Help RTD Ensure Equitable Policies and Standards
Review and Provide Feedback on Proposed Title VI Policy ChangesRTD is in the process of updating its Title VI Program — a collection of policies, plans, and other initiatives that prevents discrimination in our public transportation services and ensures equal access for all. We want you to help shape the program. By reviewing and commenting on proposed policy changes, you can help RTD enhance equitable transit service in your community.
What is the Title VI Program, and Why is RTD Updating It?
As a transit agency that receives federal funds, RTD must abide by federal civil rights law — including Title VI of the Civil Rights Act (Title VI). Title VI prohibits discrimination based on race, color and national origin (including limited English proficiency) in providing our services and programs to the community. In other words, RTD must ensure equal access and demonstrate compliance with Title VI to the Federal Transit Administration (FTA). The Title VI Program helps us achieve both goals, and it includes but is not limited to the agency’s Public Participation Plan, Language Access Plan, service policies and standards, and equity analyses.
The program is updated every three years or as otherwise directed by the FTA, and it is submitted to the FTA’s Civil Rights Oversight Division for review and approval. The last Title VI Program was in place from 2022 to 2025, and this updated program will guide the agency’s actions from 2025 to 2028.
An important element of the Title VI Program is to ensure that transit agencies consider how the location of new facilities as well as service and fare changes affect minority and low-income communities. To do so, agencies use tools like equity analyses and transit service performance monitoring. Because RTD is updating the policies that inform these tools, the FTA requires that the agency involve the public in shaping them.
Before finalizing the program, we want to empower the community to share feedback on the proposed policy changes to help shape a Title VI Program that achieves our community’s vision of transit equity.
Comment on Proposed Title VI Policy Changes
Please review the proposed changes below and provide any feedback you may have — whether it be questions, concerns, suggestions or support. You can provide feedback by:
- Filling out the individual online surveys below (recommended)
- Sending an email with the subject line “Proposed Title VI Policy Changes” to [email protected]
RTD is committed to making it easy for everyone to provide comment on these important changes. Language assistance, including translation and interpretation services, is available at no cost. Please contact 303-299-2051 or [email protected] if language assistance is needed. RTD can also provide services such as Braille, large print and accessible online documents for disability-related accommodations; please contact Gabe Christie at [email protected] or 303-299-2474.
An Explanation of Title VI Policies
Major Service Change Policy
The Major Service Change Policy refers to a policy that transit agencies must establish to define what proposed service changes are considered a "major service change.” According to FTA guidelines (outlined in FTA Circular 4702.1B), this policy is necessary for transit agencies to evaluate whether significant service changes disproportionately affect minority or low-income communities,* potentially creating a disparate impact or disproportionate burden.
*The district's definition of “low income” is determined using US Census data and federal poverty guidelines established by the U.S. Department of Health and Human Services. Anyone earning 150% or less of the federal poverty level qualifies as low income, which, in this area, means an annual income of $32,580 or less for a family of three. Minority status is defined by counting people who are non-white or Hispanic/Latino in the total population.
Disparate Impact and Disproportionate Burden Thresholds
“Disparate impact” and “disproportionate burden” policies refer to thresholds used by transit agencies to evaluate whether proposed service or fare changes disproportionately affect minority or low-income populations (respectively) — even if unintentional. A disparate impact occurs when a change disproportionately affects minority populations compared to non-minority populations or overall ridership. A disproportionate burden occurs when a change impacts low-income populations more than non-low-income populations or overall ridership.
RTD conducts equity analyses comparing the impact of changes on minority versus non-minority and low-income versus non-low-income customers. For example, eliminating a bus route heavily used by minority customers might be a disparate impact, while a fare increase affecting low-income customers more could be a disproportionate burden.
RTD has the discretion to set thresholds for what counts as a disparate impact or disproportionate burden. If these thresholds are met, RTD must explore alternative options to mitigate the impact or justify the change as essential to agency operations.
"Low Income" Definition
RTD is required to define a low-income threshold. This threshold is used in equity analyses for major service changes, fare changes, and other Title VI evaluations to determine whether there may be a disproportionate burden on low-income populations. As mentioned under “Major Service Change Policy” above, RTD currently considers anyone making 150% or less of the federal poverty level as low income.
Fare Equity Policy
A Fare Equity Policy ensures that fare changes — like increases, decreases or restructuring — don't create unfair impacts on minority or low-income customers. RTD must conduct an equity analysis to identify potential disproportionate effects and set thresholds to define what qualifies as a significant impact. If a proposed fare change is found to disproportionately affect minority or low-income groups, RTD is required to explore alternatives or provide mitigations, like discounts or gradual fare increases, to reduce the burden.
Key Activity Centers Assessment (formally known as Key Public Service Destinations Assessment)
The Key Activity Centers (KAC) Assessment is not a requirement of the FTA, but it is part of RTD’s equity analyses process to further clarify whether a major service change may disproportionately impact minority or low-income customers. The KAC Assessment was established through public feedback during the 2022 Title VI Program Update process. The assessment is conducted for every bus route or rail line facing a major service change (as defined by the Major Service Change Policy) and quantifies access to jobs, education, health care, social/ human service centers and grocers.
Proposed Changes to Policies
If needed, please reference “An Explanation of Title VI Policies” above for a general overview of these policies.Major Service Change Policy
A major service change is defined as a 25% addition or reduction in the service hours of any route that would remain in effect for twelve (12) or more months. All major service changes are subject to an equity analysis that includes an analysis of adverse effects. Adverse Effect is defined as a geographical or temporal reduction in service that includes, but is not limited to eliminating a route, shortening a route by eliminating segments, rerouting an existing route, and increasing headways.
Proposed
RTD proposes to redefine “adverse effect” as any impact on transit services resulting from changes to the system (including but not limited to reductions in service, alterations to routes or schedules, or other modifications) that may:
- Disproportionately burden minority and/or low-income populations compared to non-minority and/or non-low-income populations, or
- Disproportionately benefit non-minority and/or non-low-income populations as compared to minority and/or low-income populations.
To assist in analyzing the degree of adverse effects, RTD proposes to redefine a major service change to include:
- A 25% or greater change in service hours, route miles (including re-routes), daily service span or frequency of any route/line, within a single service proposal or cumulatively in any period within 36 consecutive months
- Implementation of a new route/line
- Elimination, discontinuation, or retirement of an existing route/line
All major service changes per this new definition would then be subject to a Title VI Service Equity Analysis that includes an analysis of adverse effects. Any service change that does not meet the above criteria for a major service change would be considered a minor service change.
Reasoning for Proposed Changes
The new major service change policy would ensure that more service changes require an equity review prior to Board approval by 1) expanding the criteria for what constitutes a major service change to include changes related to frequency, coverage/availability, and span and 2) removing the necessity for a change to last 12 months or more to qualify as a major service change. Additionally, the new policy would add the 36-month cumulative component to safeguard against minor changes adding up over time to become major changes. Finally, the new policy provides improved clarity on the definition of an adverse effect and what is not considered a major service change.
"Low Income" Definition
Current
RTD defines low-income populations as those whose household income is at or below 150% of the U.S. Department of Health and Human Services (HHS) Poverty Guidelines.
Proposed
RTD proposes to re-define low-income populations as those whose household income is at or below 200% of the HHS Poverty Guidelines.
Reasoning for Proposed Changes
The proposed new definition of low income would mean that more households would be considered low income when RTD is analyzing fare and major service changes.
Fare Equity Policy
Current
Any fare change should not result in minority and low-income riders experiencing impacts that differ by more than 5% compared to the general ridership. If changes involve the addition or removal of fare media, the equity analysis must consider access to fare media, vending machines, and other ways to add value (e.g., online or through retail). If a proposed fare change results in a disparate impact or disproportionate burden, RTD will consider modifying the proposal and check if the modification removes the potential disparate impact or disproportionate burden. If a less discriminatory option isn’t available and RTD can demonstrate a substantial legitimate justification for the proposed fare change, the FTA may allow RTD to proceed with the proposed change.
Proposed
RTD proposes to add a definition for “fare change” to its fare equity policy.
A “fare change” would include increases or decreases in the price of fare media, new or discontinued fare media (i.e., types of transit payment like cash, paper pass or electronic), and changes in fare types or products (e.g., Day Pass, Monthly Pass), fare levels (e.g., Standard, Airport), and customer categories (e.g., full-fare, seniors, individuals with disabilities, Medicare recipients, LiVE, and youth under 19). Modifications to Ticket Vending Machine access (e.g., quantity, fees, payment options) are also considered fare changes.
This definition excludes Access-a-Ride services, which are not subject to Title VI requirements.
Reasoning for Proposed Changes
To clarify what constitutes a fare change and when a fare equity analysis is required in accordance with the FTA Title VI Circular.
Policies Proposed to Stay the Same
Disparate Impact and Disproportionate Burden Thresholds
Current State
A major service change should not adversely affect a minority population 10% more than non-minority populations; this level of impact is considered a disparate impact.
A major service change should not adversely affect a low-income population 10% more than non-low-income populations; this level of impact is considered a disproportionate burden.
Reasoning for Keeping the Policy
No changes are proposed to these thresholds. RTD’s current thresholds were set using statistical significance measures while also accounting for margins of error in U.S. Census data. Compared to 22 other transit agencies, RTD’s thresholds are among the most sensitive, showing RTD’s strong commitment to fairness and equity for vulnerable groups.
Key Activity Centers Assessment
Current State
To complement the quantitative disparate impact and disproportionate burden analyses above, RTD may include an assessment of access to key activity centers (employment, education, food, social and human service centers, and health care) for minority and low-income populations.
Reasoning for Keeping the Policy
No changes are proposed, as the Key Activity Centers (KAC) Assessment is seen as a best practice that exceeds FTA requirements. Introduced during the 2022 Title VI Program update, the KAC Assessment was shaped by community input.
Timeline: What to Expect and When
Contact Information
For additional information on the Title VI Program update, please contact RTD’s Transit Equity Manager at 303-299-2370 or [email protected].