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

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: