Title VI & ADA Analysis: 2027–2031 Transportation Improvement Program
Title VI of the 1964 Civil Rights Act (42 U.S.C. 2000d-1) states that “No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance." The goal is to ensure that the benefits and burdens of all government actions and investments are fairly distributed and that populations are not disproportionately affected due to their race, color, or national origin.
Title VI and other USDOT guidance do not contain specific requirements for evaluating the impacts of transportation plans and programs on Title VI populations.
The Greater Madison MPO (Metropolitan Planning Organization) conducts a qualitative transportation project analysis of the TIP, comparing the locations of transit services and programmed projects with areas that have concentrations of locally identified Title VI populations.
Evaluating the impacts of transportation infrastructure and policies is a critical part of the MPO's planning activities. Mapping populations in relation to existing and planned transportation infrastructure, jobs, and other destinations is one of the primary screening tools planning agencies use to assess whether residents' transportation needs are being adequately served and whether the costs and benefits of transportation projects and policies are fairly distributed.
Methodology for Identifying Title VI Areas
Title VI Areas are selected from the Local Priority Areas generated by the City of Madison Data Team, which uses Census block group geographies. The Data Team assigned one point to each zone that was above Madison's 80th percentile for the percentage of Black, Asian, or Hispanic/Latino residents.
Zones received an additional point if the percentage of these groups exceeded the 95th percentile. All zones awarded at least three points are identified as Title VI Areas.
Note: The zone containing Oakhill Correctional Institution is excluded.
Transit Service and Major Projects Analysis
Transit Service Analysis
Fixed-route transit service areas encompass nearly all of the areas with concentrations of Title VI populations, although for some areas it is greater than ¼ mile to the nearest stop. The largest of these apparently un-served Title VI areas is largely composed of William Lunney Lake Farm County Park, Capital Springs State Recreation Area, and the Madison Metropolitan Sewerage District—undeveloped or non-residential areas. Most Title VI areas in southwest Madison are served by routes with 30-minute mid-day headways (Routes D2, E, and H) as well as limited-stop peak-hour-only routes 55 and 75 between Madison and the Epic campus in Verona. Along S High Point Rd, a Title VI area is only served by peak-only route 55. In Fitchburg, a Title VI area along McKee Rd/CTH PD is only served by peak-only route 75.
Many comments received during the public survey mentioned above requested mid-day and weekend service on routes 55 and 75 to make them more useful for trips other than commuting to and from Epic. All-day service to Verona was initiated in 2026 with an extension of Route D2. As these routes are paid for by Epic through the City of Verona, or by Fitchburg, such changes to service are beyond the control of Metro and Madison.
Many comments also requested direct service between southwest Madison and the UW/VA Hospital area, with scheduled stops designed to support health care workforce transportation. Title VI areas in Middleton are served by route R2 with hourly mid-day service, with some areas also served by route F with 30-minute mid-day headways. Comments in the public survey requested increased service frequency on R2, and that the F and R routes continue all the way to the Capitol Square evenings and weekends as opposed to stopping at Sheboygan & Eau Claire. As with service to and through Verona, service within Middleton is paid for and must be approved by the City of Middleton, including portions of Routes F and R2.
Sun Prairie implemented weekday peak express bus service to downtown Madison in August 2019 and all-day local service with a connection to Madison and the rest of the Metro network in June 2023. These services are part of Metro Transit's fixed-route service and standard transfers between the Sun Prairie routes and other Metro fixed route services are available at no additional charge. Sun Prairie's connection to the rest of the Metro system was upgraded to a Bus Rapid Transit local service extension in 2024, and the addition of two local routes, S and W. Although Title VI areas in west and southeast Sun Prairie extend beyond the Metro service area, a large proportion of these census block group geographies beyond the service area include non-residential and undeveloped or agricultural land.
East-West BRT and the accompanying local service extensions, for which Small Starts funding was awarded, entered service in 2024 and dramatically improved transit travel times, service frequencies, and access to destinations over pre-Network Redesign services. North-South BRT planning and design work is currently underway and is funded through a federal Areas of Persistent Poverty grant, and an application for Small Starts funding was submitted in 2023.
Combined with the Metro Transit Network Redesign, the East-West and North-South BRT services will improve transit travel times, service frequencies, and access to destinations for residents of Title VI areas in North, South, East, West, and Central Madison, Middleton, and Sun Prairie. The Network Redesign service plan was designed to improve transit access for the majority of area residents, including low-income and minority residents.
Additionally, a Title VI analysis of the service plan conducted by Metro and their Consultant, Jarret Walker + Associates, with support from the MPO, found that minority and low-income residents would benefit from the Network Redesign at the same or greater rates than the population in general. Metro completed a Title VI Service Analysis in July 2024 that includes all service changes implemented following the Transit Network Redesign. Given these extensive and detailed Title VI analyses of the new service network, any further analysis here would be redundant.
As part of its Title VI compliance monitoring, Metro Transit updates its Title VI Plan every three years. The current plan update was adopted in October 2023, and reports on 2020-2022. The plan highlights Metro's current fixed-route service standards, service quality/policies, fare policy, and Title VI analyses of service and fare changes since the last plan was adopted. The policies and analyses help ensure that the level of service and location of routes, age/quality of vehicles assigned to routes, and stop and other facilities are being provided in a non-discriminatory manner, and that the fare structure is also equitable.
Pedestrian/Bicycle and Roadway Projects Analysis
There are no programmed major capacity expansion roadway projects in the Madison area that would result in significant adverse impacts to Title VI areas. Capacity expansion projects in the MPO planning area—CTH M (Oncken Rd. to STH 113), Pleasant View Road, Parmenter Street, USH 51 in Stoughton—are located on the periphery of the urban area in developing areas. There are no Title VI areas within the vicinity of these projects.
Major bicycle projects are planned through or in proximity to and serving Title VI areas in the Cities of Fitchburg, Madison, and Sun Prairie.
There are path reconstruction projects in the City of Sun Prairie that will benefit Title VI areas with rehabilitated surfaces and related improvements. In Madison, the Hermina Street Starkweather Creek bridge, East Rusk Path, Moorland Road Path, and West Beltline Frontage Road Path projects will all improve non-motorized access to and through Title VI areas in Madison. In Fitchburg, the McKee Rd path will serve adjacent Title VI areas. These projects benefit the areas in which they are located or those nearby by improving non-motorized accessibility, strengthening the social fabric of the neighborhoods, and improving health by encouraging active transportation and recreation.
The Wisconsin Bike Federation has been awarded TAP funding for its Dane County Safe Routes to School (SRTS) programs, which target schools with high proportions of students who qualify for free or reduced-price lunches, a proxy for Title VI populations.
Conclusion
The major projects analysis shows that, taken in whole, the projects in the 2027–2031 TIP do not impose disproportionately high and adverse impacts on Title VI populations. Also, the benefits of the transportation improvements and services provided are reasonably distributed to serve the needs of all populations in the area.