Frequently Asked Questions MBTA Title VI Disparate Impact and Disproportionate Burden Policy
What is Title VI?
Title VI is a law that prohibits discrimination by recipients of federal money, such as the MBTA, on the basis of race, color, or national origin, which includes the denial of language access to limited English proficient (LEP) persons.
How is the MBTA improving transit service in the Mattapan, Dorchester, and Roxbury communities to meet changing rider needs?
The MBTA has recently introduced a new service planning process to reshape service for MBTA customers. This process aims to improve efficiency by updating bus running times to match frequency and span of service with customer demand. This work will also improve bus crowding and help customers reach their destinations. Under our Title VI Program, the MBTA and MassDOT’s Office of Diversity and Civil Rights will monitor proposed changes to ensure that the results of the service planning process are fair and equitable.
Overnight service is necessary to support late night or early morning workers. How does the MBTA plan to address this issue?
The MBTA is evaluating several options to determine the feasibility of such a service that will meet the needs of the greatest number of people who would rely on any additional service; in this process, we have discussed this challenge with major stakeholders, including the City of Boston, which resulted in a survey to assess the travel needs of our riders. The findings from this study and recommended next steps will be shared with the public shortly.
Many bus stops in my community do not have shelters. How does the MBTA measure equity when looking at bus shelters?
The MBTA Operations Department is responsible for evaluating all requests for bus shelters, while the Office of Systemwide Accessibility assesses all bus stops to create a strategy to fix deficient locations. The Office of Diversity and Civil Rights monitors the fairness in the distribution and condition of shelters under Title VI of the Civil Rights Act of 1964. The creation, placement, and maintenance of bus shelters are shared between the MBTA, the City of Boston, private contractors, and other municipalities.
A civil rights analysis is completed every two years to assess whether the distribution of these shelters and associated amenities in minority areas are equally balanced with the allocation of bus shelters in non-minority communities. The MBTA follows the 2012 Bus Shelter Policy, which determines the eligibility of bus shelter placements. The following eligibility policy standards state: “Any bus stop that has more than 60 boardings is eligible for a shelter….For bus stops with fewer boardings, a combination of factors will be considered in determining eligibility.” See MBTA 2014 Title VI program, Chapter 5 page 5-12, MBTA Title VI Program for more information about the eligibility criteria for bus shelters or please see Chapter 6 page 6-23 for equity analysis results that concluded no disparities in bus shelter placement in minority communities.
The community needs to be a bigger part of the conversation. How will the MBTA include diverse community stakeholders in decision-making processes?
The MBTA is required to make efforts to include the opinions of all community members, whether in local meetings for specific projects, special advisory groups, or board meetings. Through our Title VI Program, we have created a civil rights focused Public Participation Plan to ensure diverse community members are included in discussions, and their opinions are taken into account. The MBTA and the Federal Transit Administration, which oversees our compliance with federal regulations in transit, evaluate and ensure that the MBTA designs and implements projects, policies, and procedures that are consistent with the values and interest of the people we serve.
The MBTA is aware that the process of engaging the public can be complicated and requires creative approaches to meet the diversity of the communities we serve, including access to electronic media (i.e. websites, electronic documents, mobile apps, etc.), culture, language, and geography of our service area. Through new and existing strategies, the MBTA will continue to make greater efforts to include more diverse stakeholders in the decision-making process. We have learned there is community interest in having MBTA representatives attend more community-based organizational meetings, hosting public meetings in various neighborhoods, and creating an equity advisory committee. This equity advisory committee will be designed and structured to include diverse transportation community advocates on important transit matters as they relate to equity.
In Mattapan, there is a vibrant senior citizen community that lacks vehicles but needs to reach doctor's appointments, and mothers with young children who need to reach daycare centers on-time to avoid paying penalty fees. How will the MBTA improve service to ensure that buses arrive on schedule?
As a part of the proposed Service Delivery Policy, the MBTA will set standards by mode (i.e. bus, heavy rail, light rail, ferry, commuter rail) to evaluate on-time performance for each route. The Schedule Adherence Standard for bus routes is designed to ensure that routes operate as reliably as possible without early departures, constant delays, or unpredictable wait and travel times.
The Title VI Monitoring Program helps to ensure on-time performance by evaluating whether on-time performance in minority communities is equivalent to on-time performance in non-minority areas. This analysis is conducted annually and helps the MBTA Title VI Specialist identify possible disparities and works with MBTA Operations and others to help improve any reliability problems. Chapter 6 of the 2014 MBTA Title VI Program contains information about previous Title VI monitoring results on schedule adherence for bus and trackless trolley.
The Federal Transit Administration (FTA) requires the MBTA and other transit providers that receive federal money to monitor the performance of their transit system relative to systemwide service standards and policies at least every three years. The FTA also requires transit providers to develop a policy to determine whether there is any bias on the grounds of race, color, or national origin based on the results of the monitoring activities. This is known as the Disparate Impact/Disproportionate Burden (DI/DB) policy.
Students often have to make several transfers to get to school and are always getting charged for each transfer. How does the MBTA and Boston Public Schools hold each other accountable to ensure students are not charged transfer fees and can receive their passes on time?
In response to the question, if a student has a student pass, there are no fees for transfers between buses and the subway. If a student is paying per trip on their Student CharlieCard, the same transfer rules apply as for adults. There is a free transfer from bus to bus. There is a free transfer from subway/rapid transit to the bus. If a student or anyone else transfers from bus to subway, they are charged the “step-up” price between the bus fare and the subway fare. The transfer is free, but the individual pays the subway trip price since they are now riding the subway.
The MBTA provides schools, including the Boston Public Schools, with Student CharlieCards. Student CharlieCards allow students to pay half-price for trips or purchase a Student monthly LinkPass for $30 at the MBTA Fare Vending Machines. Boston Public Schools pays for the Student Pass (called the M7) for students depending on how far they live from their school. The MBTA is only involved by providing the cards to BPS before the school year starts and shutting off cards when they are lost.
Does the MBTA consider bus stop relocation or elimination as an adverse effect?
Any individual movement of bus stops would usually involve several factors that are both within and outside of the MBTA’s control. For example, the type of changes we would make include, stop consolidation within reasonable stop spacing to improve reliability, stop elimination or relocations due to municipal request (which are outside of the MBTA’s control) and lastly, stop elimination due to lack of usage or in areas that are considered inaccessible. Any elimination of stops resulting in a longer walk for passengers can be offset by service quality or amenity improvements.
If I feel or see someone being discriminated against by an MBTA employee, how can I file a Title VI complaint?
To file a complaint alleging a violation of Title VI or related federal nondiscrimination law, contact the MBTA Title Specialist (via MBTA Customer Communications) within 180 days of the alleged discriminatory conduct at:
MBTA Customer Communications
10 Park Plaza, Suite 3910
Boston, MA 02116
617-222-3200 or 800-392-6100; or
Massachusetts Department of Transportation
The Office of Diversity and Civil Rights
10 Park Plaza
Boston, MA 02116
To file a complaint alleging a violation of the state’s Public Accommodation Law, contact the Massachusetts Commission Against Discrimination within 300 days of the alleged discriminatory conduct at:
Massachusetts Commission Against Discrimination (MCAD)
One Ashburton Place, 6th Floor
Boston, MA 02109
Talk to Us
Customer Support Representatives
617-222-3200 or 800-392-6100
Monday thru Friday 6:30 AM to 6:00 PM
10 Park Plaza, Suite 3910
Boston, MA 02116