2022 CTDOT Fare Equity Analysis and Service - Connecticut Department of Transportation - CT.gov (2023)

CTDOT 2022 Rail and Bus SAFE Analysisa 2022 CTDOT Service and Fare Equity Analysis Connecticut Department of Transportation Final - June 15, 2022 i|Page

CTDOT 2022 Rail and Bus Analysis SAFE Table of Contents Fairness Analysis of Services and Tariffs Executive Summary ..................................................... .................... i Stock Analysis Methodology ............... ......... ........................................... ........... ................................... i Proposed Changes to the Connecticut Rail System ............................ ..................................... ............. ......... i Proposed changes to the CTtransit bus system............... .................. ................................... .........ii Hartford Bus System ..... .................................................................. ............................................................. ....ii New Haven Bus System ..................................................... .................................. .................... .................ii Tariff and Service Analysis – Findings and Alternatives .... ................... ................................ .........ii Discoveries of the Railway System....... ........................ ........................... ......................................................ii Alternatives to Mitigation of Railway System ..................................................................... ............... ....................ii Bus System Discoveries ......... .............. ..................................... .........................................................iii Bus System Mitigation Alternatives ......... .................................. .............. ................................iiiIntroduction ...... ............... .................................... ............. ..................................................... ........... ............ 1Title VI Principles and Definitions ...................... ......... ......................................................... ....... ................ 1 Service Equity Review Policy .................. . .................................................. ... ... ................................ 1 Tariff Equity Analysis Policy ..................................... .. ................................................................ ................................ 2 Triggered Impact/Disproportionate Load Policy .......... .................................................. ...... 2 Major Changes to the Service.................................................. ..................................... ............. .......... 2 Tariff Changes ............................. ............. .................................... ............... .................................. .... 3Rails............ .................................................................. ............................................................. .................................. .. 4 Description of the Connecticut Rail System ........... ........................... ....................... ................................ 4 2022 Rails Service changes ................................... ........................... ....................... ......................... ..... 4 Railway Lines Main Analysis of Changes in Services ........ ............. ..................................................... .... 4 Summary of the main changes in the rail service ................................................... ............................................................ 5 Rail Service Equity Analysis ......... ................................. ............... .................................... ...... 6 Methodology ............................................................ ........ .................................................... ...... ..................... 6 Results of the Rail Service Capital Analysis .............. ......... ......................................................... ............... 7 NHL Waterbury Rail Schedule Impacts and Alternatives ................................... ........ ......................... 13 Stratford Weekend Service - Stops ......... ..... ............................................. ... .................... 14 Substitute Stratford Service ....................... .................................................. ..................... 14 Alternatives to Stratford Stop .......................... .. ..................................................... .... ..................... 15ii | Page

CTDOT 2022 Railway and Bus SAFE Analysis Completion of Railway Mitigation ................................................... ................................................................... . ......... 16 Rail Fare Equity Analysis ..................................... .... ............................................................ ...... ................... 18 CTDOT Title VI Policy ................................... . .................................................. ... ... ................................................ 18 Methodology ............ ............. ..................................................... ........... ........................................... ......... ......... 19 Tariff Change Analyzes ................................... ............ ...................................................... ....................................... 23 Determining a Discriminatory Impact ........... ............................................................ ........ ..... 28 Tariff Impacts and Alternatives ................................... ....... ..................................................... ..... .... 30 Bus ............................................ ....... ..................................................... ..... ............................................. ... 31 Proposals for Changes to the Bus Service ................................................... .................................................. 31 Bus service equity analysis ............................................................ ..................................................... ..... ..... 38 Service equity analysis methodology ..................................... ....... ......................................... 38 Bus Service Equity Analysis Results .................................. .................... ..................... 39 Impacts and alternatives of the change in bus service ................................... ................................................................ 42 Public Disclosure . ............................. .................................... ........................... ....................... .................. 44 Hearings and Public Meetings . .................................................. ................................... 44 Public Hearings ..................... ........................................... .......... ...................................................................... ... 44 Legislative Disclosure.................................................. ......................... .................................... 44 Disclosure by the Council of Governments (COG)........................................................ ................... ............. 44 Meetings of Community Based Organizations (CBO) and Faith Based Organizations (FBO) ... 45 Notices ......... ..................................... ............ ...................................................... .......... ........... 46 Press Release ..................... .... ............................................................ ...... ................................... 47 Newspaper Notices ......................... ..................................... ........ ............................................ 47 Interior Bus and Station Location Notices . ...................................................................... ............. 47 Social Media .......................... ........ ........................................... .......... ...................................... 48 SECURE Site ......... ............................. .................................... ........................... ...................... 48 Twitter, Facebook, and E-Blasts ..................................................... .......................... ................................... 48 Tools of additional comments ..................................................................... ......................... .................................... .... 49 Project email ............................................. ......................... .................................... .................... ...... 49 Project Information Line (Telephone) ..................... ......................... .................................... ..................... .. 49 Library comment box ................................... ........ .................................................... ...... ............. 49 US Postal Service ................................... .... ............................................... .. ......................................... 49 iii | Page

CTDOT 2022 SAFE Analysis on Railways and Buses Public Comments ............................................ . .................................................. ... ... ................................... 50 Language Assistance for Billing Hearing and Title VI Information ............. ......................................... 50 Post-audition research ... ..... ............................................. ... ................................................... ....... 50 Media coverage ................................................... .................................................. ........................... 50Appendix A - Summer 2022 Core Rail Service Change Threshold Analysis Results ...... ... .......... 51Appendix B - Rail Services Equity Analysis Schedule Analysis Tables ................................... ........ ............. 53Appendix C - Equity Analysis of the Rail Service Train Schedules 2021 and 2022 ............. .......... .......... 56Appendix D - Average Fare Tables for Rail Fare Equity Analysis................ ........... ................................... 59 Hartford Line ........... ............................................................ ........ .................................................... ...... .... 60 East Coast Line ..................................... .. ................................................................ .................................. 65 Complete Package.................................. .................................................. ..................................................... .... ...... 71Appendix E-Bus Key Results of the Service Change Limit Analysis .......................... ....... ...... 72Appendix F - Waterbury Line 2022 Revised Train Schedule ....................................... .................. 75Table of FiguresFigure 1 - Connecticut Rail Passenger Service Map........... ........ .................................................... ....... 4Figure 2 - 24 Windsor - Bradley International Airport ..................................... ............. ................... 31Figure 3 - Bradley-Union Connector ........... ............. .................................... ............... ................. 32Figure 4 - Old route between Waterbury and Meriden ......... ............... ................... 34Figure 5 - New Route 940 .................. .................................. .................... ............................ ......... 35Figure 6 - Closure of the Grand Avenue Highway Bridge and Route 212 .................................. .................... ..... 36Figure 7 Routes 212 and 282 during the closure of the Grand Avenue Bridge ......................................... ........... 37Table of TablesTable 1 – Waterbury Line Service Change Threshold Analysis ......... ............... .......................... 5Table 2 – Minority Serving Stations on the NHL Line – Waterbury ............. ...................... 7Table 3 – NHL Waterbury Line – Triggered Impact Analysis for Headway Changes ............ .......... 9Table 4 – NHL Waterbury Line – Triggered Impact Analysis for Stop Changes ............ 10 Table 5 – Aggregate Rail System Minority Population Comparison .. ....... .................................................... 10Table 6 – Low-income service stations in the NHL – Waterbury Line ................................................... 11 iv | Page

CTDOT 2022 Transit SAFE AnalysisTable 7 – NHL Waterbury Line – Disproportionate Load Analysis for Interval Changes .......... .. 12Table 9 – Comparison of Low Income Population of the Aggregate Rail System ...... .................................. .. 13Table 10 – Triggered Impacts and Summary of Disproportionate Load Assessment..... ... 13Table 11 – NHL Waterbury Line – Triggered Impact Analysis for Stop Changes – With Mitigation. .................................................. ..................................................... .... ............................................................ 16Table 12 – NHL Waterbury Line – Disproportionate load analysis for stop changes – with mitigation ..................................... ............. ................................... 17Table 13 – Ridership Survey 2019 Hartford Line Tare Average usage... .................................... ..... 23Table 14 - Estimate for 2021 Hartford Line Fare Average Usage by Class ..................................... ..... 24Table 15 - Annual Expenses with Hartford Fare Line by Medium by Class (Pre-20% Discount) ......... 24Table 16 - Annual Expenses with Hartford Line Rates by Medium by Classification (Post-20% Discount) ......... ........................................... ........... ..................................... ............. ................................... ... 25Table 17 -2019 Shore Line East Ridership Survey Fare Average usage by class ................................... 25Table 18 - Estimated 2021 Land Line East Tariff Average Usage by Class .... .......................... 27 Table 19 - Annual Landline Expenses with Eastern Fare by Medium by Class (Pre-20% Discount) . ...... 27Table 20 - Annual East Fare Expenses by Medium by Class (Post-20% Discount)......28Table 21 - Percentage Change in Hartford Line Fare Payments ..... .................................. ............. 29Table 22 - Percentage Change in Land Line Eastern Fare Payments ............ 29Table 23 - Percentage Variation in Payments for the Complete Package ............ ................ ................................... 29Table 24 - Efficiency of the 6 highest passengers per revenue hour for CTtransit New Haven............ 37Table 25 – Disparate Impact Analysis for Hartford Division Express Route with positive Proposed Change of Service ........................ ....... ..................................................... ..... ............................................ 40Table 26 – Triggered Impact Analysis for Local Routes of the Hartford Division with Change of Positive Proposal Service ............................................................ ........ .................................................... ...... ................... 40 Table 27 - Uneven Impact Analysis for the New Haven Division's Proposed Bus Bridge Route .... ... 41 Table 28 – Disproportionate Load Analysis for Hartford Division Express Route with positive proposed change of service............................ ...... ..................................................... .... ............... 41Table 29 – Disproportionate Load Analysis for Hartford Division Local Routes with Positive Service Change Proposals .......... ............. ..................................................... ........... ........................................... .. 42Table 30 - Disproportionate Load Analysis for Proposed New Haven Route Bus Bridge ........ 42Table 31 - Service Change Impacts and Alternatives - Hartford Local and Express Bus System 43Table 32 - Range of e-mail directed to community organizations ................... ......................... 45 v|Page

CTDOT 2022 Trânsito SEGURO Analysis Table 33 – Newspaper Notices ............................................ .................................................. ........ 47Table 34 – Disclosure on Social Media ..................................... ..... ..................................... ....... ..... 48vi | Page

CTDOT 2022 Transit SAFE AnalysisFare and Service Fairness Analysis Executive SummaryAccording to Title VI of the Civil Rights Act of 1964 and Title VI Circular 4702.1B of the Federal Transit Administration (FTA), the Connecticut Department of Transportation ( CTDOT) conducts a Service and Rate Equity Review (SAFE) anytime rate changes or major service changes are proposed to ensure changes do not unfairly impact minority and low-income populations as defined by the FTA Title VICircular. CTDOT is reviewing proposed changes to service on the Waterbury Line and offering discounted fares on the CTrail line. travel tickets. In addition, CTDOT is reviewing proposed service changes to the CTtransit bus service. Changes to fares and core rail services and proposed changes to core bus services were analyzed to determine whether there are disparate impacts for minority populations or disproportionate burdens for low-income populations. provide 22 daily trains compared to 15 daily trains today. This increase in service was made possible thanks to the installation of passing diversions and a Control Positivo (PTC) train signal system. The proposed changes affect the Waterbury Line schedule as follows: • During morning and afternoon peak periods, train service will be increased by 50% while reducing gaps, mainly northbound, compared to the current schedule . • At midday peak hours, service will be increased by 33% - 50%, while headways will be reduced by more than 30% compared to the current schedule. • These proposed changes include the absence of three Monday-Friday stops at Stratford Station during AM Peak, PM Peak & Noon, and PM Off-Peak. These are the only service reductions associated with the 2022 Waterbury Line schedule. • A new early morning train south to New York via connecting train is proposed. ), CTDOT proposes to increase the discount on tickets already discounted Hartford Line and Shore Line East for 10 trips, from ten trips for the price of nine to ten trips for the price of eight. This is equivalent to an additional 11.1% discount on the 10 already discounted tickets. i|Page

CTDOT 2022 Transit SAFE Analysis Proposed changes to the CTtransit bus system The purpose of the proposed changes to the CTtransit bus routes is to allow for better coordination with CTrail Hartford Line trains, convert two pilot bus routes to permanent routes, and introduce a new bus route express. Hartford Bus System The following changes are proposed for bus lines operating in the Hartford area: • On Route 24 (Windsor-Bradley-Windsor Locks International Airport) and Route 512 (Berlin Turnpike) schedule changes would allow for better connections to trains CTrail Hartford Line. • Route 940 (Waterbury-Meriden) is a pilot route designed to provide a direct route between Waterbury and Meriden and to strengthen connections for train arrivals/departures at Waterbury and Meriden stations. It is proposed to make it a permanent route. • The Bradley-Union Connector is a proposed new route that will provide express service between Bradley International Airport and Hartford Union Station.New Haven Bus SystemThe following change is proposed for the New Haven area: • Route 282 (East Grand Avenue Bus Bridge) began service as a temporary bus route in response to the Grand Avenue Bridge construction project. The route has proven to be one of the most efficient routes on the New Haven bus system. It is proposed to transform it into a permanent route. Service and Fare Reviews - Findings and Alternatives Rail System Findings Reviews of major changes to rail service on the Waterbury Line and changes to CTrail fares are given below: • General - The 7-train service expansion is a massive service 47% and benefit to the people of Naugatuck Valley and Waterbury Line. • Progress Changes - No disparate impacts or disproportionate burdens were identified. • Changes to stops – No disparate impacts or disproportionate loads at Waterbury Line stations were observed, however as several trains from Waterbury now also stop on the main line at Stratford this is included as a consideration. A disparate impact and disproportionate load was identified because Waterbury's proposed train schedule for summer 2022 has no stops at Stratford station (a minority service station). • Fare Changes – No disparate impacts or disproportionate charges identified. , with wider travel options for Peak and Off-Peak trains. The team recommends that the Derby-Stratford bus connections be considered as offsetting the disparate impact of the absence of the three rail stops. ii | Page

CTDOT 2022 analysis SAFE TRANSIT With the proposal to expand the service on a large scale, multiple train crossings are being introduced, along with a new signaling system. This represents a note of caution when adding stops to this untested train schedule. However, the team identified - subject to operational feasibility - three possible rail stop measures: • Monitor passenger numbers – adjust service according to observable changes in passenger numbers • Correction – adjust schedule to remove the quantified impact. This can be done by: o Maintaining similar stops on three trains in the Waterbury Summer 2022 schedule. While this would not fully offset the disparate and disproportionate impacts, it would serve to reduce the variance of the 15% cap. o Another remediation step could be to add a Stratford stop in the morning peak period to eliminate the finding of uneven/disproportionate variation. • Restore and add stops at Stratford station to the 2022 Summer Waterbury Line schedule. This would ensure that all Waterbury Line stations receive the benefits of the expanded service equally. Ultimately, following publication of the SAFE draft in April 2022, CTDOT worked with Metro-North to restore and add the Stratford Station stops to the 2022 Summer Waterbury Line schedule and remove the disparate impact and disproportionate load that would have been created on the previously proposed schedule. Bus System Findings The proposed service changes to CTtransit Route 24 resulted in a disparate impact for minority populations. Bus System Mitigation Alternatives The increase in service frequency change on Route 24 triggers a disparate impact, as this route is slightly unfavored by minorities. However, this is a change that benefits minority and non-minority pilots on the route by providing them with more frequent service. iii | Page

CTDOT 2022 Transit SAFE Analysis Introduction Title VI of the Civil Rights Act of 1964 ensures that “no person in the United States shall, on the basis of race, color, or national origin, be excluded from participation, denied benefits, or be subject to discrimination in any program or activity that receives federal financial assistance.” The Connecticut Department of Transportation (CTDOT) is committed to the Title VI objectives of the Federal Transit Administration (FTA) set out in FTA Circular 4702.1B by ensuring that FTA-assisted benefits and related services are made available and equitably distributed without into account race, color or national origin. The FTA requires transit program fund recipients, including the CTDOT, to "evaluate significant system-wide service changes and proposed improvements in the planning and programming stages to determine whether these changes have a discriminatory impact." the Waterbury Line and discounts on tickets for ten CTrail journeys. Proposed changes to bus service include extra travel on CTtransit Hartford area routes 512 (Berlin Turnpike) and 24 (Windsor-Bradley Int'l Airport-Windsor Locks). New proposed bus services include CTtransit New Haven area Route 282 (East Grand Avenue), CTtransit Express Route 940 (Waterbury-Meriden) and a CTtransit Hartford area route, the Bradley-Union Connector.Title VI Principles and DefinitionsCTDOT's FTA Title VI Program for FFY 2021 – FFY 2023 defines its Major Service Change Policy as any service change that meets at least one of the following criteria: • Route restructuring actions resulting in at least a 20% change in total route length. • Changes in service frequency that result in a 25% or greater change in annual vehicle mileage (RVM) revenue. The annual RVMs are a compilation of the weekday and weekend RVMs. • A service change adding or reducing service to a fixed guide station, resulting in a greater than 25% change in service at the station. • Service change actions resulting in at least a one hour change in service time. provided these changes remain ineffective for more than 12 (twelve) months. When a service change is proposed, there shall be a twelve month retrospective to determine whether the aggregate of any changes over the previous twelve (12) months would have triggered one of the major service change criteria. The following service changes are exempt: • Standard Seasonal Variations in Service: A seasonal route or route variation is generally a modification to the service to provide “additional” access that is not largely needed year-round, or the discontinuation of the service. Also exempt is any temporary addition to service, alteration or discontinuation of a route with the intention that it will be in operation for less than twelve months. While all changes from regular service to seasonal service and vice versa are exempt, if there are changes within the seasonal service from one year to the next, CTDOT 1|Page

The CTDOT 2022 SAFE Traffic Analysis will carry out a Service and Tariff Equity analysis if the change exceeds fifty percent (50%), regardless of an increase or decrease in the service; • Changes to routes serving sporting events, special events or contracted services in other cities or agencies; • Any service change that does not meet the definition of a major service change, such as minor route alignments, frequency, length or time point adjustments; route changes or bus stop due to temporary diversions caused by works, maintenance, closures, emergencies, labor outages or strikes, fuel shortages or safety concerns; etc. Tariff Equity Analysis Policy A tariff equity analysis will be carried out whenever CTDOT proposes a tariff change, regardless of the amount of the increase or decrease. For proposed tariff changes, CTDOT will: 1. Determine the number and percentage of users of each proposed tariff means for increase or reduction; 2. Review the rates before the change and after the change; 3. Analyze fare media generated from passenger surveys, indicating whether minority and/or low-income passengers are disproportionately more likely to use the mode of service, payment type, or proposed fare media for switching; and 4. Compare the impacts of each tariff medium between minority users and general users. A fare change is defined as an increase or decrease in fares: (a) system-wide, (b) certain modes of public transport, or (c) by fare payment type or fare medium. Exceptions are as follows: 1. “Spare the air days” or other situations where a local municipality, State or CTDOT has declared that all passengers travel free; 2. Temporary fare reductions that are mitigating measures for other actions (ie construction activities that close a segment of the rail system for a period of time); or 3. Promotional rate reductions lasting less than 6 (six) months. 4. FTA Circular 4702.1B states that a recipient may implement a tariff increase that would have a disproportionate or adverse effect, provided it demonstrates that the action meets a substantial need in the public interest and that the alternatives would have more serious adverse effects than the preferred alternative.Uneven Impact/Disproportionate Burden PolicyThe purpose of the SAFE Policy is to establish thresholds that identify when the adverse effects of a major service or tariff change result in an uneven impact for minority populations or a disproportionate burden for low-income populations. CTDOT applies the Skyrocketing Impact Policy and Disproportionate Charge Policy evenly to all major service and rate changes, regardless of mode. Major Service Changes A major service change to the rail or bus system will be deemed to have an uneven impact on minority populations or a disproportionate burden on low-income populations, whether the percentage of passengers or 2|Page

CTDOT 2022 Transit SAFE analyzes that vehicle revenue hours on impacted minority or low income rated routes are at least fifteen (15%) percent greater than the percentage of passengers or vehicle revenue hours on non-affected classified routes minorities or low-income affected by the major service change. Tariff Changes A tariff change will be considered to have an uneven impact on minority populations or a disproportionate burden on low-income populations if its implementation results in: 1. When a tariff change is proposed, the percentage of impacts of the proposed tariff change borne by minority or low-income passengers as a result of the proposed fare change is at least ten (10%) percentage points greater than the percentage impacts of this proposed fare change on the overall passenger population; or 2. When more than one fare change is proposed: o For each fare change in the package: the percentage impacts of each proposed individual fare change borne by minority or low-income passengers as a result of the proposed fare change is at least ten (10%) percentage points more than the percentage impacts of this proposed fare change on the overall passenger population; and o For the total package of fare changes: the aggregate percentage of the impacts of the proposed fare changes borne by minority or low-income passengers as a result of the proposed fare changes is at least five (5%) percentage points higher than the aggregate percentage of impacts on the total passenger population. FTA Circular 4702.1B states that a recipient may implement a tariff change that would have a disproportionate or adverse effect, provided it demonstrates that the action meets a substantial need that is in the public interest and that alternatives would have more serious adverse effects than the preferred alternative. 3|Page

CTDOT 2022 Transit SAFE AnalysisRailConnecticut Rail System DescriptionPassenger rail service in Connecticut is supported by CTDOT and consists of three main lines and three branches. Figure 1 - Connecticut Passenger Rail Service Map The New Haven Line, operated by the Metro-North Railroad (Metro-North), operates between New Haven and Grand Central Terminal in New York City. This line has three branches that extend to NewCanaan, Danbury and Waterbury. Illustrated by the red lines in Figure 1. The Shore Line East (SLE), operated by Amtrak, operates along the Northeast Corridor between NewLondon and New Haven, with some direct service to Stamford and connections to the New HavenLine. Illustrated by the purple line in Figure 1. Amtrak and TransitAmerica Services Inc. (TASI) operate intercity passenger services between NewHaven–Springfield (Hartford Line) and Amtrak on the Northeast Corridor to New York. Illustrated by blue lines in Figure 1.2022 Rail Service Changes Rail Lines Core Service Change Analysis The CTDOT Program Title VI 2021-2023 defines a major service change as any change in service that meets at least one of the following criteria: 4| Page

CTDOT 2022 SAFE Traffic Analysis • Route restructuring actions resulting in at least 20% change in the total length of the route. • Changes in service frequency that result in a 25% or greater change in annual vehicle mileage (RVM) revenue. The annual RVMs are a compilation of the weekday and weekend RVMs. • A service change adding or reducing service to a fixed guide station, resulting in a greater than 25% change in service at the station. • Service change actions resulting in at least a one hour change in service period. The threshold analysis compares the August 29, 2021 service characteristics with the proposed 2022 service characteristics, both in the threshold analysis and in the breakdown of service levels for core services and rate changes. Seven additional weekday trains are proposed to be added to Waterbury Line's 2022 schedule to provide 22 daily trains compared to 15 daily trains today. An analysis was performed to identify whether these changes qualified as a major service change as defined by the CTDOT Core Service Change Policy. Appendix A contains the details of these analyses. • NHL Waterbury Line – Major service change o The Waterbury Line service was re-scheduled in the process of adding 7 additional trains, which represented service increases for station service, train and vehicle-kilometre frequency compared to service available during the week. o Service frequency on the Waterbury Line exceeded the 25% threshold change in stops, breaks and service RVMs for the south and north during the week. o The frequency of trains and vehicles per mile 2022 compared to 2021 considered a major service change, exceeds the 25% threshold. The Waterbury Line also received 59-minute extension service extensions to the south; and 1 hour 53 minutes northbound, ranking for the longest service interval, increases during the week.Summary of major rail service changesAn overview of service changes across the Waterbury Line service is shown below, following the convention of previous SAFE analyzes. The table below shows a summary of the rail threshold analysis for changes to the Waterbury service, which only affected weekday (Monday to Friday) train service. Table 1 - Waterbury Line Service Change Threshold Analysis 5|Page

CTDOT 2022 Transit SAFE AnalyzesPeak vs. Off-Peak Break For the individual travel time periods, the analysis indicated the following: • For 2022, the peaks receive 50% increases in service, reducing headways, mainly to the north throughout the 2021 service. 2022, the midday peak hour receives 33% to 50% more service, as well as reducing breaks by more than 30% from 2021 service. • The absence of the three (3) Stratford stops - each morning peak, afternoon peak and afternoon off-peak are the only service reductions associated with this 2022 schedule. • The introduction of an early departure from Waterbury Southward on weekdays is a new train arriving at New York via connecting train, before 6 am, representing a 100% increase in the AM Off-Peak time period (pre-AM Peak). See See Appendix B for detailed information on these factors by season. Rail Service Equity Analysis Methodology As part of its Title VI program, CTDOT recently completed a demographic analysis of rail service territories on the New Haven Line, three branches including the Waterbury Line and the Shore Line East, and ranked minority stations and low-income in each row. Under the CTDOT Title VI Program, rail service territories are defined as all census tracts that are within (and touching) 2.5 miles of suburban rail stations. Data from the American Community Survey (ACS) from the 2013-2017 Census were used in the analysis. The CTDOT Title VI uneven and disproportionate load threshold of 15% (described above in the Title VI Principles and Definitions section) was used to determine whether there is a disparate impact or disproportionate burden for major service changes. As discussed above, changes to the Waterbury line resulted in a major change in service. The project team evaluated the time changes in terms of station service (ie, station stop differentials) and grade of service (ie, station weekday headway differentials (peak and off-peak)). The 2021 rail schedules were compared to the current 2022 schedules to determine peak and off-peak average stops and intervals per station for both directions of rail service. The mean reduction in stops and the mean increase in headway were then calculated for each station in each of the periods. Appendix B contains the Service Change Analysis tables. The project team then compared the average stop change and the average interval change between minority and non-minority serving stations to determine if there are disparate service impacts; and between low-income and non-low-income service stations to determine whether disproportionate charges exist. Using the 15% threshold, if service changes to minority service stations are more than 15% worse than changes to non-minority service stations, then this 6|Page

CTDOT 2022 Transit SAFE reviews mean mixed impact. Likewise, if shifts to low-income service stations are more than 15% worse than non-low-income service stations, that would be a disproportionate burden. The project team also calculated the aggregate of minority and low-income populations from the service territories of each railroad line that had a major change in service and compared this to the minority and low-income populations of the total CTDOT rail system (including the Hartford Line) aggregate service territories. To determine minority and low-income status, two Census ACS tables were used. • Table B03002 (Hispanic or Latino Origin by Race) which contains population counts by race broken down by Hispanic or Latino origin. Minority population counts were calculated as the total population minus the counts for the variable “not Hispanic or Latino” (one race: white only). • Table B06012 (Place of Birth by Status of Poverty in the Last 12 Months in the United States) that informs the poverty status by place of birth. Low-income population counts are those living below 150% of the poverty level (which is consistent with CTDOT Title VI policy). minority or low-income populations exceeded the total population of the minority rail system or low-income service territory by more than 15%. The results of the Rail Service Equity Analysis are presented below. Rail Service Equity Analysis Results As discussed above, service changes on the Waterbury Line qualify as major service changes as defined in the CTDOT Title VI Program. The line was analyzed using the criteria described above in the methodology section and the results of this equity analysis are described below. two). Table 2 – NHL Minority Service Stations – Waterbury Line NHL Mainline Stations Minority Service? Waterbury Y Naugatuck Y Beacon Falls N Seymour N Ansonia N Derby-Shelton N Stratford Y Bridgeport Y0 below displays the results of the Disparate Impact Analysis for progress changes. There are no disparate impacts on headway switching, as the variation in average headway switching between minority and non-minority service stations was less than 15% in all cases. 7|Page

CTDOT 2022 Trásito SAFE analyzes 8|Page.

CTDOT 2022 Transit SAFE Analyzes Table 3 - NHL Waterbury Line - Impact Analysis Nonsense to Interval Changes Mid-Range Mid-Range Mid-Range NHL Waterbury Line - Interval Analysis Change: Non-Trigger Change: Minority Change* Minority Results Serving Impact? Serving Stations Stations Day of week AM Peak service South -2.12% -2.73% -0.61% N Day of week Service off-peak South -34.88% -34.80% 0.08% N AM Weekday North Off-Peak Service N/A N/A N/A N/A Weekday AM North Peak Service N/A N/A N/A N/A Weekday Noon Off-Peak Service the north -29.35% -29.57% -0.22% N Day of the week PM Peak service to the north -42.97% -42.31% 0.67% N Day of the week PM Off- Service north peak N/A N/A N/A N/A*A negative number indicates that the average gap reduction at minority service stations was less than the average gap reduction at non-minority service stations. **N/A indicates that there were one or the other or no trains during the identified peak and/or off-peak period and therefore no progress. Table 4 below displays the Triggered Impact Analysis results for station stop changes on the NHL Waterbury Line. There are four disparate impacts on station stop changes, as the variation in average stop increase between stations serving minorities and non-minorities was greater than 15% in these four cases: stop because a Stratford (which is a minority serving station) was missing, but stops were added at all other stations on the line. • Uneven impact created on AM OFF-PEAK northbound service for stop changes because a new stop was added to all stations on the line except Stratford (which is a minority serving station). • Uneven impact created on northbound PM PEAK service for stop changes because a new stop has been added to all stations on the line except Stratford (which is a minority serving station) and the existing stop at Stratford is missing. • Uneven impact created on northbound PM OFF-PEAK service for stop changes as the Stratford stop for this period is absent but all other stations have maintained their stop for this period. 9|Page

CTDOT 2022 Transit SAFE Analyzes Table 4 - NHL Waterbury Line - Impact Analysis Nonsense to Average Stop Changes Average Stop NHL Waterbury Line - Stop Analysis Change: Change: No Nonsense Variance Variance Minority Results Minority Serving Minority Serving Impact? Stations Stations Weekday Morning Peak Service South 12.50% 50.00% 37.50% Y Weekday Off-Peak Morning Service South 37.50% 50.00% 12.50% N Day of week North off-peak morning service 75.00% 100.00% 25.00% Y Weekday North peak morning service 0.00% 0.00% 0.00% N Weekday Noon Off-peak North Service 25.00% 33.33% 8.33% N Weekday PM North Peak Service 12.50% 50.00% 37.50% Y Weekday PM Off-peak hours peak Northern Service -25% 0% 25% Y Aggregate Rail System Table 5 displays the aggregate minority populations of each rail line's service territories compared to the minority populations of the total CTDOT rail system (including the Hartford Line) service territories aggregates. There are no disparate impacts on the Waterbury line, where major changes in service have occurred, as the line's minority population does not exceed the total population of the rail system's minority service territory by more than 15%. Table 5 – Comparison of Minority Population of Aggregate Rail System New Waterbury Danbury Shore New Hartford Total Rail Canaan Line East Haven Line Line System Branch* Branch Total Population Served 210,759 489,384 279,318 393,207 834,375 651,020 1,920,610 Minority Population Served 80,476 23 5.0 64 96,724 165,851 403,431 347,292 816,063% Minority Line 38.18% 48.03% 34.63% 42.18% 48.35% 53.35% 42.49%% TotalRail system variation -4.31% 5.54% - 7.86% -0.31% 5.86% 10.86% N/A*Please note that some stations are shared with multiple rail lines. Rail system total calculations only include the populations of the station service area once and are not the sum of the populations of each line. Serving. (See Table 6) 10 | Page

CTDOT 2022 Transit SAFE analyzes Table 6 - NHL Low Income Service Stations - Waterbury Line NHL Waterbury Line Low Income Service? Stations Waterbury Y Naugatuck N Beacon Falls N Seymour N Ansonia Y Derby-Shelton N Stratford Y Bridgeport Y Table 7 below displays the results of the Disproportionate Load Analysis for headway changes on the NHL Waterbury Line. There are no disproportionate charges, as the variation in the average change in headways between low-income and non-low-income service stations is not greater than 15% in any case. Table 7 - NHL Waterbury Line - Disproportionate Load Analysis for Headway Changes Medium Average Headway NHL Waterbury Line - Headway Analysis Disproportionate Change: Low Change: No variance* Results Load? Income Serving Low Income Stations Serving Stations Weekday AM Peak Service South -2.12% -2.73% -0.61% N Day of Week Off-Peak Service South -34.88% -34, 80% 0.08% N Weekday AM North Off-Peak Service N/A N/A N/ A N/D Weekday AM North Peak Service N/A N/A N/A N/A Weekday Mid -day Offpeak North Service -29.35% -29.57% -0.22% N Weekday PM North Peak Service -42.97% -42.31% 0.67% N Offpeak Service north afternoon peak hours N/A N/A N/A N/A*A negative number indicates that the average gap reduction at minority service stations was less than the average gap reduction at non-minority service stations. **N/A indicates that there were one or no trains during the identified peak and/or off-peak period and therefore no progress. Table 8 below shows the results of the Disproportionate Load Analysis for station stop changes on the NHL Waterbury Line. Similar to the disparate results of the impact analysis, there are four disproportionate burdens on station stop changes, as the variation in average stop change between minority and non-minority service stations was greater than 15% in these four cases: • Disparate impact created on the AM PEAK service to the south for stop changes because a stop at Stratford (which is a low-income service station) is missing, but stops have been added at all other stations on the line. 11 | Page

CTDOT 2022 Transit SAFE Analyzes • Uneven impact created on northbound AM OFF-PEAK service for stop changes because a new stop was added to all stations on the line except Stratford (which is a low-income station). • Uneven impact created on northbound PM PEAK service for stop changes because a new stop has been added to all stations on the line except Stratford (which is a low income station) and the existing stop at Stratford is missing. • Uneven impact created on northbound PM OFF-PEAK service for stop changes as the Stratford stop for this period is absent but all other stations have maintained their stop for this period. Table 8 - NHL Waterbury Line - Disproportionate Load Analysis for Stop Changes Medium Stop Medium Stop Change: Low Change: Non-NHL Waterbury Line - Stop Analysis Disproportionate Income Low Income Variation Results Load? Serving Stations Stations Weekday Morning Peak Service South 12.50% 50.00% 37.50% Y Morning Service Off-Peak Week South 37.50% 50.00% 12.50% N Weekday Morning off-peak service to North 75.00% 100.00% 25.00% Y Day of week Morning peak service to North 0.00% 0.00% 0.00% N Weekday Midday Off Peak North Service 25.00% 33.33% 8.33% N Weekday PM North Peak Service 12.50% 50.00% 37.50% Y Weekday PM Off of Peak Hour North Service -25% 0% 25% YAggregate Rail SystemTable 9 shows the aggregated low-income populations of the service territories of each rail line compared to the low-income populations of the total CTDOT rail system (including Hartford Line) aggregated service territories. There are no disproportionate charges on the Waterbury line, where major changes in services have occurred, as the line's low-income population did not exceed the total population of the rail system's low-income service territory by more than 15%. 12 | Page

CTDOT 2022 TRANSIT SAFE Analysis Table 9 - Comparison of low -income population Aggregate System New Newbury Danbury Shore Hartford Total Rail Canaan Haven Line of the East Line System* Total population served 209.609 482.424 274.240 372.510 812.480 620.511 1,864. 280L Low Injust served 27,142 118,539 35,174 86,149 168,513 157,463 374,132% Low Income Line 12.95% 24.57% 12.83% 23.13% 20.74% 25.38% 20.07%% Variation in the Rail System Total -7, 12% 4.50% -7.24% 3.06% 0.67% 5.31% N/A*Note that some stations are shared with multiple rail lines. Rail system total calculations only include the populations of the station service area once and are not the sum of the populations of each line. NHL Waterbury Rail Schedule Impacts and Alternatives Summary of impacts of changes in service Stations on Train Intervals of service changes made on Connecticut's NHL Waterbury rail system as per Table 3. However, there were technical findings of disparate impact across stations minority and non-minority service stations when including consideration of stops at Stratford in the specified time periods, as referenced in Table 4. No disproportionate burden was found on the average change in headways between low and non-low income service stations resulting from the changes in NHL Waterbury Summer 2022 service, as indicated in Table 7. A disproportionate burden was found for low income populations in service when considering Stratford stops on the summer 2022 NHL Waterbury Line in accordance with Table 8, based on established thresholds of CTDOT Title VI Security Policies. These are summarized in the table below. Table 10 - Uneven Impacts and Disproportionate Load Assessment Summary Disproportionate Service Line Service Disproportionate Impact Causes Burden NHL - Day of the Week Off Peak and Waterbury Peak Service to/from Y - Stops Y - Stops Stratford Bridgeport A Service Line The following section examines the causes of disproportionate loads and whether alternatives exist to avoid, minimize, or mitigate these disproportionate loads. Causes and alternatives for the NHL Waterbury Line 2022 service changes We note that for the NHL Waterbury Line 2022 service changes, the amount of service at Stratford exceeded the 15% variance in both disparate impacts between minority and non-minority populations and with disproportionate burden for low-income populations in the following weekday categories: 1.) Morning peak service to the south, 2.) Morning peak service to the north, 3.) Afternoon peak service to the north, and 4 .) PM to the north Off-peak service. 13 | Page

CTDOT 2022 Transit SAFE AnalyzesWeekday Stratford Service - StopsBackgroundThe NHL Waterbury Line service currently consists of 15 weekday trains, of which three stop in Stratford. Stratford is served by mainline trains at a level of service equivalent to other NHL mainline stations. Stratford's three stops are only listed on the weekday NHL schedule; Stratford is not included in the listed Waterbury weekend train timetable. Passengers originating from Stratford traveling towards the Peak (AM Peak westbound, PM Peak eastbound) would be unlikely users as this stop would require a train change at the next station. The Stratford stops are more likely to be the destination for Waterbury Line riders, or to connect trips from Milford and East, in both cases reducing backhaul for connecting trips. Historically, Waterbury Line Stratford stops have varied in number and position based on adjacent maintenance and construction programs, and special operating procedures have been used to accommodate passenger needs. During the 2020-2022 pandemic, large differences in train volumes and stopping patterns emerged, with the general direction on building on past service levels balancing out in line with new trends. The service rebuilding effort is ongoing and is expected to continue gradually over several years as many other factors such as workforce, equipment and ancillary issues affect the recovery of public transport. The absence of Stratford stops on the NHL Waterbury schedule is the only factor influencing the average stop reduction across minority and non-minority and low-income populations for services that technically exceed the range threshold. time for the convenience of the passenger. However, there are several additional options that support service between the Waterbury Line and Stratford without the addition of stops on Waterbury Line trains: Greater Bridgeport Transit (GBT) GBT service connects directly to Stratford and Bridgeport train stations and the train Derby-Shelton station on the Waterbury Line. From Derby-Shelton train station, two southbound AMPeak trains connect in less than 15 minutes to GBT bus route 23 to Stratford, and GBT 23 from Stratford connects to two northbound PM Peak trains at Derby-Shelton , with similar travel times compared to the train service . Whilst connecting to route 23 adds a few minutes difference in journey time, there is a wider choice of arrival times to and from Stratford, with midday service possible in both directions. This alternative downplays the Stratford Variation as a replacement option. Travelers on the Bridgeport-Stratford main line have another option in lieu of the Waterbury Line Stratford stops, using the return main line service between Bridgeport and Stratford. While this backhaul switch is less convenient, it does represent another travel option. Clearly there are options for dealing with the rail stop disparity through a variety of alternative journeys. 14 | Page

Alternatively, looking at Stratford's absence of stops, technical inequalities have three alternatives: 1) Monitor Ridership, respond to perceived service need; 2) Remediate, introduce an alternative measured remediation service; 3) Restore and add old Stratford stops at affected service periods. Monitor RidershipMonitoring ridership and meeting customer transportation needs is central to CTDOT's mission. meetings and equipment cycling, where a judicial approach to stopping the addition may be necessary. One of the first steps in studying passenger numbers between the Waterbury Line and Stratford came from a recent CTDOT survey where there was a response from one person who would consider traveling to Stratford from the Waterbury Line. Remedy The project team notes that there are several factors at work regarding Stratford Stops:1) Elimination of the three currently operated stops;2) Comparative inequalities in service levels that the other seven stations would enjoy;3) Data skew when attempting to remedy in new time periods. Given these three separate elements, a step-by-step approach could progress starting with retaining Stratford on the south peak AM and north peak PM and off-peak PM in the proposed summer 2022 timeframe. fully the disparate and disproportionate results, would serve to reduce the variation of the 15% limit. Another correction step would be to also add a Stratford stop to North AM Off-Peak. In this way, NHL Waterbury's proposed summer 2022 schedule would reduce the variance of more than 15% between minority and non-minority and low-income populations. Restore and add Another alternative would be to restore and add Stratford station stops to all NHL Waterbury Line trains. This would necessarily level the playing field for all seasons, for all minorities and non-minorities, and for all low-income populations, and would not create a disparate impact or disproportionate burden, as long as the 15% variation threshold is not crossed. . The real cautionary note is that adding stops to the schedule also means increasing travel time, which could pose a problem in operating the proposed new schedule for summer 2022. The experience with new trains, the operation of the new signaling system and expanded service seasoning may be required before adding stops. This could represent a CTDOT target for the larger redefinition of the NHL service now underway or for further enhancement of the NHL Waterbury Line service. 15 | Page