BeansTheCat
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- Aug 14, 2024
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Looking over this, the T does not seem convinced that boarding will become significantly faster if routes are made fare-free. Based on the data from the current pilot and the move to all door boarding systemwide, that seems reasonable at face value. The only cost savings come from less Fare Enforcement Personnel, as described below:
This notably does not provide any estimation of how many fewer cohorts would be needed (and what the total annual savings might be). While it's not much, it does seem to suggest that costs savings and operational improvements were not given the thorough analysis that cost increases were.A curtailment of future hiring of this manner could save the MBTA approximately $2.9 million per year for each 16-person cohort of Fare Engagement Representatives not hired in the future.
Also, the MBTA appears to think that they cannot legally halt the current Fare Free "Pilot" due to FTA rules stemming from the Civil Rights Act:
All public transit fare changes, whether fare increases or decreases, are subject to federal regulation under Title VI of the Civil Rights Act of 1964, as detailed in FTA Circular 4702.1B Title VI Requirements and Guidelines for Federal Transit Administration Recipients.6,7 At a high level, Circular 4702.1B specifies that all fare changes require public engagement, equity analysis, and board approval.
FTA Circular 4702.1B appears to still be in effect (at least for now). Even if it was repealed, the optics would not be pretty in needing it for a fare increase.The ending of a fare-free bus program, meaning the resumption of fare collection for riders, after more than 6 months of operations also requires public comment, equity approval, and board approval. Given that MBTA bus routes generally have a higher percentage of riders of color and riders with low-income than the system as a whole, the creation of a fare-free bus program is likely to “pass” an equity analysis.11 However, if and when fare- free service is to end on those routes, the required equity analysis will likely return a failing result absent significant mitigation. In short, the requirement for equity analysis of any fare change lasting longer than six months makes fare-free bus programs relatively easy to begin but hard for the MBTA to end.
Lastly, it is worth noting that costs associated with the RIDE could be the most expensive part of implementing fare-free busses. ADA rules mean that if the busses are free, the RIDE largely has to be as well. This is projected to cost between $27 and $63 million (Table 3). While it is understandable to not charge paratransit users exorbitant fares, I don't think this scenario was envisioned when the ADA language was written limiting fares to no more than double fixed route fares.
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