How Your City Can Pass Its Federal Transit Equity Test and Still Fail Riders

Imagine you’re a worker on the late shift, and you just finished your job for the day. Your car has been at the shop for two weeks; you still have to pay the repair bill, and the estimate the mechanic gave you was a staggering amount you just don’t have right now. There is a bus stop across from your apartment complex ,and the route even runs near your job. On paper, you have transit access — but your shift ended at 11 p.m., and the last bus left at 7 p.m.

So you stand in the parking lot and do the math. What an Uber costs at this hour. How much of tonight’s pay that will leave you to buy groceries and pay rent. Whether to text someone for a ride again, and how many times you’ve already asked this week.

There is a bus. It just won’t get you home.  

It takes very little to put someone in this position. Only 63 percent of U.S. adults said they could cover a $400 emergency expense entirely with cash or an equivalent. When your car goes, the bus is usually what’s left — even if it leaves you stranded. 

Legally, transit agencies that receive federal funding a Title VI equity analysis before implementing major service changes. This analysis compares how a proposed change will hit minority and low-income neighborhoods compared to everyone else. If the gap stays under a certain threshold, the change is allowed. If it doesn’t, the change can’t be made.

But Title VI requires agencies to measure whether the pain is shared evenly — not whether the bus runs at all. If everyone is equally stranded, the analysis comes back clean, the service cut goes into effect, and you and every other late-shift worker still be stranded in the parking lot at 11 p.m.

To better understand “transit desserts” — or neighborhoods where the demand for transit exceeds the service provided — and what that label hides, I and my fellow researchers at Syracuse University recently conducted a study where we mapped transit access in Baltimore, Philadelphia, Nashville and Dallas. 

Our comparison flagged neighborhood after neighborhood in Philadelphia, specifically, as starved for shared mobility options, and many were far worse off than the rest of the cities. That is exactly what an equity analysis like Title VI is built to catch — at least in theory. 

But then we ran a basic service screen. We asked five basic questions about each neighborhood: Is there a transit route you can walk to? Is enough of the neighborhood within a walk of a stop? Does a bus come every 30 minutes at rush hour? Does service run at least 12 hours a day? Can you reach a decent number of jobs in 45 minutes? Fail three of those five tests, and the neighborhood is not being “served,” whatever the equity analysis says.

According to the results of this test, Philadelphia’s “transit deserts” disappeared. None of its flagged neighborhoods failed the screen. In Dallas, about four in ten did; in Nashville, more than half. 

Title VI, by contrast, asks whether a given service cut falls harder on some riders than others. It doesn’t ask whether what’s left is enough to get anyone to work. A cut can clear a Title VI test and still take away the last bus someone needed. And when you make enough of those cuts, eventually no one has a bus they can rely on.

In a car-dependent city, the logic behind a Title VI analysis can do something even worse: it can make the places with the worst transit service look the fairest on paper. 

In car-dependent regions, anyone who can find a way to buy, borrow, finance or keep a car has usually done it. Standard measures count neighborhoods with a high concentration of households that drive every day as “not needing transit.” Once almost everyone has been pushed into a car, the gap between neighborhoods’ relative “transit need” shrinks. 

What the numbers leave out is why: the people who could leave transit behind already did. 

The same cut lands differently depending on money and flexibility, too. Some riders call an Uber when the bus doesn’t come. Others wait longer, miss work, or don’t make the trip at all. A traditional equity analysis might miss that while transit deserts often look similar on paper, some of their riders might be hit harder by service cuts: a senior who no longer drives, a teenager getting to class, anyone whose car is stuck at the dealer.

This isn’t a hypothetical. Just last month, TriMet in Portland eliminated or reworked 33 bus lines against an originally projected $300 million shortfall. Cleveland slashed its own service in August. 

Each cut is judged on its own. Nobody adds up how these cuts collectively impact low-income riders: a route gone here, a line cut short there, one defensible decision at a time.

Agencies will say late-night service costs too much for too few riders, and offer on-demand rides instead. Fine. But the van has to actually show up at 11 p.m. — and when it doesn’t, that has to impact how an agency grades itself. 

Fortunately, there is something any advocate can do right now. Every agency that receives federal funding files a Title VI Program, usually on its website. Look yours up. Does it promise when the buses will run, or just draw lines where the routes go? If it is only lines, tell your agency’s board to screen for basic service before the next service cut. 

A neighborhood should not count as “served” by transit just because a route exists on a map. The pipeline behind this analysis is open and runs on public data. Push them to run it for your city.

A city should not be able to pass its equity analysis while someone is still standing in that parking lot at 11 p.m.. A system that looks fair on paper only because it pushed everyone else into a car is not equitable.