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, , physical address
LEP Languages: which languages must you translate
(See Language Assistance Plan, Four Factor Analysis)
How you assist LEP persons?
Website address for Title VI information
Sample in Appendix B of
FTA C B

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
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 rows of information

14. 5. Requirement: Public Participation Plan
Necessary to developing Language Assistance Plan, limited English proficient outreach
Seeking to determine how C B “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
B16001 for El Monte, California rows of information
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%)

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
Tip: You’ll want to understand what your agency does with federal funds and what is planned for future
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

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
Information needed:
Seated capacity of each vehicle type in fleet;
type of vehicle used on each type of service operated;
standee passenger policy.
Vehicle Load Standard:
Maximum ratio of total passengers to seated capacity by vehicle and service type.

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 B)
Chapter III for all agencies
Chapter III and IV for transit providers with fixed routes

36. Next Steps
Gather the materials/ information suggested by this Tool & C B 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?