The headline on Phillip Matier’s and Andrew Ross’s story just sounded bad:  “BART spending $800K to define three words.”  It is easy to imagine the public saying “That’s more than 250,000 per word,” or “I’d have done it for half that.”  In fact, commenters on the online version of the San Francisco Chronicle story had lots of other three-word proposals like “Clean the Trains,” “Oh Hell No!,” and the ever-popular “Kiss my a%%.”

The sticker price is a shocker, but on reading BART’s report you realize advertising dozens of meetings in the San Francisco market, hiring interpreters for those meetings and translators for all the relevent documents in Chinese, Khmer, Korean, Lao, Russian, Spanish, Tagalog, and Vietnamese can add up quickly.  And those weren’t senseless extras.  The point of this exercise was to reach users who were not necessarily affluent, native-born, white English speakers.

But let’s not allow the 800 large to distract us from the larger impact of the story.  That money was a drop in the bucket compared with what BART lost and could lose.  Because the agency had not officially considered the impact of a “major service change”  on Title VI populations (low-income, minorities, limited English proficiency) FTA had already killed $70 million toward a people mover line from Colisuem Station to the Oakland Airport and another $100 million for an airport line was in jeopardy.

 The language in question is descibed in Title VI Circular 4702.1A, May 13, 2007, Requirement to Evaluate Service and Fare Changes (page V-5): 

In order to comply with 49 CFR Section 21.5(b)(2), 49 CFR Section 21.5(b)(7) and Appendix C to 49 CFR part 21, recipients to which this chapter applies shall evaluate significant system-wide service and fare changes and proposed improvements at the planning and programming stages to determine whether those changes have a discriminatory impact.  For service changes, this requirement applies to “major service changes” only.  The recipient should have established guidelines or thresholds for what it considers a “major” change to be.  Often, this is defined as a numerical standard, such as a change that affects 25 percent of service hours of a route.  [emphasis added] 

 For my money, when FTA uses words like often it is like a teacher saying “You might want to remember this.”  That means its going to be on the test and it is not unreasonable to think FTA was dropping a broad hint that 25% might be a good standard.   That lesson was not lost on the good people at BART who did their homework and adopted 25% after reviewing other large agencies, to wit: 

To establish a threshold or “upper limit” for a service change, BART must first define these terms so they can be communicated to and discussed with the public. The term “major” relates to how BART proposes to measure its service.  In advance of soliciting community input, BART staff researched best practices from major transit agencies throughout the United States to inform its approach. The FTA Circular 4702.1A states that a numerical standard such as a change that affects 25% of service hours of a route can serve as a dividing line between minor and major service changes. Transit agencies in New York, Houston, San Jose, Portland, Chicago, Sacramento, and Atlanta have adopted this industry standard of 25% per line.  [from  BART Summary Report June 25 2010 Establishing a Major Service Change Threshold] 

 The number 25 cannot stand alone.   Transit agencies adopting a standard reading something like “Metro defines a major service change as 25%,” would be in real trouble.  BART says the 25% applies to new lines, line length, service levels (the amount of service operated on a line), service hours,  aggregate changes across all the Lines on the BART System: annual net increases or decreases to Line Length, service levels, or service hours which exceed 20 percent in aggregate when combined over all the lines on the BART system, or the cumulative changes within a three-year period.  BART is a large, well-run, and credible transit property but the language about major service changes was missing from their Title VI documentation.  It cost them big–and I don’t mean the $800,000–so take a moment to review your docs so you won’t repeat their mistake.