Sample of Large Title VI Plan

Title VI Program
Updated 2019

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UTA Title VI Program

(Intentionally Left Blank)

TABLE OF CONTENTS

Introduction .................................................................................................................................................. 1
General Requirements................................................................................................................................. 2
Title VI Notice to the Public .................................................................................................................... 2
Title VI Complaint Procedure .................................................................................................................. 3
Title VI Investigations, Complaints, and Lawsuits ................................................................................. 3
Public Participation Plan......................................................................................................................... 4
Summary of Outreach Efforts ................................................................................................................. 4
Language Assistance Plan .................................................................................................................. 15
Subrecipient Monitoring ...................................................................................................................... 15
Board Membership and Recruitment ................................................................................................. 17
Facilities Siting and Construction ....................................................................................................... 18
Service and Fare Equity Analyses ....................................................................................................... 18
Title VI Policies .......................................................................................................................................... 19
Major Service Change Policy ............................................................................................................... 20
Disparate Impact & Disproportionate Burden Policy ......................................................................... 20
System-Wide Service Standards & Service Monitoring .......................................................................... 23
Vehicle Loads ....................................................................................................................................... 23
Vehicle Headways ................................................................................................................................ 24
On-Time Performance .......................................................................................................................... 25
Service Availability ............................................................................................................................... 26
Distribution of Amenities ..................................................................................................................... 27
Vehicle Assignment.............................................................................................................................. 29
Demographic Data Report ........................................................................................................................ 31
Current Service and Service Area ....................................................................................................... 31
Ridership Characteristics and Demographics .................................................................................... 45
Attachment A – Notice to the Public ........................................................................................................ 52
Attachment B – Title VI Complaint Form ................................................................................................. 54
Attachment C – Customer Communications Policy ................................................................................ 58
Attachment D – List of Complaints .......................................................................................................... 61
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Attachment E – Title VI Compliance Policy .............................................................................................. 76
Attachment F – Public Input Opportunities Policy .................................................................................. 81
Attachment G – LEP Plan ......................................................................................................................... 87
Attachment H – Ridership Survey .......................................................................................................... 102
Attachment I – Board Resolution on Title VI Program .......................................................................... 104
Attachment J – Service and Fare Equity Analyses ................................................................................ 107

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INTRODUCTION

Transportation has been at the forefront of the push for equal treatment and civil rights.
Transit is a point of integration and opportunity for those that need and use it. Transit serves
as a bridge within homes and communities, connecting people both socially and
professionally. Transit’s unique position in our society has put it in the center of the fight for
equality in the United States. From the early fight against the segregation of rail cars in the
19th Century to the impetus of the modern Civil Rights movement when Rosa Parks refused
to give up her seat and the Montgomery Bus Boycott that followed, Transit has been part of
the movement. The Utah Transit Authority (UTA), under the guidance and direction of the
Federal Transit Administration’s guidance found in Circular 4702.1B “Title VI Requirements
and Guidelines” prepares this Title VI program as an intentional process aimed at preventing
unintentional discrimination in the delivery of our services and programs.

TITLE VI OF THE CIVIL RIGHTS ACT OF 1964

The Civil Rights Act of 1964 was signed into law to combat and curtail common practices
that systematically denied the rights of certain people based on their race, the color of their
skin and/or the nation in which they were born. The act included eleven “titles”, which
provided legal protections and outlined requirements aimed at the equitable treatment of
historically disadvantaged populations.
No person in the United States shall, on the ground of race, color, or national origin,
be excluded from participating in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving Federal financial assistance.
- Title VI of the Civil Rights Act of 1964
Title VI specifically outlines that agencies, such as UTA, must ensure the equitable
distribution and delivery of its federally funded programs and services. In consideration of
the extensive reach of transit agencies’ ability to impact the lives of those who utilize its
services, the Federal Transit Administration (FTA) has issued specific guidance on Title VI
compliance in FTA Circular 4702.1B. The circular is designed to help FTA recipients ensure
the level and quality of public transportation service is provided in a nondiscriminatory
manner, promote full and fair participation in public transportation decision-making without
regard to race, color, or national origin and ensure meaningful access to transit-related
programs and activities by persons with limited English proficiency.

UTA’S COMMITMENT

UTA has established a series of core values that guide its service model, one of which is
inclusivity. The organization welcomes robust representation and diversity and prioritizes the
community it serves as a True North that guides its decisions and service. It is the Authority’s
commitment to follow what John F. Kennedy called “simple justice, [which] requires that
public funds, to which all taxpayers of all races contribute, not be spent in any fashion which
encourages, entrenches, subsidizes, or results in racial discrimination.”

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GENERAL REQUIREMENTS

All recipients of funding from the FTA are required to “keep such records and submit to the
secretary timely, complete, and accurate reports at such times, and in such form and
containing such information, as the secretary may determine to be necessary to enable him
to ascertain whether the recipient has complied or is complying with this [rule].” 1 Guidance
on how to fulfill recordkeeping requirements are further elaborated upon and clarified within
FTA circular 4902.1B. The circular states that primary recipients must submit their
documentation of compliance on a three year basis and that the entity’s governing entity
must approve the Title VI Program prior to submission. The approval of UTA’s Title VI Program
has been included as Attachment I.
Chapter III of the circular also outlines the components that are required of all recipients of
FTA funds. They include:
1.
2.
3.
4.
5.
6.
7.
8.
9.

Title VI Public Notice
Title VI Complaint Procedures
List of Title VI Investigations, Complaints, and Lawsuits
Public Participation Plan
Language Assistance Plan
Board Membership and Recruitment
Subrecipient Monitoring
Facilities Siting and Construction
Equity Analyses of major service and fare changes implanted since the previous Title
VI program submission

TITLE VI NOTICE TO THE PUBLIC

The FTA requires that transit agencies inform the public of their rights and protections under
Title VI. UTA strives to keep members of the public apprised of their rights and protections
against discrimination afforded them in Title VI by providing and posting a notice to the public
explaining their rights at various locations throughout the system and on UTA’s website,
Rideuta.com. A copy of the notice can be found in Attachment A.

LIST OF LOCATIONS NOTICE IS POSTED

UTA has taken action to make this notice visible and consistently present throughout its
transit system. Below is a list of the locations the notice is posted.
• All TRAX and FrontRunner train stations
• All fixed route and paratransit buses
• UTA Front Lines Headquarters entrance at 669 West 200 South, Salt Lake City
• Customer Service / Lost & Found Office, 600 West 250 South, Salt Lake City
• Customer Service Office, 3600 South 700 West, Salt Lake City
• Timpanogos Transit Center, 1145 South 750 East, Orem
1

49 CFR Part 21.9(b)

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• Ogden Transit Center, 2393 South Wall Ave, Ogden

TITLE VI COMPLAINT PROCEDURE

UTA’s Title VI notice to the public includes instructions on how to file a complaint alleging
discrimination on the basis of race, color and national origin through UTA’s customer service
line. There is also an option to submit a complaint online or through a downloadable Civil
Rights complaint form. Any complaint received through the customer service line can be
flagged as Civil Rights related and the Civil Rights Department is notified through the
electronic customer feedback database where complaints are recorded and tracked.
Included in Attachment B is UTA’s official Civil Rights complaint form in English and Spanish.
An ADA accessible version of this form that can be translated into multiple languages is
available through an online form, which is emailed directly to the Civil Rights Department.
UTA follows Corporate Policy 5.1.1, Customer Communications, which is included as
Attachment C in this program. This corporate policy outlines the process used to investigate
and track complaints related to Title VI.

TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS

FTA requires all recipients to prepare and maintain a list of any of the following
that allege discrimination on the basis of race, color, or national origin: active
investigations conducted by entities other than FTA; lawsuits; and complaints
naming the recipient. This list shall include the date that the investigation, lawsuit,
or complaint was filed; a summary of the allegation(s); the status of the
investigation, lawsuit, or complaint; and actions taken by the recipient in response,
or final findings related to, the investigation, lawsuit, or complaint. This list shall be
included in the Title VI Program submitted to FTA every three years.
- FTA Circular 4702.1B

In compliance with the above directive, UTA will list all investigations, lawsuits and
complaints throughout the period of 2016, 2017 and 2018.

INVESTIGATIONS

On February 19, 2016, Michael Clara filed Complaint No. 2016-0151 with FTA. In that
complaint, he primarily alleged that UTA failed to grant a request by the Glendale Middle
School Community Council to install a bus stop and that UTA had failed to conduct a service
equity analysis of its streetcar project. UTA submitted a response on June 17, 2016. FTA
informed Mr. Clara by letter dated October 7, 2016 that the information reviewed by FTA did
not support a finding that UTA had failed to comply with Title VI requirements.

LAWSUITS

There were no Title VI lawsuits during the reporting period.

COMPLAINTS

UTA has had 195 customer service complaints in which the complainant alleged
discrimination on the basis of race, color, or national origin. A full list of the complaints is

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included as Attachment D. These complaints were received, investigated and resolved
internally by UTA staff in accordance with UTA Corporate Policy 5.1.1 (Attachment C).
A customer has many options when making a complaint alleging discrimination. A customer
can call into customer service, submit an electronic Civil Rights complaint through UTA’s
online form, submit a paper form, or issue a complaint to any department where a record can
be recorded and tracked with UTA’s customer feedback database. This is an intentionally
inclusive approach, designed to ensure that any complaint alleging discrimination on the
basis of a protected class is addressed appropriately and that Civil Rights staff is notified and
involved where appropriate.

PUBLIC PARTICIPATION PLAN

Public involvement is an integral part of proactively ensuring unintentional negative impacts
on protected populations. In order to incorporate the voices of the public in its planning,
service, and programs UTA has developed two policies. They are 1.1.28 – Title VI Compliance
Policy (Attachment E) and 1.1.6 – Public Input Opportunities (Attachment F). These policies
outline the outreach methods used to engage minority and limited English proficient
populations in discussions about service and fare changes.

SUMMARY OF OUTREACH EFFORTS

The Authority has the potential of implementing major service changes three times per year
on “change day”. These change days occur once in April, August, and December. With the
exception of the Provo-Orem BRT analysis being approved in March of 2018, all of the major
changes and solicitations for public input occurred during these times of year. The following
change days had at least one major change and included a public input process.
•
•
•
•
•
•
•
•

April 2016
August 2016
December 2016
April 2017
August 2017
April 2018
August 2018
December 2018

APRIL 2016 PUBLIC OUTREACH

The April 2016 change day had two route eliminations, four routes with route changes, two
routes with increased frequency, trips added to two routes and various minor adjustments to
routes to improve service and efficiency.

PUBLIC OUTREACH & COMMENT
Public comment period held December 18 – February 5. Below is a summary of the activities
UTA conducted to inform riders and solicit feedback.

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•
•
•

•
•
•

Public hearing notice was published in the Provo Daily Herald, on the state website
and on UTA’s website.
A formal public open house was held January 5 at the Provo City Library.
Comments were accepted via UTA’s website, via email at
[email protected], through the mail and by phone through UTA Customer
Service.
Notices placed on affected bus routes to inform riders of the proposed changes and
opportunities to provide comment.
Personal contact made with the customers on the affected routes; alternative
transportation solutions for affected riders being discussed.
Proposed changes presented to Utah County local elected officials at the February
meeting of the Utah County Regional Planning Committee.

SUMMARY OF COMMENTS
During the comment period, UTA received a total of four comments. Two comments were
received at the open house and the other two comments received via email. Below is a
summary of the comments received.
•
•
•
•

One commenter was in favor of the changes due to the increased service on other
routes.
One commenter was disappointed, but understood the reasons for the changes after
discussion with staff.
One commenter opposed the change due to personal hardship; staff is working on
alternative solutions.
One comment was unrelated to the proposal.

AUGUST 2016 PUBLIC OUTREACH
PUBLIC COMMENT AND OUTREACH

In accordance with UTA policy, a public comment period was held from April 22 through May
23, 2016. Several activities were conducted during this period to inform riders and the public
and to obtain feedback:
•
•
•
•

•

The public hearing notice was published in The Salt Lake Tribune and the Deseret
News, on the state website and on rideuta.com.
A formal public open house was held for changes made in the Salt Lake Business
Unit at West Valley City Hall at 3600 South Constitution Boulevard in West Valley City.
A formal public open house was held for changes made in the Mt. Ogden Business
Unit at the Davis County Central Library at 155 Wasatch Drive Layton, UT
Comments were accepted via UTA’s website, via email at
[email protected], through the mail, and by phone through UTA Customer
Service.
Notices were placed on the affected bus routes to inform riders of the proposed
changes and opportunities to provide comment.

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•

The proposed changes were discussed in a business meeting with Salt Lake County
representatives and UTA planners.

Overall, four comments were received for the Salt Lake Business Unit during the proposal’s
comment period – one at the public hearing and three at [email protected]. Low
participation is directly related to the proposed changes eliminating required transfers,
allowing passengers on these routes to experience a “one-seat” ride while traveling east to
west across the Salt Lake Valley. Cost savings from the changes would also allow planners to
increase Sunday frequency on routes 33 and 35.
Eight comments were received for the Mt. Ogden Business Unit during the proposal’s
comment period – six at the public hearing and two at [email protected]

COMMENTS:
SALT LAKE BUSINESS UNIT:
•
•
•
•

One commenter wrote that he “strongly supports” the proposed changes.
A second commenter supported the changes but also suggested that routes 41 and
45 be combined in the same manner.
One online commenter didn’t provide feedback on the proposal but did ask for more
service in the Draper and South Jordan areas.
The fourth comment was received at the official public hearing and asked UTA to
make adjustments in its ridership counting methodology.

MT. OGDEN BUSINESS UNIT:
•
•
•
•
•

One commenter expressed support for the changes
Two commenters said they supported the changes and suggested more service to a
local school
One commenter expressed a desire for a stop near the mall
Three commenters didn’t provide feedback on the proposal but did ask for more
service elsewhere.
One commenter expressed concern on the routes he used to ride no longer providing
for his needs and made suggestions on how they could be improved.

OUTCOME:
Based on the feedback received, the following changes were made:
•

•
•
•

Route 33 was extended from the Millcreek TRAX Station to West Valley Central
Station. It follows the previous path for route 35 and will run on 15-minute headways
on weekdays.
Route 35 terminates at West Valley Central Station. Routes 33 and 35 will always
interline so passengers no longer need to transfer at West Valley Central Station.
Span of service on Sundays for routes 33 and 35 was extended from 9 a.m. to 7 p.m.
to 7 a.m. to 8 p.m.
Sunday service frequency for routes 33 and 35 were increased, providing all-day, 30
minute service. Previously, the routes offered 60-minute frequencies on Sundays.

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•

•

Route 39 terminates at the Meadowbrook TRAX Station and interlines with route 41.
This eliminated the need for passengers to transfer buses in order to continue
traveling east or west.
All changes proposed in Mt. Ogden Business Unite proceeded as proposed.

The primary reason for these changes was to improve the passenger experience by giving
riders a one-seat ride across the valley along two major corridors (3300/3500 South and
3900/4100 South).

APRIL 2017 PUBLIC OUTREACH
ROUTE 667

The public comment period for this change occurred from January 5 to February 5 of 2017.
Notice was listed on UTA’s website, the state website, Utah.gov, the Ogden Standard
Examiner and the Davis County Clipper, both local newspapers. Comments were accepted
via mail, email, at the public hearing and by phone. The public hearing was held on January
19, 2017. It was publicized by and held at the PARC facility. Seven people attended this
meeting and there was no opposition to the proposed changes. One respondent was
somewhat supportive, but offered alternative proposals. This information was provided to the
Planning Department for consideration.
In addition to the public hearing and public comment period, all known riders’ care providers
were identified and directly contacted by UTA’s Special Services Business Unit.

ROUTE 477
The public comment period for this change occurred from January 5 to February 5 of 2017.
Notice was listed on UTA’s website, Utah.gov, the Ogden Standard Examiner and the Davis
County Clipper, both local newspapers. The public hearing was held on January 19, 2017.
Comments were accepted via mail, email, at the public hearing, phone and Open UTA, which
is an online forum for discussion. The public outreach hearing was held January 26, 2017 at
the Farmington City Hall. In addition to this, UTA made direct contact with Farmington City,
Station Park, Lagoon, Hampton Inn and the University Medical Center in the region regarding
the change.
Response from Farmington City and local businesses were all positive and 50% of
community members were in support of the changes. 50% of community responses were
opposed. The three respondents in opposition to the changes expressed concern regarding
access to Lagoon and downtown Farmington locations during peak times. Alternative routes,
specifically routes 455 and 470, are able to provide transportation to the specified locations.
One respondent suggested running a second route to downtown or having the 667 resume a
more frequent downtown schedule during Lagoon’s off-season. UTA Planning is considering
both options for future proposed changes.

AUGUST 2017 PUBLIC OUTREACH

For August 2017 Change Day, the UTA Ogden Business Unit proposed changes for routes
626 and 627 and the elimination of routes 664 and 665, which provide service to Hill Air
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Force Base. UTA proposed changing the southern terminus of route 626 to the Clearfield
FrontRunner station instead of the Weber State Davis campus. The route would then change
to the 627 at the Clearfield FrontRunner station and continue to the Weber State Davis
campus.

PUBLIC COMMENT AND OUTREACH
In accordance with UTA policy, a public comment period was held from April 10 through May
10, 2017. Several activities were conducted during this period to inform riders and the public
and to obtain feedback:
•

•
•
•
•

The public hearing notice was published in the Standard Examiner, the Davis County
Clipper, on the state’s public notice website and on rideuta.com. Information on the
comment period was also published on UTA’s social media channels.
One formal public open house was held on April 25 at the Weber State Davis Campus
(2750 University Park Blvd., Layton, Utah). The hearing was attended by 11 people.
Fliers were posted on Ogden Business Unit buses, especially those that serviced the
base.
Hill Air Force Base was directly contacted, and UTA worked with the base to publicize
the comment period.
Comments were accepted via UTA’s website, via email at
[email protected], through the mail and by phone. Comments were also
accepted on the Open UTA platform. (59 comments overall for route 664 and 665
proposal, 33 visitors for the route 626 and 627 proposal). Registered users on Open
UTA received an email inviting them to review the proposals and provide feedback.

Overall, 12 comments were received during the proposal’s comment period for the route 626
and 627 proposal – two at the public hearing, six on Open UTA and four at
[email protected]. For the route 664 and 665 proposal, 30 comments were
received – 7 at the public hearing, 8 at [email protected] and 15 on the Open UTA
system.

THE PROPOSED CHANGES WERE AS FOLLOWS:
(From the public notice)
Routes 626 and 627 – The route 626 proposal includes moving the southern terminus of the
route to the Clearfield FrontRunner station instead of the Weber State Davis campus. The
route will then change to the 627 at the Clearfield FrontRunner station and continue to the
Weber State Davis campus. The route 627 proposal also includes extending the north
section of the route from the Weber State Davis campus to the Clearfield FrontRunner
station, where it will connect with the realigned 626. No other changes are proposed for the
existing 626 or 627 alignments. The proposal also includes adding 30-minute peak hour
weekday service to both routes, increasing the weekday span of service to roughly 9 p.m.,
and adding 60-minute Saturday service to both routes.
(From the public notice)

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Routes 664 and 665 – UTA proposes to eliminate these two routes due to low ridership.
Representatives from UTA Rideshare will be available to explain vanpool and other
transportation options during the public hearing.

COMMENTS:
For routes 626 and 627 – Eleven comments were in support of the proposal. One comment
received was neutral and offered an alternative service scenario.
For routes 664 and 665, five comments were for the proposal, 20 comments were against,
and 5 were neutral or undecided. Many commenters offered alternative proposals, all of
which were forwarded to the planning staff at the Ogden Business Unit.

OUTCOME:
Based on the feedback received and other factors, both proposals moved forward for UTA’s
August Change Day beginning April 17, 2017.

APRIL 2018

For April 2018 Change Day, the UTA Timpanogos (Utah County) Business Unit proposed
changes for routes 833, 834, 840 and 864. The proposal for routes 833 and 834 included
the elimination of two weekday trips due to schedule changes related to the implementation
of Positive Train Control on FrontRunner and a discontinuation of all Saturday trips due to low
ridership. The route 840 (a seasonal route) proposal called for the route to be discontinued
and replaced by adding additional route 841 trips, and the route 864 is a proposed new
route to serve the west side of I-15 near the Lehi Station.

PUBLIC COMMENTS AND OUTREACH
In accordance with UTA policy, a public comment period was held from January 4 through
February 13, 2018. Several activities were conducted during this period to inform riders and
the public and to obtain feedback:
•

The public hearing notice was published in the Provo Daily Herald, on the state’s public
notice website and on rideuta.com. Information on the comment period and hearing was
also published on UTA’s social media channels. In addition, the UTA’s Special Services
business unit sent postcards to each impacted paratransit customer or to the customer’s
caregiver.

•

Two formal public open houses were held. One open house took place January 18 at the
Provo City Library (550 North University Avenue in Provo, Utah), and the second took
place January 29 at the Provo Recreation Center (320 West 500 North in Provo, Utah). A
total of 28 people attended the two hearings.

•

Fliers were posted on select Utah County buses and on Utah County paratransit vehicles.

•

Comments were accepted via UTA’s website, via email at [email protected],
through the mail and by phone.

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Overall, seven comments were received on all proposals. One commenter (received via
email) provided feedback in regards to the proposed new route, route 864. The commenter
suggested some adjustments to the proposal in order for transit to better accommodate his
growing business. The commenter also offered to provide bus turnaround and pull out
locations near his office building.
A total of six comments were received regarding the service proposals for routes 833 and
834 – four via email, one at the public hearing and one via telephone. All comments were in
opposition to the elimination of Saturday service on these routes, mainly due to the negative
impact this change would have on area paratransit customers. Additionally, at the public
hearing held on January 29, those who attended were generally opposed to the changes for
route 833.
No comments were received regarding the proposed cancellation of route 840.

THE PROPOSED CHANGES WERE AS FOLLOWS:
(From the public notice)
•
•

•

•
•

Route 833: Elimination of two weekday trips due to schedule changes. All Saturday trips
will be discontinued due to low ridership.
Route 834: Elimination of two weekday trips due to schedule changes. Route will be
extended to the intersection of Orem Center Street and State Street to allow for transfers
to route 850 near Orem City Offices. All Saturday trips will be discontinued due to low
ridership.
Route 840: Route to be discontinued and replaced by adding additional route 841 trips.
Proposed change will provide customers with more seat availability between the Orem
FrontRunner Station and Utah Valley University.
Route 864: This is a proposed new route to serve the west side of I-15 near Lehi Station.
Route will be interlined with route 863 and will only offer weekday peak hour service.
The proposed fixed bus route changes should be of interest to paratransit eligible riders.
UTA is required to provide paratransit at a comparable level of service as to what is
provided by the fixed route system. The public transportation guidelines of the Americans
with Disabilities Act (ADA) require UTA to provide paratransit services only within a ¾ mile
service corridor on either side of a fixed bus route and around a light rail (TRAX) station.
UTA Paratransit must provide services during the same days and hours of operation as
these fixed route services. Areas that would no longer have fixed bus routes would no
longer have direct curb-to-curb paratransit services.

OUTCOME:
Based on the feedback received and other factors, the proposal for route 833 did not move
forward. For route 834, the proposed alignment changes proceeded, but Saturday service
was not eliminated. Route 840 is seasonal service, and the route was discontinued for the
season but was not permanently eliminated as proposed, and the addition of route 864
proceeded as outlined. Service changes begin April 8, 2018.

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AUGUST 2018 & PROVO-OREM BRT (UVX)
TIMPANOGOS BUSINESS UNIT

For August 2018 Change Day, the UTA Timpanogos (Utah County) Business Unit proposed
changes to several routes. The proposed changes were as follows:

NEW SERVICE
•

The Provo-Orem BRT, now called the Utah Valley Express or “UVX,” will begin operation,
replacing the Routes 830 and 838 fixed bus service.

ALIGNMENT CHANGES
•

Route 821: realigned near the Provo Towne Center Mall to use University Avenue
between East Bay Blvd. and 920 South in both directions in south Provo. Provo Towne
Centre Mall will be served by UVX.

•

Routes 811/850/862: stop changes in Orem to connect to UVX near Orem University
Place Mall.

CONNECTING CHANGES
•
•
•

Route 841: more trips to enhance connectivity between Orem Station/UVU.
Route 840: eliminated around campus (all stops covered by 841).
Route 862: extended to the Orem Station and replace some Route 830 stops.

PUBLIC COMMENTS AND OUTREACH

In accordance with UTA policy, a public comment period was held from April 25 through May
24, 2018. Several activities were conducted during this period to inform riders and the public
and to obtain feedback:
•

•

•
•

A public hearing notice was published in the Provo Daily Herald, on the state’s public
notice website and on rideuta.com. Information on the comment period and hearing was
also published on UTA’s social media channels.
Three formal public open houses were held: on May 15 from 5-7 p.m. at the Provo City
Library; on May 16 from 6-8 p.m. at the Spanish Fork Senior Center; on May 17 from 5-7
p.m. at the American Fork Senior Center.
A total of 10 people attended the three public hearings.
Comments were accepted via UTA’s website, via email at [email protected],
through the mail and by phone.

A total of seven comments were received regarding the service proposals. One via email and
six at the public open houses. Comments included excitement about the opening of the UVX
and support for FrontRunner service and passes for UVU, desire for more bus service overall,
and concern/suggestions for improving connections/transfers between FrontRunner and
bus. One person commented that it’s difficult to go to Salt Lake County for paratransit
eligibility.
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Based on the feedback received and other factors, the proposed service changes will be
implemented on August 13, 2018. In addition, an unrelated comment received regarding
Route 831 was adopted by UTA service planners.

SALT LAKE BUSINESS UNIT
For August 2018 Change Day, the UTA Salt Lake (Salt Lake County) Business Unit proposed
changes weekday and Saturday changes to Routes 33, 35 and 35M, and changes to Routes
39 and 41. The proposed changes were as follows:

WEEKDAYS
•
•

Route 35M: Begin service at 6 a.m. and end service at 7 p.m.
Route 33 and 35: Begin service at 4:15 a.m. from Magna and 5:15 a.m. from
Millcreek Station. Service would begin early enough from Magna that the existing
connection to the first northbound Blue Line TRAX would be maintained. End service
at 10:30 p.m. from Magna and 11:30 p.m. from Millcreek Station.

SATURDAYS
•
•

Route 35M: Begin service at 9 a.m. and end service at 7 p.m.
Route 33 and 35: Begin service at 6 a.m. and end service at 11 p.m. Service on
3300 South between Millcreek Station and Wasatch Boulevard, would largely remain
the same.

ROUTES 39 AND 41: to make better connections to the Green Line at West Valley Central
Station.
•

•

Route 39: extend west from Meadowbrook Station to West Valley Central Station via
the current Route 41 alignment. At West Valley Central Station, Route 39 would turn
into Route 41, maintaining a one-seat ride between Wasatch Blvd. and 5600 West.
Route 41: shorten route to end at West Valley Central Station on the eastern end. At
West Valley Central Station, Route 41 would turn into Route 39, maintaining a oneseat ride between 5600 West and Wasatch Boulevard.

PUBLIC COMMENTS AND OUTREACH

In accordance with UTA policy, a public comment period was held from April 18 - May 17,
2018. Several activities were conducted during this period to inform riders and the public
and to obtain feedback:
•

•
•

A public hearing notice was published in the Salt Lake Tribune and Deseret News, on
the state’s public notice website and on rideuta.com. Information on the comment
period and hearing was also published on UTA’s social media channels.
Two formal public open houses were held: on May 3 from 4-6 p.m. at West Valley
City Hall; on May 9 from 6:30-8 p.m. at the Magna Library.
A total of 6 people attended the public hearings.

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•

Comments were accepted via UTA’s website, via email at
[email protected], through the mail and by phone.

A total of five (5) comments were received regarding the service proposals. One via email,
one via phone to Eric Callison, and three at the public open houses. Comments included
support for the changes to Route 39 and 41, concern about travel time on Route 35 versus
Route 35M, concern about connections, and a comment about future plans to extend Route
35M to the top of 3300 South.
Based on the feedback received and other factors, the proposed changes to morning service
on Route 33, 35 and 35M were not implemented. The remaining proposed service changes
began August 13, 2018.

OGDEN BUSINESS UNIT
For August 2018 Change Day, the UTA Ogden (Davis and Weber Counties) Business Unit
proposed the following service changes:
•
•

FrontRunner: commuter rail service will be suspended between Ogden and Pleasant
View after August 10, 2018.
Route 616: modified schedule with increased frequency and span of service in
conjunction with the FrontRunner changes.

PUBLIC COMMENTS AND OUTREACH
In accordance with UTA policy, a public comment period was held from May 1 – June 1,
2018. Several activities were conducted during this period to inform riders and the public
and to obtain feedback:
•

•

•
•

•

A public hearing notice was published in the Ogden Standard Examiner, on the
state’s public notice website and on rideuta.com. Information on the comment period
and hearing was also published on UTA’s social media channels.
Two formal public open houses were held: on May 16 from 4:30 – 6:30 p.m. at the
Pleasant View Municipal Building; on May 17 from 4:30 – 6:30 pm. at the North
Ogden City Council Chambers.
o A total of 1 person attended the public hearings.
Comments were accepted via UTA’s website, via email at
[email protected], through the mail and by phone.
Two additional open houses were held in advance of the formal public hearings: May
12 in Pleasant View and May 14 in North Ogden.
o A total of 41 people attended the open houses
An on-board survey was also conducted of riders on FrontRunner between Ogden and
Pleasant View (northbound and southbound) and on Route 616. The survey was also
made available at the open houses.

A total of two comments were received regarding the service proposals, both via email.
Comments included support for the proposed changes to Route 616 and expressed desire
for more bus service – specifically on the west side of I-15 through Farr West - and future
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long-term improvements to FrontRunner. One comment reflected over-crowding on some
trips since the previous change day.
Based on the feedback received and other factors, the proposed service changes will be
implemented on August 13, 2018.

DECEMBER 2018

SPECIAL SERVICES BUSINESS UNIT
For December 2018 Change Day, the UTA Special Service Business Unit proposed
implementing a new Flex route, F605, to service the Centerville, West Bountiful, Woods Cross
and Bountiful communities. Flex route buses run on a fixed route and schedule, but unlike
regular bus routes, passengers can request in advance a deviation or a special stop up to ¾
of a mile from the regular route.
The route is proposed to have a fixed alignment with set time points but will deviate up to ¾
mile upon advanced request. The route is also proposed to run select trips to the Woods
Cross FrontRunner station. The proposed F605 would operate weekdays from 6:00 a.m. to
9:00 p.m., with 30-minute frequency all day. No Saturday or Sunday service is proposed.

PUBLIC COMMENT AND OUTREACH
In accordance with UTA policy, a public comment period was held from September 11
through October 10, 2018. Several activities were conducted during this period to inform
riders and the public and obtain feedback.
•

•
•

A public hearing notice was published in the Salt Lake Tribune, Ogden Standard
Examiner and the Davis County Clipper. The notice was also published on the State’s
public notice website and on www.rideuta.com. Information on the comment period
was also published on UTA’s social media channels.
One formal public open house was held on September 26, 2018 from 4:30 p.m. until
6:30 p.m. The open house was held at the Davis County Library South Branch.
Comments were also accepted via UTA’s website, email at
[email protected], through the mail and by phone.

A total of three people attended the open house, although none submitted written comment.
A total of eight (8) comments were received by email to [email protected], and a
total of seven (7) comments were received via UTA’s website and Customer Comment
system. One of the comment received included a letter from residents of Centerville, Utah
accompanied by the names and addresses of 86 residents.
Comments included support for the new route, but concerns were expressed about a section
of the alignment along DaVinci Lane between Main Street and 400 West, and the proposed
location for a bus stop.
Based on the feedback received and in response to residents’ significant concerns about the
route along DaVinci Lane, UTA proceeded with implementing the new route in December, but
planners adjusted the alignment for the F605 to use 400 South instead of DaVinci Lane.
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LANGUAGE ASSISTANCE PLAN

UTA is committed to being fully compliant with Title VI and Executive Order 13166 and to
truly find ways to provide meaningful access to people with limited English proficiency. In
order to accomplish this, UTA prepared a Limited English Proficiency (LEP) Plan and has
included it in this program as Attachment G.

SUBRECIPIENT MONITORING

To provide subrecipients of federal funds assistance and information to ensure continued
compliance with all grant requirements, UTA conducts three levels of subrecipient
monitoring: project oversight, assessments and ongoing assistance.

PROJECT OVERSIGHT

UTA’s Subrecipient Monitoring Procedures outline pre and post-award compliance
requirements for subrecipients including pre-award document submission and review, post
award compliance monitoring and closeout. Subrecipients are required to upload financial
and program documents and civil rights documents including a Title VI plan during the
application process.
Post-award compliance activities ensure subrecipients are compliant with federal and state
regulations. For the eligible activities in this program, this includes compliance in areas such
as financial management, technical capacity, procurement, asset management (use,
protection, maintenance, etc.), and civil rights, including Title VI, ADA, and DBE.
UTA requires all subrecipients to follow UTA's policies and procedures. As part of UTA's
compliance program, site visits and inspections are performed for each subrecipient at least
biennially. Quarterly and annual financial and performance reporting are also required to
ensure subrecipients are using federal funds for the purpose they were intended. All UTA
subrecipient awards are managed through an online grant management system which
generates notifications to subrecipients when reporting and other compliance activities are
due. UTA is also notified when subrecipients submit reports and if subrecipients are noncompliant with reporting requirements.
Close-out activities are conducted following final payment of funds for the project. All
expenses, reimbursement and procurement activities are reviewed and a final report is
completed by the subrecipients to ensure compliance with the award requirements.
Additional continuous control responsibilities are reviewed.

ASSESSMENTS

The Grant Administrator performs annual risk assessments of subrecipients by conducting
annual compliance reviews, which includes reviewing external annual audits,
monthly/quarterly performance reports and Title VI plans and other documents. If results of
assessments identify known or potential concerns, the Grant Administrator may conduct
additional procedures such as testing payments, site audits to gain an understanding of
internal controls and ensuring federal requirements are met including equipment reporting
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wage requirements, match and suspension and debarment when applicable. All
procurements over $3,000 are conducted by UTA to ensure compliance with federal
procurement rules.
Further, the Grant Administrator monitors and provides feedback and training to
subrecipients on federal compliance requirements. UTA’s Internal Audit and Accounting
Departments also serves as a resource to management in providing special reviews of
financial, operational and/or regulatory compliance. Upon request, Internal Audit can review
selected programs and assist staff with recommendations by providing independent and
objective consulting services.

SUBRECIPIENT TILE VI PROGRAM REVIEW

As a designated recipient of FTA funds, UTA receives, administers and allocates funds to
subrecipients and is responsible for documenting compliance with Title VI. UTA’s
responsibilities include monitoring subrecipient compliance with Title VI, collecting and
reviewing Title VI documents, including subrecipient Title VI data to FTA and providing
assistance and support to subrecipients.
In the case in which a primary recipient extends federal financial assistance to any
other recipient, such other recipient shall also submit such compliance reports to
the primary recipient as may be necessary to enable the primary recipient to carry
out its obligations under this part.
- Title VI Circular
UTA and its sub-recipients receiving funds or equipment from the federal government
through UTA are required to submit the following information as part of their application and
periodically as required by FTA thereafter, as long as a federal interest remains in their
equipment or program:
•
•
•
•

Title VI Plan—must be updated no less than every 3 years;
LEP—Limited English Proficiency Plan submitted as part of the Title VI plan
FTA Certifications and Assurances—must be signed and submitted annually
Recipients that have transit-related, non-elected planning boards, advisory councils
or committees, or similar bodies, the membership of which is selected by the
recipient, must provide a table depicting the racial breakdown of the membership of
those committees, and a description of efforts made to encourage the participation
of minorities on such committees or councils.

To monitor Title VI compliance, UTA:
•
•
•

Documents subrecipient compliance with the general requirements;
Collects and maintains subrecipient Title VI program documents on a designated
schedule; and
Forwards subrecipient Title VI information to the FTA, if requested.

Subrecipients must submit a Title VI Plan to UTA with their application. Technical assistance
with development of their plan including access to UTA Title VI demographic information and
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analysis, sample documents, the option to adopt UTA’s Title VI Program elements including
public involvement activities. Title VI resources are also available through the UTA Mobility
Management website (www.utahridelink.org /5310-Grant/5310-Resource). UTA reviews all
subrecipient Title VI Programs on a biennial basis and also receives and reviews annual
reports submitted on or by Sept. 30th.

BOARD MEMBERSHIP AND RECRUITMENT

Recipients that have transit-related, non-elected planning boards, advisory
councils or committees, or similar committees, the membership of which is
selected by the recipient, must provide a table depicting the racial breakdown of
the membership of those committees, and a description of efforts made to
encourage the participation of minorities on such committees.
- Title VI Circular

UTA has one committee, the Committee on Accessible Transportation, and one board, the
Citizen’s Advisory Board, that are selected internally and are subject to the Title VI Circular’s
requirement above. The UTA Board of Trustees and Local Advisory Council are appointed by
the Utah Governor or local counties and municipalities.

COMMITTEE ON ACCESSIBLE TRANSPORTATION (CAT)

UTA established an advisory committee in the 1980s to discuss disability related issues long
before the passage of the Americans with Disabilities Act. That committee evolved into the
Committee on Accessible Transportation (CAT). After the passage of the ADA in 1990, the
UTA Board of Trustees formally created the CAT by way of a charter. The purpose of the CAT
is to provide an ongoing opportunity to advise UTA on accessibility issues related to facilities,
service, equipment, plans and programs to assure non-discrimination for people with
disabilities. Representatives of all ages, disabilities and minority groups, as well as residents
in all UTA service areas, are invited and encouraged to serve on the Committee.
When UTA seeks to fill positions on the CAT, posters are placed on all fixed route buses
(when seeking multiple positions), information is posted on the home page of UTA’s website,
and social media sites are used to reach out to the general riding public. This broad-based
recruitment seeks to build a Committee with a range of experiences within the disability
community in order to address various questions on accessibility within the transit system.
The CAT consists of people with disabilities, advocates, and service providers within the
service area.
In an effort to engage minority populations, the CAT membership application states, “UTA’s
inclusive transportation services are offered to a diverse rider community and geographic
areas. Involvement on the CAT is encouraged by individuals representing various races,
colors and national origins.”

CITIZEN’S ADVISORY BOARD (CAB)

The Community Transit Advisory Committee (CTAC) was created in 2015 to give a voice to the
citizens within the service area. In the 2017 legislative session, the Utah legislature
formalized the Citizen’s Advisory Board (CAB) as a requirement to transit districts serving
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over 200,000 people and stipulated that board membership should represent, “the diversity
of the public transit district area.” Although not legally required any longer, UTA is still
incorporating the CAB into its service delivery.
As UTA sought to engage potential membership for the CAB that would “represent the
diversity of the service area”, various agencies and businesses were asked for nominations
of potential CAB members.
UTA’s outreach efforts included engagement with:
•
•
•
•
•
•
•
•

14 advocacy groups representing minority groups, low-income populations, and
persons with disabilities,
5 agencies representing seniors
8 educational institutions
4 chambers of commerce
5 businesses
6 outdoor recreational entities
Utah Department of Workforce Services, which represents a comprehensive state
resource for employment, public assistance, refugee services, and more
2 governmental stakeholders

These nominations were taken and a final group of 10 individuals were selected to serve on
the CAB.

COMPOSITION OF MEMBERSHIP BY RACE/ETHNICITY
Number of
Members

White

Black

Hispanic

Asian

Hawaiian Native
and Pacific Islander

CAT

12

12

0

0

0

0

CAB

10

7

0

2

0

1

FACILITIES SITING AND CONSTRUCTION

The FTA, in accordance with 49 CFR part 21, requires that recipients conduct a Title VI equity
analysis during the planning stages when determining the site or locations of facilities in
order to ensure that any displacements of persons from their residences and businesses are
not determined on the basis of race, color, or national origin.
During the time period of this report, there were no “facilities” sited for construction that
would meet the definitions and requirements as outlined in the circular.

SERVICE AND FARE EQUITY ANALYSES

The FTA’s circular requires that every fare or major service change must have an analysis
performed prior to implementation of the change to measure any adverse impacts on
minority and low-income populations. UTA has embraced this process and has made equity
an integral part of its planning process. Eight service and fare equity analyses were
conducted during the reporting period and are included as Attachment H.
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TITLE VI POLICIES

FTA Circular 4702.1B requires the development of specific policies that help a transit
provider identify when further actions must be taken when engaging in activities that may
cause an adverse impact on populations protected by Title VI. Some of these policies must
be brought to the public in order to allow comment and participation in the development of
these policies and have them approved by the Authority’s governing entity. UTA’s policies
have been developed and are official corporate policies. The official policy is included as
Attachment E and include:
1- Major Service Change Policy
2- Disparate Impact Policy
3- Disproportionate Burden Policy

PUBLIC ENGAGEMENT

FTA requires that transit providers include a description of the public engagement process
for setting the major service change policy, disparate impact policy, and disproportionate
burden policy. UTA adopted a “Title VI Compliance Policy” in May 2013 to cover these
requirements.
To solicit feedback from the public on the draft Title VI Compliance Policy, UTA created a
notice that was advertised in local newspapers in the service area. The Deseret News and
Salt Lake Tribune ran the notice on April 19 and 21, 2013. Comments were accepted
through May 3, 2013. Although UTA tried to solicit feedback in local Spanish newspapers,
there were no papers to run the notice in. The notice and draft policy was posted on UTA’s
website, www.rideuta.com, as well as on the Utah state government’s website,
www.utah.gov, under “Public Notices”. At the time, the state website provides 35 language
translation options. An email notification was sent out by the Salt Lake County Office of
Diversity Affairs, which maintains an email list that goes to anyone interested in diversity
issues. Additional targeted outreach was done, which included mailing a letter and the policy
or sending an email to community organizations that work with minority or low-income
populations, including the following agencies.
•
•
•
•
•
•
•
•
•
•
•
•

Utah Coalition of La Raza
Centro de la Familia
Comunidades Unidas
Centro Civico Mexicano
The Utah Multicultural Affairs Commission
National Tongan American Society
Refugee and Immigration Center
Horizonte Training Center
Catholic Community Services
International Rescue Committee
Lutheran Social Service of Utah
Rescue Mission of Salt Lake

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One request was made for the policy to be translated into Vietnamese, which was done. The
policy and notice were published by the requester in a local Vietnamese newsletter.
Comments could be submitted by email, mail, or phone. Four comments were received by
email and one by phone. One comment expressed the belief that including minorities in the
policy resulted in favoritism to them, to the detriment of Caucasian people. That person was
sent a further explanation of the Title VI laws and how UTA must comply with them. The draft
policy was modified to incorporate three of the comments.

MAJOR SERVICE CHANGE POLICY

A major service change policy defines which proposed changes would require a Title VI
Service and Fare Equity Analysis. All equity analyses are presented to the UTA Board of
Trustees for their consideration and are subsequently included herein as Attachment J.
UTA’s Major Service Change Policy states:
UTA will seek public input on the following types of changes. These changes will be
considered "major changes" which require equity analysis in compliance with FTA's Title
VI Circular.
a. The Addition of Service;
b. A proposed service level reduction in miles, hours, or trips of thirty three percent
(33%) or more of any route;
c. The elimination of all set-vice during a time period (peak, midday, evening,
Saturday, or Sunday);
d. A proposed twenty-five (25%) or greater change in route alignment;
e. A proposed fare change.

DISPARATE IMPACT & DISPROPORTIONATE BURDEN POLICY
DISPARATE IMPACT DEFINITION

Disparate impact refers to a facially neutral policy or practice that disproportionately
affects members of a group identified by race, color, or national origin, where the
recipient’s policy or practice lacks a substantial legitimate justification and where there
exists one or more alternatives that would serve the same legitimate objectives but with
less disproportionate effect on the basis of race, color, or national origin

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DISPROPORTIONATE BURDEN DEFINITION

Disproportionate burden refers to a neutral policy or practice that disproportionately
affects low-income populations more than non-low-income populations. A finding of
disproportionate burden requires the recipient to evaluate alternatives and mitigate
burdens where practicable.

POLICY

The transit provider shall define and analyze adverse effects related to major
changes in transit service. The adverse effect is measured by the change between
the existing and proposed service levels that would be deemed significant.
- Title VI Circular

While performing a Title VI analysis on a proposed major change, UTA examines the potential
adverse impact that may occur specific to minority and low income populations. UTA
considers the degree of adverse impacts and analyzes those effects when planning any
service or fare change. The circular specifies that a transit provider must establish a
threshold for determining when adverse effects of service changes are borne
disproportionately by minority and/or low income populations.
UTA’s threshold for determining adverse impacts is outlined in policy as:
1. UTA will measure the burdens of service and fare changes on minority riders to
determine when minority riders are bearing a disparate impact from the change
between the existing service or fare and the proposed service or fare.
2. UTA will measure the burdens of service and fare changes on low-income riders
to determine when low-income riders are bearing a disproportionate burden of
the change between the existing service or fare and the proposed service or fare.
3. A threshold of 5% will be used to determine disparate impact on minority
populations and disproportionate burden on low-income populations. This 5% is
based on the margin of error from the US Census data that UTA uses to
determine the populations in the service area. This means that if the burden of
the set-vice or fare change on minority or low-income populations is more than
5% worse than it is for the non-protected populations, then the change will be
considered either a disparate impact or a disproportionate burden.
Finding a Disparate Impact
1. At the conclusion of UTA's Analysis, if UTA finds a disparate impact on the basis
of race, color, or national origin, UTA shall seek to modify the proposed changes
in a way that will mitigate the adverse effects that are disproportionately borne
by minorities. Modifications made to the proposed changes must be reanalyzed
in order to determine whether the modifications actually removed the potential
disparate impacts.

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2. If UTA chooses not to alter the proposed services changes despite the potential
disparate impact on minority populations, or if UTA finds, even after the
revisions, that minority riders will continue to bear a disproportionate share of
the proposed service or fare change, UTA may implement the change only if:
a. UTA has substantial legitimate justification for the proposed change; and
b. UTA can show that there are no alternatives that would have a less
disparate impact on the minority riders but would still accomplish the
transit provider's legitimate program goals. In order to show this, UTA
must consider and analyze alternatives to determine whether those
alternatives would have less of a disparate impact on the basis of race,
color, or national origin, and then implement the least discriminatory
alternative
Finding a Disproportionate Burden. If at the conclusion of the analysis, UTA finds that lowincome populations will bear a disproportionate burden of the proposed major service
change, UTA will take steps to avoid, minimize, or mitigate impacts where practicable. The
provider should also describe alternatives available to low-income passengers affected by
the service changes.

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SYSTEM-WIDE SERVICE STANDARDS & SERVICE MONITORING
VEHICLE LOADS
STANDARD

UTA has set the following standard for vehicle loads:
For Bus Rapid Transit and peak only service, the median maximum load on a trip should be
no greater than the vehicle seating capacity.
For other fixed-route bus services and commuter rail, the median maximum load on a trip is
no greater than 150% of seating capacity.
Light rail has determined that average weekly loads on regularly scheduled trips should not
exceed 100% of the seating capacity. If the loads regularly exceed capacity, then vehicles will
be added to the consist until the maximum consist size is reached. Thereafter loads should
not exceed 150% of seating capacity.

MONITORING

Utilizing the FTA’s definition of a minority route, UTA reviewed all of its current routes and the
number of trips that exceeded the maximum load capacity as set forth in our standards. UTA
had 1.18 million trips in calendar year 2018. 38% of the trips taken during this time period
were on routes designated as a minority route. Of the 1,187,294 trips taken in 2018, only
8,047 of the trips exceeded the standard. The table below shows the number of trips above
capacity during this period broken up into minority vs non-minority routes and the percentage
they comprise.
Minority
Routes

Non-minority
Route

Number of Trips above capacity

385

7,662

Percent of trips above capacity

4.8%

95.2%

FINDINGS

There were no findings of any disparate impacts on minority populations in UTA’s vehicle
loads. Only 4.8% of all of the trips that were over capacity occurred on minority routes.

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VEHICLE HEADWAYS
STANDARD

The average number of minutes between regional commuter trains should not exceed 60
minutes. The average number of minutes between light rail trains should not exceed 20
minutes.
UTA’s Service Design Guidelines identify four tiers or minimum levels of bus service. Route
alignments and level of service are based on current or modeled productivity, the propensity
of the alignment for transit use, as well as service design guidelines for route and stop
spacing.
The transit propensity index is calculated based on a combination of factors - minority
population density, transit supportive population density, job density, intersection density,
higher-education student density, intersection density, and zero-car household density.

In brief, the tiers are as follows:
Tier

Minimum Level of Service

Minimum Transit
Performance Index

Minimum Productivity

One

15 minute service
weekdays & Sat, 30
minute service Sunday

300

20 passengers per service hour

Two

30 minute weekday,
60 minute Saturday

200

10 passengers per service hour

Three

60 minute weekday

100

10 passengers per hour
5 passengers per hour flex routes

Peak Only

No minimum headway

100

7 passengers per service mile

MONITORING

Below is a table depicting the average headway by minority and non-minority routes by rail
and bus. The data is presented as the number of minutes between the arrival of one transit
vehicle and the arrival of the next.
Minority Routes

Non-minority Route

System Average

Bus Headway

23

27.6

25.9

Rail Headway

14.8

16

15.7

FINDINGS

There were no findings of any disparate impacts on minority populations in UTA’s headway
monitoring. As evidenced in the table, the headways for routes serving in a minority area
have more frequent headways than non-minority routes.
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ON-TIME PERFORMANCE
STANDARD

For commuter rail service, on-time is defined as departing stations 0 seconds early and less
than 5 minutes late. The on-time standard is 88% on-time for all departures. UTA
continuously monitors on-time performance and conducts analysis to determine root causes
of non-standard performance then makes adjustments where feasible.
For light rail service, on-time is defined as departing stations 0 seconds early and less than 5
minutes late. The on-time standard is 88% on-time for all departures. Light rail service is
continually monitored and schedule adjustments or other corrective action taken annually at
a minimum.
For fixed-route bus, on-time is defined as departing time point crossings 0 seconds early and
less than 5 minutes late for regular fixed-route and 0 seconds early and less than 15
minutes late for flex routes. UTA will evaluate whether adjustments are necessary when:
•
•

The on-time performance for the whole route is consistently below 88%
Running time adjustments to individual trips are so large that they disrupt the cycle
time of the whole route

For paratransit, on-time is defined as at least 90% of customers picked up within 10 minutes
before to 20 minutes after the stated pick-up time and 90% of customers dropped off within
30 minutes of any stated appointment time.

MONITORING

UTA conducted monitoring for the period of 2018 to determine if there are any disparate
impacts on minority routes’ on-time reliability. Please note that UTA only has one
FrontRunner line, which is its commuter rail. This line is not a minority route so there is no
on-time reliability data for commuter rail minority lines.
Minority Routes

Non-minority Route

System Average

Bus Reliability

92.3%

87.7%

89.3%

TRAX Reliability

94.6%

93.9%

94%

N/A

85.9%

85.9%

FrontRunner Reliability

FINDINGS
There were no findings of any disparate impacts on minority populations in UTA’s on-time
performance. As is shown in the table, minority routes are, on average, more consistently on
time than non-minority routes.

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SERVICE AVAILABILITY
STANDARD

For commuter rail, stations are preferably situated 7-8 miles apart, dependent on land use
and travel time considerations.

For light rail, stations should be approximately 1 mile apart in suburban areas and 1/2 mile
apart in urban areas. Light rail service operated as a street car should have approximately
1/4 mile stop spacing. Service availability for fixed bus is based on route and stop spacing.
Recommended route spacing for fixed and flex routes in the UTA system is as follows:
Environment

Route Spacing

Central Business District

1/8 mile to 1/4 mile

Urban

1/4 mile to 1/2 mile

Suburban

1/2 mile to 1 mile

Rural

As needed based on surrounding development and activity

Recommended stop spacing for fixed and flex routes in the UTA system is as follows:
Environment

Stop Spacing

Central Business District

400 – 800 feet

Urban

500 – 1,000 feet

Suburban

600 – 1,200 feet

Rural

800 or as needed based on surrounding development & activities

MONITORING

In evaluating the availability of transit services, UTA reviewed the population within its taxing
districts and compared it to the populations that fall within a walk access to any transit stop
or station. UTA has defined its service area as everything that falls within our taxing districts.
The areas with walk access are those census blocks that fall within an area that is within a
certain distance, according to the actual road access of the area, from a transit stop or
station. The distances from stop or station are:
•
•
•

¼ mile from a bus stop
½ mile from a light rail or bus rapid transit station
3 miles from a commuter rail station

.

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The table below shows the number of people within the service area, the number of people
with walk access, and the number of minorities within each group.
Total
Population

Minority
Population

Percent
Minority

Service Area Population

2,310,052

511,161

22.1%

Population With Walk Access

1,531,569

391,043

25.5%

66.3%

76.5%

Percent of Population With Walk Access

According to the data presented, the overall population with walk access has 3.4% more
minorities than the service area’s population. Additionally, 76.5% of all of the minority
population in our service area fall within the walk access compared to 66.3% of the service
area at large.

FINDINGS

There were no findings of any disparate impacts on minority populations in UTA’s service
availability. Overall, minorities had a greater amount of walk access than non-minority
populations.

DISTRIBUTION OF AMENITIES
STANDARD

UTA is responsible for establishing a policy for how transit amenities are added to the system
and ensuring the equitable distribution of amenities throughout the service area. “Transit
amenities” refer to items of comfort, convenience, and safety that are available to the
general riding public. They include, but are not limited to items such as seating, shelters,
canopies, provisional information, escalators, elevators, and waste receptacles. Additionally,
UTA is making efforts to upgrade existing stops to the Americans with Disabilities Act (ADA)
standards.
In accordance with this requirement, UTA has developed a master plan outlining all of the
criteria involved in prioritizing which stops will receive improvements, what improvements are
warranted based on use, and outlines construction specs for improvements. The Bus Stop
Master Plan outlines and encourages partnerships with local government and property
owners to improve the accessibility, comfort, and convenience of the riding public.
The creation of this document required an extensive inventory of all of UTA’s 6,055 bus
stops, standardizing the specifications by which all stops would be improved and updating
UTA’s decision making matrix for prioritizing what amenities will be added to a stop. An
updated decision making matrix is included on the following page.

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Category

1 Point

2 Points

3 Points

4 Points

5 Points

-

-

-

-

Yes

1 to 19

20 to 39

40 to 59

60 to 79

80 +

1 Route

2 Routes

3 Routes

4 Routes

5+ Routes

1 Route

2 Routes

3 Routes

4 Routes

5+ Routes

Title VI
Route

Minority
OR Low
Income

Minority
AND Low
Income

2 x Minority
+ Low
Income

2 x Minority +
2x Low
Income

1 of 5
Elements

2 of 5
Elements

3 of 5
Elements

4 of 5
Elements

5 of 5
Elements

Non-ADA Compliant*
Total Stop Activity (TSA)
– Average Daily
Weekday**
Transfer Point***
Equal to or Greater than
30 min. freq.
Less than 29 the min.
freq.
Serves Title VI
Community
Safety
Intersection
Parking Allowed
Obstacle(s) Present
No lighting Present
Sidewalk Not Level

* Non-ADA compliant bus stop locations automatically receive five (5) points
** TSA Data is average weekday ridership taken from the last eight change day periods
***One (1) additional point is assessed each route at the transfer point with 30
minute or less frequency
As is shown above, there are additional points given in prioritizing amenities that would serve
a Title VI community.

MONITORING

UTA presently has 6,055 bus stops in its system. Of those stops, 2,197 of them are in an
area where the percent of minorities in the surrounding population exceed the system
average of 22.1%. Surrounding population is determined by applying a ¼ mile walk access
radius and incorporating any census blocks that are overlapped. Most recently, 2010-2016
ACS data was used in the formulation of these figures.
Since the number of stops within the system that serve a minority population above the
system average is 36.3% of all stops, this figure is used as the point of reference in
determining any potential disparity in amenity distribution.
Percent of Stops on Minority
Lines with this amenity

Percent of all stops with
this amenity

Shelter

37.6%

10%

Seating

35.8%

20.3%

Trash Receptacle

38.1%

13.8%

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Additional stations are available on UTA’s TRAX lines, FrontRunner commuter rail and Bus
Rapid Transit lines. The amenity distribution are uniformly applied at these stations as all of
them have shelters, seating, electronic signage, schedules, and trash receptacles. For
informational purposes, below is a representation of the number of stations that are in
minority areas.
Number of Stations

Minority Stations

Percent Minority

FrontRunner

15

8

53.3%

Blue Line

24

15

62.5%

Red Line

25

18

72%

Green Line

18

14

77.8%

S-Line

7

5

71.4%

UVX (BRT)

18

9

50%

FINDINGS

There were no findings of any disparate impacts on minority populations in UTA’s amenity
distribution.

VEHICLE ASSIGNMENT
STANDARD

Vehicle assignment refers to the process by which transit vehicles are placed into
service in depots and on routes throughout the transit provider’s system.
- Title VI Circular

The guidelines that UTA uses in assigning vehicles to routes are as follows. The quantity of
buses in each Business Unit is determined by the demand, which is the peak pull-out for the
calendar year. The Planning Department from each Business Unit generates information
regarding routes and schedules that is cut into runs and blocks for Operators to work. This
information is shared with the respective Business Units’ Maintenance Departments. Buses
are assigned within a service area according to the characteristics of the service, such as
canyon, commuter express, shuttle or regular transit bus service, passenger loads, and
topography of the service area. Specially equipped canyon buses have different
specifications than buses that operate in regular transit service in the valley.
Each Maintenance Department determines vehicle assignment based on criteria stipulated
by the planners and operational characteristics as to what type of equipment is required for
each route or schedule. The vehicle type that can accommodate the runs and blocks is
entered into the Fleet Control Sign-out database software program. Also, the status of buses
that are out for repair, body work, or temporarily out of service is updated in the database.
Vehicles are assigned on a daily basis through a Sign-out Sheet. All-day blocks (runs that are
out around 16 hours or more) are typically assigned the same type of bus each day. Any
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remaining buses are assigned to tripped blocks (buses sent out during overloads or blocks
that are less than 8 hours in duration). Once the sign-out sheet is generated, the sign-out is
sent to Operations Dispatch for Operator assignment.

MONITORING

UTA has developed a report that produces the average age of the vehicles used on any given
route. The specific timeframe used for this monitoring was for the time period of June, July
and August of 2018. All routes were analyzed and the average of the entire system was
taken for minority routes and non-minority routes. During this time period, the minority
routes’ vehicles were .6 years newer than non-minority route trips and 2 years newer when
looking at the blocks they served. See the table below for the figures.

Trips
Average Age in
Years

Blocks

Non-Minority

Minority

Non-Minority

Minority

7.3

6.7

9

7

UTA’s rail and BRT system have a designated vehicle that was purchased at the same time
and assigned specifically to a route. All vehicles on each route are the same age and cannot
be distributed to other routes due to specification and branding.

FINDINGS
There were no findings of disparate impact on minority populations in UTA’s vehicle
assignment

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UTA Title VI Program 2019

DEMOGRAPHIC DATA REPORT

The FTA requires fixed route providers of public transportation to collect information on the
race, color, national origin, English proficiency, language spoken at home, household income,
and travel patterns of their riders using customer surveys. UTA must then use this
information to develop maps and a demographic profile comparing minority riders and nonminority riders, trips taken by minority and non-minority riders, and the demographics of fare
usage by fare type amongst minority and low-income riders.

CURRENT SERVICE AND SERVICE AREA

In order to determine the extent to which members of minority groups are beneficiaries of the
programs UTA offers, UTA maintains maps using Geographic Information System (GIS)
technology. GIS data is used to evaluate proposed major changes and measure the impacts
any changes may have on the population we try to serve, with special emphasis on
monitoring unintended impacts on populations protected under Title VI. The following maps
were prepared using demographic data from American Community Survey (ACS) 2012-2016
5-year estimates, which was dispersed into census blocks, in lieu of the larger block groups.
This was done in order to use the smallest geographic area possible for the analysis. The
distribution was dictated by population ratios from 2010 Census Data. This data is updated
annually. The UTA service area is geographically large and difficult to present in a single map.
Subsequently, the maps are broken up into the three business units in order to provide a
more detailed view of each area. For reference, the first map shows the entire service area
and each business unit’s area. The remaining maps are broken up into service area.
The maps included in this section include.
1. Overview of UTA’s service area and available service
2. Mt. Ogden Minority Population Density
3. Salt Lake Minority Population Density
4. Mt. Timpanogos Minority Population Density
5. Mt. Ogden Facility Improvements
6. Salt Lake Facility Improvements
7. Mt. Timpanogos Facility Improvements
8. Mt. Ogden Minority Concentrations
9. Salt Lake Minority Concentrations
10. Mt. Timpanogos Minority Concentrations
11. Mt. Ogden Low Income & Poverty
12. Salt Lake Low Income & Poverty
13. Mt. Timpanogos Low Income & Poverty

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RIDERSHIP CHARACTERISTICS AND DEMOGRAPHICS

In order to develop a demographic profile of the members of the community using transit
services, UTA conducted an on board survey of its riders between October 2015 and
February 2016. During this survey period, 16,408 usable surveys were collected. The study
relied on a tablet-based questionnaire. Staff conducted surveys directly with riders on UTA
transit vehicles. The data collected from this effort were weighted and expanded using
Automatic Passenger Counter (APC) data maintained by UTA. A copy of the survey is included
as Attachment H. The data from the survey was used to create the following charts and
figures.
Surveying was conducted on Mondays through Thursdays and focused on trips occurring
between 6:30 a.m. and 9:00 p.m. The survey staff rode trips in both directions of travel. The
survey sampling plan was designed to obtain surveys from 9% of average weekday boardings
by route/line, time period, and direction, roughly proportional to actual ridership.
The table below shows ridership and both targeted and achieved sampling for UTA buses and
each rail line. Surveying on all rail lines and the UTA bus system as a whole exceeded targets.
Overall, greater than 12% of UTA ridership was surveyed.

Throughout this section, “Low Income” refers to any household making under $30k per year.
Moderate income is any household reporting an annual income between $30k and $75k.
Any household reporting income over $75k a year is considered high income.

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DEMOGRAPHIC OVERVIEW
Of the people surveyed, 24.9% of them
identified as a minority per the FTA’s
definition. This is 3% higher than population
of UTA’s service area.

Low income (less than $30k per
year) comprise 44.5% of those
surveyed. When comparing this to
2015 ACS poverty data, this is
24.1% more than the population of
UTA’s service area.

The table to the left shows
the racial/ethnic
breakdown within the
three income groups.
Below is a breakdown of
the 13,306 respondents
who answered both the
income and race/ethnicity
question broke up into the
three groups.
Low Income: 5,915 (44%)
Moderate: 4,509 (34%)
High: 2,882 (22%)

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TRAVEL PATTERNS
FTA requires that transit providers include
information regarding the trips taken by
transit provider’s ridership including the
demographic profile comparing minority riders
and non-minority riders. The following three
tables show the reported purpose for the trips
taken.

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UTA reviewed the demographics and income
level of its riders’ need to use transit services.
Riders were asked if they used transit because
they had no other option or if they were able to
utilize other means to get around, but choose
to use transit.
As is evident in the charts below, minorities
comprise 9% more of the captive riders than
those riding by choice. Additionally, low income
riders are captive at a rate of more than
double their high income counterparts.

CHOICE VS CAPTIVE
Minority

HAD ANOTHER CHOICE

TRANSIT ONLY OPTION

Non-Minority

20%

80%

29%

71%

CHOICE VS CAPTIVE
Transit only option

HIGH INCOME

MODERATE INCOME

LOW INCOME

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Had another choice

30%

70%

46%

54%

69%

UTA Title VI Program 2019

31%

WEEKLY TRANSIT USE
1.5% 5.3%

8.5%

The three charts on this page show the
frequency by which the surveyed riders
utilize transit services. The majority of
riders stated that they used the system
five or more times per week

24.7%

60.0%

1 - 2 times

3 - 4 times

5 or more

First Time

Less than 1

TRANSIT USE BY RACE/ETHNICITY
Minority
LESS THAN 1

Non-Minority
79.2%

20.8%

FIRST TIME

25.9%

74.1%

5 OR MORE

25.5%

74.5%

3 - 4 TIMES

24.7%

75.3%

1 - 2 TIMES

24.0%

76.0%

TRANSIT USE BY INCOME LEVEL
Low Income
LESS THAN 1
FIRST TIME

Moderate Income

High Income
32%

36%

31%

48%

25%

27%

5 OR MORE

46%

34%

19%

3 - 4 TIMES

47%

32%

21%

1 - 2 TIMES

47%

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24%

DEMOGRAPHICS BY MODE

OVERALL BY MODE
Depicted in these three charts are a
breakdown of those surveyed that utilize
UTA’s three primary modes of
transportation.

14.2%

46.6%

Please note that the chart, “Ridership by
Mode”, counts the number of trips on a
mode, but some customers reported
trips on multiple modes on the same
survey.

39.2%

Commuter Rail

Light Rail

Bus

RACE/ETHNICITY BY MODE
Minority

Non-Minority

FIXED BUS

26.1%

73.9%

TRAX

25.8%

74.2%

COMMUTER RAIL

18.2%

81.8%

INCOME LEVEL BY MODE
Low Income

Moderate Income

TRAX

COMMUTER RAIL

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33.6%

48.9%

FIXED BUS

34.3%

42.6%

30.6%

High Income

39.5%

UTA Title VI Program 2019

17.5%

23.1%

29.9%

FARE USAGE

FARE PAYMENT TYPE USAGE
19%

U OF U SUTDENT

1%

BUS TOKEN

2%

REDUCED FARE

6%

PAPER TICKET

17%

PAPER MONTHLY

1%

OTHER PAYMENT

19%

OTHER EFC
MEDICAID

2%

FREE FARE ZONE

2%
13%

FAREPAY

19%

CASH

0%

5%

10%

FARE USAGE BY
RACE/ETHNICITY
Minority

Non-Minority

15%

UTA has assessed the
responses as to what method of
payment was used in
determining the demographics
and usage of different fare
payment types. These charts
depict their payment type usage
and the demographic/income
levels of the riders surveyed.
Note: EFC: Electronic Fare Card

20%

FARE USAGE BY
INCOME
Low Income

Moderate Income

High Income

ALL PAYMENT TYPES

24.9%

75.1%

ALL PAYMENT TYPES

44%

34%

22%

U OF U STUDENT

24.0%

76.0%

U OF U STUDENT

46%

31%

23%

BUS TOKEN
REDUCED FARE

33.0%
13.6%

67.0%
86.4%

27.3%

72.7%

PAPER TICKET

PAPER MONTHLY

26.1%

73.9%

PAPER MONTHLY

45%

OTHER PAYMENT

24.6%

75.4%

OTHER PAYMENT

44%

20.5%

79.5%

OTHER EFC

MEDICAID

30.8%

69.2%

MEDICAID

FREE FARE ZONE

30.7%

69.3%

FREE FARE ZONE

FAREPAY
CASH

19.0%
31.8%

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81.0%
68.2%

FAREPAY
CASH

UTA Title VI Program 2019

22%

67%

REDUCED FARE

PAPER TICKET

OTHER EFC

21% 6%

73%

BUS TOKEN

29%

32%

39%

36%

29%
10% 4%

86%
28%

57%
35%
55%

19%
24%

32%
39%

32%

11%

16%
26%

38%
31%

15%

ATTACHMENT A – NOTICE TO THE PUBLIC

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ATTACHMENT B – TITLE VI COMPLAINT FORM

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ATTACHMENT C – CUSTOMER COMMUNICATIONS POLICY

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ATTACHMENT D – LIST OF COMPLAINTS
2016 Complaints
Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

Status

Action Taken

12/30/15

29789

Passed by - Allegedly due to protected status

Race

Black/African
American

Closed Trend

Operator coached

1/13/16

31059

National
Origin

Did not specify

Closed Trend

1/21/16

31751

Race

Black/African
American

Closed Trend

2/22/16

34677

Unfair treatment due to protected status

Race

Black/African
American

Closed

2/29/16

35314

Unfair treatment due to protected status

Race

36066

National
Origin

Closed Trend

3/8/16

Hispanic

Closed

3/18/16

37006

Race

Did not specify

Closed

3/21/16

37208

Operator passed desired stop - Allegedly due to
protected status
Customer stated they were treated poorly due to
protected status
Operator involved in political conversation with
another customer - alleged discriminatory
conversation

Black/African
American

National
Origin

Did not specify

Closed

3/25/16

37780

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

Closed

3/31/16

38374

Unfair treatment due to protected status

National
Origin

Hispanic

Closed

4/4/16

38618

4/4/16

38573

Black/African
American
Black/African
American

Closed Trend
Closed Trend

No action taken - Policy allows
operator discretion in deciding how
to handle this situation
No action taken - Investigation found
no fault in UTA employee
Repeat call - Operator already
coached
No action taken - Unable to
corroborate customer account.

4/4/16

38624

Did not specify

Closed

Operator coached

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Customer not allowed on bus with bike - Allegedly
this is different treatment based on protected
status
Customer stated they were treated poorly due to
protected status

Customer stated they were treated poorly due to
protected status
Customer stated they were treated poorly due to
protected status
Alleged different treatment based on race in a
fare dispute

Race
Race
Race

UTA Title VI Program 2019

No action taken - Policy allows
operator discretion in deciding how
to handle this situation
Operator coached
No action taken - Policy allows
operator discretion in deciding how
to handle this situation
Operator coached
tion taken - Unable to corroborate
customer account.
No action taken - Video contradicted
customer account.
Operator coached

Date
Feedback
Recorded

Report #

4/5/16

38816

4/5/16

38765

4/5/16

38746

4/8/16

39219

4/27/16

41199

5/14/16

43029

5/17/16

Basis of
Complaint

Race/Color/National
Origin

Status

Action Taken

Race

Black/African
American

Closed Trend

No action taken - Investigation found
no fault in UTA employee

Race

Black/African
American

Closed Trend

Race

Did not specify

Closed

Race

Native American

Race

Black/African
American

Closed Trend
Closed Trend

Passed by - Allegedly due to protected status

Race

Did not specify

Closed

43245

Customer stated they were treated poorly due to
protected status

Latino/Brazilian

Closed

5/25/16

44100

Unfair treatment due to protected status

National
Origin
National
Origin

Hispanic

Closed Trend

6/6/16

44988

Passed by - Allegedly due to protected status

Race

Black/African
American

Closed

6/7/16

45215

Unfair treatment due to protected status

Race

6/9/16

45463

No action taken - Investigation found
no fault in UTA employee
No action taken - Unable to
corroborate customer account.
No action taken - Fare payment was
not valid.
No action taken - Unable to
corroborate customer account.
No action taken - Video showed
unsafe conditions
No action taken - Investigation found
no fault in UTA employee
No action taken - Unable to
corroborate customer account.
No action taken - Operator was
unable to determine that the
customer wanted the bus as they
were not at the stop
No action taken - Investigation found
no fault in UTA employee
No action taken - Video contradicted
customer account.

7/12/16

48727

7/23/16

49602

8/31/16

53440

9/8/16

54143

Passed by - Allegedly due to protected status

9/12/16

54435

Unfair treatment due to protected status

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Summary of Complaint
Customer observed negative treatment they
stated was due to another person's protected
class
Customer stated they were treated poorly due to
protected status
Customer stated they were treated poorly due to
protected status
Alleged different treatment based on race in a
fare dispute
Customer stated they were treated poorly due to
protected status

Alleged different treatment based on race in a
fare dispute
operator involved in allegedly discriminatory
conversation
Alleged different treatment based on race in a
fare dispute
Customer stated they were treated poorly due to
protected status

Race
National
Origin
Race
National
Origin
National
Origin
Race

Black/African
American
Black/African
American
Did not specify
Black/African
American
Hispanic
Did not specify
Did not specify

UTA Title VI Program 2019

Closed
Closed Trend
Closed Trend
Closed Trend
Closed Trend
Closed Trend
Closed Trend

Operator coached
No action taken - Investigation found
no fault in UTA employee
No action taken - Investigation found
no fault in UTA employee
No action taken - Unable to
corroborate customer account.
Operator coached

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

9/24/16

56000

operator involved in allegedly discriminatory
conversation

Race

10/10/16

57585

Passed by - Allegedly due to protected status

Race

10/10/16

57636

Unfair treatment due to protected status

Race

Black/African
American

Closed

10/27/16

59214

Race

Did not specify

Closed Trend

11/5/16

60066

11/7/16

60110

11/8/16

Race/Color/National
Origin
Black/African
American
Black/African
American

Status

Action Taken

Closed

Operator coached

Closed Trend

No action taken - Customer not at
stop
No action taken - Policy allows
operator discretion in deciding how
to handle this situation
No action taken - Video contradicted
customer account.

Customer stated they were treated poorly due to
protected status
Customer observed negative treatment they
stated was due to another person's protected
class
Customer stated they were treated poorly due to
protected status

Race

Black/African
American

Closed

National
Origin

Middle Eastern

Closed

60277

Unfair treatment due to protected status

Race

Closed

11/12/16

60763

Customer not allowed on bus with bike - Allegedly
this is different treatment based on protected
status

Black/African
American

National
Origin

Hispanic

Closed Trend

No action taken - Unable to
corroborate customer account.

11/14/16

60774

Passed by - Allegedly due to protected status

Hispanic

Closed Trend

11/29/16

62180

Customer stated they were treated poorly due to
protected status

National
Origin

11/30/16

62260

No action taken - Unable to
corroborate customer account.
No action taken - No follow up from
customer
No action taken - Customer not at
stop

12/13/16

No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Race

Black/African
American

Passed by - Allegedly due to protected status

Race

Native American

63465

Customer observed negative treatment they
stated was due to another person's protected
class

Closed Trend

Race

Black/African
American

Closed

No action taken - Unable to
corroborate customer account.

12/19/16

63979

TRAX operator did not deploy ramp - Allegedly
due to protected status

National
Origin

Hispanic

64817

National
Origin

No action taken - Customer
attempted to board the train from
the wrong side of the train.

12/28/16

Customer stated they were treated poorly due to
protected status

Closed Not At
Fault

Hispanic

Closed

Operator coached

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Closed

2017 Complaints
Date
Feedback
Recorded

Basis of
Complaint

Race/Color/National
Origin

Status

Action Taken

Race

Did not specify

Closed Not At
Fault

No action taken - Upon follow-up,
customer rescinded allegations and
apologized. Operator let customer
ride for free.

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

66253

Unfair treatment due to protected status

Race

Did not specify

1/14/17

66855

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

1/26/17

68014

Fare dispute - Customer felt singled out due to
protected status

National
Origin

Hispanic

2/2/17

68728

Alleged different treatment based on race in a
fare dispute

Race

Did not specify

2/9/17

69548

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

2/18/17

70506

Customer was allegedly singled out due to
protected status

Race

Black/African
American

2/21/17

70585

Unfair treatment due to protected status

National
Origin

Hispanic

Closed

Operator coached

2/28/17

71221

Passed by - Allegedly due to protected status

National
Origin

Hispanic

No action taken - Unable to
corroborate customer account.

3/9/17

72390

Alleged different treatment based on race in a
fare dispute

Closed Not At
Fault

Race

Did not specify

Closed

3/11/17

72614

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

Closed Not
Verified

Report #

Summary of Complaint

1/4/17

65516

Fare dispute - Customer felt singled out due to
protected status

1/10/17

66209

1/10/17

64 | P a g e

UTA Title VI Program 2019

Closed Not
Verified
Closed Not At
Fault
Closed Not
Verified
Closed Not At
Fault
Closed
Closed Not At
Fault
Closed Not At
Fault

No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Operator coached
No action taken - Unable to
corroborate customer account.
No action taken - Fare payment was
not valid.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

3/20/17

73370

Fare dispute - Customer felt singled out due to
protected status

Race

Black/African
American

4/3/17

74689

Unfair treatment due to protected status

Race

Black/African
American

4/4/17

74739

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

4/4/17

74868

Passed by - Allegedly due to protected status

Race

Black/African
American

4/6/17

75049

Customer stated they were treated poorly due to
protected status

Race

Did not specify

4/11/17

75445

Passed by - Allegedly due to protected status

Race

Native American

4/12/17

75619

Unfair treatment due to protected status

National
Origin

Hispanic

Closed

Operator coached

4/13/17

75709

Discourteous Treatment from another passenger

Race

Black/African
American

Closed

4/18/17

76129

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

4/19/17

76208

Alleged different treatment based on race in a
fare dispute

Closed Not
Verified

No action taken - Another customer
was the offender

Color

Did not specify

Closed

4/21/17

76379

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

Closed Not At
Fault

4/21/17

76410

Passed by - Allegedly due to protected status

Race

Did not specify

Closed

4/26/17

76797

Customer was allegedly singled out due to
protected status

Race

Polynesian

4/29/17

77111

Customer stated they were treated poorly due to
protected status

National
Origin

Closed Not At
Fault

Hispanic

Closed

5/1/17

77164

Unfair treatment due to protected status

Color

Did not specify

Closed

65 | P a g e

UTA Title VI Program 2019

Status
Closed Not At
Fault
Closed Verified
Closed Not At
Fault
Closed Not At
Fault
Closed Not
Verified
Closed Verified

Action Taken
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Customer educated on fare payment
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Customer not at
stop

Operator coached
No action taken - Video contradicted
customer account.
No action taken - Unable to
corroborate customer account.
No action taken - No customer
visible in video of incident
No action taken - Operator
addressed safety concerns
No action taken - Video contradicted
customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

5/3/17

77497

5/15/17

78583

5/23/17

79351

6/7/17

80677

6/13/17

Basis of
Complaint

Race/Color/National
Origin

Status

Action Taken

Customer was allegedly singled out due to
protected status
Alleged different treatment based on race in a
fare dispute
Alleged different treatment based on race in a
fare dispute
Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

Closed

Race

Black/African
American

Color

Did not specify

Closed Verified
Closed Verified

No action taken - Unable to
corroborate customer account.

Race

Native American

Closed

81309

Passed by - Allegedly due to protected status

Race

Black/African
American

Closed Not At
Fault

6/28/17

82703

Passed by - Allegedly due to protected status

Judaism

Jewish

Closed

7/27/17

85230

Passed by - Allegedly due to protected status

National
Origin

Hispanic

8/10/17

86720

Unfair treatment due to protected status

Race

Black/African
American

Closed Not At
Fault

8/14/17

86873

Passed by - Allegedly due to protected status

National
Origin

Hispanic

8/15/17

87080

Customer was allegedly singled out due to
protected status

Race

Black/African
American

8/26/17

88322

Passed by - Allegedly due to protected status

National
Origin

Hispanic

8/30/17

88682

Customer stated they were treated poorly due to
protected status

Race

Did not specify

8/31/17

88843

Passed by - Allegedly due to protected status

Race

Black/African
American

9/5/17

89167

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

66 | P a g e

Summary of Complaint

UTA Title VI Program 2019

Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed
Closed Not At
Fault
Closed Not At
Fault

Operator coached
Operator coached
No action taken - Unable to
corroborate customer account.
No action taken - Operator
addressed safety concerns
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Not enough information provided to
follow up
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Not enough information provided to
follow up
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

9/14/17

90214

Alleged different treatment based on race in a
fare dispute

Color

Did not specify

9/15/17

90352

Operator was allegedly involved in discriminatory
conversations with other passengers

Color

Did not specify

10/11/17

92877

Passed by - Allegedly due to protected status

Color

Did not specify

10/11/17

92937

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

10/13/17

93111

TVM malfunction resulted in customer getting a
ticket for not paying a fare. Alleged the ticket was
given due to protected status

10/13/17

93154

10/19/17

93600

11/1/17

Status
Closed Not At
Fault
Closed Not
Verified
Closed Verified
Closed Not At
Fault

Action Taken
No action taken - Unable to
corroborate customer account.
Operator coached
Verified pass by - Cannot determine
if motive was racial
No action taken - Unable to
corroborate customer account.
No action taken - TVMs appeared to
be functional and the customer did
not have valid fare. Let customer
know he could appeal the ticket.

Race

Did not specify

Closed Not
Verified

Operator was allegedly involved in discriminatory
conversations with other passengers
TRAX operator did not open the door - Allegedly
due to protected status

National
Origin

Hispanic

Closed

Retrained Operator

Race

Asian

Closed

Not enough information provided to
follow up

94614

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

11/2/17

94710

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

11/11/17

95492

Passed by - Allegedly due to protected status

Race

Did not specify

11/21/17

96363

Customer was allegedly singled out due to
protected status

Race

Black/African
American

11/21/17

96370

Customer stated they were treated poorly due to
protected status

Race

Native American

11/28/17

96778

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

67 | P a g e

UTA Title VI Program 2019

Closed Not At
Fault
Closed Not At
Fault
Closed Verified
Closed Not At
Fault
Closed Not
Verified
Closed Not At
Fault

No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Video contradicted
customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

11/30/17

96926

Passed by - Allegedly due to protected status

Race

Black/African
American

12/2/17

97160

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

12/6/17

97519

Fare dispute - Customer felt singled out due to
protected status

Race

Black/African
American

12/6/17

97576

Fare dispute - Customer felt singled out due to
protected status

Race

Black/African
American

12/8/17

97793

Customer stated they were treated poorly due to
protected status

Color

Did not specify

12/11/17

97949

Passed by - Allegedly due to protected status

Race

Asian

12/26/17

99402

Customer stated they were treated poorly due to
protected status

Race

Did not specify

68 | P a g e

UTA Title VI Program 2019

Status

Action Taken

Closed Verified
Closed Not At
Fault

Verified pass by - Cannot determine
if motive was racial

Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault

No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

2018 Complaints
Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

Status

Action Taken

1/8/18

100352

Passed by - Allegedly due to protected status

Race

Black/African
American

Closed

Verified pass by - Cannot determine
if motive was racial

1/9/18

100511

Discourteous Treatment from another passenger

Race

Black/African
American

1/16/18

101092

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

1/30/18

102388

Race

Native American

2/1/18

102513

2/1/18

102579

2/8/18

Smoking on UTA property - Customer felt singled
out due to protected status
Not assisted at customer service area - Customer
presented during a time when the office was
closed - Alleged they were not helped due to their
race.

Closed Not
Verified
Closed Not
Verified
Closed Verified

Race

Did not specify

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

103160

Passed by - Allegedly due to protected status

Color

Did not specify

2/21/18

104154

Operator was allegedly involved in discriminatory
conversations with other passengers

Race

Black/African
American

2/24/18

104408

Alleged different treatment based on race in a
fare dispute

Race

Did not specify

2/27/18

104575

Alleged different treatment based on race in a
fare dispute

National
Origin

Did not specify

Closed

2/27/18

104571

Operator passed desired stop - Allegedly due to
the operator having dark skin and the customer
having light skin

Color

White

Closed

3/7/18

105340

Unfair treatment due to protected status

Color

Did not specify

Closed

69 | P a g e

UTA Title VI Program 2019

Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault

Train host coached
No action taken - Unable to
corroborate customer account.
Operator coached
Put $5 on FAREpay Card to
compensate customer for
inconvenience
No action taken - Policy allows
operator discretion in deciding how
to handle this situation
No action taken - Unable to
corroborate customer account.
Operator coached
No action taken - Policy allows
operator discretion in deciding how
to handle this situation
No action taken - Video contradicted
customer account.
No action taken - Customer provided
incorrect information on timing and
opportunity to pull video expired.
Additionally, the operator was also
white.
Retrained Operator

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

3/19/18

106449

Alleged different treatment based on race in a
fare dispute

Color

Did not specify

3/26/18

106938

Customer stated they were treated poorly due to
protected status

National
Origin

Arabic

4/2/18

107525

Passed by - Allegedly due to protected status

Color

Did not specify

4/10/18

108361

Customer stated they were treated poorly due to
protected status

Race

Did not specify

4/12/18

108591

Customer stated they were treated poorly due to
protected status

Race

Did not specify

4/16/18

108843

National
Origin

Indian

Closed

No action taken - Video contradicted
customer account.

4/18/18

109026

Race

Hispanic

Closed

Customer educated on fare payment

4/19/18

109197

Race

Black/African
American

Closed

Operator coached

4/20/18

109302

Customer stated they were treated poorly due to
protected status

Race

Did not specify

4/20/18

109375

Customer stated they were treated poorly due to
protected status

National
Origin

Did not specify

4/23/18

109469

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

4/23/18

109543

Customer stated they were treated poorly due to
protected status

Race

Did not specify

Closed

4/24/18

109630

Passed by - Allegedly due to protected status

Color

Did not specify

4/26/18

109771

Passed by - Allegedly due to protected status

Race

4/26/18

109862

Customer stated they were treated poorly due to
protected status

Black/African
American

Closed Not At
Fault

Race

White

70 | P a g e

Customer reportedly was told they had to speak
English by an operator
Alleged different treatment based on race in a
fare dispute
Customer stated they were treated poorly due to
protected status

UTA Title VI Program 2019

Status
Closed Not At
Fault
Closed Verified
Closed
Closed Not
Verified
Closed Not At
Fault

Closed Not
Verified
Closed Verified
Closed Not At
Fault

Action Taken
No action taken - Train hosts cannot
waive fare payment
Operator coached
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

No action taken - Unable to
corroborate customer account.
No action taken - Investigation found
no fault in UTA employee
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Closed

Customer not at stop

Closed

Operator coached

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

4/30/18

110085

Alleged different treatment based on race in a
fare dispute

Race

Did not specify

5/1/18

110217

Passed by - Allegedly due to protected status

Race

5/1/18

110110

Customer stated they were treated poorly due to
protected status

Black/African
American

Closed Not
Verified
Closed Verified

Color

Did not specify

Closed

5/4/18

110521

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

5/5/18

110599

Another passenger was demanding that others on
the bus should speak English

National
Origin

Did not specify

5/9/18

110980

Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

5/10/18

111014

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

5/15/18

111459

Passed by - Allegedly due to protected status

Race

Black/African
American

5/30/18

112631

Passed by - Allegedly due to protected status

Race

Did not specify

5/31/18

112727

Passed by - Allegedly due to protected status

Race

Black/African
American

5/31/18

112761

Passed by - Allegedly due to protected status

Race

Black/African
American

6/13/18

113958

Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

6/19/18

114400

Customer stated they were treated poorly due to
protected status

National
Origin

Hispanic

71 | P a g e

UTA Title VI Program 2019

Status

Closed Not At
Fault
Closed Not At
Fault
Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not
Verified

Action Taken
No action taken - Unable to
corroborate customer account.
Verified pass by - Operator coached
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Operator coached
No action taken - Investigation found
no fault in UTA employee
No action taken - Pass used
appeared to be fraudulent
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Video contradicted
customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

6/22/18

114802

Passed by - Allegedly due to protected status

Race

Did not specify

6/27/18

115176

Passed by - Allegedly due to protected status

Race

Did not specify

6/29/18

115390

Customer stated they were treated poorly due to
protected status

Color

Did not specify

7/2/18

115605

Customer stated they were treated poorly due to
protected status

Color

Did not specify

Closed

7/3/18

115696

Customer stated they were treated poorly due to
protected status

Race

Did not specify

7/12/18

116418

Alleged different treatment based on race in a
fare dispute

Closed Not
Verified

Race

7/14/18

116595

Alleged different treatment based on race in a
fare dispute

Race

7/16/18

116668

Customer stated they were treated poorly due to
protected status

Color

Did not specify

7/18/18

116848

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

7/18/18

116841

Passed by - Allegedly due to protected status

Color

Did not specify

7/27/18

117591

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

7/28/18

117701

Alleged different treatment based on race in a
fare dispute

Race

Black/African
American

8/2/18

118080

Customer stated they were treated poorly due to
protected status

Race

Did not specify

72 | P a g e

Black/African
American
Pacific
Islander/Native
Hawaiian

UTA Title VI Program 2019

Status
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault

Closed
Closed Not At
Fault
Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not
Verified

Action Taken

Stop not in service - No action taken
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Investigation found
no fault in UTA employee
No action taken - Unable to
corroborate customer account.
No action taken – No customer
information provided.
No action taken - Unable to
corroborate customer account.
Not enough information provided to
follow up
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Video contradicted
customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

8/4/18

118264

Customer was allegedly singled out due to
protected status

Race

Black/African
American

8/11/18

118945

Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

8/14/18

119225

Passed by - Allegedly due to protected status

Race

Black/African
American

8/23/18

120132

Customer stated they were treated poorly due to
protected status

Race

White

8/28/18

120569

Customer alleged that UTA was not offering free
passes to a school because it was largely a school
for refugees

National
Origin

Did not specify

8/29/18

120796

Passed by - Allegedly due to protected status

Race

Black/African
American

8/31/18

121150

Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

9/4/18

121319

Customer stated they were treated poorly due to
protected status

Race

Did not specify

9/4/18

121351

Customer stated they were treated poorly due to
protected status

Race

Native American

9/7/18

121991

Customer stated they were treated poorly due to
protected status

Race

Did not specify

9/20/18

123181

Passed by - Allegedly due to protected status

Race

Did not specify

9/25/18

123571

Passed by - Allegedly due to protected status

National
Origin

Hispanic

10/1/18

124039

Passed by - Allegedly due to protected status

Race

Native American

73 | P a g e

UTA Title VI Program 2019

Status
Closed Not
Verified
Closed Verified
Closed Not At
Fault
Closed Not At
Fault
Closed
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed
Closed Not
Verified
Closed Not At
Fault
Closed

Action Taken
No action taken - Unable to
corroborate customer account.
No action taken - Investigation found
no fault in UTA employee
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
UTA has information about free
passes for educational programs on
website - Directed person to set
policy to ask for passes.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Not enough information provided to
follow up
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Verified pass by - Cannot determine
if motive was racial

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

10/1/18

124048

Customer stated they were treated poorly due to
protected status

Race

Native American

10/5/18

124466

Passed by - Allegedly due to protected status

Race

Black/African
American

10/12/18

125165

Customer was allegedly singled out due to
protected status

Race

Black/African
American

10/22/18

125877

Customer stopped by UTA police - Matched
description of suspect – UTA questioned the rider,
who felt that it was racially motivated

Race

Black/African
American

Closed

Customer was not the suspect questioned for three minutes and
released - After receiving complaint,
officers followed up with
complainant

10/24/18

126001

National
Origin

Hispanic

Closed

No action taken - Unable to
corroborate customer account.

10/29/18

126384

Race

Did not specify

10/31/18

126564

Passed by - Allegedly due to protected status

Race

Black/African
American

11/2/18

126782

Unfair treatment due to protected status

Race

Black/African
American

11/6/18

126958

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

11/8/18

127251

Customer was allegedly singled out due to
protected status

Race

Did not specify

11/8/18

127246

Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

11/9/18

127323

Customer stated they were treated poorly due to
protected status

Color

Hispanic

74 | P a g e

Customer observed negative treatment they
stated was due to another person's protected
class
operator involved in allegedly discriminatory
conversation

UTA Title VI Program 2019

Status
Closed Not At
Fault
Closed Not At
Fault
Closed Verified

Closed Verified
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault
Closed Not At
Fault

Action Taken
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
Operator coached

Operator coached
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.
No action taken - Unable to
corroborate customer account.

Date
Feedback
Recorded

Report #

Summary of Complaint

Basis of
Complaint

Race/Color/National
Origin

11/12/18

127481

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

11/19/18

128098

Race

White

11/26/18

128412

11/29/18

128652

12/3/18

128921

Customer stated they were treated poorly due to
protected status

Race

Black/African
American

12/3/18

128939

Customer reportedly was told they had to speak
English by an operator

National
Origin

Did not specify

12/3/18

128983

Customer stated they were treated poorly due to
protected status

Race

Did not specify

12/12/18

129803

Alleged different treatment based on race in a
fare dispute

National
Origin

Hispanic

12/14/18

129943

Passed by - Allegedly due to protected status

Race

Black/African
American

12/15/18

130063

Unfair treatment due to protected status

National
Origin

Hispanic

12/17/18

130235

Customer was allegedly singled out due to
protected status

Race

Black/African
American

12/20/18

130619

Customer stated they were treated poorly due to
protected status

Race

White

12/26/18

130875

Passed by - Allegedly due to protected status

Race

Did not specify

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Customer stated they were treated poorly due to
protected status
Alleged different treatment based on race in a
fare dispute
Alleged different treatment based on race in a
fare dispute

Race
Race

Black/African
American
Black/African
American

UTA Title VI Program 2019

Status
Closed Not At
Fault
Closed Verified

Action Taken
No action taken - Unable to
corroborate customer account.
Operator coached

Closed

Fare Inspector coached

Closed

Fare Inspector coached

Closed –
Not at
Fault
Closed Verified
Closed –
Not at
Fault
Closed –
Not at
Fault
Closed –
Not
Verified
Closed Verified
Closed –
Not at
Fault
Closed –
Not at
Fault
Closed –
Not at
Fault

No action taken - Unable to
corroborate customer account.
Operator coached
No action taken - Unable to
corroborate customer account.
No action taken - Policy allows
operator discretion in deciding how
to handle this situation
No action taken - Unable to
corroborate customer account.
Operator coached
No action taken - Investigation found
no fault in UTA employee
No action taken - Operator
addressed safety concerns
Customer not at stop

ATTACHMENT E – TITLE VI COMPLIANCE POLICY

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ATTACHMENT F – PUBLIC INPUT OPPORTUNITIES POLICY

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ATTACHMENT G – LEP PLAN
Utah Transit Authority
Limited English Proficiency (LEP) Plan

INTRODUCTION

This Limited English Proficiency (LEP) Plan has been prepared to address the responsibilities
of Utah Transit Authority (UTA), as a recipient of federal financial assistance, relating to the
needs of individuals with limited English language skills. LEP persons are those who do not
speak English as their primary language and have limited ability to read, speak, write or
understand English.

LEGAL REQUIREMENTS

The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964 and its
implementing regulations, which states:
No person in the United States shall, on the ground of race, color, or national origin,
be excluded from participation in, be denied the benefits of, or be otherwise
subjected to discrimination under any program or activity that receives Federal
financial assistance.
Executive Order 13166, "Improving Access to Services for Persons with Limited English
Proficiency" (August 16, 2000), indicates that differing treatment based upon a person's
inability to speak, read, write or understand English is a type of discrimination on the basis of
national origin. The Executive Order states that recipients must take reasonable steps to
ensure LEP persons have meaningful access to their programs and activities.
In addition, the Federal Transit Administration Circular 4702.1B dated October 1, 2012,
"Title VI Requirements and Guidelines for Federal Transit Administration Recipients,"
reiterates the obligation to take responsible steps to ensure meaningful access to benefits,
services, and information for LEP persons and requires that FTA recipients develop a
language assistance plan.

FOUR FACTOR ANALYSIS

The U.S. Department of Transportation (DOT) issued its Policy Guidance Concerning
Recipient 's Responsibilities to Limited English Proficient (LEP) Persons in Federal Register:
December 14, 2005 (Volume 70, Number 239)1- This guide states that DOT recipients are
required to take reasonable steps to ensure meaningful access to programs by LEP persons.
This coverage extends to the recipient's entire program. There are four factors for agencies to
consider when assessing language needs and determining what steps to take to ensure
meaningful access for LEP persons:
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1. The number or proportion of LEP persons eligible to be served or likely to be encountered
by a program, activity or service of the recipient;
2. The frequency with which LEP individuals come in contact with the program;
3. The nature and importance of the program, activity or service provided by the recipient to
people’s lives;
4. The resources available to the recipient and costs.

FACTOR 1: THE NUMBER OR PROPORTION OF LEP PERSONS IN THE AREA

The FTA identified four items that should be included in the first factor of the analysis, which
comprise the headings below

HOW LEP POPULATIONS INTERACT WITH UTA
The way the general public interacts with UTA is through direct contact employees that
facilitate our services. These would include positions such as vehicle (bus and light rail)
operators, fare inspectors, UTA police officers, train hosts, customer service representatives,
etc. Additionally, customers would interact with UTA through our written publications and our
website.

IDENTIFICATION OF LEP COMMUNITIES
UTA reviewed data provided by LEP.gov to determine the proportion of LEP persons in the
area. While 5.7% of the residents of the counties served by UTA are considered LEP, the
most prevalent of the languages is, by far, Spanish comprising 72% of all LEP and make up
4.2% of the total population. There is a significant difference between the number of Spanish
LEP speakers and all other language speakers, with the rest being 0.2% of the population or
less.
The following table lists the languages with over 1,000 LEP speakers in the counties UTA
serves.
Table 1: Top LEP Languages

Spanish
Chinese
Vietnamese
Other Pacific Island
Korean
Serbo-Croatian
Other Indic langs.
Other Asian langs.
African langs.
Tagalog
Russian
Portuguese

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Total LEP
Population
82145
4780
3604
2530
1755
1711
1701
1488
1326
1145
1101
1018

Source: LEP.gov/maps

Percentage of
Total Population
4.2%
0.2%
0.2%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%

UTA Title VI Program 2019

Percentage of
LEP Population
72.3%
4.2%
3.2%
2.2%
1.5%
1.5%
1.5%
1.3%
1.2%
1.0%
1.0%
0.9%

LITERACY SKILLS OF LEP POPULATIONS IN NATIVE LANGUAGE
In examining the efficacy of written communications, UTA has identified the literacy rates in
the main countries representing the languages spoken by highest populations of LEP
persons. Below is a table that depicts the literacy rates of the countries where the most LEP
persons may have originated from. Table 2 below depicts the adult literacy rates (15 years of
age and older) of four major countries that contribute to the LEP population.
Table 2: Literacy Rates

Mexico
China
Vietnam
South Korea

Literacy Rate
94.9%
96.4%
94.5%
97.9%

Source: CIA World Factbook & Unesco

Although Mexico is listed above, the Spanish speaking population is not exclusively from
Mexico but from all over Latin America. In the Unesco regional overview of Latin America and
the Caribbean, they estimate that adult literacy rates for the region was 92% in 2012 and
has only increased since then.
Considering that high rates of literacy in the countries that the local LEP populations
originate from, it would appear that written translations would be effective.

ANALYSIS OF LEP POPULATIONS’ SERVICE LEVEL
Analysis of UTA service has shown that minority, low income, and LEP populations are well
represented in the proportion of service available. UTA has created maps showing where
higher than average populations of LEP speakers reside. When there are proposed changes
that may impact these communities, special consideration is given to provide notice and
consideration to LEP persons. UTA planners are advised to review the impacts to those
language speakers when making service changes, so that information regarding
concentrations of LEP speakers can be used in formulating UTA’s public participation plan.
In examining the LEP maps produced of UTA’s service area, much of the areas are within
walking distance to transit services. Additionally, UTA offers ample service in low-income and
minority population areas, and much of the LEP community would be considered low-income
and/or self-identify as a racial/ethnic minority.

FACTOR 2: FREQUENCY LEP INDIVIDUALS USE UTA

UTA has reviewed the most recent on board survey data to determine the general number of
people that took the survey who reported that they spoke English “less than well” or “not at
all”. Of the 16,408 respondents, 622 responded to indicate that they had limited English
proficiency. This comprises 3.8% of the respondents.

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Table 3 lists the number and
languages UTA has required
interpreter services for when
customers contacted UTA’s customer
service line. It is also worth noting
that UTA has full time customer
service staff that speak Spanish
fluently and take Spanish speaking
calls frequently. These calls are not
represented on the chart below. The
source of the data is from the
contracted interpreting service UTA
employs to address languages other
than Spanish or provide Spanish
translation services when staff is not
available to take calls. Although the
exact number of Spanish speaking
calls is not tracked, it is estimated
that customer service takes 15-20
Spanish speaking calls a day. Even
when only factoring calls that have
been outsourced, Spanish still
comprises over 93% of the requests
for interpretation UTA receives.

FACTOR 3: NATURE AND IMPORTANCE OF UTA ON PEOPLE’S LIVES

For many people, transit services are an indispensable part of their lives. The Department of
Transportation’s LEP policy states that, “providing public transportation access to LEP
persons is crucial. An LEP person’s inability to utilize effectively public transportation may
adversely affect his or her ability to obtain health care, or education, or access to
employment.” Additionally, In UTA’s 2015-2016 survey of riders, 55% of the respondents
said that UTA’s services or walking was their only option. When examining only minority
populations’ response to this question, 64.6% of minority respondents stated that they had
no transportation options other than UTA or walking.

FACTOR 4: RESOURCES AVAILABLE TO UTA

UTA is committed to assuring that resources are used to reduce the barriers that limit access
to information and services by LEP persons. Many costs associated with delivery of service to
LEP individuals are already included in the daily cost of doing business with a diverse
population.
DOT’s LEP Guidance distinguishes oral language services (“interpretation”) from written
language services (“translation”), so UTA will follow these definitions when looking at
language assistance.
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A) CURRENT LANGUAGE ASSISTANCE RESOURCES
•

•

•

•

•

•
•
•

•

•
•

UTA employs several bilingual Customer Service Representatives and Paratransit
Scheduling Specialists who work various shifts. Agents are able to transfer calls to
the representative or a contracted translation service with the needed language
skills. The specific languages and scheduled availability changes with the turnover of
staff. UTA actively seeks to hire more bilingual Customer Service and Paratransit
Scheduling staff.
Since many of our employees have valuable language skills, a UTA Language Bank
was created. This is a list of employees who are proficient in languages besides
English and can be a resource when dealing with customers. A voluntary survey was
administered to employees to gather the data. The list of employees, which notes the
ability to speak, read, and write the language, will be maintained by the Title VI
Compliance Officer and distributed to all managers and supervisors, and those
departments most likely to need ad hoc language interpretation and translation
services.
Whenever UTA advertises public hearings, the notices include a statement saying
that printed materials in alternate formats or a language interpreter for non-English
speaking participants are available when requested at least five (5) working days
prior to the date of the scheduled event. Notices are also posted on the State of Utah
public notices website (http://pmn.utah.gov), which has a translation option that
includes 35 languages.
UTA created a “how to” video in Spanish for UTA's Ticket Vending Machines. The
English version is the top viewed video produced by UTA with 61k views and the
Spanish version is the 15th most viewed video with 5.7k views.
UTA’s website has a button at the top of its home page and in the navigation bar
which says “Español”, and the user can get a Spanish translation of anything on the
site.
Ticket vending machines at TRAX and FrontRunner stations have instructions in
English and Spanish.
Universal symbol pictures are on signs in buses, TRAX vehicles, and at stations
showing safety warnings and rules for riding.
Spanish instructions are on many buses, trains, and amenities (such as instructions
for standing behind the yellow line, how to signal the operator for a stop,
surrendering certain seats for passengers with disabilities, and location of emergency
exits).
UTA established an ongoing contract for telephone interpreting services. Information
on how to use the service was distributed to all managers, supervisors, and Office
Coordinators, and to all Customer Service employees. Training is provided for
Customer Service employees on how and when to use the service.
UTA has also established a contract with a community organization, the Refugee and
Immigrant Center, for in-person interpreters.
UTA utilizes professional document translation services consistently to ensure that
the messages being conveyed to the public are correctly translated.

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LANGUAGE ASSISTANCE IMPLEMENTATION PLAN

To evaluate possible improvements or alter the mix of language assistance services that UTA
provides, resources that could be used for providing LEP assistance were reviewed. This
included determining the cost of a professional interpreting and translation service,
identifying which documents would be designated as “vital” for translation, taking an
inventory of community organizations that UTA could partner with for outreach and
translation efforts, and the amount of staff training needed and feasible.
The following sections outline the goals and processes UTA will follow to make improvements
to the language assistance programs. Where resources are not available to implement all
desired programs, ideas will be prioritized by importance and cost effectiveness by UTA’s top
management, with recommendations from the Civil Rights department and from community
organizations UTA has partnered with.

TASK 1: IDENTIFYING LEP INDIVIDUALS REQUIRING LANGUAGE ASSISTANCE

The four factor analysis, in section III of this plan, shows the percentages and estimates of
the number of people in the LEP population in UTA’s service area.
UTA will continue to maintain maps which show census block groups where higher than
average concentrations of LEP persons reside. These maps will be updated when new
census data becomes available.
There are also several measures that can be taken to identify individuals who may need
language assistance:

•

When open houses or public meetings are held, a sign-in table is set up with a staff
member there to greet and briefly speak to each attendee. This conversation will allow
the employee to informally gauge the attendee’s ability to speak and understand
English. If an interpreter of that language is available, the LEP person will be directed to
speak with the interpreter. If no one is available, the employee can give the LEP person
a card with information on where interpretation services can be obtained.

•

Notices of open houses and public meetings will contain an explanation that language
assistance for LEP persons is available upon request, along with a contact name and
phone number.

•

Employees at public events could utilize the telephone interpreting service for help
dealing with LEP persons at the meeting. If requests are made ahead of time, in-person
interpreters will be made available.

•

Customers who come in to UTA offices or contact UTA by phone will be greeted by an
employee familiar with how to connect them with appropriate interpreting services,
either with a UTA employee or through an interpreting service.

•

An automated Customer Service telephone menu system can answer many schedule
questions in Spanish. Those needing more assistance can be connected to a Customer
Service Representative.

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TASK 2: LANGUAGE ASSISTANCE MEASURES

There are numerous language assistance measures available to LEP persons, including oral
and written language services. UTA staff will respond to LEP persons in the most efficient and
cost-effective way available, whether by telephone or in writing.
This section lists the ways in which language assistance will be provided.

UTA STANDARD:
Due to the wide gap between the number of Spanish LEP speakers and all the other
language groups, UTA will routinely make vital document translations available in Spanish.
Other languages will be added to this translation list if the proportion exceeds 4% LEP
speakers in the UTA service area, as based on demographic data. Vital documents in other
languages will be made available upon request or through use of the telephone interpreting
service to have a document read to the LEP person. As shown in the table of interpreting
services provided during the previous three years, UTA provides interpretation service in any
language needed, even if UTA employees are unable to provide them internally.

A) WRITTEN TRANSLATION OF VITAL DOCUMENTS
“Vital documents” are defined as those documents without which a person would be unable
to access transit services. If interactions with the public include letters, notices, or forms, and
the nature of these documents would be considered of critical importance to LEP persons,
consideration shall be given to written translation of the documents or forms. The Civil Rights
department of UTA can be a resource in helping define what is and is not considered a vital
document.
A vital document may include, but is not limited to:
•
•
•
•
•
•
•

Applications
Consent Forms
Letters containing important information regarding participation in a UTA program or
service
Notices pertaining to the reduction, denial, or termination of service or benefits
Notices or letters that require a response from the beneficiary
Notices advising LEP persons of the availability of free language assistance
Any future documents or outreach materials that are deemed to be a vital document

Whether or not a document (or the information it solicits) is “vital” will depend on the
importance of the program, information, encounter, or service involved, and the
consequence to the LEP person if the information in question is not accurate or timely
disseminated.
Sometimes a very large document may include both vital and non-vital information. This may
also be the case when the document title and a phone number for obtaining more
information on the contents of the document in languages other than English is critical, but
the document is sent out to the general public and cannot reasonably be translated into
many languages. In a case like this, vital information may include, for instance, providing
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information in appropriate languages regarding where an LEP person might obtain an
interpretation or translation of the document.

B) SIGNAGE
UTA’s Title VI Compliance Officer will work with the departments involved to determine what
signage on vehicles or at transit stops and stations require translation. Heavy emphasis will
be placed on using universal images or pictorial representations that can be understood
without language on signage whenever possible.
UTA public buildings frequented by customers will be evaluated to determine the feasibility of
posting signage or notices in the most commonly spoken languages stating that interpreters
are available, and the phone number to reach UTA Customer Service to get that assistance.

C) PROVIDING ORAL LANGUAGE ASSISTANCE
UTA will not pass on to our customers the cost of providing
language assistance to meet our LEP requirements. UTA will
provide competent interpreters in a timely manner. The
following are ideas that UTA has evaluated and will implement
as resources become available to add to our current language
assistance offerings.
• UTA will partner with local human service organizations that
provide services to LEP individuals and seek opportunities to
provide information on UTA programs and services.
• Charts are available at many locations throughout our system
(pictured to the left) that a person speaking a language other
than English can point to the language they speak and UTA
staff can call into our interpreter service to effectively
communicate with LEP persons.
• UTA will post the UTA Title VI Compliance Policy and our Title
VI Program on the agency website, rideuta.com.
• UTA will take reasonable steps to hire personnel with specific
language skills. This may include using terminology similar to
“second language skills preferred” on job announcements and
ads, and giving extra credit for these skills during the selection
process.
• During the evaluation process for people with disabilities at
the UTA Evaluation Center, which UTA requires to qualify for
Paratransit service, many LEP customers prefer to bring their
own interpreter to appointments. The evaluation gathers
detailed and personal information about the extent of the
customer’s physical and mental limitations and functional
abilities. UTA will continue to ask LEP customers to bring their own interpreter to these
evaluation appointments. If a customer does not know someone who can interpret, UTA
will provide a qualified interpreter at no cost to the applicant.
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•

“I Speak” charts which list various languages and let LEP persons point to identify their
language. “Interpreter” cards which can be distributed to customers. The card states
“Interpreter” in the nine most commonly used languages in the area, and gives the UTA
Customer Service phone number (below).

FAMILY, FRIENDS AND BYSTANDERS: Surveys with UTA Bus Operators have indicated that most
of the time another person is present on the vehicle who can assist in interpreting the
language for LEP customers. UTA personnel should only use family, friends or bystanders for
interpreting in informal, non-confrontational contexts, and only to obtain basic information at
the request of the LEP customers. Using family, friends or bystanders to interpret could result
in a breach of confidentiality, a conflict of interest, or an inadequate interpretation. Barring a
difficult circumstance, UTA personnel should not use minor children to interpret.

DIFFICULT CIRCUMSTANCES: UTA personnel are expected to follow the general procedures
outlined in this Plan; however, difficult circumstances may require some deviations. In such
situations, employees are to use the most reliable, temporary interpreter available, such as
bilingual UTA personnel or a bystander. In an emergency, employees should ensure that
everyone follows applicable evacuation or other procedures, and should be on the lookout for
anyone who may not understand verbal instructions in English.

D) ENSURING THE COMPETENCY OF INTERPRETERS AND TRANSLATORS
UTA will verify the competency of people who may act as interpreters and translators as
much as possible.
•
•

•

•

UTA will rely on professional interpreting services whenever appropriate. UTA will not
pass the cost of these translation services on to any customer.
UTA will only use an interpreter or translator that is not from a professional service if
they can demonstrate the ability to communicate or translate information accurately in
both English and the target language.
UTA will instruct the interpreter or translator not to deviate into a role as counselor,
legal advisor, or any other role aside from interpreter or translator. Interpreters working
for UTA must restate the UTA representative’s words in the target language and also
translate replies in English for the representative, without adding any comments or
asking any questions of their own.
UTA will ask interpreters or translators to attest that they do not have a conflict of
interest on the issues for which they would be providing interpretation services.

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TASK 3: TRAINING STAFF

A part of ensuring meaningful access for LEP persons, UTA employees need to know their
obligations under Title VI, and all employees in positions with regular public contact should
be properly trained.
UTA will provide training to ensure that:
•
•

Employees having contact with the public know about LEP policies and procedures.
Employees having contact with the public are trained to work effectively with in-person
and telephone interpreters.

UTA employees that are likely to come into frequent contact with LEP persons include:
•
•
•
•
•

Customer Service Representatives and Telephone Information Specialists
Paratransit Reservation agents
Transit Police
Bus Operators (Train Operators will be trained as resources allow, since they do not
have much public contact.)
Train Hosts

LEP TRAINING PLAN
Training will be conducted for all new employees, as identified above, will be combined with
existing new training sessions that might be scheduled. LEP training shall include the
following information.

1.

A summary of the UTA’s obligations and responsibilities to LEP persons under the DOT
LEP Guidance;

2.

A summary of UTA’s language assistance plan and procedures;

3.

A description of the types of language assistance that UTA is currently providing and
instructions on how agency staff can access these products and services.

TASK 4: PROVIDING NOTICE TO LEP PERSONS

It is important to let LEP persons know what language services UTA provides and that those
services are available free of charge. Notification ideas that UTA will use include:

•

Having cards to distribute which state “Interpreter” in the nine most commonly used
languages in the area, and lists the UTA Customer Service phone number to get that
assistance.

•

Stating in outreach documents (brochures, booklets, pamphlets, and flyers) that
language services are available free of charge, and giving the phone number where
those services can be obtained.

•

Working with community-based organizations to inform LEP persons of the language
assistance available.

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•

Presentations and/or notices at schools and religious organizations serving many nonEnglish speakers, letting them know of important actions or where community
involvement is critical.

EXISTING PUBLIC SERVICE ANNOUNCEMENTS AND COMMUNITY OUTREACH
UTA typically communicates to the public through the following methods:

•

Announcements and handouts available in vehicles and at stations

•

UTA website and social media sites

•

Customer service phone lines

•

Press releases

•

Newspaper, radio, and television advertisements

•

Announcements and community meetings

•

Information tables at local events

Some of these communication tools are geared towards riders who are using the system,
while other methods are intended to reach members of the public at large, who may or may
not use the transit system. Both methods can be used to inform people of the availability of
language assistance.

TARGETED OUTREACH TO LEP POPULATIONS
Targeted community outreach can consist of meeting with agencies that serve LEP
populations and attending community meetings and events to inform people of the agency’s
service in general and that language assistance is available.
UTA will seek to partner with its existing community contacts and other agencies that are
seen as credible and trusted to notify the LEP population of the availability of language
services.
Notification can also be distributed through programs used by LEP persons, such as English
classes for speakers of other languages.

TASK 5: MONITORING AND UPDATING THE LEP PLAN

UTA will determine, on an ongoing basis, whether new documents, programs, services, and
activities need to be made accessible for LEP individuals, and how we might want to provide
notice of any changes in services to the LEP public and to employees. UTA will also consider
whether changes in demographics, types of services, or other needs require more frequent
reevaluation of the LEP plan.
Evaluation of this LEP plan will help track UTA’s outreach efforts, discover dissemination
problems, make corrections, and find out whether language services provided have impacted
UTA ridership and/or relations with local immigrant and other LEP communities. The results
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of this monitoring will help improve future efforts, as the LEP plan is meant to be an evolving
document which will be updated as needed.
UTA has appointed a compliance officer to evaluate and monitor LEP services offered by UTA
in conjunction with the relevant business units within UTA. The responsibilities of the Title VI
Compliance Officer shall include reporting to the agency regarding the activities noted below.
•
•

•

•
•

Periodically review demographic data regarding LEP service to evaluate emerging LEP
populations
Work with UTA departments to identify and address deficiencies in LEP services that
may compromise meaningful access by LEP individuals to the programs administered
by UTA
Review suggestions for improvement to LEP service and determine whether
implementation is practical, economical and consistent with the mission of the
authority
Monitor the implementation of reasonable improvements
Prioritize those suggestions which cannot be implemented at a nominal cost to the
authority. Consideration should be given to the number or proportion of LEP
individuals who will benefit from the suggested improvement, the cost to the
authority, and whether the change can be implemented in a manner consistent with,
and without unduly burdening, the fundamental mission of the authority

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LEP MAPS

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ATTACHMENT H – RIDERSHIP SURVEY

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UTA Title VI Program 2019

ATTACHMENT I – BOARD RESOLUTION ON TITLE VI PROGRAM
(Intentionally Left Blank)

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UTA Title VI Program 2019

ATTACHMENT J – SERVICE AND FARE EQUITY ANALYSES
Included in this section are all of the Service and Fare Equity (SAFE) Analyses conducted during
calendar year 2016 through 2018. They include:
1. April 2016 Change Day Analysis…………………………………………………………………………..Page 1
2. August 2016 Change Day Analysis……………………………………………………………………….Page 6
3. April 2017 Change Day Analysis…………………………………………………………………………..Page 16
4. August 2017 Change Day Analysis……………………………………………………………………….Page 40
5. April 2018 Change Day Analysis…………………………………………………………………………..Page 75
6. Provo-Orem BRT Title VI Equity Analysis………………………………………………………………..Page 107
7. August 2018 Change Day Analysis……………………………………………………………………….Page 161
8. December 2018 Change Day Analysis………………………………………………………………….Page 187

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UTA Title VI Program 2019

Title VI Analysis of Service Changes
By Utah Transit Authority
April 10, 2016 Service Changes
Prepared by Ruth Hendricks
Title VI Compliance Officer
669 West 200 South, Salt Lake City, UT 84101
801-741-8871

Description of April 2016 Service Changes
The Timpanogos Division proposes eliminating two unproductive routes, the 836 and the 842, and redirecting
those resources to routes that will serve more riders.
Timpanogos Division Changes
Route 836 – Franklin, River Grove, Provo Station
Route 842 – Orem 800 North, Center St., Orem Station
Route 821 – South County, Provo Station
Route 833 – Airport, Provo Station
Route 834 – Riverwoods, Provo Station
Route 850 – State Street

Eliminate route
Eliminate route
Increase frequency
Increase frequency
Increase frequency
Increase peak service

This action will result in many customers receiving improved service and producing an increase in ridership.
Reasons for the Change
Planners noted that routes 836 and 842 had low ridership and they fell outside the Timpanogos service planning
office’s efficiency measures. Recently UTA’s revamped service planning office helped establish service
standards that flag routes when their performance falls outside specific performance measures and the routes
that failed to meet the Timpanogos standards also failed these new UTA standards.
Ridership - Route elimination / Route increase
Average Boardings
Average Boardings
Route
per Trip
per Day
836
5
61
842
5
123
821
16
625
833
6
63
834
7
174
850
24
2,138

UTA Title VI Analysis of April 2016 Service Changes

Attachment J: Page 1

Page 1

The number of boardings these service changes will generate is calculated using the average trip load of the
improved routes being multiplied by the number of new trips, minus the average existing ridership on the routes
being eliminated. Planners estimate the changes will produce 33,469 more boardings, annualized.
IPR (Investment per Rider) for all the affected routes are estimated to go from $3.00 to $2.88 and boardings per
hour are estimated to go from 17.99 to 18.74.
What alternatives were considered?
•
•
•

Doing nothing
Delaying service changes until August 2016
Moving ahead with the planned changes.

Various approaches taken over the last few years to support these routes include the following.
Changes to Route 836 – Provo West side, Franklin/Dixon, Provo FrontRunner Station
• Aug 2015 - Minor Schedule adjustments
• Aug 2014 - Routing changed and schedule adjusted to 60/90 minute frequency.
• Aug 2013 - Alignment changed due to Rt 830 alignment change. Route and schedule adjusted for
reliability and with some select trips reduced. 830 is a more direct alignment to match upcoming BRT
alignment. So 833 and 836 alignments changed to cover old 830 alignment. 836 alignment extended to
cover Provo College.
• Dec 2012- New circulator route in west Provo to make one-way clockwise loops to collect and distribute
customers from the neighborhoods to the commuter rail station.
Changes to Route 842 - Orem Center / 800 North
• Aug 2013 – Schedule adjusted for reliability with some reduction on select trips.
• Apr 2013 – Schedule adjusted to better meet trains.
• Dec 2012 – New service serves Orem Central station to Riverwoods via Geneva Road, 800 North, and
Orem Center Street
The changes made have still resulted in low ridership on the routes.

Title VI Impact Analysis
For this analysis, the minority and low-income population within a ¼ mile buffer of the affected routes was
calculated.

UTA Title VI Analysis of April 2016 Service Changes

Attachment J: Page 2

Page 2

Affected Routes – Negative Impacts / Positive Impacts
Affected
Routes

Type of Change

Total
Population

Minority
Population

% Minority

Low-Income
Population

% Low-income

836

Route elimination

13,296

1,871

14.07%

4,044

30.40%

842

Route elimination

13,064

1,932

14.79%

2,366

18.11%

821

Additional trips

23,495

2,225

9.47%

2,868

12.21%

833

Additional trips

10,542

2,027

19.23%

2,814

26.69%

834
850

Additional trips
Additional trips

16,490
45,071

2,186
5,379

13.26%
11.93%

7,050
9,156

42.75%
20.3%

Total population

121,958

15,620

12.81%

28,298

23.2%

Total population - eliminations

26,360

3,803

14.43%

6,410

24.3%

Total population - additions

95,598

11,817

12.36%

21,888

22.9%

Regional Population Data
Total Service
Area Population
2,192,127

Total Minority
Population
629,642

%
Minority
21%

Total
Households
664,137

Total Low-Income
Households
142,512

% Low-Income
Households
21%

Conclusion
In comparing the demographics for the Timpanogos service change to the regional population for UTA’s
service area, the minority percentage for the Timpanogos routes being eliminated is 14.4%. The minority
percentage for the routes receiving added trips is 12.4%. Both of these percentages are well below the regional
minority average of 21%. Also, both percentages are within the 5% threshold that UTA has set to determine
disparate impact on minority populations Therefore, making the planned changes does NOT have a disparate
impact on minority populations.
The low-income percentage for the routes being eliminated is 24.3%. The low-income percentage for the routes
receiving added trips is 22.9%. Both of these percentages are above the regional low-income average of 21%, so
all of these routes serve low-income areas. However, both route eliminations and route additions are within the
5% threshold that UTA has set to determine disproportionate burden on low-income populations. Therefore,
making the planned changes does NOT have a disproportionate burden on low-income populations.

UTA Title VI Analysis of April 2016 Service Changes

Attachment J: Page 3

Page 3

UTA Title VI Analysis of April 2016 Service Changes

Attachment J: Page 4

Page 4

UTA Title VI Analysis of April 2016 Service Changes

Attachment J: Page 5

Page 5

TITLE VI SERVICE EQUITY ANALYSIS AUGUST CHANGE DAY 2016
Prepared by Kenya Fail
Manager, Civil Rights Compliance
669 West 200 South, Salt Lake City, UT 84101
The Federal Transit Administration (FTA) issued Circular 4702.1B in 2012, which defines Title VI and
Environmental Justice compliance procedures for recipients of FTA-administered transit program funds.
Specifically, the FTA requires recipients, including Utah Transit Authority, to “evaluate significant system-wide
service changes and proposed improvements at the planning and programming stages to determine whether
those changes have a discriminatory impact.”
The entire Title VI report for the Utah Transit Authority service changes concept plan is available online.

Definitions:
Minority: The FTA defines a minority person as one who self-identifies as American Indian/Alaska Native,
Asian, Black or African American, Hispanic or Latino, and/or Native Hawaiian/Pacific Islander. Minority
percentages in the Utah Counties Area are mapped in (See attached charts).
Low Income: The FTA defines a low-income individual as one whose household income is at or below the
poverty guidelines set by US Census Bureau 2010-2014 American Community Survey (ACS). Thresholds are
based on household size and income, which form the basis of this review. Low-income percentages in the Utah
Counties Area are mapped in (See attached charts).
Disparate Impact: The Federal Transit Administration defines “disparate impacts” as neutral policies or
practices that have the effect of disproportionately excluding or adversely affecting members of a group
protected under Title VI, and the recipient’s policy or practice lacks a substantial legitimate justification. If the
results of the analysis indicate a potential for disparate impacts, further investigation is performed. This report
uses qualitative assessments and/or the “four-fifths rule” to determine whether disparate impacts exist. In this
analysis, if the quantitative results indicate the proposed service changes provide benefits to minority/lowincome groups at a rate less than 80 percent of the benefits provided to non-minority/non-low-income groups,
there could be evidence of disparate impacts and mitigation measures should be identified.
On Sunday, August 14, select rail and bus schedules will be changed to adjust connections, better utilize
resources and, in some cases, implement Prop 1 improvements. Four routes in Davis and Weber counties will
see improvements using Prop 1 funds, and Prop 1 funding will facilitate the addition of a new route in Davis
County.

Attachment J: Page 6

Davis and Weber Service Highlights
Routes 455 and 473 will have additional trips added to their schedules using Prop 1 funds. On route 640, Prop
1 funds will be used to expand Saturday service hours and increase bus frequency to every 30 minutes. Route
667, which runs from Farmington FrontRunner Station to Lagoon, will operate year-round Monday through
Saturday to improve access to FrontRunner, Station Park shopping and the new University of Utah hospital.
Additions to Service
Total
Route
Population

Minority
Population

Minority %

Households

Low-Income
Household

455

69,651

14,892

21.4%

26,199

7,952

473

63,993

14,963

23.4%

24,457

8,203

640

36,005

9,166

25.5%

12,393

3,511

667

2,113

104

4.9%

636

57

628

10,018

2,790

27.8%

3,797

1,464

Low-Income
Household %
30.4%
29.5%
33.5%
38.6%
38.6%

The chart listed above shows Routes 455, 473 and 640 are highly populated minority and low-income areas
which have increased service and frequency. Route 667 has an increase to service and is highly populated in
the low-income area. Prop 1 improvements will also be used to add a new route between Clearfield and
Layton. Route 628, the Midtown Trolley, has been sponsored by local businesses and will be free to riders.
This free service will directly benefit minority and low-income populations which are highly populated on this
route. Eventually, unique buses with a trolley-style look will be used on the route.
Route 470 and 612 will also see small adjustments for improved reliability and connections. Some weekday
trips on route 603 will no longer serve Ogden Clinic. Route 603 serviced on weekdays the Ogden Clinic with
one early morning trip heading northbound. The route assisted with layover concerns in the system. The
adjustment to this route was made to have a consistent pattern all day long. The route had an average of .08
people board or alight for 2015. The route services the Ogden Clinic on Sundays.
In comparing the demographics for the Davis and Weber county service changes to the total population for UTA’s
service area, the minority percentage and low-income percentage for all routes increasing service directly benefit
these areas. Based on the demographic data in U. S. Census Bureau and 2010-2014 American Community Survey,
UTA found the average minority population in the service are is 22% and average percentage of low-income
households is 22%. All routes with proposed increase of changes were over the average with the exception of
route 455 and 667 in the minority category. Therefore, making the planned changes does NOT have a disparate
impact on minority or low-income populations.

Attachment J: Page 7

Salt Lake County Service Highlights
In Salt Lake, many bus routes had schedule adjustments to allow for improved connections and reliability.
Routes 2,6, 17, 21, 33, 35, 39, 41 54, 62, 200, 201, 205, 209, 213, 217, 220, 232, 240, 248,320, 354, 509, 516,
519, 525 and 902 will all see minor schedule changes. All adjustments will facilitate in passengers easing
connections within the system creating an added benefit for all users. The planned changes do NOT create a
disparate impact on minority or low-income populations.
Utah Country Service Highlights
Utah County bus routes will also see small changes, as routes 805, 806, 821, 822 and 840 are adjusted to
improve reliability and route 811 is adjusted to make connections with the new TRAX Blue Line schedule. A
detour around an Orem WinCo on route 862 has been made permanent. The change allows route 862 to stay
within the same block group which serves both minority and low income populations. Therefore, the planned
changes do NOT create a disparate impact on minority or low-income populations.
Flex Route Service Highlights
Saturday service will be added to several flex routes in an effort to give flex route riders more travel options.
Routes F94, F514, F504, F578, F556 and F618 will have Saturday service with 60 minute frequency between 7
a.m. and 7 p.m. The weekday headways for the routes listed above remained the same with the exception of
route F504. Route F504 runs clockwise and the counterclockwise loop runs every forty minutes on Saturday
instead of sixty minutes. The planned changes do NOT create a disparate impact on minority or low-income
populations.
The table below is rounded to the nearest 5 minutes:
Weekday
Route

LineName

DirectionName

Saturday

APR2016

AUG2016

APR2016

AUG2016

F504

SOUTH JORDAN FLEX

LOOP-CCW

45

45

-

F504

SOUTH JORDAN FLEX

LOOP-CW AM/PM

30

30

-

F514

300 W FLEX

TO 10000 S TRAX

40

40

-

60

F514

300 W FLEX

TO DRAP FRTRNR

40

40

-

60

F556

5600 W FLEX

TO 6200 S

40

40

-

60

F556

5600 W FLEX

TO VA

40

40

-

60

F578

7800 S FLEX

TO 7800 S TRAX

40

40

-

60

F578

7800 S FLEX

TO JORDN LNDING

40

40

-

60

F618

OGDEN BDO FLEX

COUNTRCLOCKWISE

30

30

-

60

F94

SANDY FLEX

TO 9000 S TRAX

30

30

-

60

F94

SANDY FLEX

TO 9400 PNR

30

30

-

60

Attachment J: Page 8

40

-

Rail Service Highlights
The weekend schedules of all TRAX lines and the S-line are being adjusted to improve transfers. The
Frontrunner schedule will not be changed. The planned changes do NOT create a disparate impact on minority
or low-income populations.

Title VI Impact Analysis
For this analysis, the minority and low-income population within a ¼ mile buffer of the affected routes was
calculated.
Current Regional Population Data
Total Service
Area Population

Total Minority
Population

%
Minority

Total
Households

Total Low-Income
Households

% Low-Income
Households

2,243,347

485.342

21.6%

696,768

147,241

21.1%

Conclusion
The service populations were reviewed and considered in all services changes for this period including minority
and low income as listed above. Overall, none of the service changes increasing service, minor eliminatations
or re-routings created any disparate impacts to minority or low-income populations. The majority of service
was increased in minority or low-income population areas from April 2016 change day to August 2016 change
day. See comparasion chart below:

APR2016
Route

33
35
39
455
470
473
628
640
667
F504
F514
F556
F578
F618
F94

AUG2016

Weekda y Sa turda y Sunda y
44
53
57
103
184
31
79
35
16
18
16
18
16
18

24
49
23

8
17
7

139

114

APR2016

Weekda y Sa turda y Sunda y
87
32
42

45
32
18

35
25
7

138

114

133

30
14

184
36
27
79
11
16
18
16
18
16
18

23
76
12
10
8
9
9
9
7

AUG2016

Weekda y Sa turda y Sunda y
714
897
892
2,020
3,490
714
1,355
577
353
321
289
322
332
293

Attachment J: Page 9

370
826
371

132
313
109

2,712

2,488

524
226

Weekda y Sa turda y Sunda y
1,324
564
607
2,630
3,490
933
381
1,355
186
353
309
289
322
332
295

655
533
271

553
491
108

2,670

2,488

334
1,377
205
218
162
165
176
160
129

Attachment J: Page 10

Attachment J: Page 11

Attachment J: Page 12

Attachment J: Page 13

Attachment J: Page 14

Attachment J: Page 15

Title VI Service
Equity Analysis
April 2017

0|Page

Utah Transit Authority
Prepared by: Andrew Gray

Attachment J: Page 16

Contents
Introduction .................................................................................................................................................. 2
Summary of Proposed Changes .................................................................................................................... 2
Route 477 – Cancellation of Route: ...................................................................................................... 2
Route 667 – Change in Routing and Schedule: ..................................................................................... 2
UTA Policy and Definitions ............................................................................................................................ 3
Definitions ............................................................................................................................................. 3
Major Service Change ........................................................................................................................... 4
Evaluation and Analysis of Service and Fare Changes .......................................................................... 4
Disparate Impact and Disproportionate Burden .................................................................................. 5
Finding a Disparate Impact ................................................................................................................... 5
Finding a Disproportionate Burden ...................................................................................................... 6
Proposed Changes......................................................................................................................................... 7
Route 477 .................................................................................................................................................. 7
Public Outreach ..................................................................................................................................... 9
Route 667 ................................................................................................................................................ 10
Public Outreach ................................................................................................................................... 12
Analysis of Proposed Changes .................................................................................................................... 13
Route 477 ................................................................................................................................................ 14
Low-Income Analysis........................................................................................................................... 14
Minority Analysis................................................................................................................................. 15
Route 667 ................................................................................................................................................ 16
Low-Income Analysis........................................................................................................................... 16
Minority Analysis................................................................................................................................. 17
Findings of Analysis ..................................................................................................................................... 18
Route 477 ................................................................................................................................................ 18
Route 677 ................................................................................................................................................ 18

1
Attachment J: Page 17

Introduction
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and
national origin in programs and activities receiving federal financial assistance. The Utah Transit
Authority has committed to the Federal Transit Administration (FTA) Title VI objectives set forth
in Circular 4702.1B ensuring that FTA‐assisted benefits and related services are made available
and are equitably distributed without regard to race, color, or national origin.
The following analysis is of proposed changes to be implemented in April of 2017. These
changes are being proposed to improve service delivery. Though the proposed changes are
facially neutral, this analysis, in accordance with FTA requirements, will ensure that these
changes will not have disproportionate and negative impacts on minority and low-income
populations within UTA’s service area. If these changes are found to be discriminatory, UTA will
take all steps necessary to ensure services are equitable and compliant with federal guidelines
and requirements.

Summary of Proposed Changes
Route 477 – Cancellation of Route:
Route 477 connects Center Street in North Salt Lake to The Pioneer Adult Rehabilitation Center
(PARC) in Clearfield. The proposed change will eliminate this route due to changes in partner
needs, a historic decline in ridership and present low ridership.
The reduction of the mileage of any route in excess of 33% meets the major service change
definition and must have a Title VI Analysis performed. This proposed change meets this
definition.

Route 667 – Change in Routing and Schedule:
Route 667 is a “Free Fare Shuttle” in Farmington, which loops through the Farmington
FrontRunner Station, Lagoon (amusement park) and downtown Farmington. Due to heavy loads
in the summer and connection issues with FrontRunner, the proposal is to modify the schedule
to provide better transfers to and from Frontrunner and spread passenger loads across trips. In
order to accomplish this, there would be a reduction in services. Rather than a bus coming by
roughly every 30 minutes from 8:09 am to 8:13 pm, no service will run to downtown
Farmington in the AM and PM peak periods, and every 60 minutes during the mid-day.

2
Attachment J: Page 18

Any changes proposing a change in alignment of 25% or greater meet the major service change
definition and must have a Title VI analysis performed. This proposed change meets this
definition.

UTA Policy and Definitions
UTA has developed corporate policy 1.1.28 Title VI Compliance Policy to evaluate the impacts of
proposed major services changes on minority and low-income populations. The following policy
references refer to subsections of the aforementioned corporate policy and were created to
ensure that all equity analyses are performed using the same parameters.

Definitions

A. “Disparate Impact” refers to a facially neutral policy or practice that disproportionately
affects members of a group identified by race, color, or national origin, where the
recipient's policy or practice lacks a substantial legitimate justification and where there
exists one or more alternatives that would serve the same legitimate objectives but with
less disproportionate effect on the basis of race, color, or national origin.
B. “Disproportionate Burden" refers to a neutral policy or practice that disproportionately
affects low-income populations more than non-low-income populations.

C. “Low-income Population" refers to any readily identifiable group of low-income persons
who live in geographic proximity, and, if circumstances warrant, geographically
dispersed/ transient persons (such as migrant workers or Native Americans) who will be
similarly affected by a proposed FTA program, policy or activity.
D. "Minority Person” include the following:
1. American Indian or Alaska Native, which refers to people having origins in any of the
original peoples of North and South America (including Central America), and who
maintain tribal affiliation or community attachment.
2. Asian, which refers to people having origins in any of the original peoples of the Far
East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia,
China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and
Vietnam.
3. Black or African American, which refers to people having origins in any of the Black
racial groups of Africa.
4. Hispanic or Latino, which includes persons of Cuban, Mexican, Puerto Rican, South
or Central American, or other Spanish culture or origin, regardless of race.

3
Attachment J: Page 19

5. Native Hawaiian or Other Pacific Islander, which refers to people having origins in
any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
E. ''Minority Population" means any readily identifiable group of minority persons who live
in geographic proximity.
F. "National Origin" means the particular nation in which a person was born, or where the
person's parents or ancestors were born.
G. “System Average” The system average is the averages of minorities and low-income
persons within the total populous of the geographic regions that UTA serves. The
present system averages are expressed below in tabular format using 2011-2015 5-year
population estimates provided by American Community Survey (ACS) data.
Low-Income System Average:
Number of Households:
703,314
Low-Income Households: 144,649
Percent Low-income:
20.6%

Minority System Average:
Population:
Minority Population:
Percent Minority:

2,273,056
499,458
21.97%

Major Service Change

UTA will consider the following types of changes to be “major changes”, which require public
input and a Title VI equity analysis in compliance with FTA’s Circular 4702.1B
a) The Addition of Service;
b) A proposed service level reduction in miles, hours, or trips of thirty three percent (33%)
or more of any route;
c) The elimination of all service during a time period (peak, midday, evening, Saturday, or
Sunday);
d) A proposed twenty-five (25%) or greater change in route alignment;
e) A proposed fare change.

Evaluation and Analysis of Service and Fare Changes

1. UTA will analyze proposed major changes to service and any proposed fare changes in
accordance with FTA's Circular C 4702.1B as amended.
2. UTA will evaluate the impacts of all major service changes cumulatively when there is
more than one route being affected for a service change period
3. UTA will primarily utilize American Community Survey (ACS) Data, block group data and/
or ridership data to evaluate and analyze any proposed major service and fare changes.
This data will be analyzed with Geographic Information System (GIS) software.

4
Attachment J: Page 20

4. UTA will rely on population data and use the smallest geographic area that reasonably
has access to the stop or station effected by the proposed major service change. This
will be translated into a one-quarter mile radius to a bus stop, one-half mile to a light
rail station and three miles to a commuter rail station.

Disparate Impact and Disproportionate Burden

1. UTA will measure the burdens of service and fare changes on minority riders to
determine when minority riders are bearing a disparate impact from the change
between the existing service or fare and the proposed service or fare.
2. UTA will measure the burdens of service and fare changes on low-income riders to
determine when low-income riders are bearing a disproportionate burden of the change
between the existing service or fare and the proposed service or fare.

3. A threshold of 5% will be used to determine disparate impact on minority populations
and disproportionate burden on low-income populations. This 5% is based on the
margin of error from the US Census data that UTA uses to determine the populations in
the service area. This means that if the burden of the service or fare change on minority
or low-income populations is more than 5% worse than it is for the non-protected
populations, then the change will be considered either a disparate impact or a
disproportionate burden.

Finding a Disparate Impact

1. At the conclusion of UTA's Analysis, if UTA finds a disparate impact on the basis of race,
color, or national origin, UTA shall seek to modify the proposed changes in a way that
will mitigate the adverse effects that are disproportionately borne by minorities.
Modifications made to the proposed changes must be reanalyzed in order to determine
whether the modifications actually removed the potential disparate impacts.
2. If UTA chooses not to alter the proposed services changes despite the potential
disparate impact on minority populations, or if UTA finds, even after the revisions, that
minority riders will continue to bear a disproportionate share of the proposed service or
fare change, UTA may implement the change only if:
a. UTA has substantial legitimate justification for the proposed change; and
b. UTA can show that there are no alternatives that would have a less disparate
impact on the minority riders but would still accomplish the transit provider's
legitimate program goals. In order to show this, UTA must consider and analyze
alternatives to determine whether those alternatives would have less of a

5
Attachment J: Page 21

disparate impact on the basis of race, color, or national origin, and then
implement the least discriminatory alternative

Finding a Disproportionate Burden

If at the conclusion of the analysis, UTA finds that low-income populations will bear a
disproportionate burden of the proposed major service change, UTA will take steps to avoid,
minimize, or mitigate impacts where practicable. UTA will also describe alternatives available to
low-income passengers affected by the service changes.

6
Attachment J: Page 22

Proposed Changes
Route 477

7
Attachment J: Page 23

Route 477 makes two trips every weekday and does not run weekend service. The first trip
departs from Center & Orchard Dr. in North Salt Lake at 7:55 AM and concludes at PARC Center
at 9:02 AM. The second trip departs from PARC Center at 3:05 pm and concludes at Center &
Orchard Dr. at 4:04 PM.
The original intent of route 477 was to provide service to those who participate in Pioneer Adult
Rehabilitation Center (PARC). PARC provides services to people with disabilities along the
Wasatch Front. Route 477 was created when Davis County school buses stopped providing
transportation. When Davis County discontinued its service, the paratransit services at the time
did not have capacity to accommodate the number of riders needing transportation, which
prompted a fixed-route solution. This is why route 477 only runs once in the morning heading
north to PARC and once south from PARC in the evening with no weekend service.
Since the formation of the route, roughly half of the participants at PARC have transferred to
paratransit and ridership has declined. The average ridership for calendar year 2016 is 30 per
day compared to 46 when the route was first created in August of 2005. See the line graph
below for a month-by-month breakdown of route utilization over an 11 year period.

8
Attachment J: Page 24

At the request of PARC, a meeting was held between UTA and PARC on October 24, 2016 to
discuss public transit options for those who were participating in their services. Through this
discussion it was determined that riders who use route 477 to get to PARC may be best served
through paratransit services rather than the fixed-route services. UTA and PARC reviewed
participant ridership and determined all present riders would be eligible for paratransit. UTA
and PARC proceeded to conduct a public outreach campaign to gather input from riders and
relevant caretakers as to whether paratransit would more adequately address the needs of 477
riders. PARC took responsibility to ensure that all effected participants were informed of the
change and assisted with the paratransit eligibility process.

Public Outreach

The public comment period for this change was from January 5 to February 5 of 2017. Notice
was listed on UTA’s website, Utah.gov, the Ogden Standard Examiner and the Davis County
Clipper, both local newspaper. Comments were accepted via mail, email, at the public hearing
and by phone. The public hearing was held on January 19th, 2017. It was publicized by and held
at the PARC facility. Seven people attended this meeting and there was no opposition to the
proposed changes. One respondent was somewhat supportive, but offered alternative
proposals. This information was provided to planning for consideration.
In addition to the public hearing and public comment period, all known riders’ care providers
were identified and directly contacted by UTA’s Special Services Business Unit.

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Route 667

Route 667 is a free fare shuttle from the Farmington FrontRunner station, Station Park
shopping complex, Lagoon amusement park, The Hampton Inn, and downtown Farmington in a
figure 8 loop. The purpose of this route is to connect riders to recreational facilities from easily
accessible locations. To better accomplish this purpose, UTA has proposed to modify the
schedule to provide better transfers to and from FrontRunner and to spread passenger loads
across route 667 trips. The proposed changes would eliminate service to downtown Farmington
in the AM and PM peak periods, and every 60 minutes during the mid-day.
This route’s fare is a sponsored fare, meaning that the individual riders are not required to pay
fare to ride. The sponsorship is led by Farmington City who seeks partners who benefit from the
shuttle and to contribute a portion of the costs.
The table below shows the stops on Route 667 that have a proposal to decrease the headways
and fall out the downtown Farmington Loop. The time frame for both tables’ average boardings

10
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are calculated using the data from June 2016 through August 2016. This time frame was
selected because it is the time frame when the route is used most and would have the most
impact on riders and little data exists for off-season running since it had not run off season trips
until after August 2016.
Name of Stop Decreasing
Frequency
105001 MAIN ST 479 N
105003 MAIN ST 305 N
106001 STATE ST 398 W
107064 STATE ST 108 W
107065 STATE ST 220 W
301012 STATE ST 45 E
301333 600 N 111 W
301410 PARK LN 331 W

Average Weekday
Boardings
0.00
0.00
0.00
0.00
0.00
0.33
0.14
0.48

Average Saturday
Boardings
0.00
0.00
0.00
0.00
0.00
1.00
0.00
0.91

The following table shows those stops that fall on the Lagoon, FrontRunner and Park Station
loop and will have proposed increased headways.
Name of Stop Increasing
Frequency
105021 LAGOON DR 375 N
106007 100 N 873 W
106008 STATE ST 720 W
301055 450 N 850 W
301056 850 W 450 N
301313 PARK LN 189 N
301422 UNION AVE 184 N
301423 UNION AVE 185 N

Average Weekday
Boardings
97.31
0.00
0.04
266.98
12.14
0.00
2.00
0.81

Average Saturday
Boardings
169.45
1.56
0.22
542.00
26.73
0.00
0.00
0.89

According to the route 667 bus stop level ridership information above, Lagoon is the largest
market draw on the route and there is very little ridership on Main Street in downtown
Farmington. In addition, there is large growth potential at the Station Park and University of
Utah hospital stations. The proposed schedule changes aim to improve the transit experience
for the biggest markets and increase connectivity timing to the FrontRunner schedule, while
still providing some level of service to downtown Farmington.

11
Attachment J: Page 27

Even with shortening the route on selected trips throughout the day, the 667 still can’t meet
every train perfectly. The revised schedule is based on observed travel patterns and available
ridership data.

Public Outreach

The public comment period for this change was from January 5 to February 5 of 2017. Notice
was listed on UTA’s website, Utah.gov, the Ogden Standard Examiner and the Davis County
Clipper, both local newspaper. The public hearing was held on January 19th, 2017. Comments
were accepted via mail, email, at the public hearing, phone and Open UTA which is an online
forum for discussion. The public outreach hearing was held January 26th, 2017 at the
Farmington City Hall. In addition to this, there was direct contact with Farmington City, Station
Park, Lagoon, Hampton Inn and the University Medical Center in the region.
Response from Farmington City and local businesses were all positive and 50% of community
members were in support of the changes. 50% of community responses were opposed. The
three respondents in opposition to the changes expressed concern regarding access to Lagoon
and downtown Farmington locations during peak times. Alternative routes, specifically routes
455 and 470, are able to provide transportation to the specified locations. One respondent
suggested running a second route to downtown or having the 667 resume a more frequent
downtown schedule during Lagoon’s off-season. UTA Planning is considering both options for
future proposed changes.

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Attachment J: Page 28

Analysis of Proposed Changes
UTA is required to analyze the potential impacts of any major service change as it relates to
Low-income populations and minority populations. Pursuant to this requirement, UTA has
created the following maps, tables and related data. The data in this section was compiled
utilizing American Community Survey (ACS) 2011-2015 5-year estimates, which was dispersed
into census blocks, in lieu of the larger block groups. This was done in order to use the smallest
geographic area possible for the analysis. The distribution was dictated by population ratios
from 2010 Census Data. Analysis was done based on the stops of the route. All stops have had a
one quarter mile radius applied to them based on the actual accessibility of the route by road.
Any census block that is overlapped by this “walkability radius” has its population included as
those effected by the proposed changes. These aggregated numbers are compiled as a
comparison group to the service area average to determine disparate impact and
disproportionate burden.
The maps in this section will show the route, individual stops with a walkability radius, and
census blocks with concentrations of low-income households or minority individuals above the
system average, which are shaded according to density.

13
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Route 477

Low-Income Analysis

The total effected population by the proposed elimination compared to the system average are
shown below in tabular format below.
Low-Income System Average:
Number of Households:
703,314
Low-Income Households: 144,649
Percent Low-income:
20.6%

Route 477:
Number of Households:
Low-Income Households:
Percent Low-income:

8,904
2,175
24.4% (+3.8%)

As expressed in the table above, the total low-income households negatively impacted by this
elimination is 3.8% greater than the system average. This is still below the 5% threshold.

14
Attachment J: Page 30

Minority Analysis

The total effected population by the proposed elimination compared to the system average are
shown below in tabular format below.
Minority System Average:
Population:
2,273,056
Minority Population:
499,458
Percent Minority:
21.97%

Route 477:
Population:
Minority Population:
Percent Minority:

25,202
4,032
19.1% (-2.87%)

As expressed in the table above, the low-income households negatively impacted by this
elimination is 2.87% below the system average.

15
Attachment J: Page 31

Route 667
Low-Income Analysis

The total effected population by the proposed elimination compared to the system average are
shown below in tabular format below.
Low-Income System Average:
Number of Households:
703,314
Low-Income Households: 144,649
Percent Low-income:
20.6%

Route 667:
Number of Households:
Low-Income Households:
Percent Low-income:

717
69
9.6% (-11%)

As expressed in the table above, the total low-income households negatively impacted by this
elimination is 11% below the system average.

16
Attachment J: Page 32

Minority Analysis

The total effected population by the proposed elimination compared to the system average are
shown below in tabular format below.
Minority System Average:
Population:
2,273,056
Minority Population:
499,458
Percent Minority:
21.97%

Route 667:
Population:
Minority Population:
Percent Minority:

3,213
175
5.4% (-16.57%)

As expressed in the table above, the low-income households negatively impacted by this
elimination is 16.57% below the system average.

17
Attachment J: Page 33

Findings of Analysis
Route 477
There were no disparate impacts or disproportionate burden found in the analysis of this
service change. While there were more low-income households in the area impacted by these
changes than the system average, it did not exceed the 5% threshold that would require
additional steps to minimize, mitigate or offset the adverse effects.
In spite of not having negative impacts to minority or low-income populations beyond the 5%
threshold, there was still concern regarding the riders of this route who had disabilities. UTA
has been sensitive to the needs of those riders, which is why there was more outreach than is
typical for a standard change. UTA collaborated with PARC to be as inclusive of those impacted
as possible and to hear their concerns. All riders were offered and qualified for paratransit
services. Since Utah’s Division of Services for People with Disabilities (DSPD) is paying the cost
of transportation, there is no increased cost to the individual rider and feedback received
through public outreach was overall positive. The replacement service of paratransit will
provide a more personalized experience to the individuals. After reviewing all of these factors,
UTA does not feel that these changes will negatively impact riders, but will likely make their
transportation experience better.

Route 677
There were no disparate impacts or disproportionate burden found in the analysis of this
service change. The proposed changes will take place in a predominantly non-minority and nonlow-income area.

18
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Report of the Meeting
of the
Board of Trustees of the Utah Transit Authority (UTA)
held at UTA FrontLines Headquarters located at
669 West 200 South, Salt Lake City, Utah
March 22, 2017
Board Members Present:
Robert McKinley, Chair
Sherrie Hall Everett, Vice Chair
Jeff Acerson
Cortland Ashton
Keith Bartholomew
Necia Christensen
Karen Cronin

Babs De Lay
Charles Henderson
Dannie McConkie
Bret Millburn
Brent Taylor
Troy Walker

Board Members Excused/Not in Attendance: Greg Bell, Jeff Hawker, Michael Romero
Also attending were members of UTA staff, as well as interested citizens and media
representatives.

Welcome and Call to Order. Chair McKinley welcomed attendees and called the meeting to
order at 1:37 p.m. with eleven voting board members present. The board and meeting
attendees then recited the Pledge of Allegiance.
Safety Minute. Chair McKinley yielded the floor to Dave Goeres, UTA Chief Safety, Security &
Technology Officer, for a brief safety message.
1
Attachment J: Page 35

General Public Comment Period. In-person public comment was given by George Chapman.
Resolution: R2017-03-01: 2016 Performance Report.
Presentation of Item. Jerry Benson, UTA President/CEO, delivered a presentation on the
agency’s 2016 performance, covering progress on reforms, general accomplishments,
financial performance, and performance against board goals .
Public Input. One comment was received online and was read in the meeting by Robert
Biles acting in his capacity as secretary of the board. In-person comment was given by
George Chapman.
Trustee Millburn joined the meeting at 2:17 p.m.
Board Discussion and Decision/Action. Chair McKinley asked if any trustees had a
reason to recuse themselves from discussing or voting on this item. No trustees
indicated any conflicts. Discussion ensued. Questions were posed by the board and
answered by Mr. Benson. Trustee Bartholomew requested time at the board retreat to
discuss metrics that favor the agency’s values. Trustee Henderson expressed concern
with awarding the partial percentage recommended by staff on the revenue goal. A
motion to approve the resolution was made by Trustee De Lay and seconded by Trustee
Walker. Further discussion ensued. Trustee Henderson proposed that the motion be
amended to approve the resolution replacing the partial completion on the revenue
goal with the percentage of actual revenue awarded in 2016. Trustee De Lay agreed to
amend her motion. Trustee Taylor expressed opposition to UTA’s performance incentive
program. Chair McKinley counseled Trustee Taylor that his concerns about the
performance incentive program would be better addressed at the retreat because the
program itself is “not being reviewed at this point.” He said the question at hand is what
percentage should be applied to the 2016 performance incentive program already
approved. Trustee Taylor stated that he would like to provide his rationale for a
substitute motion. He then expressed concern with hiring lobbyists. Chair McKinley
interjected that a discussion on lobbyists was not relevant to the current topic and
asked Trustee Taylor to restrict his comments to the performance incentive program.
Trustee Taylor opined that ridership should be a major factor in performance incentive
awards and also mentioned discomfort with the points awarded for public trust and
asked that the factor be reconsidered. He expressed further discomfort with the “size
and scope” of the performance incentive program. Trustee Taylor made a substitute
motion to eliminate the performance incentive program for 2016 and in the future.
There was no second on the motion and Chair McKinley declared the motion dead.
2
Attachment J: Page 36

More discussion ensued. Trustee De Lay requested additional information on the
performance incentive program in the future. Chair McKinley indicated the performance
incentive program is part of the board’s upcoming workshop agenda. Mr. Benson stated
that the executive team is doing a thorough review of UTA’s compensation program
generally and requested the opportunity to present a newly aligned compensation
program to the board later in the year. An amended motion to approve resolution with
an accomplishment award of 77.7 percent from an available amount of $914,435.86 was
made by Trustee De Lay and seconded by Trustee Walker. The motion carried by
majority consent with one nay vote from Trustee Taylor.
Presentations/Informational Items.
2017 Risk Assessment Process. UTA Chief of Internal Audit Riana De Villiers delivered a
presentation on the internal audit risk assessment process including internal audit
responsibilities and plan development.
Public Hearing Report – April Change Day. A report on the April Change Day was given
by staff. UTA Regional Manager of the Mount Ogden Business Unit Eddy Cumins covered
two route changes in Davis County, UTA Public Hearing Officer Erika Shubin summarized
public outreach on the changes, and UTA Civil Rights Compliance Officer Andrew Gray
reviewed the Title VI analysis. During the presentation questions were posed by the
board and answered by staff. Trustee Taylor requested that the current version of the
presentations given in board meetings be included in the packet.
Closed Session. Chair McKinley indicated that a change was needed to the order of the agenda
and asked for a motion to go into closed session to discuss matters related to pending litigation.
A motion to move into closed session was made by Trustee Christensen and seconded by
Trustee Millburn. The motion was approved by unanimous consent and the board moved into
closed session at 3:27 p.m.
Open Session. A motion to return to open session was made by Trustee Millburn and seconded
by Trustee De Lay. The motion carried by unanimous consent and the board returned to open
session at 4:43 p.m.
Action Taken Regarding Matters Discussed in Closed Session.
Legal Agreement. A motion to approve the agreement as presented during closed
session was made by Vice Chair Everett and seconded by Trustee Bartholomew. The
motion carried by majority consent with one nay vote from Trustee Taylor.
3
Attachment J: Page 37

Trustee De Lay left the meeting at 4:46 p.m.
Board Member Event Participation. Chair McKinley asked that this item be deferred to
the April agenda in the interest of time.
Board Workshop Pre-Work and Milestone Timeline of Activity. Trustee Henderson
asked trustees to visit with their appointing authorities and use the questions outlined
in the meeting packet to prompt a dialog. He encouraged trustees to engage in and
complete the pre-work in order to maximize the time available during the board
workshop. Trustee Henderson asked if any trustee had an objection to forming a
strategic plan with a horizon of 20 years. No objections were raised.
Utah Legislative Session Overview. Chair McKinley asked that this item be deferred to
the April agenda in the interest of time.
Items for Consent. Consent items were comprised of the following:



Approval of February 22, 2017 Meeting Report
Title VI Equity Analysis of April Service Changes



CEO Performance Plan
A motion to approve the consent items was made by Trustee Christensen and seconded
by Trustee Walker. The motion carried by unanimous consent.

Other Business.
Board Process Policy 4.4.1 – Actual and Potential Conflicts of Interest. This item was
deferred to the April agenda.
SB174 Legislative Task Force Appointment. Chair McKinley stated that during the
legislative session SB174 was passed. One of the provisions of the bill sets up a
legislative task force to review governance of the state’s transportation agencies and
UTA was given one appointment. Chair McKinley recommended Trustee Millburn to
represent the agency on the task force. No motion was required on this item, but the
board voted to affirm the appointment by majority consent with ten aye votes and one
abstention by Trustee Millburn.

4
Attachment J: Page 38

Adjournment. The meeting was adjourned at 4:55 p.m. by motion.
Transcribed by Cathie Griffiths
Assistant to the President/CEO
Utah Transit Authority
[email protected]
801.237.1945
Video and audio recordings of this meeting are posted online.

5
Attachment J: Page 39

Attachment J: Page 40

Attachment J: Page 41

Attachment J: Page 42

Title VI Service
Equity Analysis
August 2017
0

Utah Transit Authority
Prepared by: Andrew Gray
Attachment J: Page 43
Graphics and Data: Joseph Taylor and James Wadley

Contents
Introduction .................................................................................................................................................. 3
Summary of Proposed Changes .................................................................................................................... 3
Route 664 & 665 – Cancellation of Routes: .......................................................................................... 3
Route 809 – Addition of Route: ............................................................................................................ 3
Route 627 – Addition to Route: ............................................................................................................ 3
UTA Policy and Definitions ............................................................................................................................ 4
Public Input on UTA Policy .................................................................................................................... 4
Definitions ............................................................................................................................................. 4
Major Service Change Definition .......................................................................................................... 5
Evaluation and Analysis of Service and Fare Changes .......................................................................... 6
Disparate Impact and Disproportionate Burden .................................................................................. 6
Finding a Disparate Impact ................................................................................................................... 6
Finding a Disproportionate Burden ...................................................................................................... 7
Proposed Changes......................................................................................................................................... 8
Routes 654 and 655 .................................................................................................................................. 8
Route 809 ................................................................................................................................................ 14
Route 627 ................................................................................................................................................ 15
Public Outreach........................................................................................................................................... 16
Ogden Business Unit Public Outreach .................................................................................................... 16
Routes 664 & 665 ................................................................................................................................ 17
Route 627 ............................................................................................................................................ 18
Timpanogos Business Unit Public Outreach ........................................................................................... 18
Analysis of Proposed Changes .................................................................................................................... 19
Route 664 ................................................................................................................................................ 20
Low-Income Analysis........................................................................................................................... 20
Minority Analysis................................................................................................................................. 21
Route 665 ................................................................................................................................................ 22
Low-Income Analysis........................................................................................................................... 22
Minority Analysis................................................................................................................................. 23
Route 809 ................................................................................................................................................ 24
Low-Income Analysis........................................................................................................................... 24

1
Attachment J: Page 44

Minority Analysis................................................................................................................................. 25
Route 627 ................................................................................................................................................ 26
Low-Income Analysis........................................................................................................................... 26
Minority Analysis................................................................................................................................. 27
Cumulative Analysis of Changes ............................................................................................................. 28
Eliminations:........................................................................................................................................ 28
Additions: ............................................................................................................................................ 28
Findings of Analysis ..................................................................................................................................... 29
Elimination of Routes 664 & 665 ............................................................................................................ 29
Justification for Continuing with Changes .......................................................................................... 29
Addition of Routes 809 & 627 ................................................................................................................. 31

2
Attachment J: Page 45

Introduction
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and
national origin in programs and activities receiving federal financial assistance. The Utah Transit
Authority has committed to the Federal Transit Administration (FTA) Title VI objectives set forth
in Circular 4702.1B ensuring that FTA‐assisted benefits and related services are made available
and are equitably distributed without regard to race, color, or national origin.
The following analysis is of proposed changes to be implemented on August 13 of 2017. These
changes are being proposed to improve service delivery throughout the system. Though the
proposed changes are facially neutral, this analysis, in accordance with FTA requirements, will
ensure that these changes will not have disproportionate and negative impacts on minority and
low-income populations within UTA’s service area. If these changes are found to be
discriminatory, UTA will take all prudent steps necessary to ensure services are equitable and
compliant with federal guidelines and requirements.

Summary of Proposed Changes
Route 664 & 665 – Cancellation of Routes:
Routes 664 and 665 are a connection route between the Layton Frontrunner Commuter Rail
station and Hill Airforce Base during peak hours. It is proposed to eliminate these routes due to
low ridership. The elimination of service constitutes a major change.

Route 809 – Addition of Route:
The proposed creation of Route 809 is to be a new fixed route to provide local, limited service
between Pleasant Grove and the American Fork FrontRunner Station. There will be two trips
running in the morning from Pleasant Grove to the American Fork FrontRunner station, then
two trips in the afternoon from the American Fork FrontRunner to Pleasant Grove. The addition
of services is considered a major change.

Route 627 – Addition to Route:
The route 627 proposal includes extending the north section of the route from Weber State
Davis Campus to the Clearfield Commuter Rail Station, where it will connect with the 626. This
addition would constitute a change of over twenty-five percent of the current route alignment,
which constitutes a major change.

3
Attachment J: Page 46

UTA Policy and Definitions
UTA has developed corporate policy 1.1.28 Title VI Compliance Policy to evaluate the impacts of
proposed major services changes on minority and low-income populations. The following policy
references refer to subsections of the aforementioned corporate policy and were created to
ensure that all equity analyses are performed using the same parameters.

Public Input on UTA Policy
In order to create UTA’s Title VI Compliance Policy, which describes how UTA will determine
disparate impact on minority populations and disproportionate burden on low-income
populations, UTA sought public involvement per FTA Circular 4702.1b requirements. To solicit
feedback from the public, UTA advertised a public notice in local newspapers in the service
area. The notice and draft policy was posted on UTA’s website, rideuta.com, as well as on the
Utah state government’s website, Utah.gov, under “Public Notices”. The state website provides
35 language translation options. An email notification was sent out by the Salt Lake County
Office of Diversity Affairs, which maintains an email list that goes to anyone interested in
diversity issues. Additional targeted outreach was done, which included mailing a letter and the
policy or sending emails to community organizations that work with minority or low-income
populations.

Definitions
A. “Disparate Impact” refers to a facially neutral policy or practice that disproportionately
affects members of a group identified by race, color, or national origin, where the UTA’s
policy or practice lacks a substantial, legitimate justification and where there exists one
or more alternatives that would serve the same legitimate objectives but with less
disproportionate effect on the basis of race, color, or national origin.
B. “Disproportionate Burden" refers to a neutral policy or practice that disproportionately
affects low-income populations more than non-low-income populations.
C. “Low-income Population" refers to any readily identifiable group of low-income persons
who live in geographic proximity, and, if circumstances warrant, geographically
dispersed/ transient persons (such as migrant workers or Native Americans) who will be
similarly affected by a proposed FTA program, policy or activity.
D. “Low-income person” refers to a person whose median household income is at or below
150% of the U.S. Department of Health and Human Services (HHS) poverty guidelines.
UTA utilizes American Community Survey (ACS) poverty data to determine low-income
status when utilizing population data.

4
Attachment J: Page 47

E. "Minority Person” includes the following:
1. American Indian or Alaska Native, which refers to people having origins in any of the
original peoples of North and South America (including Central America), and who
maintain tribal affiliation or community attachment.
2. Asian, which refers to people having origins in any of the original peoples of the Far
East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia,
China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and
Vietnam.
3. Black or African American, which refers to people having origins in any of the Black
racial groups of Africa.
4. Hispanic or Latino, which includes persons of Cuban, Mexican, Puerto Rican, South
or Central American, or other Spanish culture or origin, regardless of race.
5. Native Hawaiian or Other Pacific Islander, which refers to people having origins in
any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
F. ''Minority Population" means any readily identifiable group of minority persons who live
in geographic proximity.
G. "National Origin" means the particular nation in which a person was born, or where the
person's parents or ancestors were born.
H. “System Average” The system average is the averages of minorities and low-income
persons within the total populous of the geographic regions that UTA serves. The
present system averages are expressed below in tabular format using 2011-2015 5-year
population estimates provided by American Community Survey (ACS) data.
Low-Income System Average:
Population:
2,243,746
Low-Income Population: 457,949
Percent Low-income:
20.4%

Minority System Average:
Population:
Minority Population:
Percent Minority:

2,277,445
499,870
21.9%

Major Service Change Definition
UTA will consider the following types of changes to be “major changes”, which require public
input and a Title VI equity analysis in compliance with FTA’s Circular 4702.1B
a) The Addition of Service;
b) A proposed service level reduction in miles, hours, or trips of thirty three percent (33%)
or more of any route;
c) The elimination of all service during a time period (peak, midday, evening, Saturday, or
Sunday);

5
Attachment J: Page 48

d) A proposed twenty-five (25%) or greater change in route alignment;
e) A proposed fare change.

Evaluation and Analysis of Service and Fare Changes
1. UTA will analyze proposed major changes to service and any proposed fare changes in
accordance with FTA's Circular C 4702.1B as amended.
2. UTA will evaluate the impacts of all major service changes cumulatively when there is
more than one route being affected for a service change period
3. UTA will primarily utilize American Community Survey (ACS) Data, block group data and/
or ridership data to evaluate and analyze any proposed major service and fare changes.
This data will be analyzed with Geographic Information System (GIS) software.
4. UTA will rely on population data and use the smallest geographic area that reasonably
has access to the stop or station effected by the proposed major service change. This
will be translated into a one-quarter mile radius to a bus stop, one-half mile to a light
rail station and three miles to a commuter rail station.

Disparate Impact and Disproportionate Burden
1. UTA will measure the burdens of service and fare changes on minority riders to
determine when minority riders are bearing a disparate impact from the change
between the existing service or fare and the proposed service or fare.
2. UTA will measure the burdens of service and fare changes on low-income riders to
determine when low-income riders are bearing a disproportionate burden of the change
between the existing service or fare and the proposed service or fare.
3. A threshold of 5% will be used to determine disparate impact on minority populations
and disproportionate burden on low-income populations. This 5% is based on the
margin of error from the US Census data that UTA uses to determine the populations in
the service area. This means that if the burden of the service or fare change on minority
or low-income populations is more than 5% worse than it is for the non-protected
populations, then the change will be considered either a disparate impact or a
disproportionate burden.

Finding a Disparate Impact
1. At the conclusion of UTA's Analysis, if UTA finds a disparate impact on the basis of race,
color, or national origin, UTA shall seek to modify the proposed changes in a way that
will mitigate the adverse effects that are disproportionately borne by minorities.

6
Attachment J: Page 49

Modifications made to the proposed changes must be reanalyzed in order to determine
whether the modifications actually removed the potential disparate impacts.
2. If UTA chooses not to alter the proposed services changes despite the potential
disparate impact on minority populations, or if UTA finds, even after the revisions, that
minority riders will continue to bear a disproportionate share of the proposed service or
fare change, UTA may implement the change only if:
a. UTA has substantial legitimate justification for the proposed change; and
b. UTA can show that there are no alternatives that would have a less disparate
impact on the minority riders but would still accomplish the transit provider's
legitimate program goals. In order to show this, UTA must consider and analyze
alternatives to determine whether those alternatives would have less of a
disparate impact on the basis of race, color, or national origin, and then
implement the least discriminatory alternative

Finding a Disproportionate Burden
If at the conclusion of the analysis, UTA finds that low-income populations will bear a
disproportionate burden of the proposed major service change, UTA will take steps to avoid,
minimize, or mitigate impacts where practicable. UTA will also describe alternatives available to
low-income passengers affected by the service changes.

7
Attachment J: Page 50

Proposed Changes
Routes 654 and 655

8
Attachment J: Page 51

Routes 664 and 665 are commuter-focused routes within the Ogden Business Unit that each
run six trips from the Layton FrontRunner station to Hill Airforce Base in the morning and five
trips from Hill Airforce Base to the Layton FrontRunner station in the afternoon. The primary
focus of this route is to provide transportation to those working on base. Any stops inside of the
base require passage through a guard station where credentials must be presented to gain
access, which includes the operator.
Low ridership relative to the cost of service has been the influential factor in the decision to
propose the complete cancellation of these two routes. There is greater ridership on route 665,
which can be attributed to a 2014 addition of service to Weber State University Davis. WSU
Davis has several other routes which can replace the service left by the cancellation of the 665.
The bubble graph on the following page is an
excerpt from a decision-making tool utilized by
UTA’s planners to assist in prioritizing upcoming
changes. It utilizes the legend pictured on the
right to show the type of route (first column) and
the average percent of the bus that is filled. The
bus on 664 runs at an average of 6.5% capacity
while the 665 runs at 10.7% capacity. Both are
commuter shuttles.
The X-axis of the bubble chart is how many riders,
on average, are aboard the bus during operational
hours. 664 averages 8.4 riders per revenue mile
and the 665 averages 10.7.
The Y-axis expresses in miles how long the
individual rider remains on the bus when they
have boarded. The 664 averages 2.5 miles per
rider while the 665 averages 3.2. In the context of
the rest of the Ogden Business Unit, which
encompasses Davis, Weber and Ogden Counties, it
is evident that these routes are below average in
their ridership and utilization.

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10
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UTA has proposed to transition fixed route bus riders to the more economical Vanpool and
RideVan Plus. Vanpool is a service where UTA provides a van to a group of commuters traveling
to work who would like to travel together. This service is already utilized by riders on base.
RideVan Plus is a hybrid commuting option for commuters who can take the Frontrunner or
TRAX to the station nearest their destination, then travel as a group in the UTA provided van to
and from their destination. The van remains parked at the station overnight. This solution
would still provide existing bus users transportation on base at a less expensive option. The
average cost per Vanpool users is approximately $110 a month, but can be as low as $30 a
month depending on the monthly distance traveled and number of vanpool participants.
RideVan Plus has a maximum charge of $93. The cost of RideVan Plus would cover the cost of
the participant’s premium monthly pass, which is regularly priced at $198. If the rider has a pass
provided through their employer, school, etc., then $50 will be deducted from the cost of
RideVan Plus and the rider will be required to pay the difference.
664 Ridership
Since May of 2015, there has been a downward trend in ridership, as illustrated in the graph
below, which shows the daily average of boardings by month from May of 2014 through April
of 2017.

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The table below shows the average daily boarding and alighting numbers by stop for January
through May of 2016 and the same time frame in 2017. The first, and most frequented stop is
the Layton Frontrunner station. Subsequent stops are all on Hill Airforce Base. Only one of the 8
stops on base averages more than one boarding or alighting per day.

665 Ridership Information
As with the 664, the 665 has been experiencing a downward trend in ridership in recent
months. As shown in the chart, the downward trend began in August of 2016 and has steadily
decreased since.

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The 665 has higher average boardings than the 664, but this is due to the three stops off base,
which is a direct line from the FrontRunner to Weber State University Davis. These stops were
added in April of 2015 when ridership began going up.
The table below lists the individual stop utilization broken up to those on Hill Air Force Base
(HAFB) and those off base. The stop at the Layton FrontRunner station has the most boardings
and alights as a connector to the commuter rail and the Weber State University stop has the
second highest. The most utilized stop on base, located at 538 South Southgate Avenue is
within .3 miles from a stop off base which is regularly serviced by route 627.
The final data point is the percent of all boardings and alightings that occur on base. Based on
these figures, the majority of the ridership on these routes is not on base.

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Route 809

The 809 has been proposed as a new route in Utah County in our Timpanogos Business Unit
that will utilize a deadhead trip on Route 806 and provide connectivity from downtown
Pleasant Grove to the American Fork FrontRunner station. It is proposed to run two trips in the
morning at 5:30am and 6:00am and will travel west from Downtown Pleasant Grove and end at
the American Fork FrontRunner station, then two trips in the afternoon at 6:30pm and 7:00pm
heading east and terminating at downtown Pleasant Grove. The initial proposal included
additional routing that would have included additional routing, but after the public comment
period yielded no definitive support for the longer routing, it was curtailed. Initial route
proposal is depicted below.

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Route 627

UTA is proposing an addition to the existing route 627 within the Ogden Business Unit. The
proposed addition would provide a direct connection from Weber State University (WSU) Davis,
where the route presently ends, through Clearfield City to the Clearfield Station. This can be
used as an alternative to the proposed cancellation of route 665, which provides service from
the Layton FrontRunner Station to WSU Davis. Current alignment follows.

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Public Outreach
Ogden Business Unit Public Outreach
On April 25, 2017, UTA held a public hearing to solicit public input on the proposed elimination
to routes 664 and 665 and the proposed addition to route 627. All of these changes were in the
Ogden Business Unit and were combined into one public hearing. The comment period for
these changes was between April 10 and May 10 of 2017. The public hearing was held on April
25th at Weber State Davis’ campus in Layton, UT. The campus is central to the changes and the
location of one of the most frequented stops on the routes being eliminated. The hearing and
notice of changes were advertised in the Davis County Clipper, the Ogden Standard Examiner,

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the State of Utah’s public notice website and on rideuta.com. Comments were also solicited on
the agency’s Open UTA online comment system. The hearing and comment period were also
promoted on UTA’s social media channels.

Routes 664 & 665
Overall, 30 people offered comments, with some providing comments on both routes – seven
at the public hearing, eight at [email protected] and 15 on the Open UTA system. In
total, 11 people attended the public hearing, and 59 visitors reviewed the proposal on the Open
UTA system.

These changes were also posted on UTA’s website and available for public comment
electronically. The changes were viewed 49 times and responded to 15 times.

Route 664 Feedback
Regarding route 664, of the 27 respondents, 18 were against, five were for, and three were
undecided concerning the elimination of route 664. Those for the changes expressed
appreciation for the more efficient transportation alternative of RideVan Plus and Vanpool and
gave logistical suggestions about parking.
Those against the expressed concerns that generally fell into the following categories


There may be a delay in qualifying for RideVan Plus and/or Vanpool for new employees.



Lack of connectivity from FrontRunner to employment on base.



Lack of flexibility for transit dependent individuals moving to alternatives that will only
travel to and from base once per day



Previous service issues may have caused poor ridership



General concern for one’s inability to get to work, though do not mention the proposed
alternatives

Route 665 Feedback
Of the 24 respondents for this route, six were for the changes, 13 against and five undecided
about the proposed elimination. Comments mirrored those for the 664, but had less comments

Alternative Transportation Reception
By the end of June, the Special Services Program had heard from twenty-one 664 & 665 riders
who requested more information about the Vanpool and RideVan Plus options. Of those, 11

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ultimately were not interested in joining or creating a Vanpool, which provides transit from
one’s home to the end location. They expressed that they would either like more flexibility in
their schedule or would work to join a RideVan Plus option. Two of the remaining ten had
already joined a Vanpool. UTA has followed up with everyone who contacted Special Services
regarding the requirements to set up a RideVan Plus and is seeking enough commitments to
begin the program at this location.

Route 627
FEEDBACK FROM MEETING:
These changes were also posted on UTA’s website, on the Open UTA system and available for
public comment electronically. On the Open UTA system, the proposal was viewed 33 times.
Twelve comments were received during the proposal’s comment period – two at the public
hearing, six on Open UTA and four at [email protected]. Eleven of the comments
expressed support for the proposal, and one comment was neutral and included an alternate
proposal. Some commenters gave logistical comments, but all were positive in their responses.

Timpanogos Business Unit Public Outreach
On May 25, 2017, UTA held a public hearing to solicit public input on the proposed changes to
route 809. This change took place in the Timpanogos Business Unit and was the only major
service change in this area. The comment period for this proposed addition was between May
11, 2017 and June 11, 2017. The public hearing was held on May 25 at the Pleasant Grove
Recreation Center, which is located near the community where changes are being proposed.
The hearing and notice of changes were advertised in the Provo Daily Herald, on rideuta.com,
on the State of Utah’s public notice site, and on UTA’s Open UTA system. On the Open UTA
system, 48 visitors viewed the proposal. There were no attendees as the public hearing and one
phone call placed concerning the proposal to add route 809. The phone call requested that it be
full service so that paratransit could be added to the region.
For the 809 proposal, 14 comments were received with 10 as favorable and four as undecided.

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Analysis of Proposed Changes
UTA is required to analyze the potential impacts of any major service change as it relates to
low-income populations and minority populations. Pursuant to this requirement, UTA has
created the following maps, tables and related data. The data in this section was compiled
utilizing American Community Survey (ACS) 2011-2015 5-year estimates, which was dispersed
into census blocks, in lieu of the larger block groups. This was done in order to use the smallest
geographic area possible for the analysis. The distribution was dictated by population ratios
from 2010 Census Data. Analysis was done based on the stops of the route. All stops have had a
one quarter mile radius applied to them based on the actual accessibility of the route by road.
Any census block that is overlapped by this walkability radius has its population included as
those effected by the proposed changes. These aggregated numbers are compiled as a
comparison group to the service area average to determine disparate impact and
disproportionate burden.
The maps in this section will show the route, individual stops with a walkability radius, and
census blocks with concentrations of low-income households or minority individuals above the
system average, which are shaded according to density.

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Route 664
Low-Income Analysis

As expressed in the figure and table above, the total low-income populations negatively
impacted by this elimination is 1.9% less than the system average.

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Minority Analysis

As expressed in the figure and table above, the low-income households negatively impacted by
this elimination is 6% above the system average.

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Route 665
Low-Income Analysis

As expressed in the table and figure above, the low-income households negatively impacted by
this elimination is 3.9% above the system average.

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Minority Analysis

As expressed in the table and figure above, the minority populations negatively impacted by
this elimination is 14.2% above the system average.

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Route 809
Low-Income Analysis

As expressed in the table and figure above, the low-income populations impacted by this
addition is 11.3% above the system average.

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Minority Analysis

As expressed in the table and figure above, the minority populations impacted by this addition
is 5.7% below the system average.

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Route 627
Low-Income Analysis

The figure above is just of the routing and stops proposed to be added. The table and figure
show that the low-income populations impacted is 19.3% above the system average.

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Minority Analysis

The figure above is just of the routing and stops proposed to be added. The table and figure
show that the low-income populations impacted is 4.8% above the system average.

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Cumulative Analysis of Changes
In accordance with UTA Policy, UTA will evaluate the impacts of all major service changes
cumulatively when there is more than one route being affected for a service change period.
Since the proposed changes during this change period fall into those being added and those
being eliminated, they are being evaluated in these two categories.

Eliminations:
The cumulative demographics of the populations being effected by the elimination of both
route 664 and route 665 are expressed below.

Route 664 & 665 Low-income
Affected Population: 3,429
Low-Income Population:
834
Percent: 24.3%
Difference from System Ave: 3.9%

Route 664 & 665 Minority
Affected Population:
Minority Population:
Percent:
Difference from System Ave:

3,559
1,291
36.3%
14.3%

Additions:
The cumulative demographics of the populations being effected by the additions of route 627
and to 809 are expressed below.
Route 809 & 627 Low-income
Affected Population: 18,783
Low-Income Population:
6420
Percent: 34.2%
Difference from System Ave: 13.8%

Route 809 & 627 Minority
Affected Population: 18,927
Minority Population: 3,684
Percent: 19.5%
Difference from System Ave:
2.4%

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Findings of Analysis
Elimination of Routes 664 & 665
There were no disproportionate burden found in the analysis of this service change. While
there were more low-income households in the area impacted by these changes than the
system average, it did not exceed the 5% threshold that would require additional steps to
minimize, mitigate or offset the adverse effects.
There may be disparate impacts on minorities in these eliminations. When examining
population data, the minority populations impacted by these changes exceeded the UTA
designated threshold of a 5% negative impact. UTA has examined various mitigating factors and
has determined that it has met the requirements to continue with the proposed changes
despite these potential disparate impact that population demographics may suggest.

Justification for Continuing with Changes
Obtaining accurate demographics on this route was a challenge. Since these are commuter
routes originating at a FrontRunner station, it is improbable that the population immediately
within the ¼ mile walk buffer would be the primary users of the route. This may be negated if
the primary route destination were accessible by the general public, but with only those with
credentials to get on base being able to ride the routes this decreases, again, the probability of
the immediate population around the stops accessing the originating stop at the FrontRunner.
With the boardings on base being as low as they are, it would appear unlikely that those living
on base are accessing the route either. With these considerations, the ridership is likely people
from around the system that are accessing FrontRunner to get to the base or WSU Davis. For
those who are accessing WSU Davis, UTA has prepared a map of the other routes connecting
FrontRunner to campus, which will be included at the end of this section. In this map, all offbase stops are mitigated by alternative routes.
In looking at a ridership survey conducted in 2015 and 2016 where over 16,000 riders were
surveyed throughout the system, there were a combined average of 96 riders on these routes
at the time of survey. Of these riders, 13 were captured. 100% of those surveyed on this route
self-reported as white and non-Hispanic. UTA, however, determined that this was not an
adequate sample size to properly reflect the ridership demographics and only includes it as
informational as to efforts made by the agency to ascertain the most accurate information
available.

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Pursuant to FTA Circular 4702.1B, UTA has reviewed possible changes to the proposed changes.
In this review, it was determined that UTA has a substantial and legitimate justification to
proceed with the proposed changes due to the low ridership illustrated on pages 9-13 of this
report. Continuance of these routes would not be financially viable for the limited number of
riders utilizing them when RideVan Plus and Vanpool could meet the need in a more efficient
way. UTA conducted outreach to ensure current riders were aware of and engaged with
Rideshare and/or Vanpool programs. These options provide a viable alternative for those who
are transit dependent an work on base.

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Addition of Routes 809 & 627
There were no disparate impacts or disproportionate burden found in the analysis of this
service change. While route 809 did have 5.7% less minorities in the impacted populations than
the system average, UTA has determined that the addition does not meet UTA’s policy on
disparate impact. The policy states that the changes must have a “5% worse” effect on
protected populations. This addition does not negatively impact minority populations since
there was no adverse effect such as a decrease in service to fund this new route. Additionally,
Utah County, where the addition takes place, only has a minority population of 14.9% which is
less than the effected population.

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Attachment J: Page 75

Attachment J: Page 76

Attachment J: Page 77

Attachment J: Page 78

Title VI Service and
Fare Equity Analysis
April 2018
1

Utah Transit Authority
Prepared by: Andrew Gray
Graphics and Data: Joseph Taylor

Attachment J: Page 79

Contents
Introduction .................................................................................................................................................. 3
Summary of Proposed Changes .................................................................................................................... 3
Route 834 – Addition to Route: ............................................................................................................ 3
Route 864 – Creation of Route: ............................................................................................................ 3
Removal of Fare Media: ........................................................................................................................ 3
UTA Policy and Definitions ............................................................................................................................ 4
Definitions ............................................................................................................................................. 4
Major Service Change ........................................................................................................................... 5
Evaluation and Analysis of Service and Fare Changes .......................................................................... 5
Disparate Impact and Disproportionate Burden .................................................................................. 6
Finding a Disparate Impact ................................................................................................................... 6
Finding a Disproportionate Burden ...................................................................................................... 7
Proposed Changes......................................................................................................................................... 8
Routes 834 ................................................................................................................................................ 8
Route 864 .................................................................................................................................................. 8
Fare Media Elimination ............................................................................................................................. 9
Public Outreach........................................................................................................................................... 10
Analysis of Proposed Changes .................................................................................................................... 12
Route 834 ................................................................................................................................................ 13
Route 864 ................................................................................................................................................ 16
Removal of Fare Media ........................................................................................................................... 18
Findings of Analysis ..................................................................................................................................... 24
Routes 834 – Addition to Route.............................................................................................................. 24
Routes 864 – Addition of Route .............................................................................................................. 24
Removal of Fare Media ........................................................................................................................... 24
Appendix A - April 2018 Change Day Public Comment Report ................................................................... 26

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Introduction
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and
national origin in programs and activities receiving federal financial assistance. The Utah Transit
Authority has committed to the Federal Transit Administration’s (FTA) Title VI objectives set
forth in Circular 4702.1B by ensuring that UTA’s services are made are equitably offered and
resources distributed without regard to race, color, or national origin.
The following analysis is of proposed changes to be implemented on April 8th of 2018. These
changes are being proposed to improve service delivery throughout the system. Though the
proposed changes are facially neutral, this analysis, in accordance with FTA requirements, will
ensure that these changes will not have disproportionately negative impact on minority and
low-income populations within UTA’s service area. If these changes are found to be
discriminatory, UTA will take all prescribed and prudent steps to ensure services are equitable
and compliant with federal guidelines and requirements.

Summary of Proposed Changes
Route 834 – Addition to Route:
It is proposed to add to the northern leg of the 834 route in Utah County. This new routing
would connect the Riverwoods shopping complex in Provo and State Street. The added mileage
is greater than 25% of the original route, which constitutes a major change according to UTA
policy.

Route 864 – Creation of Route:
The Thanksgiving Point area has a large number of office buildings with substantial traffic delays
which will be exacerbated by upcoming road construction projects. Route 864 will provide a
connector from the commuter rail station to the office buildings on the west side of the I-15
freeway. The addition of service constitutes a major change according to UTA policy.

Removal of Fare Media:
It is proposed to eliminate the technology associated with the ability to pay with mobile digital
wallets (Apple Pay, Google Pay, etc.) and contactless credit/debit cards as a fare media
available through our card readers. This method of payment has limited use and direct
alternatives exist on all modes of transit excluding contactless credit/debit cards on bus. The
elimination of this fare media constitutes a major change.

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UTA Policy and Definitions
UTA has developed corporate policy 1.1.28 Title VI Compliance Policy to define and evaluate
the impacts of proposed major services changes on minority and low-income populations in
conjunction with a public outreach process. In developing this policy, UTA solicited feedback
through newspapers within the service area, published on UTA’s website (rideuta.com), and
Utah’s government website in the public notices section (Utah.gov) which provides translation
options. In conjunction with the Salt Lake County Office of Diversity Affairs, which maintains an
email list of local entities and individuals with interest in diversity issues, UTA sent an email
notification soliciting feedback in the development of this policy. Additional targeted outreach
was done, which included mailing a letter and the policy or sending emails to community
organizations that work with minority or low-income populations.
The following references to policy are from subsections of corporate policy 1.1.28 and were
created to ensure that all equity analyses are performed using the same parameters and are in
line with FTA Circular 4702.1B.

Definitions
A. “Disparate Impact” refers to a facially neutral policy or practice that disproportionately
affects members of a group identified by race, color, or national origin, where the
recipient's policy or practice lacks a substantial legitimate justification and where there
exists one or more alternatives that would serve the same legitimate objectives but with
less disproportionate effect on the basis of race, color, or national origin.
B. “Disproportionate Burden" refers to a neutral policy or practice that disproportionately
affects the low-income population more than non-low-income populations.
C. “Low-income Population" refers to any readily identifiable group of low-income persons
who live in geographic proximity, and, if circumstances warrant, geographically
dispersed/ transient persons (such as migrant workers or Native Americans) who will be
similarly affected by a proposed FTA program, policy or activity.
D. "Minority Person” include the following:
1. American Indian or Alaska Native, which refers to people having origins in any of the
original peoples of North and South America (including Central America), and who
maintain tribal affiliation or community attachment.
2. Asian, which refers to people having origins in any of the original peoples of the Far
East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia,

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China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and
Vietnam.
3. Black or African American, which refers to people having origins in any of the Black
racial groups of Africa.
4. Hispanic or Latino, which includes persons of Cuban, Mexican, Puerto Rican, South
or Central American, or other Spanish culture or origin, regardless of race.
5. Native Hawaiian or Other Pacific Islander, which refers to people having origins in
any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
E. ''Minority Population" means any readily identifiable group of minority persons who live
in geographic proximity.
F. "National Origin" means the particular nation in which a person was born, or where the
person's parents or ancestors were born.
G. “System Average” The system average is the averages of minorities and low-income
persons within the total populous of the geographic regions UTA serves. The present
system averages are expressed below in tabular format using 2011-2015 5-year
population estimates provided by the American Community Survey (ACS).
Low-Income System Average:
Population:
2,243,746
Low-Income Population: 457,949
Percent Low-income:
20.4%

Minority System Average:
Population:
Minority Population:
Percent Minority:

2,277,455
499,870
21.9%

Major Service Change
UTA will consider the following types of changes to be “major changes”, which require public
input and a Title VI equity analysis in compliance with FTA’s Circular 4702.1B
a) The Addition of Service;
b) A proposed service level reduction in miles, hours, or trips of thirty three percent (33%)
or more of any route;
c) The elimination of all service during a time period (peak, midday, evening, Saturday, or
Sunday);
d) A proposed twenty-five (25%) or greater change in route alignment;
e) A proposed fare change.

Evaluation and Analysis of Service and Fare Changes
1. UTA will analyze proposed major changes to service and any proposed fare changes in
accordance with FTA's Circular C 4702.1B as amended.

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2. UTA will evaluate the impacts of all major service changes cumulatively when there is
more than one route being affected for a service change period
3. UTA will primarily utilize American Community Survey (ACS) Data, block group data and/
or ridership data to evaluate and analyze any proposed major service and fare changes.
This data will be analyzed with Geographic Information System (GIS) software.
4. UTA will rely on population data and use the smallest geographic area that reasonably
has access to the stop or station effected by the proposed major service change. This
will be translated into a one-quarter mile radius to a bus stop, one-half mile to a light
rail station and three miles to a commuter rail station.

Disparate Impact and Disproportionate Burden
1. UTA will measure the burdens of service and fare changes on minority riders to
determine when minority riders are bearing a disparate impact from the change
between the existing service or fare and the proposed service or fare.
2. UTA will measure the burdens of service and fare changes on low-income riders to
determine when low-income riders are bearing a disproportionate burden of the change
between the existing service or fare and the proposed service or fare.
3. A threshold of 5% will be used to determine disparate impact on minority populations
and disproportionate burden on low-income populations. This 5% is based on the
margin of error from the US Census data that UTA uses to determine the populations in
the service area. This means that if the burden of the service or fare change on minority
or low-income populations is more than 5% worse than it is for the non-protected
populations, then the change will be considered either a disparate impact or a
disproportionate burden.

Finding a Disparate Impact
1. At the conclusion of UTA's Analysis, if UTA finds a disparate impact on the basis of race,
color, or national origin, UTA shall seek to modify the proposed changes in a way that
will mitigate the adverse effects that are disproportionately borne by minorities.
Modifications made to the proposed changes must be reanalyzed in order to determine
whether the modifications actually removed the potential disparate impacts.
2. If UTA chooses not to alter the proposed services changes despite the potential
disparate impact on minority populations, or if UTA finds, even after the revisions, that
minority riders will continue to bear a disproportionate share of the proposed service or
fare change, UTA may implement the change only if:

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a. UTA has substantial legitimate justification for the proposed change; and
b. UTA can show that there are no alternatives that would have a less disparate
impact on the minority riders but would still accomplish the transit provider's
legitimate program goals. In order to show this, UTA must consider and analyze
alternatives to determine whether those alternatives would have less of a
disparate impact on the basis of race, color, or national origin, and then
implement the least discriminatory alternative

Finding a Disproportionate Burden
If at the conclusion of the analysis, UTA finds that low-income populations will bear a
disproportionate burden of the proposed major service change, UTA will take steps to avoid,
minimize, or mitigate impacts where practicable. UTA will also describe alternatives available to
low-income passengers affected by the service changes.

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Proposed Changes
Routes 834
Route 834 runs every 30 minutes during
peak times and provides a connection
from Provo Central Station through
downtown Provo, near the BYU Campus,
residential areas, the Riverwoods
shopping area and finally the Riverwoods
Urgent Care and surrounding offices.
It is proposed to carry the route further
west along Orem Center Street and
provide a connection to State Street.
This will relocate the stop closest to the
Riverwoods Urgent Care center, but
provide expanded service to Western
Orem. Additionally, it is proposed to
reroute a small section of the route
along University Avenue which rejoins
the original routing via 2230 North. This
will add stops and provide a stop that
will connect the 834 to a future BRT station.

Route 864
The Thanksgiving Point and Silicone Slopes area of Lehi has been the fastest growing region in
Utah. It is positioned in northern Utah County around the I-15 freeway with a high density of
tech companies set up in the area with new offices being built. UTA has proposed to add a
route that will provide a circuit around the FrontRunner commuter rail station and the office
buildings to the west side of the freeway. Traffic in the area is already excessive, but will be
exacerbated by extensive road construction in the area. This route would make accessing local
destinations easier for those utilizing the commuter rail station in the area.

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Fare Media Elimination
It has been proposed that UTA discontinue accepting contactless bank cards (VISA, MasterCard,
Discover, AmEx, etc.) and Near Field Communication (NFC)-enabled mobile wallet applications
as fare payment via UTA’s Electronic Fare Collection (EFC) System. NFC-enabled mobile wallet
applications would include, but are not limited to, Apple Pay, Google Pay and Samsung Pay. As
an entity that accepts bank cards as payment, UTA is expected to comply with the Payment
Card Industry Data Security Standard (PCI-DSS). In an assessment of UTA’s compliance with PCIDSS standards, our card readers accepting this method of payment was identified as a potential
risk. UTA would need to invest a minimum of $1.5 million in new hardware and software to
mitigate the risk. It was determined that rather than incurring these costs, UTA proposed to
eliminate this payment option.
Mobile wallet applications and contactless bank cards were used an average of about 3,400
times per month in 2017, which equals roughly $11,200 in electronic fares sales. There is an
average of 709 distinct users of this payment method each month whom average five trips per
month which accounts for approximately 0.15% of our ridership each year. The use of this
method of payment has been generally stagnant since 2009 when the Authority launched its
EFC system.
Those who use an NFC-enabled mobile wallet application must have the app installed on their
device, set up an account and input credit card information in order to use this option. Once
they have set up their device, they must then approach one of our card readers and tap their
phone to the reader. In order to use a contactless bank card, the card must have the capability,
which is most typically indicated by a

symbol on the card. The card is tapped on the card

reader and the fare is charged directly to the card.
In determining the potential impacts on riders, other payment methods that are available as a
direct replacement and did not require excessive steps or requirements were accounted for.
UTA recently instituted a mobile app, UTA GoRide, which allows the purchase and use of fares.
Much like with the mobile wallet apps, this app does require an account and a credit card be
input before it can be used. UTA GoRide could replace the mobile wallet applications with a
relatively simple and comparable setup process. Although the rider may need to download a
different app, there is still a method to pay for fare through a smart phone. The impact should
be minimal on those riders accustomed to paying for fare via their mobile device. The UTA Go
Ride App method benefits the rider’s financial security by not having to pull out a credit card to

9
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tap on the reader and have that sensitive data transmitted each time it is used. It also
eliminates the opportunity for the loss of a credit card by not securing it again.
When paying with a credit card, all locations with Ticket Vending Machines (TVM) have the
option to pay for fare with a credit card at rail and Bus Rapid Transit (BRT) stations. It does
require additional steps where the rider would need to interface with the TVM in order to
purchase their ticket, but it is available at the place they board using the payment type they
already use. Although this may require planning for the time it takes to use a credit card to
purchase a ticket with the TVM, the option to pay with a credit card is still available. However,
TVMs are only located on rail and Bus Rapid Transit (BRT) stations, whereas the card readers
are presently on all buses. Those riders who use their contactless bank cards on buses would
lose their ability to pay with a credit card by tapping the card reader with it. There is no way for
UTA reader equipment to differentiate between those who would use the mobile wallet apps
and those that use the contactless bank cards so there is no way to gauge the number of people
who would not have the direct replacement of the UTA GoRide app, but would need to use a
different fare payment method. UTA has proposed to eliminate a fare media that cannot easily
be replaced by another payment method. The proposed elimination will be analyzed with
specific emphasis on the impact to riders of bus in order to ensure that the change is not
inadvertently discriminatory to minority and/or low-income populations.

Public Outreach
UTA held a public comment period from Jan. 4 to Feb. 13, 2018 to gather feedback on proposed
changes to routes 833, 834, 840 and 864. All of these routes are operated out of UTA’s
Timpanogos Business Unit in Utah County. In addition to the changes being analyzed here, UTA
had proposed to cancel Saturday service on the 833 and 834 which received negative feedback
during the comment period and public meetings. The proposed changes on the 833 and 834
triggered a disproportionate burden on low-income populations while the proposed changes to
the 833 triggered a disparate impact on minority populations. Due to the feedback received and
Title VI implications, the proposed changes were withdrawn.
The required public notice was posted on rideuta.com, the State of Utah’s Public Notice
website, on the buses operating on the fixed route buses as well as on the paratransit vehicles
that operate in Utah County. The notice was also printed in the Provo Daily Herald. Extra effort
was made to reach out to customers utilizing paratransit that took Saturday trips on the routes
where the service was proposed to be cancelled. This effort consisted of postcards being sent

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directly to the homes and caregivers of impacted paratransit riders. The postcards detailed the
proposed changes and offered a direct invitation to one of the two public hearings offered
during the comment period. Ultimately, the proposals that impacted paratransit riders were
cancelled. The first public hearing was held January 18 at the Provo City Library and the second
was held January 29 at the Provo Recreation Center.
A total of 28 people attended the public hearings, and six comments were officially received for
the public record throughout the comment period. One commenter (received via email)
provided feedback in regards to the changes proposed for routes 863 and 864. The commenter
suggested some adjustments to the proposal in order for transit to better accommodate his
growing business. The commenter also offered to provide bus turnaround and pull out
locations near his office building.
A total of five comments were received regarding the service proposal for route 833. Three
comments were received by email and two by telephone. All comments were in opposition to
the elimination of Saturday service on this route, mainly due to the negative impact this change
would have on area paratransit customers. Additionally, at the public hearing held on January
29 those who attended were generally opposed to the changes for route 833. The negative
comments were all regarding the changes that are no longer being proposed. Of the remaining
changes, there has been no negative feedback.
UTA included the temporary elimination of route 840 in the comment period. This route is on
the Utah Valley University campus and is proposed to be eliminated during the summer
semester and has historically returned for spring semester. It has been proposed to not bring
this route back, but will have a title VI analysis performed prior to a full elimination of the
route.

11
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Analysis of Proposed Changes
UTA is required to analyze the potential impacts of any major service change as it relates to
low-income populations and minority populations. Pursuant to this requirement, UTA has
created the following maps, tables and related data. The data in this section was compiled
utilizing American Community Survey (ACS) 2011-2015 5-year estimates, which was dispersed
into census blocks, in lieu of the larger block groups. This was done in order to use the smallest
geographic area possible for the analysis. The distribution was dictated by population ratios
from 2010 Census Data. Proposed service changes were analyzed based on the stops of the
route. Fare media analysis was performed based on the location the fare media was used to
board the transit vehicle. All stops and tap locations have had a one quarter mile radius applied
to them based on the actual accessibility of the stop or tap location by road. Any census block
that is overlapped by this walkability radius has its population included as those effected by the
proposed changes. These aggregated numbers are compiled as a comparison group to the
service area average to determine whether there would be a disparate impact on minority
populations and/or a disproportionate burden borne by low-income populations.
The maps in this section will show the route, individual stops with a walkability radius, and
census blocks with concentrations of low-income households or minority individuals above the
system average, which are shaded according to density.
FTA Circular 4702.1B states that an increase or decrease of fares by media type requires that
the “transit provider shall analyze any available information generated from ridership surveys
indicating whether minority and/or low-income riders are disproportionately more likely to use
the… payment media that would be subject the fare change.” Since the fare media that has
been proposed to be eliminated is such a small subset of riders, the most recent rider survey
did not ask questions specifically about the use of contactless bank cards and/or smart phone
payment apps. As such, the ridership data used in this analysis is of a broader group of payment
types. Considering the limitations of the ridership data, UTA has also compiled and presented
the locations where individual riders have initiated their trip and gathered the demographic
information of those locations with a one quarter mile walkability radius using the same
parameters stated above.

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Route 834
Low-Income Analysis - Addition

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 834 – Increased Access
Total Population:
1,704
Low-income Population:
591
Percent low-income: 34.7% (14.3%)

The table and figure above show the stops and distribution of low-income populations that are
gaining access as a result of the proposed changes. The low-income populations benefitting
from this addition is 14.3% above the system average.

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Minority Analysis - Addition

Minority System Average
Total Population:
2,277,455
Minority Population:
499,870
Percent Minority:
21.9%

Route 834 – Increased access
Total Population:
1,729
Minority Population:
472
Percent Minority:
27.3% (5.4%)

The table and figure above show the stops and distribution of minority populations that are
gaining access as a result of the proposed changes. The minority populations benefiting from
this addition is 5.4% above the system average.

14
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Analysis of Lost Access

Minority Population Losing Access
Total Population:
1,112
Minority Population:
147
Percent Minority: 13.2% (-8.7%)

Low-income Population Losing Access
Total Population:
1,059
Minority Population:
296
Percent Minority:
27.9% (7.6%)

As stops have been eliminated, the map above show those who have both gained and lost
access, with the table specifically focusing on those losing access to previous stops. The
minority populations impacted by this addition is 8.7% below the system average and lowincome is 7.6% above the system average.

15
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Route 864
Low-Income Analysis

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 864
Total Population:
Low-income Population:
Percent low-income:

583
72
12.4% (-9.5%)

As expressed in the table and figure above, the low-income populations impacted by this
addition is 9.5% below the system average.

16
Attachment J: Page 94

Minority Analysis

Minority System Average
Total Population:
2,277,455
Minority Population:
499,870
Percent Minority:
21.9%

Route 864
Total Population:
Minority Population:
Percent Minority:

583
91
15.7% (-4.7%)

As expressed in the table and figure above, the minority populations impacted by this addition
is 4.7% below the system average.

17
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Removal of Fare Media
Low-Income Analysis

18
Attachment J: Page 96

Low-Income Analysis Continued

19
Attachment J: Page 97

Low-Income Analysis Continued

20
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Minority Analysis

21
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Minority Analysis Continued

22
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Minority Analysis Continued

23
Attachment J: Page 101

Findings of Analysis
Routes 834 – Addition to Route
There were no findings of a disparate impact in this analysis, rather that minority populations
would benefit by the rerouting and addition of service. The data did indicate that those
potentially losing access to a stop were 7.6% greater than the system average, but the number
of low-income populations that benefit from the addition is almost double the number of those
losing access to a quarter mile walk radius. While the low-income populations may be required
to travel further to a stop, the access to the route has not been altogether eliminated. With
these considerations, UTA has determined that there were no disparate impacts on low-income
populations from these changes.

Routes 864 – Addition of Route
There were no disparate impacts or disproportionate burden found in the analysis of this
service change. While route 864 did have 9.5% less low-income in the impacted populations
than the system average, UTA has determined that the addition does not meet UTA’s policy on
disparate impact. The policy states that the changes must have a “5% worse” effect on
protected populations. This addition does not negatively impact minority populations since
there was no adverse effect such as a decrease in service to fund this new route.

Removal of Fare Media
In examining the demographics of the surrounding population around all of the stop locations
where this method of payment was used, there may be a disparate impact but there was no
indication of a disproportionate burden. As shown below, the low-income population is above
the system average by 4.3%, whereas the minority population is 5.3% above the system
average.
Minority Populations
Total Population:
1,130,915
Minority Population:
307,981
Percent Minority:
27.2% (5.3%)

Low-Income Population
Total Population:
1,109,296
Low-Income Population:
291,009
Percent Low-Income:
26.2% (4.3%)

While the demographic information indicates a disparate impact, there are several factors that
UTA must account for before concluding there is a disparate impact, especially when examining
stop-based demographic data. As mentioned previously, the actual number of people who use
this method of payment is an average of 709 people a month with no way of differentiating

24
Attachment J: Page 102

how many of these 709 people use a mobile phone app versus a contactless bank card on a bus,
which is the only type of payment method that does not have a direct replacement with a TVM
or UTA’s GoRide phone app.
The only data specific to this payment method available are the locations the card is being
used. However, the usage location does not exclusively indicate the rider’s origin where
demographics could potentially show ridership. The locations are mapped any time this
payment method was used in the system, which includes any place of transfer and/or the start
of a return trip. While this is the only data available, it does not show the actual rider’s
demographics and casts too broad a net throughout the system to be reliable for such a small
number of riders.
In UTA’s most recent ridership survey, where this fare payment method was classified as “Other
electronic fare payment”, the demographics of those respondents using other electronic fare
payment was 22.9% minority. There are, however, many other types of payment that could fall
into this category and may not be a direct reflection of the proportionately small subset of
those using mobile wallet applications and contactless bank cards. However, as a comparison
group of the demographics of those that use electronic fare media, the results of the survey are
included below. Note that ridership data is not compared to the system average as defined by
the populous of the service area, but that it is compared to the demographics of our ridership
data as collected from the survey.
Other EFC Ridership - Minority Populations
Total Population:
3,274
Minority Population:
671
Percent Minority:
20.5% (-4.4%)

Other EFC Ridership – Low-income Population
Total Population:
2,617
Low-Income Population:
843
Percent Low-Income: 32.2% (-12.3%)

If this data were to reflect the demographics of those using the payment method proposed to
be eliminated, this would indicate that electronic fare media is used less by minority and lowincome populations than the ridership average.
In spite of the tap location demographics, the small number of people using this fare payment
method (0.15% of ridership) and the general demographics of riders who use other electronic
fare media, UTA has determined that there is no disparate impact or disproportionate burden
borne by minority or low-income populations.

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Appendix A - April 2018 Change Day Public Comment Report
Utah County
Routes 833, 834, 840 and 864
Comment Period: 1/4/18-2/13/18
Prepared by Erika Shubin, UTA Public Hearing Officer
For April 2018 Change Day, the UTA Timpanogos (Utah County) Business Unit proposed changes
for routes 833, 834, 840 and 864. The proposal for routes 833 and 834 included the elimination
of two weekday trips due to schedule changes related to the implementation of Positive Train
Control on FrontRunner and a discontinuation of all Saturday trips due to low ridership. The
route 840 (a seasonal route) proposal called for the route to be discontinued and replaced by
adding additional route 841 trips, and the route 864 is a proposed new route to serve the west
side of I-15 near the Lehi Station.
Public Comments and Outreach
In accordance with UTA policy, a public comment period was held from Jan. 4 through Feb. 13,
2018. Several activities were conducted during this period to inform riders and the public and
to obtain feedback:







The public hearing notice was published in the Provo Daily Herald, on the state’s public
notice website and on rideuta.com. Information on the comment period and hearing
was also published on UTA’s social media channels. In addition, the UTA’s Special
Services business unit sent postcards to each impacted paratransit customer or to the
customer’s caregiver.
Two formal public open houses were held. One open house took place Jan. 18 at the
Provo City Library (550 North University Avenue in Provo, Utah), and the second took
place Jan. 29 at the Provo Recreation Center (320 West 500 North in Provo, Utah). A
total of 28 people attended the two hearings.
Fliers were posted on select Utah County buses and on Utah County paratransit
vehicles.
Comments were accepted via UTA’s website, via email at [email protected],
through the mail and by phone.

26
Attachment J: Page 104

Overall, seven comments were received on all proposals. One commenter (received via email)
provided feedback in regards to the proposed new route, route 864. The commenter suggested
some adjustments to the proposal in order for transit to better accommodate his growing
business. The commenter also offered to provide bus turnaround and pull out locations near his
office building.
A total of six comments were received regarding the service proposals for routes 833 and 834 –
four via email, one at the public hearing and one via telephone. All comments were in
opposition to the elimination of Saturday service on these routes, mainly due to the negative
impact this change would have on area paratransit customers. Additionally, at the public
hearing held on Jan. 29, those who attended were generally opposed to the changes for route
833.
No comments were received regarding the proposed cancellation of route 840.
The proposed changes were as follows:
(From the public notice)








Route 833: Elimination of two weekday trips due to schedule changes. All Saturday trips
will be discontinued due to low ridership.
Route 834: Elimination of two weekday trips due to schedule changes. Route will be
extended to the intersection of Orem Center Street and State Street to allow for
transfers to route 850 near Orem City Offices. All Saturday trips will be discontinued due
to low ridership.
Route 840: Route to be discontinued and replaced by adding additional route 841 trips.
Proposed change will provide customers with more seat availability between the Orem
FrontRunner Station and Utah Valley University.
Route 864: This is a proposed new route to serve the west side of I-15 near Lehi Station.
Route will be interlined with route 863 and will only offer weekday peak hour service.
The proposed fixed bus route changes should be of interest to paratransit eligible riders.
UTA is required to provide paratransit at a comparable level of service as to what is
provided by the fixed route system. The public transportation guidelines of the
Americans with Disabilities Act (ADA) require UTA to provide paratransit services only
within a ¾ mile service corridor on either side of a fixed bus route and around a light rail
(TRAX) station. UTA Paratransit must provide services during the same days and hours of
operation as these fixed route services. Areas that would no longer have fixed bus
routes would no longer have direct curb-to-curb paratransit services.

27
Attachment J: Page 105

Outcome:
Based on the feedback received and other factors, the proposal for route 833 will not go
forward. For route 834, the proposed alignment changes will proceed, but Saturday service will
not be eliminated. Route 840 is seasonal service, and the route will be discontinued for the
season but will not be permanently eliminated at this time as proposed, and the addition of
route 864 will proceed as outlined. Service changes will begin April 8, 2018.

28
Attachment J: Page 106

Attachment J: Page 110

Attachment J: Page 111

Attachment J: Page 112

Attachment J: Page 113

Executive Summary
RE:

Title VI Analyses for April Change Day and Provo-Orem BRT

Introduction
Two service and fare equity analyses were conducted to review the proposed changes for April
change day and the proposed changes associated with the Provo-Orem Bus Rapid Transit. The
analysis was performed in accordance with Federal Transit Administration’s Circular 4702.1B,
which outlines the Title VI requirements and guidelines for recipients of Federal Transit funds.
Service and fare equity analyses are conducted to ensure that proposed changes to service and
fares do not inadvertently negatively impact minority or low-income populations. All major
changes, even if they appear to be neutral, are analyzed.
UTA has specific parameters set in policy to define the parameters used to determine the
demographics of those impacted by the proposed fare and service changes. Impacted
populations are compared to the population of the service area to measure whether minority
and/or low-income populations are negatively impacted at a greater rate. If negative impacts
exceed 5% of the comparison group, UTA takes all prescribed and prudent steps to ensure
services are equitable and compliant with federal guidelines and requirements. The Authority
has defined the parameters for what would trigger additional steps as a 5% negative impact
and analyzes the impacts on minority and low-income populations separately. A greater than
5% impact would trigger a finding of either a Disparate Impact, which would be if the finding is
regarding minority populations, or a Disproportionate Burden, which would be a finding
regarding low-income populations.
Proposed Changes – April Change Day
Major Changes
Route
834
864

Change
Extend route from Riverwoods to State St/Center St in Orem
New route serves Thanksgiving Point area

Fares Change

Eliminate contactless bank cards and NFC-enabled mobile wallet
applications (Apple Pay, Google Pay, etc.) as payment method on
card readers. Accounts for only .15% of fare revenue.

Attachment J: Page 114

Proposed Changes – Provo-Orem Bus Rapid Transit
Changes to Parallel or Connecting Service
Route
811
821
830
838
840
850
862

Change
Route will no longer service Mt. Timpanogos Transit Center
Route will serve State St, 300 South in Provo instead of East Bay area
Route replaced by BRT
Route replaced by BRT
Route acts as a UVU campus shuttle. Proposed to be eliminated. All
stops covered by route 841
Route will no longer service Mt. Timpanogos Transit Center
Route extended to Orem FrontRunner Station; route will no longer
service Mt. Timpanogos Transit Center

Additional Proposed Changes
Route
821
823
846
849
862

Change
Route serves Payson, Salem, Spanish Fork, to Provo via I-15
(Springville portion of route to 823)
Route serves Springville, South Provo (created from 821)
Route will serve Orem 800 East, Orem 800 North, Geneva Rd,
Vineyard (created from 862)
Route will serve UVU, Orem 1200 West, Orem 1600 North (created
from 862)
Split into routes 846, 849

Findings – April Change Day
The service and fare equity analysis of the proposed addition to route 834, the addition of route
864, and the removal of a fare media resulted in no findings.
Findings – Provo-Orem Bus Rapid Transit
The proposed changes for the Provo-Orem BRT system will not be implemented until August
change day. However, the FTA requires that these proposed changes be analyzed for Title VI
prior to the beginning of revenue operations. Therefore, the following routes have had a
service and fare equity analysis conducted in anticipation of the August change day schedule.
Some of these changes are dependent on available funding and may or may not be
implemented depending on the actions of the UTA Board of Trustees.
The service and fare equity analysis of the Provo-Orem BRT replacement of route 830 and 838
resulted in no findings. Of the other proposed changes, there were findings on the following
routes:

Attachment J: Page 115

Route 821 Realignment – Disparate impact and disproportionate burden. The realignment
removes service from an area with a large percentage of low income and minority populations.
However, the new route increases the population with access to the route 13 times. Those with
increased access are more than twice the system average in low-income and 10.5% over the
system average for minority populations. Additionally, the populations losing access to the 821
would gain access to the Provo-Orem BRT which connects them to the new alignment.
Route 840 Elimination –There is a finding of disproportionate burden. The low-income
population in the area is 16.2% greater than the system average. The 840 route is a shuttle
service that circulates around the campus of Utah Valley University. This route does, however,
have low ridership and the plan to reallocate the operations budget from the 840 into the 841,
which stops at all the same stops, is a substantial and legitimate business reason to proceed
with the proposed changes. The 841 has 12 times the amount of ridership and brings riders
from the Orem Central Station onto the UVU campus instead of only running on campus as the
840 does.
Creation of two routes from Route 821 – There is a finding of disproportionate burden. The
proposal is to eliminate 9 stops in a low-income population in an area that is 16.2% greater
than the system average. The underutilization of the stops being eliminated and the potential
gains by offering more expedited service and more service in Spanish Fork was determined to
be a substantial and legitimate business reason to proceed with the proposed changes.

Attachment J: Page 116

Title VI Service and
Fare Equity Analysis
Provo-Orem Bus Rapid Transit

Utah Transit Authority
Prepared by: Andrew Gray
Graphics and Data by: Joseph Taylor

0|Page
Attachment J: Page 117

Contents
Introduction .................................................................................................................................................. 3
Summary of Proposed Changes .................................................................................................................... 4
Provo-Orem Bus Rapid Transit: ............................................................................................................. 4
Changes to Parallel or Connecting Service............................................................................................ 4
Additional Proposed Changes ............................................................................................................... 4
Fare Considerations .............................................................................................................................. 4
UTA Policy and Definitions ............................................................................................................................ 5
Definitions ............................................................................................................................................. 5
Major Service Change ........................................................................................................................... 6
Evaluation and Analysis of Service and Fare Changes .......................................................................... 7
Disparate Impact and Disproportionate Burden .................................................................................. 7
Finding a Disparate Impact ................................................................................................................... 7
Finding a Disproportionate Burden ...................................................................................................... 8
Proposed Changes......................................................................................................................................... 9
Provo-Orem BRT Replacement ................................................................................................................. 9
Route 830 - Removal ............................................................................................................................. 9
Route 838 – Removal .......................................................................................................................... 10
Provo-Orem BRT - Addition................................................................................................................. 11
Fare Considerations ............................................................................................................................ 13
Mt. Timpanogos Transit Center – Stop Relocation ............................................................................. 13
Route 821 – Realignment........................................................................................................................ 14
Route 862 – Addition to Route ............................................................................................................... 15
Route 840 – Elimination .......................................................................................................................... 16
Additional Proposed Changes ................................................................................................................. 17
Route 821 – Split into two routes ....................................................................................................... 17
Route 862 – Split into two routes ....................................................................................................... 18
Analysis of Proposed Changes .................................................................................................................... 19
Route 830 ................................................................................................................................................ 20
Route 838 ................................................................................................................................................ 22
Proposed BRT .......................................................................................................................................... 24
Comparative Analysis of Route 830 & 838 to Provo-Orem BRT ............................................................. 26

1
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Route 830 & 838 Removal – Mitigating Stops ........................................................................................ 27
Fares Consideration ................................................................................................................................ 28
Route 821 – Realignment........................................................................................................................ 29
Route 840 ................................................................................................................................................ 32
Route 821 – Split into 821 & 823 ............................................................................................................ 34
Route 862 – Split into 845 & 849 ............................................................................................................ 37
Findings of Analysis ..................................................................................................................................... 40
Replacement of Route 830 ..................................................................................................................... 40
Replacement of Route 838 ..................................................................................................................... 40
862 Alignment Changes .......................................................................................................................... 41
Mt. Timpanogos Transit Center .............................................................................................................. 41
Fare Considerations ................................................................................................................................ 42
Route 821 – Realignment........................................................................................................................ 42
Route 862 – Addition to Route ............................................................................................................... 42
Route 840 – Elimination .......................................................................................................................... 42
Additional Proposed Changes ................................................................................................................. 43
Route 821 – Split into 821 & 823 ........................................................................................................ 43
Route 862 – Split into 846 & 849 ........................................................................................................ 43

2
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Introduction
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and
national origin in programs and activities receiving federal financial assistance. The Utah Transit
Authority has committed to the Federal Transit Administration’s (FTA) Title VI objectives set
forth in Circular 4702.1B ensuring that FTA‐assisted benefits and related services are made
available and are equitably distributed without regard to race, color, or national origin.
The following analysis is of proposed changes to be implemented in August of 2018. These
changes are being proposed to improve service delivery and connectivity throughout Utah
County locations, including two major universities. Though the proposed changes are facially
neutral, this analysis, in accordance with FTA requirements, will ensure that these changes will
not have disproportionately negative impacts on minority and low-income populations within
UTA’s service area. If these changes are found to be discriminatory, UTA will take all prescribed
and prudent steps to ensure services are equitable and compliant with federal guidelines and
requirements.
FTA Circular 4702.1B specifically requires “transit providers that have implemented or will
implement a New Start, Small Start, or other new fixed guideway capital project shall conduct a
service and fare equity analysis. The service and fare equity analysis will be conducted six
months prior to the beginning of revenue operations [emphasis added], whether or not the
proposed changes to existing service rise to the level of ‘major service change’ as defined by the
transit provider. All proposed changes to parallel or connecting service will be examined. If the
entity that builds the project is different from the transit provider that will operate the project,
the transit provider operating the project shall conduct the analysis. The service equity analysis
shall include a comparative analysis of service levels pre-and post- the New Starts/Small
Starts/new fixed guideway capital project. The analysis shall be depicted in tabular format and
shall determine whether the service changes proposed (including both reductions and
increases) due to the capital project will result in a disparate impact on minority populations.
The transit provider shall also conduct a fare equity analysis for any and all fares that will
change as a result of the capital project.”
Pursuant to this guidance and requirement, UTA has conducted this Service and Fare Equity
Analysis for the Provo-Orem BRT fixed guideway project and related changes. It is with the
express permission of the Federal Transit Administration that UTA brings the analysis before
the board five months prior to the beginning of revenue operations.

3
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Summary of Proposed Changes
Provo-Orem Bus Rapid Transit:
Utah Transit Authority will begin operation of the Provo-Orem Bus Rapid Transit (BRT) in August
of 2018. The proposed Provo-Orem BRT will serve Utah Valley University, Brigham Young
University, Downtown Provo, two malls, two commuter rail stations and several other key
locations throughout Provo and Orem. Peak headways are proposed at 6 minutes and will have
increased amenities both at stops and on the transit vehicle itself.

Changes to Parallel or Connecting Service
As the Provo-Orem BRT is completed, it will replace the existing routes 830 and 838’s. It will
also absorb their operational budget. The 830 presently runs nearly the exact routing as the
proposed BRT line from the Orem FrontRunner commuter rail station to the Provo station. The
830 has 15 minute headways. The 838 runs from the Provo station and connects the University
mall and the East Bay Technology Park and runs three times in the morning and three times in
the evening. The transition will decrease the number of stops on both of these routes.
Routes 830, 811, 850 and 862 currently service the Mount Timpanogos Transit Center, which is
a quarter mile away from a proposed BRT Station. The 830 stop at this location will not be
replaced by the Provo-Orem BRT. Routes 811, 850 and 862 will be moving stop locations to
more efficiently interface with the new BRT station. Route 862 had s proposed alignment
change to better interface with the Provo-Orem BRT and provide better service.

Additional Proposed Changes
The Utah Transit Authority has proposed two other changes that may be approved to come into
service at the same time that the Provo-Orem BRT will. These changes are pending budgetary
approval, but are included in this analysis in order ensure Title VI requirements are
incorporated in the decision making process. They will increase and target service to
communities in the Utah Valley in an effort to increase access and ridership.

Fare Considerations
There is a proposal from the Mountainland Association of Governments to provide a sponsored
fare for the Provo-Orem BRT which would be at no cost to the individual rider. Sponsorship
would pay what would have been collected through farebox recovery.

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UTA Policy and Definitions
UTA has developed corporate policy 1.1.28 Title VI Compliance Policy to define and evaluate
the impacts of proposed major services changes on minority and low-income populations in
conjunction with a public outreach process. In developing this policy, UTA solicited feedback
through newspapers within the service area, published on UTA’s website (rideuta.com), and
Utah’s government website in the public notices section (Utah.gov) which provides translation
options. In conjunction with the Salt Lake County Office of Diversity Affairs, which maintains an
email list of local entities and individuals with interest in diversity issues, UTA sent an email
notification soliciting feedback in the development of this policy. Additional targeted outreach
was done, which included mailing a letter and the policy or sending emails to community
organizations that work with minority or low-income populations.
The following references to policy are from subsections of corporate policy 1.1.28 and were
created to ensure that all equity analyses are performed using the same parameters and are in
line with FTA Circular 4702.1B.

Definitions
A. “Disparate Impact” refers to a facially neutral policy or practice that disproportionately
affects members of a group identified by race, color, or national origin, where the
recipient's policy or practice lacks a substantial legitimate justification and where there
exists one or more alternatives that would serve the same legitimate objectives but with
less disproportionate effect on the basis of race, color, or national origin.
B. “Bus Rapid Transit (BRT)” refers to a high-quality bus-based transit system that delivers
fast and efficient service that may include dedicated lanes, busways, traffic signal
priority, off-board fare collection, elevated platforms and enhanced stations. Since BRT
contains features similar to a light rail or subway system, it is often considered more
reliable, convenient and faster than regular bus services. With the right features, BRT is
able to avoid the delays that can slow regular bus services, like being stuck in traffic and
queuing to pay on board.
C. “Disproportionate Burden" refers to a neutral policy or practice that disproportionately
affects the low-income population more than non-low-income populations.
D. “Low-income Population" refers to any readily identifiable group of low-income persons
who live in geographic proximity, and, if circumstances warrant, geographically
dispersed/ transient persons (such as migrant workers or Native Americans) who will be
similarly affected by a proposed FTA program, policy or activity.

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Attachment J: Page 122

E. "Minority Person” include the following:
1. American Indian or Alaska Native, which refers to people having origins in any of the
original peoples of North and South America (including Central America), and who
maintain tribal affiliation or community attachment.
2. Asian, which refers to people having origins in any of the original peoples of the Far
East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia,
China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and
Vietnam.
3. Black or African American, which refers to people having origins in any of the Black
racial groups of Africa.
4. Hispanic or Latino, which includes persons of Cuban, Mexican, Puerto Rican, South
or Central American, or other Spanish culture or origin, regardless of race.
5. Native Hawaiian or Other Pacific Islander, which refers to people having origins in
any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
F. ''Minority Population" means any readily identifiable group of minority persons who live
in geographic proximity.
G. "National Origin" means the particular nation in which a person was born, or where the
person's parents or ancestors were born.
H. “System Average” The system average is the averages of minorities and low-income
persons within the total populous of the geographic regions UTA serves. The present
system averages are expressed below in tabular format using 2011-2015 5-year
population estimates provided by the American Community Survey (ACS).
Low-Income System Average:
Population:
2,243,746
Low-Income Population: 457,949
Percent Low-income:
20.4%

Minority System Average:
Population:
Minority Population:
Percent Minority:

2,277,455
499,870
21.9%

Major Service Change
UTA will consider the following types of changes to be “major changes”, which require public
input and a Title VI equity analysis in compliance with FTA’s Circular 4702.1B
a) The Addition of Service;
b) A proposed service level reduction in miles, hours, or trips of thirty three percent (33%)
or more of any route;
c) The elimination of all service during a time period (peak, midday, evening, Saturday, or
Sunday);

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Attachment J: Page 123

d) A proposed twenty-five (25%) or greater change in route alignment;
e) A proposed fare change.

Evaluation and Analysis of Service and Fare Changes
1. UTA will analyze proposed major changes to service and any proposed fare changes in
accordance with FTA's Circular C 4702.1B as amended.
2. UTA will evaluate the impacts of all major service changes cumulatively when there is
more than one route being affected for a service change period
3. UTA will primarily utilize American Community Survey (ACS) Data, block group data and/
or ridership data to evaluate and analyze any proposed major service and fare changes.
This data will be analyzed with Geographic Information System (GIS) software.
4. UTA will rely on population data and use the smallest geographic area that reasonably
has access to the stop or station effected by the proposed major service change. This
will be translated into a one-quarter mile radius to a bus stop, one-half mile to a light
rail station and three miles to a commuter rail station.

Disparate Impact and Disproportionate Burden
1. UTA will measure the burdens of service and fare changes on minority riders to
determine when minority riders are bearing a disparate impact from the change
between the existing service or fare and the proposed service or fare.
2. UTA will measure the burdens of service and fare changes on low-income riders to
determine when low-income riders are bearing a disproportionate burden of the change
between the existing service or fare and the proposed service or fare.
3. A threshold of 5% will be used to determine disparate impact on minority populations
and disproportionate burden on low-income populations. This 5% is based on the
margin of error from the US Census data that UTA uses to determine the populations in
the service area. This means that if the burden of the service or fare change on minority
or low-income populations is more than 5% worse than it is for the non-protected
populations, then the change will be considered either a disparate impact or a
disproportionate burden.

Finding a Disparate Impact
1. At the conclusion of UTA's Analysis, if UTA finds a disparate impact on the basis of race,
color, or national origin, UTA shall seek to modify the proposed changes in a way that
will mitigate the adverse effects that are disproportionately borne by minorities.

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Attachment J: Page 124

Modifications made to the proposed changes must be reanalyzed in order to determine
whether the modifications actually removed the potential disparate impacts.
2. If UTA chooses not to alter the proposed services changes despite the potential
disparate impact on minority populations, or if UTA finds, even after the revisions, that
minority riders will continue to bear a disproportionate share of the proposed service or
fare change, UTA may implement the change only if:
a. UTA has substantial legitimate justification for the proposed change; and
b. UTA can show that there are no alternatives that would have a less disparate
impact on the minority riders but would still accomplish the transit provider's
legitimate program goals. In order to show this, UTA must consider and analyze
alternatives to determine whether those alternatives would have less of a
disparate impact on the basis of race, color, or national origin, and then
implement the least discriminatory alternative

Finding a Disproportionate Burden
If at the conclusion of the analysis, UTA finds that low-income populations will bear a
disproportionate burden of the proposed major service change, UTA will take steps to avoid,
minimize, or mitigate impacts where practicable. UTA will also describe alternatives available to
low-income passengers affected by the service changes.

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Attachment J: Page 125

Proposed Changes
Provo-Orem BRT Replacement
Route 830 - Removal
Route 830 runs from the Orem Central Station, which is serviced by the commuter rail
FrontRunner, through Orem and Provo connecting Utah Valley University and Brigham Young
University and ends at the Provo Central Station. According to the 2015-2016 on board survey
conducted by UTA, this route is largely ridden by students going to and from class (54% of riders
surveyed). 73% of riders also reported that transit was their only method of travel other than
walking to get where they were going, making this route crucial for many people. In calendar
year 2016, this route averaged 2,380 boardings per day and is the second most utilized route in
the Timpanogos Bus Unit. This route will be eliminated and immediately replaced with the
Provo-Orem BRT.

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Route 838 – Removal
Route 838 runs six times per day, three in the morning and three in the afternoon. The
schedule is shown below. This route averages 42 boardings per day and is primarily focused on
connecting the FrontRunner station to shopping and employment destinations. The 838 will be
replaced by the Provo Orem BRT. The route of the Provo-Orem BRT will not follow the exact
path of the 838 it is replacing, but it will provide ample opportunity through similar stop
locations and an additional stop on the southern end of the East Bay Technology Park to get to
and from the same locations with increased service.

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Attachment J: Page 127

Provo-Orem BRT - Addition
The proposed Provo-Orem BRT will serve Utah Valley University, Brigham Young University,
Downtown Provo, two malls, two commuter rail stations and several other key locations.
Residential density in key sections of the project is the highest in Utah outside downtown Salt
Lake. However, the area was designed with insufficient highway capacity, and what capacity
exists is now overwhelmed. At peak hours, University Parkway and University Avenue both
have very long wait times, with traffic waiting 2-4 cycle lengths just to reach the front of the
line. In that environment sits Route 830, the most heavily used in the county in terms of
passengers per mile, but it is stuck in the same traffic.

There is market demand to intensify and redevelop the corridor. There is room to widen, and
giving another lane to vehicles is one option for creating capacity needed to serve emerging
redevelopment, but this is a temporary solution that may encourage more auto dependency.
The more sustainable solution is the congestion free transit that bus rapid transit would offer.
51% of the Provo-Orem BRT’s route will offer dedicated lanes that regular traffic will not be

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Attachment J: Page 128

able to access. In addition, UTA will include GPS in the buses that will interface with stop lights
that will prioritize any transit vehicles running behind schedule. In a travel forecasting report
conducted jointly by Metro Analytics and the Wasatch Front Regional Council, it was estimated
one-way boardings will be around 12,000 per day which will greatly benefit both the
community utilizing the Provo-Orem BRT and decrease traffic for those not riding this service.

In addition to a dedicated lane, UTA will be constructing stations much like a light rail which will
decrease wait time. An artist’s rendering is shown above of the Provo Library Station concept.
This illustration shows seating, shelter, garbage receptacles, card readers and TVMs. The
Authority has also ordered 25 articulating buses, 18 of which will be in service at any time.
These buses will provide ample seating and near level-boarding from stations. As shown in the
image below, they have five doors to accommodate center platform stations in the middle of
the road (as shown in the image above) and side platform stations with one station on each
side of the road.

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Attachment J: Page 129

Fare Considerations
Mountainland Association of Governments (MAG) has expressed interest in allocating funding
to sponsor the fare of the Provo-Orem BRT. This fare sponsorship would require no fare to be
paid by the individual rider, but would be paid on their behalf by MAG. If this proposal is not
approved, UTA may offer no cost to riders as a promotional fare with no plans to have this
exceed the six month promotional fare period. If, for any reason, the promotional fare period is
going to be exceeded, UTA will conduct a fare equity analysis before it becomes the permanent
fare in accordance with UTA policy and FTA requirements.

Mt. Timpanogos Transit Center – Stop Relocation
The Mount Timpanogos Transit Center is located at 1145 South 750 East, just east of the
University Place Mall. The routing requires the present service on the 830 to divert from
University Parkway, turn at the light, stop at the transit center, then proceed south ultimately
taking another turn to get back onto University Parkway. A map is shown below. Eliminating
this detour will make the Provo-Orem BRT more efficient. A station will be placed on University
Parkway less than a quarter mile away from the Mt. Timpanogos Transit Center.

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Attachment J: Page 130

In response to this, there will also be a need to modify other routes servicing the Transit Center
in order to increase connectivity to the Provo-Orem BRT. Routes 811, 850 and 862 will have
their trips to the Mount Timpanogos Transit Center adjusted to meet the nearest Provo-Orem
BRT station. The 811 will stop along University Parkway and not proceed north to the transit
center. The 850 will stop at the BRT station and not turn into the transit center. The 862 will
proceed south on 800 East, West on University Parkway and go around the block utilizing State
Street and 800 South. UTA considers these changes included in the stop to station comparative
analysis of the 830 removal as these other routes have the same populations impacted as those
of the 830. Additionally, stops along the 862 are listed as mitigation in this area as it connects
northern riders to the new BRT Station. See below for a map illustrating the new routing.

Route 821 – Realignment
It is proposed to realign route 821 in the northern section of its route, specific to how it
approaches the Provo Central Station where Frontrunner and the Provo-Orem BRT have
stations. The route will remain on State Street until it can approach the Provo Central Station
from the north where riders can connect with the Provo-Orem BRT and reach destinations
previously directly reached by the 821 such as the East Bay Technology Park.

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Attachment J: Page 131

Route 862 – Addition to Route
On the northern end of the proposed Provo-Orem BRT route, there are some proposed changes
to the route 862 which would add service to the Orem FrontRunner station. These stops are
included as a mitigating factor as they provide some connectivity that may have been lost to
those in the area who were accustomed to accessing the 830 on one of the stops on Geneva
Road. Additionally, there is some rerouting, as shown in the image below, on the east side of
the route that will eliminate the Mount Timpanogos Transit Center from the route then connect
the 862 to the BRT station on University Parkway then go around the block.

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Attachment J: Page 132

Route 840 – Elimination
Route 840 follows nearly the same routing as the 841 but only runs around the UVU campus. It
is proposed to eliminate service to this route due to low utilization and reallocate the resources
to and increase capacity on the 841 by providing up to three buses at stops during high demand
periods.

The ridership of the 840 averages 88 boardings per day during spring semester at UVU and 117
times during the fall. In comparison, the 841 has 1,142 average boardings per day in the spring
and 1,403 in the fall. The difference shows that there is higher ridership demand from the Orem
Central Station going to the UVU campus than going around the campus itself. There will be a
reduction in the number times a bus will stop at each stop as combined 841 and 840 headways
will be reduced, but the highest demand is for capacity when a FrontRunner train stops and
riders are seeking to get to campus. The 841 headways would be 30 minutes.

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Attachment J: Page 133

Additional Proposed Changes
In addition to the changes listed above, the Timpanogos business unit has proposed additional
improvements to service. These proposed service changes are in conjunction with the ProvoOrem BRT and therefore are added to this analysis per the FTA Circular 4702.1B’s requirement
that “all proposed changes to parallel or connecting service will be examined.” These changes
are pending budgetary approval and may not be put into service, but will be analyzed here in
order to ensure both compliance with FTA requirements and that they are not inadvertently
discriminatory to minority and/or low-income populations.

Route 821 – Split into two routes
As shown in the image to the right, it
is proposed to take the existing 821,
shown as a dotted line. and turn it
into two routes. At present, this route
takes people North and South
between Provo Central Station the
cities of Spanish Fork, Salem and
Payson. In an effort to expedite the
time spent in transit, it is proposed to
divert what would be the new 821
after passing through Spanish Fork on
to the freeway directly and up to the
Provo Central Station. The proposed
new route 823 would serve more of
Springville and take the new northern
routing previously explained for the
821. The stops being eliminated
between Springville and Spanish Fork
are, by in large, unused. The most
used stop averages eleven boardings
per day, but is 1,085 feet from a stop that will be kept. Of the remaining eight stops, four of
them average zero boardings per day, two average three boardings and the remaining two
stops average 1 and 2 boardings per day respectively. The proposal would increase headways to
30 minutes during peak times on the weekdays and 60 minute peak headways on Saturday.

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Attachment J: Page 134

Route 862 – Split into two routes
It is proposed to take the existing 862 route with the proposed alignment changes previously
explained and create two new routes. The proposed route 846 will follow the eastern edge of
the existing 862 and will take a western course that will provide additional service to Orem and
Vineyard as it continues past the freeway and provides new service on the west of the Freeway.
The proposed route 849 will continue on the alignment of the 862 and carries it all the way
down through Orem, UVU and ends at the Provo Central Station. Both the 846 and 849 will
have 30 minute peak headways on the weekdays and 60 minute peak headways on Saturday.

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Attachment J: Page 135

Analysis of Proposed Changes
UTA is required to analyze the potential impacts of any major service change as it relates to
Low-income populations and minority populations. Pursuant to this requirement, UTA has
created the following maps, tables and related data. The data in this section was compiled
utilizing American Community Survey (ACS) 2011-2015 5-year estimates, which was dispersed
into census blocks, in lieu of the larger block groups. This was done in order to use the smallest
geographic area possible for the analysis. The distribution was dictated by population ratios
from 2010 Census Data. Analysis was done based on the stops of the route. All stops have had a
one quarter mile radius applied to them based on the actual accessibility of the route by road.
Any census block that is overlapped by this “walkability radius” has its population included as
those effected by the proposed changes. These aggregated numbers are compiled as a
comparison group to the service area’s average to determine disparate impact and
disproportionate burden.
When analyzing a bus stop, UTA uses a one quarter mile walk radius from the stop. However,
since the transit behaviors of a BRT more closely resemble a light rail platform than a traditional
bus stop, UTA conducted further research and consultation with the Federal Transit
Administration (FTA) to determine if the half mile metric was applicable to bus rapid transit. We
considered many factors in regards to the decision of what is a reasonable distance someone
would walk to ride the Provo-Orem BRT. The place of boarding is in a dedicated station where
the amenities are comparable to a light rail station. The proposed headways, at 6 minutes, are
less than half of that of the rail system in Salt Lake City. The transit vehicles are large,
articulating and have five doors that resemble level boarding. In light of these differences, UTA
has determined that a half mile walk radius is the appropriate measure for this mode of
transportation, which is the standard practice in many studies and corroborated by the FTA.
Please note that any disparity in population size between Low Income and Minority Populations
is due to the way in which American Community Survey counts low income populations.
“Group quarters”, a type of housing, is eliminated from low income ACS data, resulting in the
reduced population for that demographic. Group quarters includes residential treatment
centers, group homes, military barracks, correctional facilities and college residence halls.
The maps in this section will show the route, individual stops with a walkability radius, and
census blocks with concentrations of low-income individuals or minority individuals above the
system average, which are shaded according to density.

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Attachment J: Page 136

Route 830
Low-Income Analysis

The total impacted population compared to the system average are shown below in tabular
format below.
Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 821 – Increased Access
Total Population:
29,571
Low-income Population:
7,171
Percent low-income:
24.3% (3.9%)

As expressed in the table above, the total low-income population impacted by this elimination
is 3.9% greater than the system average.

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Minority Analysis

The total impacted population compared to the system average are shown below in tabular
format below.
Minority System Average
Total Population:
2,277,445
Low-income Population:
499,870
Percent low-income:
21.9%

Route 821 & 823 – Increased Access
Total Population:
36,159
Low-income Population:
6,858
Percent low-income:
19% (-2.9%)

As expressed in the table above, the low-income population impacted by this elimination is
2.9% below the system average.

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Attachment J: Page 138

Route 838
Low-Income Analysis

The total impacted population compared to the system average are shown below in tabular
format below.
Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 821 – Increased Access
Total Population:
1,546
Low-income Population:
785
Percent low-income: 50.8% (30.4%)

As expressed in the table above, the total low-income population impacted by this elimination
is 30.4% greater than the system average.

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Attachment J: Page 139

Minority Analysis

The total impacted population compared to the system average are shown below in tabular
format below.
Minority System Average
Total Population:
2,277,445
Low-income Population:
499,870
Percent low-income:
21.9%

Route 821 & 823 – Increased Access
Total Population:
1,519
Low-income Population:
928
Percent low-income: 58.3% (36.4%)

As expressed in the table above, the low-income population impacted by this elimination is
36.4% above the system average.

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Attachment J: Page 140

Proposed BRT
Low-Income Analysis

The total impacted population compared to the system average are shown below in tabular
format below.
Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 821 – Increased Access
Total Population:
45,479
Low-income Population:
24,647
Percent low-income: 53.9% (33.5%)

As expressed in the table above, the total low-income population impacted by this addition
33.5% greater than the system average.

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Attachment J: Page 141

Minority Analysis

The total effected population compared to the system average are shown below in tabular
format below.
Minority System Average
Total Population:
2,277,445
Low-income Population:
499,870
Percent low-income:
21.9%

Route 821 & 823 – Increased Access
Total Population:
53,882
Low-income Population:
11,816
Percent low-income:
21.9%

As expressed in the table above, the minority population impacted by this addition is at the
system average.

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Attachment J: Page 142

Comparative Analysis of Route 830 & 838 to Provo-Orem BRT

Low-Income Population:
Population:
Low-Income Population:
Percent Low-income:

1,470
365
24.8% (+4.4%)

Minority Population:
Population:
Minority Population:
Percent Minority:

1,599
279
17.4% (-4.5%)

As expressed in the table above, the number of people excluded from the impacted populations
is numerically a small (less than 3% of the BRT’s service area). Low-income people negatively
impacted by this replacement are 4.5% more than the system average while the minority
population is 4.5% less than the system average. It also completely mitigates route 838.

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Attachment J: Page 143

Route 830 & 838 Removal – Mitigating Stops
Low-Income and Minority Analysis with mitigation from routes 831, 811 and an extended 862

The total effected population by the proposed elimination of Route 830 and not covered by the
Proposed BRT or mitigating stops are shown below in tabular format below.
Low-Income Population:
Minority Population:
Population:
406
Population:
441
Low-Income Population: 105
Minority Population:
77
Percent Low-income:
25.9% (+5.5%)
Percent Minority:
17.5% (-4.4%)
As expressed in the table above, the total low-income population negatively impacted by this
elimination and with the addition of mitigating stops and an increased BRT access is 5.5%
greater than the system average. The minority population is 4.4% less than the system
average. The total population not covered represents 28% of the non-mitigated areas and .8%
of the BRT’s service area.

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Attachment J: Page 144

Fares Consideration
The FTA Circular 4702.1B states that transit providers “shall analyze any available information
generated from ridership surveys” when choosing datasets for fare changes. In the 2015 and
2016, UTA conducted an On-Board Survey of over 16,000 people where demographics were
collected and compiled based on several factors, route being one of them. Route 830 had 210
respondents and will be the dataset used in examining the possibility of a sponsored fare. 27 of
the respondents selected, “prefer not to answer” on the income question. That difference is
shown in the tables below. The sponsored fare that may be contributed by Mountainland
Association of Government is designed to cover the portion of the operation budget that is
anticipated to be covered by fare collection revenue and would cover the rider’s fare. The
individual rider would not be expected to pay a fare.

Average from all Surveyed

Average from all surveyed on 830

Low-Income Pop. (Under 10k annual):
Population:
13,306
Low-Income Population: 1,601
Percent Low-income:
12%

Low-Income Pop. (Under 10k annual):
Population:
183
Low-Income Population:
38
Percent Low-income:
20.8% (+8.8%)

Low-Income Pop. (Under 20k annual):
Population:
13,306
Low-Income Population: 3,531
Percent Low-income:
26.5%

Low-Income Pop. (Under 20k annual):
Population:
183
Low-Income Population:
78
Percent Low-income:
42.6% (+16.1%)

Low-Income Pop. (Under 30k annual):
Population:
13,306
Low-Income Population: 5,915
Percent Low-income:
44.5%

Low-Income Pop. (Under 30k annual):
Population:
183
Low-Income Population:
114
Percent Low-income:
62.3% (+17.8%)

Minority Population:
Population:
Low-Income Population:
Percent Low-income:

Minority Population:
Population:
Minority Population:
Percent Minority:

16,408
4,081
24.9%

210
61
29% (+4.1%)

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Attachment J: Page 145

Route 821 – Realignment
Low-Income Analysis

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 821 – Increased Access
Total Population:
8,813
Low-income Population:
3,727
Percent low-income: 42.3% (21.9%)

As expressed in the table and figure above, the low-income populations impacted by this
addition is 21.9% above the system average.

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Attachment J: Page 146

Minority Analysis

Minority System Average
Total Population:
2,277,455
Minority Population:
499,870
Percent Minority:
21.9%

Route 821 – Increased access
Total Population:
8,888
Minority Population:
2,875
Percent Minority: 32.4% (10.5%)

As expressed in the table and figure above, the minority populations impacted by this addition
is 10.5% above the system average.

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Attachment J: Page 147

Analysis of Lost Access

Minority Population Losing Access
Total Population:
680
Minority Population:
437
Percent Minority: 64.3% (42.4%)

Low-income Population Losing Access
Total Population:
670
Minority Population:
356
Percent Minority: 53.9% (33.5%)

As stops have been eliminated, the map above show those who have both gained and lost
access, with the table specifically focusing on those losing access to previous stops. The
minority populations impacted by this addition is 7% above the system average and low-income
is 24% above the system average.

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Route 840
Low-Income Analysis

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 821 – Increased Access
Total Population:
3,629
Low-income Population:
1,327
Percent low-income: 36.6% (16.2%)

As expressed in the table and figure above, the low-income populations impacted by this
addition is 16.2% above the system average.

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Minority Analysis

Minority System Average
Total Population:
2,277,445
Low-income Population:
499,870
Percent low-income:
21.9%

Route 821 & 823 – Increased Access
Total Population:
3,683
Low-income Population:
916
Percent low-income:
24.9% (3%)

As expressed in the table and figure above, the minority populations impacted by this addition
is 3% above the system average.

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Route 821 – Split into 821 & 823
Low-Income Analysis

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 864 – Increased Access
Total Population:
9258
Low-income Population:
3,776
Percent low-income: 40.8% (20.4%)

The table and figure above show the stops and distribution of low-income populations that are
gaining access as a result of the proposed changes. The low-income populations benefitting
from this addition is 20.4% above the system average.

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Minority Analysis

Minority System Average
Total Population:
2,277,445
Low-income Population:
499,870
Percent low-income:
21.9%

Route 821 & 823 – Increased Access
Total Population:
9,321
Low-income Population:
2,813
Percent low-income:
30.2% (8.3%)

The table and figure above show the stops and distribution of minority populations that are
gaining access as a result of the proposed changes. The minority populations benefiting from
this addition is 9.8% above the system average.

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Analysis of Lost Access

Minority Population Losing Access
Total Population:
1,794
Minority Population:
519
Percent Minority:
28.9% (7%)

Low-income Population Losing Access
Total Population:
1,740
Minority Population:
772
Percent Minority:
44.4% (24%)

As stops have been eliminated, the map above show those who have both gained and lost
access, with the table specifically focusing on those losing access to previous stops. The
minority populations impacted by this addition is 7% above the system average and low-income
is 24% above the system average.

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Route 862 – Split into 845 & 849
Low-Income Analysis

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 864 – Increased Access
Total Population:
15,540
Low-income Population:
4,875
Percent low-income:
31.4% (10%)

The table and figure above show the stops and distribution of low-income populations that are
gaining access as a result of the proposed changes. The low-income populations benefitting
from this addition is 10% above the system average.

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Minority Analysis

Low-income System Average
Total Population:
2,243,746
Low-income Population:
457,949
Percent low-income:
20.4%

Route 821 & 823 – Increased Access
Total Population:
18,404
Low-income Population:
4,542
Percent low-income:
24.7% (4.3%)

The table and figure above show the stops and distribution of minority populations that are
gaining access as a result of the proposed changes. The minority populations benefiting from
this addition is 4.3 % above the system average.

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Analysis of Lost Access

As the changes were analyzed, the map above shows those who have both gained and lost
access. There is only one census block that does not have access to the route when it used to,
but there is nobody living in the census block. As such, nobody would lose access due to this
proposed change.

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Findings of Analysis
Replacement of Route 830
There were no findings of a disparate impact or disproportionate burden in the removal of the
830. The BRT covers all of the routing of the 830 with one exception at the Mount Timpanogos
Transit Center. Though the number of stop to stations is not the same, the increased amenities,
travel time and headways would drive people to travel farther to access the new service. When
the comparison of stops with a quarter mile radius are overlaid with the new stations having a
half mile radius, the populations excluded from this radius is minimal and within UTA’s
threshold for Disparate Impact and Disproportionate burden. When mitigating stops from the
826, 850 and 811 are added, the number of people that do not fall within a quarter mile to a
mitigating stop and/or a half mile to a BRT station decreases 82%. There is, however, a shift in
demographics that may indicate that the low-income populations exceed the threshold set by
the Authority in regards to disproportionate burden. However, considering the population size
and the demographics of those directly impacted by the replacement being within the
threshold, UTA has determined that this would not be considered a disproportionate burden.

Replacement of Route 838
There were no findings of a disparate impact or disproportionate burden in the removal of the
838. In examining the new stops with a half mile walk radius, we actually find that the numbers
this route could serve is 51% low-income and 61% are minority. Close to 400 additional people
fall within this new expanded walk radius and those who were added have a greater
concentration of low-income and minority populations. Below are tables showing the
demographics of those in the BRT as compared to the 838. There were no census blocks
excluded from the comparison and there is likely a net gain for protected populations as shown
in the tables below.
Provo-Orem BRT Stops covering the 838:
Low-Income Population:
Population:
Low-Income Population:
Percent Low-income:
Route 838:

1866
967
51% (+30.6)

Low-Income Population:
Population:
1,546
Low-Income Population: 785
Percent Low-income:
50.8% (+30.4%)

Minority Population:
Population:
Minority Population:
Percent Minority:

1914
1174
61% (+39.1%)

Minority Population:
Population:
Minority Population:
Percent Minority:

1,519
928
58.3% (+36.4%)

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862 Alignment Changes
There were no findings of a disparate impact or disproportionate burden in the proposed
alignment changes to the 862. The changes on the east side of the 862 will not provide any stop
changes, excluding the Timpanogos Transit Center stop shifting to one that will connect riders
to the Provo-Orem BRT. These changes have been determined to not detrimentally impact
riders. The riders on the west side will benefit from the proposed addition of routing
connecting Utah Valley University to the FrontRunner Station. The populations now receiving
access to this route are listed below and are not outside of the UTA threshold for disparate
impact or disproportionate burden in that they do not negatively impact low income and
minority populations in excess of 5%, whereas the addition positively impacts the population
below.
Low-Income Population:
Population:
Low-Income Population:
Percent Low-income:

2559
609
25.5% (+5.1%)

Minority Population:
Population:
Minority Population:
Percent Minority:

3577
609
17% (-4.9%)

Mt. Timpanogos Transit Center
In examining the changes being made to the Mt. Timpanogos Transit Center, it is clear that this
detour would not have been efficient when trying to run the kind of service that the BRT will
run. It requires light dependent left hand turns and a station is proposed to be built within one
quarter mile of the Transit Center. Excluding this stop is easily mitigated by nearby route 862
stops where the route 862 will provide a connection to the Provo-Orem BRT station. The other
changes being made to connect riders to the BRT instead of detouring to the Mt. Timpanogos
Transit Center are required to access the new service and be effective. When considering the
demographics of those being impacted, UTA does not identify any disproportionate burden or
disparate impact in this change. The new station and mitigating stops provide adequate service
to connect those used to boarding the 830 or other routes at this center.

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Fare Considerations
The low-income and minority riders on the 830 are greater than the system average established
by the most recent ridership survey. In consideration of this, UTA does not find a
disproportionate burden or disparate impact on protected populations if the fare were
sponsored as has been proposed. All riders, regardless of their status, would equally have
access to the sponsored fare and the geographic and ridership data both indicate that this
sponsored fare would be offered to minority populations equally or in excess of the system
average and far exceed the system average for low-income populations.

Route 821 – Realignment
According to ACS data, the proposed changes would result in direct access to this route being
eliminated to 680 people. The demographics of those individuals does result in a disparate
impact and a disproportionate burden as more than half of those impacted have been
identified as minority and/or low income. The proposed reroute would, however increase the
number of people with a quarter mile walk access to this route by 13 times. Those with
increased access are more than twice the system average in low-income (21.9%) and 10.5%
over the system average for the minority population. In addition to the increased access
brought by the 821 proposed realignment, those that live in the area where the route currently
runs have access to the Provo-Orem BRT which will have increased service and will bring a
direct connection to the proposed alignment of the 821. With the increased service on the BRT
in the area and the added populations with access to the 821, it would appear that there is an
actual net gain for minority and low-income populations than if service were not changed in the
area. As this analysis is being performed prior to a public comment period, the feedback of the
public will be accounted for as prior to this proposal being implemented.

Route 862 – Addition to Route
There were no findings of a disparate impact or disproportionate burden in the realignment of
the 862. This does not exclude any populations from the change, but adds service and stops
that mitigate some of the stops excluded in the 830 to Provo-Orem BRT replacement.

Route 840 – Elimination
There were no findings of a disparate impact in the proposed elimination of the 840. The data
does indicate a disproportionate burden. In reviewing the proposal UTA has determined that in

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removing this route from service in order to allocate resources to the much more heavily used
841, which services all the same stops, that the riders using this route will have an adequate
mitigation in place to which they can plan their transit needs and would benefit from the
increased capacity from the Provo Central Station to locations around campus.

Additional Proposed Changes
Route 821 – Split into 821 & 823
The northern realignment of the 821 was reviewed in the previous section and those concerns
were addressed in that section of the analysis. When reviewing the additional proposal to
realign the route to exclude stops between Spanish Fork and Springville, the data below shows
the number of people excluded by this proposal not already analyzed in the 821 realignment.
Minority Population Losing Access
Total Population:
1,114
Minority Population:
82
Percent Minority: 7.3% (-14.6%)

Low-income Population Losing Access
Total Population:
1,070
Minority Population:
416
Percent Minority: 38.9% (18.5%)

As the table above indicates, there is a finding disproportionate burden, but no disparate
impact on those that would lose access from the proposed change. It is worth noting again that
the stops the proposal would eliminate, the most used stop averages 11 boardings per day and
is 1,085 feet from a stop that will still be serviced. Of the remaining eight stops that would be
eliminated, half of them average zero boardings per day and the other half do not exceed three
average boardings per day. UTA is yet to go to public comment regarding this proposal and has
not received budgetary approval to proceed, but will consider the feedback received regarding
the change prior to implementation. Steps will be taken to avoid, minimize or mitigate any
potential impacts that may be brought to light through the public comment period.
Based on ridership and the projected benefits UTA, has determined that there is a legitimate
business justification to proceed with changes if approved.

Route 862 – Split into 846 & 849
There were no findings of a disparate impact or disproportionate burden in the proposal to
create two routes out of the 862. There were no populated census blocks removed from a
quarter mile walk access to current service and the populations with added service by the
proposal are above both the low-income and minority system averages.

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