After being rebuked by federal authorities, transit advocates, and state legislators for not completing a study of the impact of cutting late-night services on low-income and minority riders, the MBTA's Fiscal and Management Control Board seemed to have learned its lesson: as the board prepared to approve fare hikes on Monday, it had prepared no less than three “equity impact” studies.
But none of them, WGBH News has learned, addressed the final changes the board actually approved that day. Three days after that vote, the board has yet to complete such an analysis.
The apparent snafu was the result of last-minute tweaks to the fare changes, introduced during the board’s hearing on Monday. Seconds before the authorizing vote, board members were informed that they would need another, fourth impact study representing the new changes.
Rather than wait for that study to be concluded, the board voted to approve the changes “pending the completion and acceptance” of the new report, MBTA spokesperson Joe Pesaturo told WGBH News in an email.
Federal guidelines say that transit agencies are required to conduct and review such analyses for "proposed"—not already-approved—changes.
U.S. Federal Transit Administration officials did not return a request for comment by deadline. Pesaturo said in an email that the T “is complying with FTA regulations,” though he did not respond to a request to cite specific guidelines demonstrating that.
The news comes as the T's board is already facing criticism for having abandoned a similar equity analysis for the proposed cuts to late-night service, which had apparently suggested the cuts did have disproportionate impact on low-income and minority riders. On Wednesday, state Sen. Linda Dorcena Forry told WGBH's All Things Considered that she wanted the T's board "to just take a pause until this analysis is complete."
The board appeared to take the opposite approach to fare hikes, noted former state transportation secretary James Aloisi (who is an occasional contributor to WGBH News). Aloisi said the last-minute changes to the fare increase suggested a board rushing to conclude the new plan and, in the process, making “a hiccup that reminds us ... that government can’t and typically doesn’t work in a vacuum.” Aloisi added that the federal analysis requirement exists for a reason: “It highlights that public transportation is not just about mobility—it’s about social equity.”
Board member Brian Lang, who acknowledged that it was his own proposed amendments lowering certain bus fares and extending transfer discounts that changed the proposal, said he was "confident that the analysis will be more favorable” because the changes reduced fare increases.
But while that reasoning would seem self-evident, the equity impact analyses measure relative—not just absolute—impacts.
For example, one of the last-minute changes, a reduction of cash fare for bus rides by 12.5 percent, from $2.25 to $2.00—would affect relatively few minority or low-income riders, according to the T’s own studies. The same data shows that minority and low-income riders would benefit much more from a reduction to Charlie Card fares, which were also reduced on the day of the vote — but by 3 percent.