Diving Into Your Title VI Program

1. Diving Into Your Title VI Program Preparing a Title VI Program for Transit Providers Operating Fewer than 50 Vehicles and Not in a UZA of 200,000

2. What Are We Talking About Today? Title VI Program Components Introductions Caltrans Due Date Working through the Preparing Title VI Program Tool Questions & Homework Reminder

3. 1. Requirement: Title VI Notice to the Public Information needed: • Where/Who receives Title VI complaints, and answers Title VI questions? • Need phone number, email, physical address • LEP Languages: which languages must you translate • (See Language Assistance Plan, Four Factor Analysis) • How you assist LEP persons? • (See Language Assistance Plan, Four Factor Analysis) • Website address for Title VI information • Sample in Appendix B of • FTA C 4702.1B

4. 2. Requirement: List of Locations Where Title VI Notice Is Posted Information needed: • Where will you post your notice? • Suggested locations: public spaces in your office/headquarters; bus shelters; on buses. • Must be posted on your website

5. 3. Requirement:Title VI Complaint Procedures & Complaint Form Information needed: • Where/Who receives and investigates Title VI complaints? • Need physical address to mail or submit complaint form in person. • Samples in Appendix C and D of FTA C4702.1B • Translation requirements (See Language Assistance Plan, Four Factor Analysis)

6. 4. Requirement: Transit-Related Title VI Complaints Information needed: • Have any public transit related Title VI investigations, complaints or lawsuits been filed with your agency? • If yes, list: date filed, summary of allegations, status, actions taken by recipient of final findings. • Sample in Appendix E of FTA C4702.1B

7. 5. Requirement: Public Participation Plan Information needed: • Demographic analysis (See Language Assistance Plan, Four Factor Analysis) • Who are the minority, LEP, and traditionally underserved populations in your service area that should be targeted through proactive outreach? • What kinds of projects does your agency undertake? • Do public participation efforts vary based on project type? • Resources include FTA Environmental Justice Webpage and www.LEP.gov • Goals: • Promote INCLUSIVE public participation • Engage minority, LEP, and traditionally UNDERSERVED populations • PROACTIVE strategies

8. 5. Requirement: Public Participation Plan Homework assignment: Demographic analysis 1. Define your service area 2. Identify service area population 3. Identify LEP populations within your service area • #1. is a local decision • #2 and #3 is a Census activity

9. 5. Requirement: Public Participation Plan US Census American Fact Finder Go to Fact Finder: FactFinder2.census.gov

10. 5. Requirement: Public Participation Plan • Go to Advanced Search • Show Me All

11. 5. Requirement: Public Participation Plan • Enter Topic or Table Name: • Topic - Language • Table Name – B16001: Language Spoken At Home By Ability To Speak English for the Population 5 Years and Over

12. 5. Requirement: Public Participation Plan • Select B16001: 1 year, 3 year, 5 year estimates, American Community Survey (ACS) ACS 1 year – most current. Good for large, urban areas. ACS 5 year – most reliable. Best for small, rural areas.

13. 5. Requirement: Public Participation Plan B16001 for El Monte, California - 119 rows of information

14. 5. Requirement: Public Participation Plan • Necessary to developing Language Assistance Plan, limited English proficient outreach • Seeking to determine how C. 4702.1B “Safe Harbor provision” applies re translation of vital documents [Chapter III-9 (c)] - 5% or 1,000 persons speaking English “less than very well”

15. 5. Requirement: Public Participation Plan • Total population – 105,751 persons • Spanish or Spanish Creole • Speak English less than “very well” - 32,999 • (31%) • Chinese • Speak English less than “very well” – 10,854 • (10%) • Vietnamese • Speak English less than “very well” – 5,103 • (5%) B16001 for El Monte, California - 119 rows of information

16. 5. Requirement: Public Participation Plan City of El Monte • Three languages meet the 5% or 1,000 persons threshold • Spanish • Chinese • Vietnamese Will require written translation of vital documents

17. 6. Requirement:Summary of Outreach Efforts Information needed: • List/summary of any outreach efforts made • What outreach do you undertake: • Annually? • For specific projects? • At specific locations: senior centers, schools, military bases, etc.? • Tip: • Consider starting with this step to develop your Public Participation Plan.

18. 7. Requirement:Language Assistance Plan • Goals: • Ensure MEANINGFUL ACCESS to your services, programs, benefits, activities etc. for LEP persons • AVOID engaging in discrimination on basis of language, race, national origin. Required Elements: • Results of four factor analysis • How you provide language assistance by language • How you provide notice of language assistance to LEP persons • How you monitor, evaluate, update the LAP • How you train employees to provide language assistance

19. 7. Requirement:Language Assistance Plan Where to start: • Factor One • Complete the homework assignment • Factors Two and Three • Survey staff of your agency on previous interactions and experience with LEPs • Develop LEP outreach approach • Where can LEPs access your services • Where are LEPS in your community? • Best way to engage with LEPs? • Interview community agencies that work with LEPs • Conduct outreach Tip: Develop your plan using strategies that work best for your community

20. 7. Requirement:Language Assistance Plan Tip: • The Notice to the Public can work as a tool for promoting your language assistance program • What are other cost-effective ways of reaching your LEP communities? Where to start: • Factor Four • Inventory the outreach methods and strategies you’ll use for outreach • Look at your Public Participation Plan • Inventory additional resources available to you • Cost out strategies, methods, and resources • Do you have an existing budget for outreach/marketing?

21. 7. Requirement:Language Assistance Plan Where to start: • Who/Which department is responsible for implementation? • What are you doing now to respond to LEPs? • What did you learn from the 4 factor analysis? • Is language a barrier to access & how will you address this? Required Elements: • How you provide language assistance by language • How you provide notice of language assistance to LEP persons • How you monitor, evaluate, update the LAP • How you train employees to provide language assistance

22. 8. Requirement: Table Depicting the Membership of Non-Elected Committees And Councils Information needed: • Do you have any non-elected committees, TAG’s, councils? • Sample in Appendix F of FTA C4702.1B

23. 9. Requirement: Subrecipient Assistance and Monitoring Information needed: • Does your agency have any subrecipients? • Do you pass FTA funds or vehicles to any non-profits, social service agencies, etc. • Do you have MOU’s with any organizations? • What is the nature of these agreements Tip: You’ll want to understand what your agency does with federal funds and what is planned for future

24. 10. Requirement:Title VI Equity Analysis Information needed: • Has your agency determined the site for a new facility? • Facility may include: storage and maintenance facilities and operation centers • If so, what studies were undertaken during the planning stages? • Any new site planned for near future? Goals: • Avoid DISPARATE TREATMENT • Avoid ADVERSE IMPACTS

25. 11. Requirement: Board Approval of Title VI Program Information needed: • When does this need to go before the Board/City Council, etc. to be submitted by June 30, 2014 • Develop timeline backwards from date Title VI Program needs to be completed • Can submit a resolution, meeting minutes etc. from governing body

26. 12. Requirement: System-Wide Service Standards and Policies Vehicle Load Standard: • Maximum ratio of total passengers to seated capacity by vehicle and service type. Information needed: • Seated capacity of each vehicle type in fleet; • type of vehicle used on each type of service operated; • standee passenger policy.

27. 12. Requirement: System-Wide Service Standards and Policies Vehicle Headway Standards: • Minutes between buses on a route headed in the same direction by type of service, by weekday/Sat/Sun, peak/off-peak, day/evening/night. Information needed: • System schedules; • local definition of peak and off-peak hours; • system service policies; • current vehicle load factors by route and time.

28. 12. Requirement: System-Wide Service Standards and Policies On-Time Performance Standard: • Statement of minimum acceptable actual vehicle arrival times versus schedule by line, route and service type. Information needed: • System definition of “on-time” performance by service type (dial-a-ride, • local fixed route, commuter or express, etc.); • current on-time performance data by service type; • system policies regarding on-time performance.

29. 12. Requirement: System-Wide Service Standards and Policies Service Availability Standard: • Statement of planning goal for population proximity to fixed route bus or rail service. Also planning goal for distance between bus stops by type of service. Information needed: • Count or estimation of current population within ¼ mile of a fixed route bus line or ½ mile of rail service; • average distance between fixed route bus stops by service type (e.g. local versus express).

30. 12. Requirement: System-Wide Service Standards and Policies Service Availability Standard: • Transit’s ¾ mile sphere of influence • 100% of total population within ¾ mile of fixed route

31. 12. Requirement: System-Wide Service Standards and Policies Vehicle Assignment Policy: • Statement of how vehicle fleet will be assigned to depots, routes and service types to ensure an equitable use across system within constraints of service requirements and restrictions imposed by operating conditions. Information needed: • Bus fleet information including vehicle length, capacity, year of manufacture, air conditioning, low floor or other notable differences in amenities; • any requirements or restrictions in type of bus that can be operated on certain routes or services; • existing vehicle assignments by service depot/operating base (if more than one depot or base).

32. 12. Requirement: System-Wide Service Standards and Policies Transit Amenities Policy: • Statement of how transit amenities will be installed among bus and rail routes to ensure equitable distribution of such amenities across the system. • Transit amenities are items of comfort, convenience, and safety such as benches, shelters, trash cans, information materials, electronic signage, transfer centers, and such. Information needed: • Listing of existing and planned transit amenities under control of transit provider; system policies regarding amenities.

33. Next Steps - Workshops San Diego Los Angeles Monday, May 19th– Pre CalACT Conference Thursday, June 1st– Access Services, Los Angeles

34. Next Steps Homework assignment: Demographic analysis 1. Define your service area 2. Identify service area population 3. Identify LEP populations within your service area • #1. is a local decision • #2 and #3 a Census activity

35. Next Steps For the Workshop • Print the regulations • Do the demographic homework assignment • Bring laptop for working • Bring past/existing plan, work in progress, etc. • Title VI Guidelines: • (FTA C 4702.1B) • Chapter III for all agencies • Chapter III and IV for transit providers with fixed routes • http://www.fta.dot.gov/documents/FTA_Title_VI_FINAL.pdf

36. Next Steps Gather the materials/ information suggested by this Tool & C4702.1B requirements: • Notice • Locations • Complaint Procedures • Title VI Complaints • Public Participation Plan • Outreach summary 7. Language Assistance Plan 8. Non-Elected Committee Membership 9. Subrecipient Monitoring 10. Title VI Equity Analysis 11. Board/ City Council Approval 12. System-Wide Standards and Policies

37. Next Steps QUESTIONS?