An MBTA-commissioned report—one the T dragged its feet completing until after announcing it would end late-night service—shows cutting that service will have a disproportionate impact on low-income and minority riders.

The T's Fiscal and Management Control Board was presented with new findings Wednesday indicating that those groups would, in fact, experience a “disparate” or “disproportionate” burden from the cuts. The findings were just one piece of a marathon session of hearings in which the board was presented with a preliminary budget for the agency's fiscal year 2017, which incorporates the cuts to late-night service, fare increases, and myriad other efforts to reduce the agency's overall operating deficit to zero by the end of December 2017.

The so-called equity impact analysis is a study required in major policy changes by federal civil rights regulations aimed at protecting vulnerable communities from major changes to transportation policies. The regulations require transit officials to determine whether such changes would have undue impact on those communities and, if so, examine alternative or mitigating changes.

Board officials had commissioned two such studies, one looking at the board's proposal to cut late-night service, the other at the board's proposed increases in fares across the system. A draft presentation created by T staff had apparently indicated that cuts to late-night service would, in fact, impact minority and low-income riders more than all riders in general.

But that study was never formally presented to the board. Instead, MBTA officials decided the study wasn't required, and dismissed the initial findings of disparate impacts “incomplete.” The board voted unanimously to approve the cuts.

Now, the new impact study, commissioned after Federal Transit Administration officials warned that the study was required, would seem to confirm that minority and low-income riders will indeed be impacted disproportionately if late-night service is cut—and by margins greater than previous indications suggested.

Minority riders and low-income riders, according to the report, make up 54 percent and 64 percent of late-night bus ridership, respectively—significantly higher numbers than is true during regular hours.

When it comes to late-night train ridership, the figures are more stark: Minority riders make up 47 percent of late-night train ridership, versus 29 percent during regular hours; and 59 percent of late-night train riders are low-income, versus 24 percent during regular hours.

MBTA General Counsel John Englander, while taking issue with the study's methodology and results, nonetheless told the board Wednesday that T staff was recommending “moving forward to consider and provide for mitigation.”

What such a plan would look like, how much it would cost, and to what extent it would bite into the anticipated $9 million in savings that were the ostensible rationale for eliminating late-night service in the first place is not immediately clear.

What was clear was that there is little appetite for mitigating that impact with rail service. Among six initial suggestions T staff made to the board was that “we would intend to provide mitigation service only with bus, and not to provide any additional rail service, whether peak or off-peak.”

Board Chair Joseph Aiello agreed, asking if language could be incorporated into a resolution specifying that “the intention here is preserve bus, rather than use any rail assets.”

Board member Monica Tibbits-Nutt, seemingly concerned with the findings, suggested that the board “really look at what the needs are for the populations that have been asking for the service at night.”

“And if we're going to do a [late-night] pilot again,” Nutt added, the board should “really have a much better understanding than I think we've had, historically, of whether the MBTA should be in the business of providing late-night service.”