The Federal Transit Administration requires that recipients of FTA funds – like Nassau County – analyze whether major changes to their transit systems have a discriminatory impact. Despite relatively clear intentions to make changes to its transit system, the County has not done the required analysis, according to documents received earlier this month in response to a request under the state Freedom of Information Law.

TSTC previously noted that Veoila appears to be contemplating service cuts and fare hikes when it takes over operations for LI Bus. In fact, it is virtually impossible to see how changes will not be made. The County’s 2012 Budget cuts its contribution to LI Bus by nearly 73%. It is hard to see how this will suffice to maintain existing service and fares.

As frequent readers of MTR are well aware, funding for public transportation comes from various sources. One such source of funding is the Federal Transit Administration (FTA), of which the County is a recipient. The FTA requires that recipients explain how funding is being used and ensure certain requirements are met related to various issues, including civil rights.

FTA Circular 4702.1A details the Civil Rights requirements that must be met by a FTA funds recipient. One requirement in particular concerns fare and service changes; recipients must “evaluate significant system-wide service and fare changes and proposed improvements at the planning and programming stages to determine whether those changes have a discriminatory impact.” (Page V-5)

As of now, it is unclear what service and fare changes will be made after Veolia takes the reins from MTA. It does appear, however, that Veolia is in the planning stages of making changes. As such, the County is required to do an equity analysis for any fare change as well as significant service cuts (in an October 4, 2011 response to a TSTC FOIL request, the County confirmed an equity analysis had not been done). Recipients typically define what constitutes a major change in their systems — but changing operators is obviously a major change. An analysis should be done if fare changes are being planned and regardless of the level of cuts in order to show the impact, if any, of the County’s refusal to work with MTA to find a way to continue their arrangement. If there is a disparate impact on a certain portion of the population, Nassau County citizens and the FTA must be told.

Image: Screenshot of Veolia Transportation website for LI Bus.