by employing census demo- look at areas where service reduction is considered and graphic data at the block-group and block level and using make sure that other routes overlap and cover the region GIS analytical techniques. fully. We never remove all coverage from a region during a reduction. Whenever fare increases are considered, we In general, the transit agencies mentioned GIS map- include ameliorating or mitigating options so that the ping and analysis and census data most often in their change in fare does not unduly harm those least able to responses regarding resources available to them when pay. In this sense, we always offer fare savings alterna- reducing service or increasing fares. tives, too, so as to lessen the effect of fare increases, e.g., 7-day and 31-day passes with their special rates. As for G. Policy Regarding Review of Legal Issues When groups which are often at a disadvantage in paying, we Reducing Service or Increasing Fares include special pass rates for them (students, seniors, disabled/Medicare recipients). 1. Review of Legal Issues Our Short Range Transit Plan is the document, which de- scribes fully our legal process for addressing issues in- Forty transit agencies stated that they have a policy volving service reduction or fare increases. of reviewing legal issues that may arise when consider- ing a reduction in transit service and/or an increase in Finally, some of the agencies' responses indicated for fares; however, 22 agencies reported that they do not example, that they consulted the Title VI or ADA laws, have such a policy. relied on a "robust public hearing process," or relied on review by the local FTA office. One agency said that it Table 7. made "a good faith effort" to assure that the agency Transit Agencies with a Policy of Reviewing complied with the law, while another agency said that Legal Issues When Reducing Service or Increas- it sought to make certain that resources are "distrib- ing Fares uted equitably." Another agency commented that a "[r]eview of legal issues in regard to Title VI and the Transit Agencies That 40 ADA [is] part of [a] larger review of potential impacts Have a Policy of Reviewing on access to jobs and services" and that its review "al- Legal Issues ways includes extens[ive] public participation." Transit Agencies That 22 2. Use of a Legal Memorandum Do Not Have a Policy of Reviewing Legal Issues Fifty-four agencies reported that they do not prepare Transit Agencies Not 2 or have not prepared for the agency an internal legal Responding memorandum on issues that are anticipated to arise when the agency is considering a reduction in transit Some of the responses were that the agency's service and/or an increase in fares, whereas six transit "[s]trategic investments staff conducts detailed statisti- agencies reported that they do have a legal memoran- cal analyses to determine the impact of proposed service dum. Four agencies did not respond to the question. or fare changes on minority communities for the pur- pose of determining whether or not mitigating action would be required," that the agency "reviews issues