TO: Mayor and Members of City Council
THRU: Jay Reinstein, Assistant City Manager
FROM: Randy Hume, Transit Director
DATE: June 11, 2018
RE:
Title
Transit Title VI Program
end
COUNCIL DISTRICT(S):
Council District(s)
All
b
Relationship To Strategic Plan:
Goal 4: Desirable Place to Live, Work and Recreate
Objective D: To develop and maintain public transportation investments with high quality transit and airport services
Executive Summary:
The Transit Department is the recipient of federal transit grant funds, with numerous terms and conditions. Federal Transit Administration (FTA) requires grantees to update and submit for approval a Title VI program every three years. The City's/FAST's Title VI program update is due on June 1, 2018.
Title VI prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. FTA has reduced reporting requirements for smaller transit systems and grantees like FAST operating less than 50 peak period buses in recent years. Due to confusion between Title VI which is part of the Civil Rights Act of 1964 and Environmental Justice (EJ) which was initiated by Executive Order, FTA separated the two closely related program. EJ is more focused on capital projects and provides protections for low-income as well as minority populations. The plan also addresses limited English proficiency (LEP).
The attached program update has few changes since the 2015 program was approved.
City Council's approval of the program update is requested for submission to FTA.
Background:
Title VI of the Civil Rights Act of 1964 protects individuals from discrimination based on race, color, or national origin in programs or activities that receive federal financial assistance. Title VI also includes provisions to ensure access to FTA funded programs for persons who have limited English proficiency (LEP). The program is an organizing framework by which the City and FAST will incorporate equity consistently across its programs, policies and services that allow everyone to participate and enjoy the benefits of the FAST transit system.
FTA’s Title VI circular provides detailed guidance to FTA funding recipients on how to comply with DOT's Title VI regulations. The program requires careful evaluation of new facilities, creation of service standards for all fixed route bus operators, approval of the Title VI program by its governing body, a demographic analysis of citizen advisory committees (i.e., FACT), and use of environmental justice principles in public outreach.
FAST has prepared the attached update for the 2018-2021 Title VI Program. This program was developed in accordance with FTA's Title VI Circular 4702.1B, "TITLE VI REQUIREMENTS AND GUIDELINES FOR FEDERAL TRANSIT ADMINISTRATION RECIPIENTS" and Environmental Justice Circular 4703.1A "Environmental Justice Policy Guidance for Federal Transit Administration Recipients."
The objective of this Title VI program update is to summarize FAST's efforts to promote equity in transit in compliance with Title VI of the Civil Rights Act of 1964. FAST used 2015 and 2016 American Community Survey data to determine the proportion of minority populations within FAST's service area, low-income populations, and limited English proficient populations. Demographic analysis shows:
• More than half of the service area (60.87%) is minority;
• More than twenty-percent (21.8%) of households are identified as low-income; and
• The total of limited English proficient populations 6,862 with Spanish consisting of 47.39% (3,252) of the total LEP.
The following program elements are also included in the plan although there is currently no activity:
• A list of Title VI investigations, complaints and lawsuits (no complaints filed);
• Monitoring program for subrecipients; and
• An equity analysis of facilities siting and construction (no new major facilities planned).
The Title VI Program notice is posted at FAST facilities and on the FAST website along with clear guidance on how one may submit a Title VI complaint.
The Title VI Plan program update incorporates FAST's service standards and policies adopted by the City Council on August 12, 2013. These standards and policies provide benchmarks to ensure that service design and operations practices do not result in discrimination. The standards include vehicle loads, vehicle headways, on-time performance, and service availability. Service policies also address amenity placement and vehicle assignment. They establish a basis for future monitoring and analysis of service delivery, availability, and the distribution of amenities and vehicles to determine whether or not any disparate impacts are evident.
This program shows FAST's commitment to ensuring its programs, policies, and services are implemented equitably.
Issues/Analysis:
Since the 2015 program update FAST has added grant subrecipients or other agencies to whom the City/FAST may pass-through FTA grant funds. FAST has established procedures to ensure these agencies comply with Title VI grant provisions.
Budget Impact:
Cost to administer are included in planning grant project budgets.
Options:
Approve the Resolution approving the Title VI Program Update for submission to FTA; or
Provide direction to staff for Title VI program changes.
Recommended Action:
Approve the Resolution approving the Title VI Program Update for submission to FTA
Attachments:
Title VI Program Update 2018-2021
Resolution