Month: December 2015

MBTA ROC Finds Possible Title VI Violations in Late Night Service Cuts

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A few weeks ago it came to our attention that the MBTA is looking to cut late-night service entirely. When the ROC heard about this, we began looking through FTA documentation and discovered that the MBTA would possibly violate FTA Title VI regulations if they cut the service entirely. According to FTA Circular 4702.1B, late-night service was considered a permanent service addition as of March 2015, twelve months after being launched in March of 2014. The ROC believes that, due to these regulations, the MBTA cannot eliminate late-night service without conducting separate disparate impact analyses for each of the affected routes. Also, in eliminating late-night service on certain routes at the end of June 2015, the MBTA may have violated these same FTA regulations.

The MBTA ROC submitted these concerns to the MBTA, MassDOT, the FMCB, and the FTA. We have asked the MBTA to provide a response regarding these concerns by the end of this month. A copy of our letter is provided below:

MBTA ROC Submits Letter Regarding Late Night Service to the MBTA

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The MBTA Rider Oversight Committee (ROC) understands the MBTA’s need to cut costs and balance the budget. That is why we originally proposed (back in 2013) that the MBTA begin late-night service contingent on their ability to successfully launch a University Pass program to pay for it. The MBTA decided to separate the two programs, unfortunately, and now late-night service is going to be finding itself in search of financing every year. The MBTA also decided to launch the service without establishing any benchmarks for success or failure, making a decision to keep or cut the service overly subjective.

We cannot argue with the reality of the current situation, though. As a result, we are asking the MBTA to take the following steps before further cutting late-night service on any route:

  • Separate the routes when conducting late-night analyses
  • Analyze late-night data from the current fiscal year (the presentation available on the FMCB website exclusively shows data from FY15, which overlooks all cost-saving measures that went into place at the beginning of FY16)
  • Conduct an analysis of late-night service that uses comparable Night Owl service as a benchmark
  • Allow the ROC to view the FY16 late-night data
  • To offset costs of late-night service for each route on weekends, implement scheduling efficiencies on each respective route during system shut-down on weekdays (by decreasing idle time resulting from last trains/buses)
  • Increase fares on late-night routes
  • Look into eliminating late-night service on lines that require the highest MBTA subsidy per rider
  • Look into implementing larger headways on routes prior to the start of late-night service
  • Wherever it is allowed by maintenance, look into running one vehicle (most likely a bus) on select routes throughout the entire night, every night (lifeline service) in lieu of current late-night service
  • Before cutting current late-night service, ensure that a new option is in place (lifeline service, Bridj, etc.)

Our letter to the MBTA detailing these recommendations is provided below: