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Notice of Request for Comments – Proposed Amendments to Board Policy No. 018-Regional Transit Service Planning and Implementation

SANDAG is in the process of circulating a draft of proposed revisions to Board Policy No. 18 for review and comment by two of its Policy Advisory Committees and the public. The proposed revisions can be found below. The revisions are being proposed in order to update the policy to clarify the process SANDAG uses to conduct equity analyses for transit fare changes to be incorporated in the Regional Comprehensive Fare Ordinance. Specifically, the policy will document the threshold of significance SANDAG will use to determine if a fare change will cause low income or minority populations to bear an unequal proportion of any adverse effects that could result from the fare change. These analyses are required by the Civil Rights Act of 1964 and Executive Order 12898.

The threshold of significance that is proposed for comment is 10%. This means that if after analyzing the impacts of a fare change on low income and minority communities to non-low income and non-minority populations in the affected transit service area, the statistics show that low income or minority populations will suffer 10% or higher adverse impacts than non-low income and minority populations, then SANDAG would be required to look at alternatives and mitigating factors. The 10% threshold is being proposed for the following reasons:

• The US Supreme Court has held that differences of less than 20% when conducting a disparity analysis are within the range of differences that can occur by mere chance.

• Use of a 10% threshold would be consistent with informal thresholds used by SANDAG on past fare change equity analyses.

• A peer analysis of other agencies shows that a majority of other agencies nationwide have set a threshold of significance that is higher than 10%, and that most are within the range of 5% to 20%.

• The Federal Transit Administration Title VI Circular provides only one example for agencies as guidance in selecting a threshold of significance and that example is 10%.

• The Federal Transit Administration requires agencies to report data with 10% precision at the 95% confidence level. As long as the data reported is within that threshold, the data is assumed to be valid.

SANDAG is seeking comments from the public on the draft changes to Board Policy No. 018. If you would like to provide comments, please attend the Transportation Committee meeting at SANDAG at 9:00 AM on Friday, March 15, 2013; the Executive Committee meeting at SANDAG at 9:00 AM on Friday, April 12, 2013, or the Social Services Transportation Advisory Committee meeting at SANDAG on Monday, March 18, 2013 at 10 AM. You may also provide your comments using the information below by no later than 5:00 PM on Monday, April 8, 2013.

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Leave Voicemail Comments at: (619) 595-5358