Loudoun County Transit: Proposed Title VI Policy Changes
Title VI of the Civil Rights Act of 1964
requires that Loudoun County Transit develop three policies to analyze transit service changes and fare changes for discriminatory impacts. These policies are the major service change policy, disparate impact policy, and disproportionate burden policy.
- Each time a service change (such as a change in a bus route or schedule) is proposed, Loudoun County Transit will determine whether the change is a major service change.
- If the proposed service change qualifies as a major service change, Loudoun County Transit will analyze whether the change is adversely effecting minority populations in a disparate manner and low-income populations in a disproportionate manner.
- Every time a fare change is proposed, Loudoun County transit will analyze whether the fare change will affect minority populations in a disparate manner and low-income populations in a disproportionate manner
If a transit service change or a fare change would result in a disparate impact or disproportionate burden to minority or low-income populations, Loudoun County Transit is required to avoid, minimize or mitigate the impact, and can only implement the service or fare change if there is substantial legitimate justification for the change and
there are no alternatives that would have less of an impact on the county’s minority and low-income communities.
Proposed Title VI Policies
Loudoun County Transit is considering these proposed Title VI Policies:
Draft Major Service Change Policy
A major service change is defined as:
Draft Disparate Impact Policy
- Adding or eliminating a bus route.
- Any change in service on any individual bus route that would add or eliminate more than 25% of the route’s weekly revenue miles (the number of mile a bus operates while carrying paying passengers).
- Any change in service on any individual bus route that would add or eliminate more than 25% of the route’s weekly revenue hours (the number of hours a bus operates while carrying paying passengers).
A disparate impact is when the average fare or service change impacts for minority riders is 15 percent or greater than non-minority riders.
Draft Disproportionate Burden Policy
A disproportionate burden is when the average fare or service change impacts for low-income riders is more than 15 percent or greater than non-low-income riders.
Loudoun County Transit accepted public comment on these policies via its website, email, U.S. mail, and outreach events from April 15, 2016 through May 15, 2016. Now that the public comment period is closed, staff will analyze all public comments received, and revise the proposed policies as appropriate. The policies will subsequently be submitted to the Loudoun County Board of Supervisors for approval.
Information about Loudoun County's current Title VI policies is online here