Abstract
Non-elected advisory and planning bodies of transit agencies help planners determine the agency’s service, operations, and future developments. The Federal Transit Administration (FTA) requires reporting of the racial and ethnic makeup of those bodies to receive federal funding. This paper collects those data and compares them with the service area demographics of those agencies. This paper is an attempt to determine if those bodies are representative of the people they serve. This paper sets forth possible metrics to judge representation by and finds that most bodies in the United States are not representative, and instead over-represent the white population. This implication suggests that people of color in the United States are not being represented in the decision-making and planning processes of the transit agencies that serve them.
Keywords
On October 1, 2012, the Federal Transit Administration (FTA) updated its Title VI requirements and guidelines for recipients of federal funding in Title VI Circular 4702.1B, setting a variety of new and updated standards for transit agencies to follow if they wish to continue receiving federal assistance. One of the reinstated requirements was “that a recipient may not, on the grounds of race, color, or national origin, ‘deny a person the opportunity to participate as a member of a planning, advisory, or similar body which is an integral part of the program.’” This took the form of mandating that agencies publish a “table depicting the racial breakdown of the membership of those bodies, and a description of the efforts made to encourage participation of minorities on such decision-making bodies ( 1 ).”
This requirement was by no means a core requirement, as it had been removed previously, but neither was it reinstated without complaint. Agencies argued that they did not always have control over who was appointed to those bodies, making it unfair to judge them on a criterion they had no control over. The FTA clarified that this requirement was only for bodies the agencies oversaw the appointment process for. Additionally, the FTA had proposed a requirement for the bodies to be representative of the service population, but this requirement was removed in response to comments. Commenters also suggested that the guidance should cover other protected identities, such as gender and disability, but the FTA clarified that Title VI only prohibits “discrimination on the basis of race, color, or national origin only ( 1 ).”
Since 2012, 15 agencies have been investigated by the FTA after complaints about their Title VI compliance were submitted to the FTA, resulting in FTA compliance reviews ( 2 ). FTA compliance reviews are in-depth documentation of the various ways that race, national origin, and other protected statuses defined by the Civil Rights Act of 1964, influence the way that transit service is provided by that agency. This can involve reviews of route changes for disparate impacts on minorities and people of color, accessibility by people with limited English proficiency, and of course, racial and ethnic representation on planning and advisory bodies.
Planning and advisory bodies make up a small fraction of these reports, with most of these compliance reviews dominated by other subjects. However, they provide an interesting look into the governance of these transit agencies, allowing for quantitative analysis of an undeniably qualitative subject. Denying a demographic the ability to participate in the planning process is a form of epistemic injustice, denying their ability to advocate for their communities’ needs, implying that their knowledge and experience is not valid in the planning process. Although there are other avenues for members of the public to engage in the governance and operations of their transit service, these data provide a starting point for understanding how the voices of people of color and racial and ethnic minorities are sought, consulted, and implemented in the planning processes of transit in the United States.
The FTA does not define what a representative advisory body should look like, appearing to rely on a general instinct as opposed to a specific metric. There are advantages and downsides to this method. A body that appears representative on paper may actually be deeply unrepresentative of the service population. This is because the FTA only requires agencies to report data on race and ethnicity, not the infinite number of other identities that may alter a person’s experience with the transit system, from gender, income, preferred transportation, and location of residence, making a holistic qualitative analysis more beneficial. Conversely, having no metric of representation means that there is no easy way to compare two agencies, or judge all agencies on the same criteria. This makes it difficult to discuss large-scale trends among agencies, hampering the ability of communities, planners, and academics to discuss, critique, and develop solutions, or even identify if there is a problem. To this end, this paper seeks to understand the level of representation on these bodies as a whole using two quantitative methods of analysis, one nation-wide, and one body-specific, and a qualitative method.
It is worth making a distinction between governance and advisory bodies. Many transit agencies are governed by appointed bodies, which are in turn advised by Citizen Advisory Boards. The former have administrative powers, including authority to hire and fire executives, set policy and manage budgets. By contrast, the latter may be called to advise on any of those subjects, but they do not have the final say. There are also further bodies that may serve to provide advice about more specific subjects, like paratransit service and community input ( 3 ). However, there are methods for purely advisory bodies to have a policy impact, including independent information gathering by bodies members, developing their own policy suggestions, and gathering political support for those recommendations ( 4 ). This study focuses specifically on non-elected advisory bodies, as those are the only type of body that the FTA requires reporting on, meaning that it is the only type of body for which there is publicly available data to collect.
Literature Review
The role of non-elected bodies for transit agencies is not unique to the transportation sphere. Similar bodies exist in many levels, from schools, to taxation, to elections, to even county fairs ( 5 ). Methods of appointment can vary wildly, from Metropolitan Planning Organizations (MPOs) that appoint a representative for each county or city ( 6 ), to appointments by elected officials. Some bodies are mandated by federal law, while most were established by the local community. However, there have been issues with representation of marginalized groups, such as low-income communities ( 7 ).
The makeup of non-elected bodies can drastically change the priorities of those bodies. For example, previous research has shown that the membership of MPOs underrepresented central cities in the vast majority of cases. Specifically, MPO membership distributed voting power by city governments, not by population, leaving central cities with fewer votes per person than suburban communities. Rarely is voting power ever doled out with respect to the populations served by these bodies. For a specific example of how representation influences policy outcomes, that same research showed that adding an additional voting member of an MPO from a suburban city would decrease transit spending by between 1% to 9%, pushing that money toward highways instead ( 8 ). Similar issues stemming from misrepresentation could impact the policy outcomes at the transit agency level.
Participation in administrative agencies by citizens can produce benefits for the participants. In addition to fostering community and imparting democratic ideals, participation in institutional decision making leads institutions to be more attentive to the desires of the service recipients ( 9 ). From the agency perspective, truly authentic public participation can lead to more effective institutional performance and faster results. Authentic participation prioritizes collaborative interaction, with the public playing the role of an equal participant and designer, not a reactive participant whose participation is sought for buy-in ( 10 ).
As entities of public engagement, non-elected bodies can fall into any of the rungs of Arnstein’s ladder of citizen participation (Figure 1). At their worst, advisory bodies are a perfunctory step, falling on the lowest rung of Arnstein’s ladder, Manipulation, where bodies are practically told what to do. No better is the third rung of Arnstein’s ladder, Informing, where bodies simply exist to be “educated” about the issues, without the chance to share their own experience with the issues. In these cases, representation is immaterial, as they have no power, not even the ability to advise. Moving up the Ladder are the slightly better Consultation and Placation rungs, where the public is consulted, and plans and operations are adjusted just enough to make it appear like their experiences and preferences are being accounted for. Crucially for this discussion, Arnstein points out that handpicked “worthy” have-nots can be placed on these bodies to have the appearance of influence, but can easily be outvoted by the traditional majority. By their nature of being appointed bodies, it is incredibly difficult for these bodies to rise to the sixth rungs and above, since the appointment process relies on those in power making those appointments ( 11 ).
Arstein’s ladder of citizen participation ( 12 ).
More specific to the transportation sector, previous academics have argued that the discrepancy between the burdens and benefits placed on people of color and low income residents is caused by a lack of meaningful public involvement. Karner and Marcantonio propose a three-step model that agencies can implement to actively include residents in the planning process. The first step of this model is to identify deficiencies that require immediate attention in disadvantaged communities by providing resources to allow the community to fully engage with this process. The second is simple: dedicate funding to meet the needs identified. The third is as crucial as the first two, guiding agencies to set specific metrics to measure their progress toward those goals. If broadly implemented, this model could have wide-ranging benefits, and limited implementations have shown promise, like in the development of the One Bay Area plan ( 13 ). A similar approach could be applied to increase the effectiveness of advisory bodies.
Non-elected governance of public services exists internationally, such as Local Authority Implementation Agencies in the United Kingdom. Established in the 1970s by the Labor Party as part of a wider restructuring of government, Local Authority Implementation Agencies were expanded in the 1980s by the Thatcher-led Conservative Party, as these non-elected bodies were easier to politically influence owing to the ability to make appointments. In the case of similar user organizations in the UK, there have been recorded incidents of dominant groups explicitly working to keep out other groups ( 14 ).
A report by Simon & Simon Research and Associates, Inc from 2002 prepared a thorough review of the makeup, purpose, design, and effectiveness of public transit boards of directors. Notably, boards of directors largely do not fall into the scope of this study, but this paper can serve to provide additional context. The authors found that most boards’ members are appointed by elected officials, serve three- to four-year terms, meet monthly, receive no compensation, are responsible for setting policy and priorities, approving budgets, and selecting CEOs. CEOs and board chairs reported that their boards of directors were most effective at gaining political support, and were generally effective for governance ( 15 ).
Crucially for this study, the 2002 report from Simon & Simon Research and Associates also included data on ethnic makeups of boards of directors. Historically, the majority of board members are white men, with men making up 75% of board membership. The authors did not report the average minority to non-minority ratio among board members, but they did report that about half of all boards surveyed did not have any African American members, three quarters had no Hispanic board members, 95% had no Asian board members, and all but one had no Native American board members. Ninety percent also had no board members described as “Some Other Race.” All in all, about a third of transit CEOs reported their agency had an all-white board. The authors found that the boards of bus only systems were less diverse than those of multi-modal systems ( 15 ).
Public Comments on FTA Circular 4702.1b
A detailed examination of the rule-making process that produced the rule that underpins this research can reveal the way that agencies interpret the rule. To accomplish this, this study examines the public comments submitted to the FTA in response to a draft version of the policy. Comments could be submitted from September 28, 2011 to December 2, 2011, during which 140 comments were submitted. The comments were diverse, both in subject matter and origin, ranging across transit agencies, MPOs, advocacy groups, and private citizens ( 16 ). This study examines comments that discuss the specific rules about non-elected advisory bodies.
Seven of the comments were essentially the same form letter, which highlighted several concerns, including the advisory body requirement. The form letter’s comments on this subject included noting that many agencies do not appoint their own board of directors, meaning they had no control over the racial breakdown of that body, and should not be judged on that metric. Additionally, the form letter noted that the collecting and reporting of the racial breakdown data was an unfunded mandate with no obvious intention, which the letter described as “a solution looking for a problem ( 17 – 23 ).”
Curiously, the form letter does not have an obvious point of origin. Some of the commenters were relatively close geographically, specifically San Luis Obispo Regional Transit Authority ( 20 ), the City of San Luis Obispo ( 17 ), Monterey-Salinas Transit ( 21 ), and the City of Culver City ( 19 ), all coastal California cities, but the other three were more scattered. The St. Cloud Metropolitan Transit Commission from Minnesota ( 23 ), the Chelan–Douglas Public Transit Benefit Area from Washington ( 18 ), and Tompkins Consolidated Area Transit, Inc. from New York ( 22 ) all sent in almost identical letters. The link between these agencies is not obvious; it is possible that a national industry organization sent a version of this form letter to agencies, and these were the ones who chose to submit it in this form, but that is pure speculation.
The form letter’s concerns about the point of the reporting requirement was echoed in other comments, with the Wisconsin Department of Transportation writing in its comment “…what is the purpose of collecting such information? What does FTA intend to do with it? What is the correlation between the racial makeup of non-elected boards and the transit decisions made by them?” ( 24 ) These questions strongly suggest a disconnect between the FTA and agencies; with the decision to include this requirement coming without a clear explanation of how the FTA chose this metric and why they believe it important.
Another major concern that agencies reported was the lack of control they had over certain bodies, especially boards of directors. As the New York State Metropolitan Transportation Authority put it in their comments, “The provision appears to presuppose that a transit provider has the legal capacity to determine the composition of such boards, advisory councils or committees. Under the MTA’s governance structure, that is not the case. … We suggest that FTA clarify that the requirement is intended to apply to boards, councils and committees that are selected by a recipient, and not those decision-making or advisory bodies the composition of which are outside the control of the recipient ( 25 ).” This complaint and suggestion was a common refrain from other large agencies, such as Atlanta’s Metropolitan Atlanta Rapid Transit Authority (MARTA) ( 26 ), the Texas Department of Transportation ( 27 ), and San Francisco’s Municipal Transportation Agency (MTA) ( 28 ). The suggestion appears to have been incorporated into the new language by the FTA in their post-comment revisions.
Notably, two comments expressed concerns that the proposed policy would be discriminatory—against the majority population, which in the United States context should read as white people. One comment was submitted by the Center for Equal Opportunity, a conservative think-tank that describes its mission as promoting colorblind non-discrimination in the United States ( 29 ), and the other was submitted by OATS Transit, Inc., a private rural transit provider in Missouri. Specifically, their comments focused on the phrase “a description of the efforts made to encourage participation of minorities on such decision making bodies.” The Center for Equal Opportunity stated in their comment that they “fear that the current wording will actually encourage such discrimination by affording preferences to “minorities.” Such discrimination would be unfair, divisive, and in violation of Title VI ( 30 ).” OATS Transit echoed this position, saying “OATS finds this wording vague and fears it would actually encourage recipients to afford preferences to minorities, which would itself be discriminatory ( 31 ).” Both used very similar language to suggest that the FTA replace the offending phrase with language that would “encourage the nondiscriminatory and nonpreferential participation” of body members. ( 30 , 31 ) While it is possible the two groups produced very similar comments without coordination, the possibility of some level of coordination is present. The possibility of influence from strongly politically aligned think-tanks on transit providers may present a future avenue of research.
Within public comments, there was disagreement about which metric should be used for representation; the Santa Clara Valley Transportation Authority argued that the bodies should reflect an agency’s ridership, not their geographic service population ( 32 ), while the California Rural Legal Assistance argued that the bodies should reflect the service area, especially in the context of bodies that represent specific subregions ( 33 ). The concern about specific subregions was echoed by Metro Transit in Minneapolis, Minnesota, who asked for clarification on whether bodies that represented specific subregions should be representative of the service area as a whole or of the specific subregion ( 34 ). The FTA did not appear to make substantive comments or changes to the policy in response to any of these comments.
There was also confusion about the definition of “representative”, and which efforts were sufficient to encourage minority participation. For example, Chicago’s Regional Transportation Authority recommended that “additional guidance be given on the types of efforts that are considered sufficient to encourage the participation of minorities on decision-making bodies and how it may be determined whether the composition of a board is “representative” of the demographics of the community they serve ( 35 ).” There was additional confusion on what the consequences of non-compliance would be, from agencies like Portland’s Metro MPO ( 36 ), and the Wisconsin Department of Transportation ( 24 ). The FTA did not address these comments in their responses.
Methodology
Identifying Agencies of Interest
The first step in this analysis was to identify agencies of interest, relying on two criteria to generate the list of potential subjects. Agencies of interest included large transit agencies, specifically bus agencies with high ridership, as buses historically have higher proportions of minority and low-income passengers ( 37 ). This list of the largest bus agencies in the United States was based on the American Public Transportation Association’s 2019 fourth quarter “Public Transportation Ridership Reports”, and included any agency with annual bus ridership of over one million unlinked passenger trips ( 38 ). Agencies that were investigated for non-compliance with the FTA’s regulations were also of interest, as those agencies may exhibit committee member selection bias in addition to other forms of bias and discrimination. These agencies were identified using the FTA’s list of Title VI compliance reviews ( 2 ), since 2012, when the requirement to report advisory body makeup was implemented.
This list of agencies totaled 67 in number, from 29 States and other jurisdictions, of which California was the most represented, with a total of 15 agencies. Texas was the second most represented state, with five agencies, followed by a four-way tie for third between New York, Washington, Florida, and Ohio. Body makeups were found via internet searches for agencies’ most recent Title VI reports, both on the FTA’s website, and on the agencies’ websites themselves. Of the 67 agencies in this sample, only 46 agencies had Title VI reports that were available for the public, which eliminated 21 agencies from this sample. Another six agencies claimed to have no non-elected transit advisory bodies, leaving the total number of agencies in this sample at 40. From those 40 agencies, data were collected on a total of 103 bodies across the country.
These bodies served a wide range of purposes, but they fell into eight broad categories: Generic (39), ADA or Accessibility Focused (26), Region Focused (11), Business or Financial Focused (7), Modal Focused (7), Boards of Directors (5), Equity Focused (3), or Other (5). “Generic” bodies did not appear to have specific purposes, besides general policy suggestions. ADA or Accessibility Focused bodies were often focused on directing and advising accessibility and paratransit policy. Region and Modal Focused bodies are respectively set up to provide guidance on the service and operation in specific geographic areas and for specific modes. Boards of Directors and Business or Financial Focused bodies were concerned with the administrative and fiscal aspects of an agency’s operations. Equity Focused bodies were explicitly concerned with the equity and justice concerns of an agency’s operations. Bodies classified as Other did not fall into any of the above categories, defying any meaningful categorization.
Identifying Demographic Data
There are dozens, if not hundreds, of possible identities that could be examined, including gender, income, residential location across the urban–suburban–rural spectrum, ability, and mode use. However, the FTA only requires that agencies report the “racial breakdown of minority representation on planning and advisory bodies” ( 1 ), so this analysis is limited to race and ethnicity by the data publicly available. Hopefully, future research can expand into these other identities. The categories that are used to describe race and ethnicity are often limiting as the FTA does not set universal definitions for ethnic groups. For example, in the following analysis, some bodies combine Asian Americans with Pacific Islanders & Native Hawaiians, while others keep the two separate-if they do not ignore the existence of Pacific Islanders and Native Hawaiians. Where possible, the two have been kept as separate categories for the highest level of resolution. Obviously, relying on heterogeneous data is less than satisfactory, but the main point of analysis is the comparison between the body’s and the service area’s percentages. This does represent a known limitation of this analysis.
To compare the racial and ethnic makeup of these advisory bodies to the demographics of the population they served, this analysis relied on the Title VI reports for the demographic makeup of their service areas. There is currently no standardized format to report these data, which means that the format of the self-reported data varies from agency to agency. In this survey of agencies, agencies were found to report service area demographics based on the American Community Survey (15 agencies), the 2000 (two agencies) or 2010 Census (six agencies), or Ridership Surveys (six agencies). Several also did not report where the data came from (fout agencies) or did not report demographic data at all. In the latter case, when available, this analysis relied on data from the 2020 Census (five agencies), and assumed that the entire city or region was the service area. There were two agencies for which demographic data could not be gathered, bringing the final number of agencies in the sample to thirty-eight, with a total of ninety-nine bodies.
Comparison to Previous Studies
Given that the most recent research on this subject was conducted over two decades ago by SIMON & SIMON Research and Associates, it is worth comparing the results of this study to that historical study. The situation has changed dramatically. The 2002 report was published before the FTA’s 2012 update to the Title VI requirements and guidelines, so it can act as a useful baseline for comparison. However, the samples and data collection methods differ between the 2002 report and this study. This study focuses only on non-elected advisory bodies, while the 2002 report focuses on transit Boards of Directors, including elected boards. Additionally, this study relies on publicly reported data, while the 2002 report relies on surveys of agency general managers or CEOs, and board chairs. Even with these differences, it can be useful to compare the two, to get a sense of the change over time. The 2002 report did not discuss diversity on boards in depth but did provide the percentage of boards with at least one member of a given ethnic group. The equivalent statistic has been produced from this study ( 15 ).
Weighted Representation
There is a practical limit to representation in republican systems. A body has a practical limit to the number of people on it, meaning that some viewpoint likely will go unrepresented or underrepresented. However, this can be minimized, by selecting the body’s membership to represent the population it serves. Given these bodies are unelected, that may be difficult to implement, but it should not be impossible. To develop a representative body, the committee appointing members could ensure that the body’s membership is weighted by the demographics of the population it serves. For example, if the Census identifies an area as having a population that is 40% White/Caucasian, 40% Black/African American, 15% Asian American/Pacific Islander, and 5% Native American/Alaskan Native, a ten-member body would represent 10% of the population per seat. Ideally under this approach, a body serving this community would have four White members, four Black members, and at least one Asian American member, along with a final member of any ethnicity.
To determine the representation of each body, this analysis asks if the body has proportional representation of all demographic groups with a share of the service area population higher or equal to the percentage share of a single seat on the body. Specifically, the number of members on each body is used to generate the number of expected seats given the population’s demographics, assigning one seat to a demographic for each 1/n share of the population, n being the number of body members. If a body’s number of members is equal or greater than the number of expected body members determined by the population, it will be considered representative.
Diversity Index
To broadly understand the level of diversity of a given body, this analysis will rely on calculating a diversity index for bodies and their service population. This avenue of analysis will use the Simpson Index ( 39 ) (Equation 1), and the US Census implementation of the Simpson Index for populations ( 40 ) (Equation 2). Both methods measure the likelihood of two randomly selected members of the population being from the different categories-in this case, racial and ethnic classifications.
nBi = number of members of ethnic group i on body B
NB = number of members on body B
nSi = Percentage of people of ethnic group i in a service area s
To understand the diversity of a body compared with the diversity of its service population, we will subtract the diversity index of the service area from the diversity index of the body, to find the difference. This way, if a body is more diverse than the service area, it will have a positive difference.
In addition to comparing individual bodies to the service populations, it is worth examining the diversity of agencies as a whole as compared with their service populations. This is approached in this study by estimating a diversity index for the agency as a whole, using a similar methodology to the Body Diversity Index.
nAi = number of members of ethnic group i in Agency A
NA = Number of Members in Agency A
These methods are blind to the actual representation on the body or agency, but they do serve as useful proxies for the diversity of representation on a body or in an agency. Diversity indexes will be calculated by excluding members whose ethnicity was not reported. Diversity indexes are presented in a box and whisker chart, to show averages and distribution and are aggregated by US Census region, which are presented in Figure 2.
Census regions and divisions of the United States ( 41 ).
Comments from the FTA
Finally, this study will examine the specific judgements and recommendations made by the FTA about agencies’ compliance in their representation of minorities in the membership of their bodies. Descriptive statistics will be presented, and the specific FTA recommendations will be discussed. The hope is that this will lead to insights about how the FTA sees the importance of this subject, and where they draw the line between non-representative and representative.
Results
Summary Statistics
Over the 98 bodies examined, 1,344 members, including vacant seats, were observed. As can be seen in Table 1, White members strongly dominated the bodies, with that group representing almost 60% of the entire sample, far ahead from the second largest group, African Americans, who represented just 16% of the sample. The average body has 13.7 members, ranging from a minimum of 3, to a maximum of 30, with a median of 13, and a standard deviation of 5.95. California was the most represented state in the sample, with 30 bodies, followed by Washington with 12, and Minnesota with 9.
Breakdown of overall frequency in sample by Ethnic Group
Comparison to Previous Studies
It is immediately clear from Table 2 that the presence of people with non-White ethnicities on bodies has increased drastically since the 2002 report. Of course, this diversity has not increased to the same degree across all ethnicities. For example, African Americans were present on over half of boards of directors, and the share of bodies with African American members today has increased by 10 percentage points. This suggests an upward trend but compared with the 35 percentage points increase (an eight-fold increase) in bodies with at least one Asian American member, it appears that the growth of inclusion depends on the earlier percentage. In short: the more underrepresented a group was on boards of directors, the more its representation will be on advisory bodies. The counterexample is Native Americans, who were the most underrepresented group in both studies and did not see the same double digit percentage point increases of other non-White groups.
Percentage of Bodies With At Least One Member of a Given Ethnic Group
It is also worth discussing the percentage of bodies with at least one White member. The results of this study found one all-African American advisory body, while the 2002 report did not find any boards without at least one White member. This suggests a slight change, but broadly, White membership of bodies appears to be firmly entrenched, even as diversity increases. Also of note, the original study did not appear to make a distinction between Asian American and the broader category of Asian American or Pacific Islander. The comparative statistic produced from the results of this study only includes body members who specifically identified as Asian American, but if the definition is expanded to the broader category, the 40% of bodies with at least one of that group increases to 42%.
Weighted Representation
Using the service area population demographics to estimate what a representative body would look like, this analysis found that 12 bodies were roughly representative of their service population. None of them were “perfectly” representative of their population, with all having one demographic being over-represented by one or two body members, or two demographics over-represented by one member. These over-represented groups were split evenly between members who identified as either White, Hispanic or Latinx, African American, or “Other” or “No Response.”
Generally, these representative bodies were smaller on average than the rest of the bodies, with an average of 6.6 members, compared with the sample average of 13.8 members. This suggests that the smaller the body, the easier it is to qualify as representative, but this is likely an artefact of the metric. A smaller body means that each seat on the body represents a larger fraction of the population, thus meaning that smaller groups are less likely to be a large enough percentage of the population that they would “qualify” for a seat. TriMet’s Finance & Audit Committee makes for a good practical example: the Committee has three members, so each Committee member can be said to represent 33% of the population they serve. There are two White members, and a single African American member. The service population of TriMet is 70% White, which, by this metric, assigns two seats to that demographic, leaving the rest “up for grabs,” as no other demographic can mathematically reach the 33% threshold.
Diversity Index
To briefly review the concept of a diversity index, this metric measures the likelihood of two randomly selected people from a population (in this case, a body, or a service population) being of two different racial or ethnic groups. It is measured on a scale from 0 to 1, with 0 representing a 0% chance of the two individuals being of two different groups, meaning the population is of a single race or mono-racial; 1 represents a 100% chance that two individuals are of two different groups, meaning that everyone in the group has a different racial or ethnic identity to everyone else.
Body diversity indexes range from 0.00 to 0.84, averaging 0.45 overall, with a standard deviation of 0.27. Twenty bodies had a diversity index of 0.00, meaning that they were mono-racial after excluding those who did not report their ethnicity. Excluding the bodies with 0.00 diversity indexes, the average diversity index jumps to 0.55, with a standard deviation of 0.17. Population diversity indexes range from 0.20 to 0.79, averaging 0.53 with a standard deviation of 0.14.
As can be seen in Figure 3, the range in differences between body diversity indexes and population diversity indexes is extreme. At the high end, there are very diverse bodies and less diverse populations in El Paso’s Sun Metro, with a diversity index difference of 0.44 for its Citizens Advisory Committee. This means that in this body, there is a 44 percentage points higher chance that two people will be of different ethnic groups than in the population. On the low end, there are extremely homogeneous bodies, such as Fairfax County’s Transport Advisory Commission, which has a diversity index difference of −0.54. This is because the Transport Advisory Commission was made up entirely of White members, yielding a body diversity index of 0.0, compared with the population diversity index of 0.54. The standard deviation of diversity index differences is 0.24.
Regional differences between population and body diversity indexes.
On average, the difference between a given population diversity index and body diversity index is −0.085, meaning that, on average, bodies have less diversity than the populations they serve by about 8.5 percentage points. The standard deviation of this measure was 0.24. Excluding the mono-racial bodies, the average is 0.005 (with a standard deviation of 0.18). There are six bodies whose diversity index differences come in between −0.01 and 0.01, and nineteen that have differences between −0.05 and 0.05, inclusive. These bodies have a level of diversity that is close to their populations. This doesn’t mean that they are necessarily representative of their service populations, of course. For example, Long Beach Transit’s Paratransit Advisory Committee has a difference of exactly 0.05, but it over represents the White and African American population, and underrepresents the Hispanic and Asian American populations.
Figure 3 is an excellent representation of the wide range seen between both the diversity indexes overall and the diversity indexes within US Census regions. Notably, overall and in each region, the diversity indexes of bodies are, on average, lower than the diversity indexes of populations. This is most apparent in the Northeast region of the United States, which includes the Middle Atlantic and New England states. This huge discrepancy has several factors. Firstly, the Northeast region has the fewest bodies in this sample, with only six bodies, compared with 22 in the Midwest, 18 in the South, and 53 in the West. Of those six bodies, two are monoracial. Two bodies do have higher diversity indexes than the populations they serve, but overall, the Northeast bodies imply a large discrepancy. However, given the limited data collected in that region, it would be irresponsible to make broad statements based on such a small sample size. However, this discrepancy suggests that further investigation is warranted.
Agency diversity indexes range from 0.00 to 0.80, averaging 0.46 overall, with a standard deviation of 0.22, all relatively close to the values seen at the individual body level. Four agencies had a diversity index of 0.00, meaning that they were mono-racial after excluding those who did not report their ethnicity. Population diversity indexes range from 0.20 to 0.79, averaging 0.53 with a standard deviation of 0.14.
By and large, agencies on average had less diverse body makeups overall than the populations they served. The average difference between populational and agency diversity indexes was −0.09, meaning that there was roughly a nine-percentage point lower chance that two members of any advisory body were of a different reported race than the service population, with a 0.24 standard deviation. At minimum, the difference was −0.71, an artefact of the data. This datapoint reflects SunTrans, which reported one body with seven white members, and one member who did not report their race. Owing to this lack of data, the agency’s diversity index is counted as 0.00, reflecting a 0% chance that two members of the agency’s body would be of different races, despite the high diversity of the service area, 0.71. At most, the difference was 0.36, from Sun Metro, reflecting a very low service population Diversity Index of 0.27, with a comparatively high agency diversityi of 0.63.
Figure 4 shows that some of the extreme variance and disconnect seen in Figure 3 is mitigated in some regions, but the variance is still high in the South and Northeast. In the Northeast region, this is still attributed to a low amount of data, while in the South, the same cannot be said, with twice as many agencies, suggesting a wide variance of diversity within agencies in the South. In all regions, the South has the lowest average agency diversity index, despite the average service population diversity index being relatively close to the overall average. These results suggest that more investigation is required.
Regional differences between population and agency diversity indexes.
Comments from the FTA
Of the 13 agencies reviewed for compliance by the FTA since 2012, only two were found to be non-compliant when it came to the subject of minority representation on their bodies: the City of Detroit’s Department of Transportation and the Delaware Department of Transportation. For both, the only deficiency found was that neither could describe the efforts made to encourage the participation of minorities on such bodies. Both were directed to prepare a detailed report describing the efforts made to encourage the participation of minorities on these bodies within the next 60 days, and document future efforts. The results of these corrective actions are not recorded in the FTA’s reports. Four other agencies were recommended to specify the actions taken to encourage minority participation, but it is unclear why those were not found to be deficient.
None of these agencies were found to be deficient in their body makeup, but Fairfax County’s Department of Transportation was recommended to increase minority representation so that the bodies are representative of the county’s demographics. The county had previously identified this as a deficiency itself and had drafted bylaws that would specifically guide the appointment of “a broad array of ages, genders, races, disabilities” that “will reflect the demographic composition of Fairfax County.”
Two agencies had no bodies, and were neither directed nor recommended to set up an advisory body. Instead, the FTA commented “It is an effective practice to establish an advisory committee representing riders and social service partners. Such a standing committee allows for ongoing input from key stakeholders in the transit system.” This statement appears to imply that these agencies should establish a body, but that the FTA does not officially recommend they do so. This indirect language resembles the “Subtweet” phenomenon by indirectly addressing an issue or a specific entity while speaking to a broader audience, often in a negative light. These are behaviors that have been shown to be perceived as less effective communication styles by readers, lowering their perceptions of the message author ( 42 ).
Conclusions
Noting that, by all three original metrics presented, a significant fraction of advisory and planning bodies of the United States transit agencies are not representative of the populations they serve, it is safe to say there is a lot of progress to be made to elevate the voices of people of color in these spaces. When the vast majority of bodies can be considered non-representative, it poses serious concerns about who is making decisions, advising planners, and “representing riders.”
These results can tell us who serves on these bodies, but they cannot tell us who should serve on them. Based on the literature, less diversity on planning bodies appears to be a negative thing, but there is no evidence that more diversity is necessarily always a positive thing, or that perfect representation is ideal either.
This research suggests that agencies should reexamine how their advisory bodies are assembled. There are several possible approaches, but it is important to implement approaches that will have real-world impacts on planning and policy outcomes, and are not perfunctory steps in a checklist. Roughly following the model proposed by Karner and Marcantonio ( 13 ), the first step should be for agencies to evaluate how the membership of their body is selected, from the process of setting the size of the body, to recruiting and interviewing potential members. Metrics for representation should be set, prioritizing membership to underrepresented communities, and specific corrective actions should be identified at the same time to be taken if a body becomes unrepresentative. Finally, agencies should work to actively include bodies in the planning process, in the hopes that more community input will be included in the final product, creating a more equitable future.
By contrast, the FTA should clarify why certain agencies are judged to have deficiencies, while others with similar issues are not. More than that, they should develop metrics that compare the representation of minorities on bodies with the demographics of their service area. In this realm, specifics are a useful starting point for agencies to self-reflect and the FTA to be proactive.
Obviously, there are methodological issues with the research conducted here. Agencies report their body membership and their service population in a variety of different ways, and this may cause issues with the analysis presented here. Addressing these deficiencies is an avenue that I strongly encourage further research into. I propose that, instead of relying simply on sporadic and variable Title VI reports, future research should replicate or refine the methodology of the 2002 Simon & Simon report on transit boards of directors ( 15 ). The methodology of that study allowed for a unified data set for easy comparison between diverse bodies. Included in a future survey should be questions about the service area demographics, both relating to ridership and census level data. Furthermore, future research should include analysis of gender, disability status, and, if possible, income. All three of those attributes were excluded from this analysis owing to the lack of data, but they add relevant and important dimensions to the public transit experiences of individuals participating in this system of advisory bodies.
Of course, it is worth emphasizing that the metrics presented here are not the only metrics by which to judge the equity impacts of a transit agency’s planning process. Furthermore, it is not even an ideal metric, given the structural issues of these entities, and their place on Arnstein’s ladder of public participation ( 11 ). This paper should not be taken as an endorsement nor a condemnation of these bodies. They have immense potential to be useful resources to guide transit agencies as they serve communities, but they also have the potential to be ignored and deprived of any authority. In the former case, these bodies contribute to a more just world, while the latter case can actively work against that quest for justice.
Footnotes
Acknowledgements
Dr. Elisa Barbour, for holding me to high standards. Dr. Jesus Barajas, for setting me down this path. Ryan Miller, Katherine Turner and Dr. Susan Handy, for edits and encouragement. My parents, for all their love and support. Misa Smith, for everything.
Author Contributions
The author confirms sole responsibility for the following: study conception and design, data collection, analysis and interpretation of results, and manuscript preparation.
Declaration of Conflicting Interests
The author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.
Funding
The author received no financial support for the research, authorship, and/or publication of this article.
