TMD, in association with Arc Solutions, completed a Title VI Fare Equity Analysis to analyze the potential impact of not charging a fee for Clipper® mobile cards and keeping the plastic Clipper® card fee at $3.00. The main question the team sought to answer is whether the fee differential will disproportionately impact minority and low-income Clipper® card customers. To complete the analysis TMD analyzed data from the 2022 MTC Clipper® Customer Address-Based Sampling (ABS) Survey conducted by MTC in early 2022. TMD collected Title VI policies from the major Bay Area operators (AC Transit, BART, Caltrain, Golden Gate, SamTrans, SF Muni, and VTA). TMD applied these agencies’ Disparate Impact Thresholds and Disproportionate Burden Thresholds to the analysis of the survey results to determine if the fee differential will disproportionately impact minority and low-income Clipper® card customers. As part of the project, TMD also conducted a peer review of agencies who offer both a mobile fare payment option and a plastic card. TMD also participated and led several virtual workshops with MTC staff and representatives from the major Bay Area operators, sharing findings from the peer review and Title VI analysis. The Title VI Analysis and Final Report was submitted to MTC in December 2022.