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MCTS briefs committee on Title VI update and service and fair equity (SAFE) analysis requirements
Summary
Milwaukee County Transit System presented a Title VI program update to the committee, describing federal Title VI obligations, the agency’s Service and Fair Equity (SAFE) analysis triggers and methodology, and examples of recent SAFE analyses for major service and fare changes.
Milwaukee County Transit System staff presented an informational update to the Committee on Transit and Transportation on Title VI of the Civil Rights Act of 1964 and the agency’s Service and Fair Equity (SAFE) analysis process.
Jesus So, planning manager for MCTS, explained that as a recipient of Federal Transit Administration (FTA) funds, MCTS must prepare a Title VI program update every three years that documents nondiscrimination policies, complaint procedures, limited English proficiency planning, public participation, minority representation on advisory bodies, and monitoring of grant subrecipients.
MCTS described the SAFE process, which the agency must run prior to any major service change (for example: changes affecting 25% of vehicle revenue hours or mileage, a 50% reduction in frequency, or creating a gap greater than a half mile). The SAFE uses established thresholds — including the four‑fifths rule ratio — to determine whether a proposed service or fare change would cause a disparate impact on protected populations (race, color, national origin) or a disproportionate burden on low‑income riders. If the analysis finds a disparate impact or disproportionate burden, the agency must attempt to avoid, minimize or mitigate the impact.
Staff reviewed recent examples: SAFE analyses were run when the flyer services were suspended in 2021, route changes in 2022, and for the Connect 1 BRT (Gold Line) in 2023. The next Title VI program update is due in 2026.
Supervisor Balinski thanked staff and noted the county’s continued commitment to Title VI compliance despite recent federal administrative guidance affecting disparate‑impact enforcement.
MCTS said its full Title VI plan is posted on the agency website and that the plan includes procedures for public notice, complaint submission, and outreach to riders with limited English proficiency. The presentation was informational only; the committee did not take action.
