Transit Authority of River City Louisville, KY. TITLE VI Program Update 2013

Transcription

1 Transit Authority of River City Louisville, KY TITLE VI Program Update 2013 Prepared by Transit Authority of River City October 2013

2 Contents 1. Program Introduction... 4 General Requirements: 2. Notice to the Public Complaint Procedures Public Participation Plan Language Assistance Plan (LEP) Non-Elected Committees & Councils Monitoring of Sub-Recipients Equity Analysis of Facilities Board Approval of Title VI Program Requirements of Transit Providers: 10. Major Service Change & Impact Policies Service Standards Service Policies Appendixes: Appendix A) Demographic & Service Profile Maps & Charts Appendix B) Summary of Service and Fare Equity Analysis Appendix C) LEP Four Factor Analysis Appendix D) Public Engagement Process Appendix E) Summary of Outreach Efforts Appendix F) Title VI Complaint Monitoring Appendix G) Title VI Complaint Form Appendix H) On-Board Survey (Demographic Ridership/Travel Patterns) Appendix I) Frequently Used Acronyms TARC 2013 Title VI Program Update 2

3 TARC 2013 Title VI Program Update 3

4 1. Program Introduction Urban transit systems in most American cities have become a genuine civil rights issue and a valid one because the layout of transit systems determines the accessibility of jobs to the black community. If transportation systems in American cities could be laid out so as to provide an opportunity for poor people to get to meaningful employment, then they could begin to move into the mainstream of American life. 1 - Dr. Martin Luther King Jr.,1967 TARC s Title VI program has been revised to comply with FTA Circular C B dated October 1, 2012 and ensures the fair dispersal of facilities and transit services throughout the service area. During 2013, the agency implemented new procedures and policies intended to augment its compliance with Title VI and improve accountability for service provision to minority populations. New elements of the program include a Major Service Change Policy, Disparate Impact Policy, Disproportionate Burden Policy and Public Involvement and Board Approval of TARC s Title VI Program. The Transit Authority of River City (TARC) receives Federal financial assistance to provide transit services. Federal funding is received in accordance with Chapter 53 of title 49 of United States Code, as amended by MAP-21. As a recipient of these funds, TARC complies with the Regulations relative to nondiscrimination in federally assisted programs of the Department of Transportation, Title 49, Code of Federal Regulations, Part 21, as they may be amended from time to time (hereinafter referred to as the Regulations). TARC has a service area population estimated at 798,591 and is required to submit Title VI update. Title VI refers to Prohibitions Against Discrimination in Federal Programs. TARC is committed to the following: 1. Ensure that the level and quality of transit service is provided without regard to race, color, or national origin; 2. Identify and address, as appropriate, disproportionately high and adverse human health and environmental effects, including social and economic effects of programs and activities on minority populations and low-income populations; 3. Promote the full and fair participation of all affected populations in transit decision making; 4. Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low-income populations; 5. Ensure meaningful access to programs and activities by persons with limited English proficiency. 1 James Melvin Washington, ed. A Testament of Hope: The Essential Writings and Speeches of Martin Luther King, Jr. TARC 2013 Title VI Program Update 4

5 2. Notice to the Public The following statement shall be posted at TARC s Customer Service Center and on the TARC website ( and other appropriate materials made available to the public: (Documents will be translated into languages other than English or furnished in accessible materials as needed upon request.) Non-Discrimination - Your Rights Under Title VI of the Civil Rights Act of 1964 The United States Department of Transportation (DOT) ensures full compliance with Title VI of the Civil Rights Act of 1964 by prohibiting discrimination against any person on the basis of race, color or national origin in the provisions of benefits and services resulting from federally assisted programs and activities. Any person, who believes that TARC has violated his /her Title VI protections, should contact TARC at or sfuqua@ridetarc.org. TARC has also developed a number of items to assist individuals who have Limited English Proficiency (LEP). Translation services in order to assist individuals who have Limited English Proficiency shall be made available to customers upon request. TARC s Title VI policy, complaint procedures and LEP Plan shall be made available upon request by contacting the TARC Planning Department at the above-noted information. For federal Title VI information please contact the Federal Transit Administration (FTA), Region 4 at (404) Federal Title VI information, including filing complaints, can also be accessed on the FTA web site at: Title VI Information, Limited English Proficient (LEP) information and Complaint Process (for printed materials, website, and other mediums upon request) TARC grants all citizens equal access to all its transportation services. It is further the intent of TARC that all citizens are aware of their rights to such access. The following information is designed to serve as an educational tool for citizens so that they may understand their civil rights laws, specifically, as it relates to Title VI of the Civil Rights Act of What is Title VI? Title VI is a section of the Civil Rights Act of 1964 requiring that No person in the United States shall on the grounds of race, color or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. Note that Title VI does not address gender discrimination. It only covers race, color and national origin. Other Civil Rights laws prohibit gender discrimination. TARC 2013 Title VI Program Update 5

6 What is LEP? As part of Title VI requirements, TARC has developed materials and information for persons with Limited English Proficiency (LEP) to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to TARC services as required by Executive Order Improving Access to Services for Persons With Limited English Proficiency,'' reprinted at 65 FR (August 16, 2000). A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English. TARC s Complaint and Investigation Procedures These procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, for alleged discrimination in any program or activity administered by TARC. TARC 2013 Title VI Program Update 6

7 3. Complaint Procedures The Transit Authority of River City (TARC) grants equal access to its programs and services to all citizens. This document serves to make citizens aware of their rights to such access, and serves to educate citizens so that they may understand the civil rights laws that protect their receipt and benefit of such services as defined by Title VI of the Civil Rights Act of Any person who believes they have been discriminated against on the basis of race, color or national origin by TARC may file a Title VI complaint by completing and submitting the agency s Title VI Complaint Form. These procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964 for alleged discrimination in any program or activity administered by TARC. These procedures do not deny the right of the complainant to file formal complaints with other state or federal agencies or to seek private counsel for complaints alleging discrimination. Every effort will be made to obtain early resolution of complaints at the lowest level possible. The option of informal mediation meeting(s) between the affected parties and TARC may be utilized for resolution. Any individual, group of individuals or entity that believes they have been subjected to discrimination prohibited under Title VI and related statutes may file a complaint. 1) A formal complaint must be filed within one-hundred eighty (180) days of the alleged occurrence. Complaints shall be in writing and signed by the individual or his/her representative, and will include the complainant s name, address and telephone number; name of alleged discriminating official, basis of complaint (race, color, national origin), and the date of alleged act(s). A statement detailing the facts and circumstances of the alleged discrimination must accompany all complaints. A TARC Title VI complaint form can be found at the end of this document. TARC encourages individuals to submit Title VI complaints in writing using this form and mailing it to: Title VI Coordinator Transit Authority of River City 1000 W. Broadway Louisville KY ) In the case where a complainant is unable or incapable of providing a written statement, a verbal complaint of discrimination may be made to TARC s Title VI Coordinator. Under these circumstances, the complainant will be interviewed, and the Title VI Coordinator will assist the complainant in completing a written statement. 3) When a complaint is received, the Title VI Coordinator will provide written acknowledgment to the Complainant, within ten (10) business days by registered mail. TARC 2013 Title VI Program Update 7

8 4) If a complaint is deemed incomplete, additional information will be requested, and the Complainant will be provided sixty (60) business days to submit the required information. Failure to do so may be considered good cause for a determination of no investigative merit. 5) Within fifteen (15) business days from receipt of a complete complaint, TARC will determine its jurisdiction in pursuing the matter and whether the complaint has sufficient merit to warrant investigation. Within five (5) days of this decision, the Executive Director of TARC or his/her authorized designee will notify the Complainant and Respondent, by registered mail, informing them of the disposition. a. If the decision is not to investigate the complaint, the notification shall specifically state the reason for the decision. b. If the complaint is to be investigated, the notification shall state the grounds of the authority s jurisdiction, while informing the parties that their full cooperation will be required in gathering additional information and assisting the investigator. 6) When TARC does not have sufficient jurisdiction, the director or his/her authorized designee will refer the complaint to the appropriate local, state or federal agency holding such jurisdiction. 7) If the complaint has investigative merit, the Executive Director or his/her authorized designee will instruct the Title VI Coordinator to fully investigate the complaint. A complete investigation will be conducted, and an investigative report will be submitted to the director within sixty (60) days from receipt of the complaint. The report will include a description of the incident, summaries of all persons interviewed, and a finding with recommendations and proposed resolution where appropriate. If the investigation is delayed for any reason, the Title VI Coordinator will notify the appropriate authorities, and an extension will be requested. 8) The director or his/her authorized designee will issue letters of finding to the Complainant and Respondent within ninety (90) days from receipt of the complaint. 9) If the Complainant is dissatisfied with TARC s resolution of the complaint, he/she has the right to file a complaint with: Kentucky Commission on Human Rights 332 W Broadway # 700 Louisville, KY or- TARC 2013 Title VI Program Update 8

9 Civil Rights Compliance Officer FTA Region IV 230 Peachtree, NW Suite 800 Atlanta, GA Telephone (404) Fax (404) A summary of TARC s monitoring program and complaints received from is shown in Appendix F. A copy of TARC s Title VI Complaint Form is shown in Appendix G. TARC 2013 Title VI Program Update 9

10 4. Public Participation Plan Introduction/Background The following plan reflects and expands on TARC s longstanding commitment to proactive, continuous and diverse public engagement throughout TARC s five-county, two-state service area. For more than a decade, TARC has provided extensive public engagement in the decision-making process involving major fare and service change proposals. Efforts include engagement and participation of low income, minority and LEP populations. Meetings have been held in areas of potential impact. A variety of communications tools and comment opportunities in languages other than English have been provided under this policy in effect since at least (See Appendix E) With a new Title VI plan including Major Service Change policies adopted in 2013, TARC has updated its Public Involvement and Participation Plan with a focus on more communications and feedback including with minority, low income and LEP populations. Goal Achieve ongoing, meaningful public involvement and participation and ensure decisions impacting policies, fares and service reflect community needs and desires with fairness and equity. Strategies/Objectives Provide continuous opportunities for public engagement about TARC services including the identification of social, economic and environmental impacts of proposed decisions Engage a variety of socioeconomic, ethnic, and cultural perspectives, including minority, low income and LEP populations. Partner with diverse representatives and community based organizations - elected officials, neighborhood organizations, faith-based groups, civic and business organizations - and others to help build awareness and encourage participation. Provide materials and comment opportunities that meet the cultural and language preferences of individuals and communities Ensure that opportunities to participate are physically, geographically, linguistically and culturally accessible. Use a variety of communications tools, meeting formats and locations, community forums, surveys, social media and other tactics to engage the public about any aspect of TARC, to inform about proposals or developments, and to receive feedback. Provide flexibility and change methods as needed. Present information about issues and proposals so that the significance and potential impact is understood. Clearly identify and communicate when, where and how participants can have influence in the decision-making process. TARC 2013 Title VI Program Update 10

11 Respond and incorporate appropriate public comments into decision-related documents and communicate the public input results to participants, other audiences and the public. Communications Methods TARC actively engages with individuals, communities and the public on an ongoing basis in a variety of ways. Many of these tools are used, with enhanced efforts including community events and TARC-hosted meetings, to circulate information and receive feedback when a major service or fare change is proposed. (See Appendix D) TARC provides information and receives input through a variety of methods including: Web site/social media Visitors can comment from a link on the homepage at Continuous commentary and updates are also provided through Twitter and Facebook. Online tools feature access to translation software for LEP populations. Community and Public Events - TARC presents information and takes comments by participating in a variety of public venues and neighborhood events including the Kentucky State Fair, Job Fairs throughout the community, and neighborhood festivals and meetings. These include the Americana Festival, sponsored by a community-based organization that serves LEP populations, and others serving low income and minority populations. Community Based Organizations (CBO) TARC works with a variety of CBOs including ethnic cultural centers; churches and faith-based organizations; geographic-specific groups such as neighborhood and community groups; civic and business organizations; universities, colleges and other schools including those providing English as a Second Language programs; service providers for children, youth, families and people with disabilities; recreational; environmental; and youth and senior-oriented organizations. The Louisville Metro Housing Authority, Americana Community Center and The Homeless Coalition are among the many CBOs that TARC has ongoing, close working relationships. TARC also works closely with a TARC Accessibility Advisory Council (TAAC) whose members have accessibility needs due to lifefunction impairments. The Council has served in an advisory capacity and as an information resource regarding accessible public transportation needs to TARC for over 25 years E-newsletter Nearly 8,400 subscribers receive notices and updates including about major service and fare change proposals. TARC 2013 Title VI Program Update 11

12 News releases An extensive media list is used for distributing information and soliciting input. The list includes media whose audiences are predominately minority populations. Elected officials and CBOs are also on the news release distribution list. Interior and Exterior Bus Advertisements Interior bus cards and rider alerts Bus Shelter advertisements/notices Flyers at CBOs/other locations and in languages other than English when needed or requested Print, electronic and online advertising including media that reaches low income and minority populations IVR customer service phone line Information in both English and Spanish including announcements about service and fare change proposals and when and how to provide input. It is TARC s practice to respond to every comment, using the same communications method used by the person who contacted TARC Public Engagement and Participation Process for Major Fare and Service Change proposals TARC continuously analyzes community service needs, ridership and continuous input and comments from the public when considering service changes. Multiple notifications and feedback techniques are used including e-blast, news release, website and social media and a rider alert on board all buses. Information clearly and in detail describes the proposed changes, with maps, public meeting times and locations. Other methods of obtaining information and providing comment , social media, phone, mail are also clearly described. All information notes that reasonable accommodations including information in an alternative format will be provided for individuals with disabilities and that language translators will also be provided upon request. TARC also provides materials in languages other than English upon request. TARC 2013 Title VI Program Update 12

13 TARC staff works with CBOs and others to identify the specific language services that community members may need. When TARC is hosting public meetings in a particular geographic area with a known, significant LEP population, the following is done: Meeting notices are produced and distributed according to the language translation encouraging community members to participate. In addition, participants can request interpreter services 48 hours in advance of a meeting, if needed. The services are provided for a fee by area organizations such as Catholic Charities and Kentucky Refugee Ministries TARC provides at least one qualified interpreter at these meetings who is fluent in the designated LEP language(s). The metro area has a number of citizens with vision and hearing impairments. TARC engages interpreter services from the Center for Accessible Living for people with hearing impairments. TARC seeks the advice from the Kentucky School for the Blind for enhancing materials for people with vision impairments At a minimum, at least one public meeting is held, with at least two weeks advance notice, when major service or fare changes are proposed. Every effort is made to hold public meetings at locations impacted by the proposed changes and at a variety of times. Meetings are held in accessible locations. TARC-hosted meeting formats are tailored to the audience and type of proposed change being made. At a minimum TARC staff provides written materials and explains the proposed changes and attendees have opportunity to make oral or written comments. In cases of major route change proposals, TARC provides surveys to attendees and through other communications to receive specific information about potential impacts of proposals and provides opportunity for making other comments and requests. TARC staff prepares a written summary of meeting and other comments including recommended changes to the proposed action based on the feedback. This summary is provided to the TARC Board of Directors for discussion and consideration before the adoption of fare increases or decisions relating to service changes. Summary of Recent Public Involvement and Participation Since the 2009 Title VI plan update, TARC has proposed two fare increases and five service changes, hosting 26 public meetings which were held throughout the community and in neighborhoods with low income and minority populations. A total of 570 people attended meetings hosted in business, minority, faith based and ethic venues. Public Involvement Summaries (Appendix E) from 2010, 2011, 2012 and 2013, document efforts and responses and include a report on the recent Title VI Proposed Service and Fare Change Policies. TARC 2013 Title VI Program Update 13

14 All meetings held were accessible by TARC fixed and paratransit service and supported by translation and interpretive services at the location if there was a need or request. In addition to comment opportunities, written surveys solicited specific feedback. Meeting locations have included local library branches, YMCA facilities, local school or Metro area colleges, places of worship, community centers, fire stations, government centers, small city town halls, Metro parks and others. Before the TARC Board of Directors adopted TARC s Title VI Proposed Service and Fare Change Policies, a public comment period was held from April 22-May 17, Information, including the draft policies, was circulated through a news release widely distributed to local elected officials, business community, neighborhood and community organizations, academic centers, the news media and LEP and ethic media and organizations. The IVR phone system notified callers in Spanish and English versions of the comment opportunities. Prominently displayed information was on TARC s website homepage where Google translation is accessible. An e-blast notification went to more than 8,000 subscribers. Twitter and Facebook notices were also posted. Comments could be made by phone, , letters, TARC website and through Twitter and Facebook. Information was also available at TARC s Nia Center customer service hub in a predominately minority neighborhood and at TARC s customer service center at TARC s headquarters. Performance Measures TARC monitors and tracks participation methods and makes adjustments in communications tools, meeting formats and other efforts based on experiences. TARC also looks for new ways to communicate and to gain input to improve public participation and provide service that is fair and equitable. TARC 2013 Title VI Program Update 14

15 5. Language Assistance Plan The Transit Authority of River City (TARC) has developed a Limited English Proficiency Plan (LEP) to help identify reasonable steps to provide language assistance to people with limited English proficiency who are seeking meaningful access to TARC services as required by Executive Order A person with Limited English Proficiency is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English. This plan elaborates on activities that TARC staff undertake to improve methods to provide meaningful access and understanding of services. It also explains procedures on how staff can identify a person who may need language assistance, the ways in which assistance may be provided; training staff, how to notify LEP persons that assistance is available, and information for future plan updates. In developing the plan, TARC undertook a U.S. Department of Transportation four factor LEP analysis which considers the following: 1) The number or proportion of LEP persons eligible in the TARC service area who may be served or are likely to encounter a TARC program, activity, or service 2) The frequency with which LEP individuals come in contact with TARC services. 3) The nature and importance of the program, activity or service provided by TARC to the LEP population 4) The resources available to TARC and overall costs to provide LEP assistance. A brief description of these considerations is provided in the following section Four Factor Analyses 1. The number or proportion of LEP persons eligible in the TARC service area who may be served or likely to encounter a TARC program, activity, or service. TARC examined the US Census report from 2010 and the Bureau s American Community Surveys and determined that 6.4% or about 62,000 people speak another language at home than English. Of the total population, the American Community Survey sample data reports that approximately 1.71% speak English less than very well. Spanish is the most frequently language spoken, if English is not the primary language. See Appendix D for additional information. TARC 2013 Title VI Program Update 15

16 2. The frequency with which LEP individuals come in contact with a TARC program, activity, or service TARC assesses how often a LEP individual may come into contact with a TARC program, activity or service through a variety of methods. TARC has a Spanish translation on its website, and has tracked approximately 1,200 hits with a total of 14,000 page views in fiscal year 2012 (FY 2012). TARC also has an interactive voice response system via telephone; this service was used approximately 4,603 times in FY Paratransit calls for Spanish language translation numbered 513 during FY The nature and importance of the program, activity, or service provided by the TARC to LEP community The nature and importance of TARC service is assumed to vary from individual to individual in the LEP community. There are a few neighborhoods where new Americans have tended to relocate and transit service is frequent. TARC also works with a number of organizations to ensure that when people first move, or are relocated, to Louisville that there are members in the community who can provide assistance and let them know about TARC s services. Given the variety and number of languages that are spoken by new Americans, TARC has found this method to be an effective way of providing outreach and information. 4. The resources available to the TARC and overall costs TARC has examined the resources available for providing assistance for persons with LEP. At this point in time, TARC is willing and able to provide translation services or interpreters on an as needed, as requested basis. TARC has established working relationships with local translation services companies to provide translations for the website and phone system. These companies would be available to work on other projects as needed. There are also a number of on-line translation services provided at no cost on the internet, which can be used for quick and/or simple translations. How to Identify an LEP Person who Needs Language Assistance The following are recommended actions to help identify people who may need assistance due to LEP: TARC customer service representatives will be aware of people who may call or come in person to TARC customer service centers who need information. The Census Bureau s I Speak Cards can be used and will help track requests for language assistance. TARC staff, at meetings or at the customer service centers, can determine a customer s ability to speak English by asking a question that would need a complete sentence response. TARC 2013 Title VI Program Update 16

17 TARC staff will keep the Census Bureau s I Speak Cards at the booth or sign-in table at events and meetings and track these requests to prepare language translations or other materials at future events. Informal surveys will be made of road supervisors, operators and dispatch staff to monitor numbers of times people with LEP may be asking for or needing information on TARC service. Language Assistance Measures TARC has made the following services available: Some members of TARC s staff have some Spanish language training and are able to talk with customers in Spanish. The TARC s website features a Spanish translation. The TARC interactive voice response system for both paratransit and fixed routes service features a Spanish translation. Census Bureau s I Speak Cards are to be located at their Customer Service locations at all times. TARC Staff Training Selected TARC staff that are most likely to come into contact with a person with LEP or work with organizations that work with new Americans will be included on the following: Review of Title VI policy and process Review of LEP plan and TARC s responsibilities What language assistance services the TARC offers; The Census Bureau s I Speak Cards Outreach Techniques TARC has worked over the years on a number of projects to improve communications and outreach with LEP populations. These include translations of brochures in Vietnamese and Bosnian. The following are current outreach activities: TARC notices about public hearings are sent to Spanish language newspapers and media outlets. Translations are available on request at meetings and are noted as such. TARC 2013 Title VI Program Update 17

18 Key print materials may be translated and made available when a concentrated population is identified or requested. TARC also works with a number of organizations whose mission is to provide services and support for people who are new to the United States and/or have limited English proficiency. The organizations include Catholic Charities, Kentucky Refugee Ministries and the Americana Community Center. TARC s approach includes using a train the trainer method and individualized marketing programs. TARC meets on an as needed basis with the organizations to discuss service needs, deal with any issues, and to exchange information. TARC is interested in hiring staff that speak multiple languages. TARC also participates in community events that are focused on the international community, most recently by attending the local World Fest, sponsored by a local government agency. TARC will continue to use different meeting formats and make sure that translation services are available for people attending meetings that have limited English proficiency. Monitoring and Updating the LEP Plan TARC will follow the Title VI Program update schedule for the LEP Plan and will review both the Title VI program and the LEP plan once the 2010 census data is available for the next update. The update will follow a S.W.O.T. analysis format as well as a review of the relevant demographic information. Strengths of program: Are the program elements working? Are people getting necessary information? Is TARC meeting the needs of LEP populations? How much are the translations being used on the website and phone system? Weaknesses of program: What are the holes? Where are the places where information is not received? Are day-to-day programs working? Opportunities: Are there new organizations that provide services to new Americans? Are there new aspects of local government agencies that can provide information? Are there school programs or other private agencies that can partner with TARC? Threats: How have resource levels changed? Are there greater numbers of LEP persons? Are there reasons why the program cannot work as successfully as planned? Has there been a change in the types of languages where translation services are needed? TARC 2013 Title VI Program Update 18

19 Dissemination of the TARC Limited English Proficiency Plan TARC includes the LEP notices with its Title IV Policy and Complaint Procedures. The Notice of Rights under Title VI to the public is posted at TARC s customer service centers and is available on the TARC website. Copies of the LEP Plan will be provided, on request, to any person(s) requesting the document via phone, in person, by mail or . LEP persons may obtain copies/translations of the plan upon request. Any questions or comments regarding this plan should be directed to: TARC Title VI Coordinator Transit Authority of River City 1000 W. Broadway Louisville, KY TARC 2013 Title VI Program Update 19

20 6. Non-Elected Committees & Councils Board of Directors Louisville Mayor Greg Fischer Board Chair Black Male Board Vice Chair White Female Board Member Black Male Board Member White Male Board Member White Male Board Member White Female Board Member White Female Board Member Black Female TARC Accessibility Advisory Council (TAAC) Demographics as of November 30, 2012 Caucasian 10 77% African-American 3 23% Male 4 30% Female 9 70% Total Members 13 Recruiting and Election Process Overview Once a year TARC makes a list of all organizations that serve disabled populations and sends the targeted organizations Executive Director a letter that makes the case for why the organization should help recruit a representative. Membership applications ae updated for current needs and goals 2012 Updated applications TARC 2013 Title VI Program Update 20

21 Broadened recruitment possibilities to colleges, senior citizens home and made applications accessible through on-line media. Elections Oct-Nov; Applications reviewed by 7-member committee and sorted by disability population represented; education; experience and community activism. Nov: Membership Committee writes resolution to accept members facing their one-year review Nov: Membership Committee writes resolution to accept new members to the Council Dec: voting to approve/deny resolutions TARC 2013 Title VI Program Update 21

22 7. Monitoring of Sub-Recipients In 2007 the Governors of Indiana and Kentucky awarded TARC designated recipient status for the Federal Transit Administration s (FTA) New Freedom and JARC (Job Access) programs. The private non-profit and for-profit organizations that have since received awards from those programs became subrecipients of FTA funds under TARC s oversight. In 2012, citing a Census Bureau determination that City of La Grange was to be included in the Louisville Urbanized Area, the FTA approved La Grange s application to become a public provider of transit services. With that approval, La Grange became a subrecipient of FTA transit formula funds (section 5307) with TARC providing oversight as the primary recipient. Among its oversight duties, TARC is responsible for assuring that each of its subrecipients equitably distributes the benefits of the funds it receives, as required by Title VI of the Civil Rights Act. Monitoring compliance of subrecipients begins with and rests on the foundation of an interagency agreement or contract. Before a subrecipient can receive any federal funds, it enters into a subrecipient agreement with TARC that certifies compliance with the requirements of Title VI. TARC requires and retains on file a copy of each subrecipient s Title VI program. If such a program does not exist, TARC will assist the subrecipient in the creation of their program. TARC has developed and maintains two tools to help ensure that subrecipients are complying with Federal laws and regulations. One tool tracks monitoring activities, the other tool is a compliance review form. TARC uses this form to review subrecipient practices and to create a summary for each subrecipient, which it keeps on file and may make available to the FTA during any Federal program management reviews. The review may include any area of applicable Federal law, including compliance with provisions of the Civil Rights Act of 1964, the ADA, as well as cross-cutting Federal requirements, such as those that pertain to procurement of buses or other revenue service vehicles (e.g. Buy America, pre-award and post-delivery audits), restrictions on lobbying, and environmental protections. TARC may, at its discretion and given the availability of funds, contract with a third party consultant to conduct reviews of subrecipient programs. At the request of FTA, in response to a complaint of discrimination, or as otherwise deemed necessary by TARC, TARC shall request that subrecipients who provide transportation services verify that their level and quality of service is provided on an equitable basis. Any and all subrecipients of federal funds for which TARC is the primary recipient are responsible for reporting Title VI complaints as outlined in Chapter IV of Circular B. TARC asks that all subrecipients notify TARC s Grants Department promptly if it receives a Title VI complaint. TARC 2013 Title VI Program Update 22

23 Schedule of Subrecipient Title VI Submissions TARC requests a copy of the subrecipients Title VI program immediately following execution of a new subrecipient agreement. An update of the program is requested every three years thereafter. TARC will collect Title VI assurances on an annual basis from each subrecipient prior to passing through FTA funds. TARC 2013 Title VI Program Update 23

24 8. Equity Analysis of Facilities Whenever TARC plans to acquire property for the purpose of constructing a new operations, maintenance or support facility, it will complete a Title VI equity analysis during the planning stage with regard to where a project is located or sited to ensure the location is selected without regard to race, color, or national origin. TARC will reach out to communities and persons potentially impacted by the selected site alternatives for the new facilities. The equity analysis will compare the impacts of any alternative sites with regard to benefits and negative impacts. This analysis will be completed before the final selection of the preferred site. When evaluating locations of facilities, TARC will examine the context of each alternative site. TARC will consider any other facilities with similar impacts in the area of each site to determine if any cumulative adverse impacts might result. Analysis will be done at the Census tract level to ensure that proper perspective is given to localized impacts. If TARC determines that the location of the project will result in a disparate impact on the basis of race, color, or national origin, TARC will only locate the project at that site if there is substantial legitimate justification, and there are no alternative locations that would have a less disparate impact on the basis of race, color, or national origin. TARC will document how both of those conditions are met. In other words, TARC will consider and analyze alternatives to determine which of those alternatives will have the least disparate impact on the basis of race, color, or national origin. Where possible, TARC will seek sites for proposed projects where the proposed activity will not fundamentally change the condition or the use of the existing property. In other words, it will see sites at which the current use is fundamentally the same as the proposed use. For example, if TARC has determined that it needs a new location for vehicle maintenance, it will seek to reuse and improve a facility where it would continue the historic use of the site. In 2010 TARC constructed a new maintenance and training facility using funds from the American Recovery and Reinvestment Act of The construction required an environmental assessment for the facility that included an equity analysis. The results of that analysis were stated as follows in the Categorical Exclusion Request: In terms of community disruption, the proposed activity will not fundamentally change the condition or the use of the existing property; therefore, impacts to the surrounding neighborhoods or community will not occur. The City of Louisville contains a diverse population of various cultures and incomes who would not be affected by the proposed activity, which is a continuation of the historic use of the site. As evaluated in this environmental review the proposed activity will not cause a disproportionately high and/or adverse effect on human health or cause an environmental impact on the surrounding area. TARC 2013 Title VI Program Update 24

25 9. Board Approval of Title VI Program TARC 2013 Title VI Program Update 25

26 TARC 2013 Title VI Program Update 26

27 10. Major Service Change & Impact Policies TARC solicited public comments on the major service change and impact policies between April 22 and May 17, The public was solicited to comment through a news release widely distributed to local elected officials, neighborhood and community organizations, and the news media. TARC also solicited comment through an e-blast to 8,000 subscribers, the ridetarc.org website, and social media outlets Twitter and Facebook. On May 20, 2013, TARC adopted the following major service change and impact policies: Major Service Change Policy: Major service changes are those that change revenue service more than 25% on a route. These changes trigger a service equity analysis that requires approval by the TARC Board of Directors. TARC adopts the following for disparate impacts and disproportionate burden policies for major service and fare changes. TARC s ultimate goal is to avoid, eliminate or minimize any disparate impacts or disproportionate burdens on Title VI populations. Any potential adverse effects of service or fare changes on minority or low-income passengers will be mitigated with proposed alternative measures. Disparate Impact Policy: TARC has defined its disparate impact policy to be +/- 10% statistical difference between the effects on minority populations compared to the impacts borne by nonminority populations. Disproportionate Burden Policy: TARC has defined its disproportionate burden policy to be +/- 10% statistical difference between the effects on low-income populations compared to the impacts borne by nonlow-income populations. Each of these policies will be applied to system-wide demographics to a) individual routes and b) routes cumulatively. TARC 2013 Title VI Program Update 27

28 11. Service Standards TARC s system-wide service standards and policies are documented in the agency s adopted Systemwide Service Standards and Policies (2009). The subset of TARC s fixed route service standards and policies called out in FTA Circular B are described below. This sections outlines system-wide service standards adopted by TARC in order to comply with 49 CFR Section 21.5(b)(2) and (7). Vehicle load and on-time performance analysis include both minority and non-minority routes. The number of revenue miles within each census tract determines minority routes. A minority route has more than 33% of its revenue miles in minority tracts. TARC s minority routes are documented in the Appendix A. Vehicle load Average load for each local route should not exceed 110% of seated capacity at the maximum load point in the peak period. For circulator routes, the maximum load would be 33. For other 40 foot buses, the maximum load would be 54 for regular routes and 44 for express trips. Individual trips may exceed 135% of seated capacity. Average load for express routes should not exceed 100% of seated capacity due to higher travel speeds. Average load for each local route should not exceed 110% of seated capacity at the maximum load point in the base period. Individual trips may exceed 135% of seated capacity, especially when operating near schools or places of employment. Vehicle Headway A maximum trunk headway of no more than 30 minutes for standard, local routes that operate into the central business district. Headways on routes that do not operate into the central business district should have a maximum trunk headway that is no greater than the time it takes to make a complete round trip. This includes peak, base, weekend, and holiday periods. These are monitored by a review of the headway report. On-time performance A vehicle is considered on-time if it departs a scheduled time point no more than 1 minute early and no more than 6 minutes late. TARC s on-time performance objective is 95% or greater. TARC s continuously monitors on-time performance and system results are published and posted as part of the monthly performance reports covering all aspects of operations. TARC 2013 Title VI Program Update 28

29 Service Availability TARC will distribute transit service so that service is available to 90% of the service area population through either a bus stop within ¾ of a mile, or a parkand-ride facility within two miles. TARC 2013 Title VI Program Update 29

30 12. Service Policies Distribution of transit amenities Shelters are located along any route in any part of the service area, with special attention paid to the needs of persons with disabilities or older adults. Sidewalks, or other suitable pedestrian paths, should be located alongside all local transit routes. Boarding pads should be constructed at all stops. Benches and/or shelters should be located at least every half mile along a route. Benches and/or shelters should be included at every stop that has more than 100 boardings per day. Benches and/or shelters should be included at stops where individual customer needs warrant a seating area. These are verified by windshield surveys and most recently through a 2008 Bus Stop Inventory. Vehicle Assignment Title VI defines vehicle assignment as the process by which transit vehicles are placed into service on routes throughout the recipient s system. TARC has a total fixed route fleet of 226 active buses with an average age of 7.78 years. Bus assignment by route is a function of ridership levels (bus capacity), route characteristics and design issues (express buses, commuter buses and replica trolleys). Staff randomly assigns vehicles to scheduled runs from the garages with the exception that smaller vehicles are reserved for designated trolley routes, circulator routes, or routes with lower ridership. Smaller buses and trolleys are typically not used on expressway runs. A Vehicle Assignment Log is kept each day and is reviewed to ensure that vehicles are rotated through the runs. Every vehicle in TARC s fleet is wheelchair accessible and can hold two bicycles. Bus type assignments by route are created with the goal of providing equitable distribution of buses to meet Title VI goals Lower capacity vehicles should be used on routes that have lower load factors that serve as feeder routes and do not have expressway routing. Higher capacity vehicles should be used on routes with higher load factors or that have expressway routing. TARC 2013 Title VI Program Update 30

31 TARC Fleet Inventory 40 foot buses % of No. of Buses Active Fleet Manufacturer and Model Year Acquired Age (Years) 0 0.0% Gillig Low-Floor 40' % Gillig Low-Floor 40' % Gillig Low-Floor 40' % Gillig Low-Floor 40' % Gillig Low-Floor 40' % Gillig Hybrid-Electric 40' % Gillig Low-Floor 40' % Gillig Hybrid-Electric 40' % Gillig Low-Floor 40' % Gillig Hybrid-Electric 40' % Gillig Low-Floor 40' % Gillig Hybrid-Electric 40' % Gillig Low-Floor 40' % Gillig Hybrid-Electric 40' % Gillig Low-Floor 40' % 30 foot buses % of No. of Buses Active Fleet Manufacturer and Model Year Acquired Age (Years) 8 3.5% Gillig Low-Floor 30' % Gillig Low-Floor 30' % Trolleys No. of Buses % of Active Fleet Year Manufacturer and Model Acquired 5 2.2% Chance Am Heritage Streetcar % Optima Am Heritage Streetcar % Age (Years) 226 Total Fixed Route Active Fleet Buses TARC 2013 Title VI Program Update 31

32 Appendix A) Demographic & Service Profile Maps & Charts TARC 2013 Title VI Program Update 32

33 TARC 2013 Title VI Program Update 33

34 TARC 2013 Title VI Program Update 34

35 Census Tracts within TARC s Service Area / Minority Census Tract Determination Total Population White Black or African American Hispanic or Latino Minority Population Minority Population % Louisville MPA 1,060, , ,046 42, , % TARC Share 850, , ,650 35, , % Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Minority Tract Census Tract 2 2,924 2, % Minority Tract Census Tract 3 2,624 1,271 1, % Minority Tract Census Tract 4 4,531 1,030 3, % Minority Tract Census Tract 6 1, , % Minority Tract Census Tract 7 2, , % Minority Tract Census Tract 8 2, , % Minority Tract Census Tract 9 2, , % Minority Tract Census Tract 10 2, , % Minority Tract Census Tract 11 3, , % Minority Tract Census Tract 12 2, , % Minority Tract Census Tract 14 2, , % Minority Tract Census Tract 15 3, , % Minority Tract Census Tract 16 2, , % Minority Tract Census Tract 17 2, , % Minority Tract Census Tract 18 1, , % Minority Tract Census Tract 21 2,469 1, % Minority Tract Census Tract 23 2,447 1, % Minority Tract Census Tract 24 4, , % Minority Tract Census Tract 27 2, , % Minority Tract Census Tract 28 1, , % Minority Tract Census Tract 30 3, , % Minority Tract Census Tract 35 3, , % Minority Tract Census Tract 36 5,062 2,441 2, % Minority Tract Census Tract 37 1, % Minority Tract Census Tract 38 3,452 2, % Minority Tract Census Tract 39 3,968 2,335 1, % Minority Tract Census Tract 40 1,803 1, % Minority Tract Census Tract 41 2,580 1, % Minority Tract Census Tract ,119 1,295 2, % Minority Tract Census Tract , , % Minority Tract Census Tract 44 4,160 3, % Census Tract 45 3,118 2, % Minority Tract Census Tract 46 3,803 2, % Minority Tract Census Tract 49 4,263 1,792 2, % Minority Tract Census Tract 50 1, % Minority Tract Census Tract 51 3,195 1,683 1, % Minority Tract Census Tract 52 3,375 2, % Minority Tract Census Tract 53 2,180 1, % Minority Tract TARC 2013 Title VI Program Update 35

36 Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Minority Tract Census Tract 56 4,281 1, % Minority Tract Census Tract 59 4,676 1,600 2, % Minority Tract Census Tract 62 2, , % Minority Tract Census Tract 63 1,782 1, % Census Tract 64 1,663 1, % Census Tract 65 2,878 1,218 1, % Minority Tract Census Tract 66 2,005 1, % Minority Tract Census Tract 68 2,082 1, % Census Tract 69 2,220 1, % Census Tract 70 2, , % Minority Tract Census Tract 71 4,508 3, % Census Tract 74 2,049 1, % Census Tract ,191 4, % Census Tract ,339 4, % Census Tract ,949 1, % Census Tract ,634 2, % Minority Tract Census Tract ,503 1, % Census Tract 77 3,294 2, % Census Tract 78 3,105 2, % Census Tract 79 1,808 1, % Census Tract 81 3,111 2, % Census Tract 82 3,881 3, % Census Tract 83 2,508 2, % Census Tract 84 2,923 2, % Census Tract 85 2,001 1, % Census Tract 87 3,945 3, % Census Tract 88 3,069 2, % Census Tract 89 4,458 4, % Census Tract 90 6,823 4,267 1, % Minority Tract Census Tract , % Minority Tract Census Tract , , % Minority Tract Census Tract ,978 3, % Census Tract 93 5,042 4, % Census Tract 94 6,393 5, % Census Tract 96 4,314 4, % Census Tract 97 2,728 2, % Census Tract 98 2,673 2, % Census Tract 99 2,822 2, % Census Tract ,553 4, % Census Tract ,607 3, % Minority Tract Census Tract ,405 3, % Census Tract ,692 3, % Census Tract ,121 3, % Census Tract ,898 3, % TARC 2013 Title VI Program Update 36

37 Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Minority Tract Census Tract ,078 3, % Census Tract ,834 3, % Census Tract ,867 2, % Census Tract ,975 4, % Census Tract ,756 3, % Census Tract ,146 4,582 1, % Minority Tract Census Tract ,092 2, % Census Tract ,526 2, % Census Tract ,230 5, % Census Tract ,794 2, % Census Tract ,751 4, % Census Tract ,348 3, % Census Tract ,691 4, % Census Tract ,444 3, % Minority Tract Census Tract ,466 1, % Minority Tract Census Tract ,253 5, % Census Tract ,828 3, % Census Tract ,274 3, % Census Tract ,958 4, % Census Tract 105 3,796 3, % Census Tract ,078 2, % Census Tract ,635 2, % Minority Tract Census Tract ,977 4, % Census Tract ,477 4, % Census Tract ,283 4, % Census Tract ,311 2, % Census Tract 108 3,856 3, % Census Tract ,723 3, % Minority Tract Census Tract ,089 3, % Census Tract ,473 2,180 2, % Minority Tract Census Tract ,850 4, % Minority Tract Census Tract ,178 4, % Minority Tract Census Tract ,820 1, % Minority Tract Census Tract ,154 5, % Census Tract ,900 5, % Census Tract ,119 1, % Census Tract ,220 5, % Census Tract ,285 4, % Census Tract ,403 2, % Minority Tract Census Tract ,671 2, % Census Tract ,313 3,348 1, % Minority Tract Census Tract 112 5,490 2,480 2, % Minority Tract Census Tract , , % Minority Tract Census Tract , , % Minority Tract TARC 2013 Title VI Program Update 37

38 Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Minority Tract Census Tract ,835 1, % Census Tract ,752 1,372 1, % Minority Tract Census Tract ,804 1,756 2, % Minority Tract Census Tract ,234 2,246 1, % Minority Tract Census Tract ,298 4,407 1, % Minority Tract Census Tract ,654 4, % Census Tract ,170 3,584 1, % Minority Tract Census Tract ,013 2, % Minority Tract Census Tract ,512 3, % Census Tract ,291 2, % Census Tract ,721 4, % Census Tract ,958 3, % Census Tract ,766 4, % Census Tract ,374 2, % Census Tract ,222 4, % Census Tract ,495 3, % Census Tract ,964 5, % Census Tract ,528 4, % Census Tract ,548 2, % Census Tract ,690 3, % Census Tract ,709 4, % Census Tract ,678 3, % Census Tract ,976 3, % Census Tract ,670 2, % Census Tract ,993 5, % Census Tract ,161 3, % Census Tract ,870 2, % Census Tract 118 2,702 1, % Minority Tract Census Tract , % Minority Tract Census Tract ,584 1, % Minority Tract Census Tract ,402 5,550 1, % Census Tract ,480 1, % Minority Tract Census Tract ,443 3, % Census Tract ,378 3, % Census Tract ,891 4, % Census Tract ,706 3, % Census Tract ,168 2, % Census Tract ,002 3, % Census Tract ,557 4, % Census Tract ,683 6, % Census Tract ,545 5, % Census Tract ,270 4, % Census Tract ,182 5, % Census Tract ,409 3, % TARC 2013 Title VI Program Update 38

39 Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Minority Tract Census Tract ,331 2, % Census Tract ,555 4, % Census Tract ,669 5, % Census Tract ,583 3, % Census Tract ,391 2, % Census Tract ,312 3, % Census Tract ,180 3, % Census Tract ,653 5, % Census Tract ,549 1, % Minority Tract Census Tract ,230 4, % Census Tract ,160 3, % Census Tract ,917 2,340 4, % Minority Tract Census Tract ,716 1,452 1, % Minority Tract Census Tract ,245 2,852 2, % Minority Tract Census Tract ,576 1,303 2, % Minority Tract Census Tract ,089 1, % Census Tract ,069 4, % Census Tract , , % Minority Tract Census Tract , , % Minority Tract Census Tract 131 2,066 1, % Census Tract 9801 Census Tract 702 1,897 1, % Census Tract ,908 2, % Census Tract ,286 2, % Census Tract 704 2,637 2, % Census Tract 705 3,150 2, % Census Tract 706 2,297 1, % Census Tract 707 2,357 1, % Minority Tract Census Tract ,530 2, % Minority Tract Census Tract ,314 4, % Census Tract ,612 5, % Census Tract ,582 1, % Census Tract ,882 6, % Census Tract ,949 3, % Census Tract ,519 5, % Census Tract ,270 3, % Census Tract ,440 3, % Census Tract ,815 5, % Census Tract ,918 3, % Census Tract ,206 3, % Census Tract 712 2,009 1, % Census Tract 501 1,670 1, % Census Tract 502 3,741 2,356 1, % Minority Tract Census Tract ,560 2, % TARC 2013 Title VI Program Update 39

40 Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Minority Tract Census Tract ,249 3, % Minority Tract Census Tract ,805 2, % Census Tract ,297 1, % Census Tract ,809 2, % Census Tract ,913 2, % Census Tract ,986 3, % Census Tract ,639 1, % Census Tract ,447 3, % Minority Tract Census Tract ,069 2, % Census Tract ,066 5,063 1, % Minority Tract Census Tract ,005 5, % Census Tract ,354 4, % Census Tract ,911 3, % Census Tract ,557 4, % Census Tract ,987 5, % Census Tract ,837 5, % Census Tract ,199 5, % Census Tract ,899 4, % Census Tract ,010 3, % Census Tract ,508 3, % Census Tract ,450 2, % Census Tract ,526 5, % Census Tract 510 4,738 4, % Census Tract ,702 3, % Census Tract ,653 3, % Census Tract ,054 2, % Census Tract ,700 5, % Census Tract ,650 3, % Census Tract 203 4,744 4, % Census Tract 204 6,065 5, % Census Tract 205 5,612 5, % Census Tract ,736 5, % Census Tract ,386 1, % Census Tract ,134 5, % Census Tract ,088 2, % Census Tract 208 5,067 4, % Census Tract 209 2,731 2, % Census Tract ,204 5, % Census Tract ,968 2,335 1, % Minority Tract Census Tract 212 4,825 4, % Census Tract 301 2,299 2, % Census Tract 302 5,164 3,761 1, % Minority Tract Census Tract ,159 2, % Census Tract ,490 3, % TARC 2013 Title VI Program Update 40

41 Census Tract Total Population White Black or African American Hispanic or Latino Minority Population % Minority Population Census Tract ,416 5, % Census Tract ,641 2, % Census Tract ,092 3, % Census Tract ,650 4, % Census Tract ,921 5, % Census Tract ,006 4, % Census Tract ,280 2, % Census Tract ,686 5, % Census Tract ,901 3, % Census Tract ,611 4, % Minority Tract Census Tracts within TARC s Service Area / Low-Income Census Tract Determination Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Louisville MPA 1,020, , % TARC Share 821, , % Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract 2 2, % Low-Income Tract Census Tract 3 2, % Low-Income Tract Census Tract 4 4, % Low-Income Tract Census Tract 6 2, % Low-Income Tract Census Tract 7 2, % Low-Income Tract Census Tract 8 2, % Low-Income Tract Census Tract 9 2, % Low-Income Tract Census Tract 10 2, % Low-Income Tract Census Tract 11 3, % Low-Income Tract Census Tract 12 3, % Low-Income Tract Census Tract 14 2, % Low-Income Tract Census Tract 15 3, % Low-Income Tract Census Tract 16 2, % Low-Income Tract Census Tract 17 1, % Low-Income Tract Census Tract 18 1, % Low-Income Tract Census Tract 21 2, % Low-Income Tract TARC 2013 Title VI Program Update 41

42 Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract 23 2, % Low-Income Tract Census Tract 24 4, % Low-Income Tract Census Tract 27 2, % Low-Income Tract Census Tract 28 1, % Low-Income Tract Census Tract 30 3, % Low-Income Tract Census Tract 35 2, % Low-Income Tract Census Tract 36 5, % Low-Income Tract Census Tract 37 1, % Low-Income Tract Census Tract 38 3, % Low-Income Tract Census Tract 39 4, % Low-Income Tract Census Tract 40 1, % Low-Income Tract Census Tract 41 2, % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract 44 4, % Low-Income Tract Census Tract 45 3, % Low-Income Tract Census Tract 46 3, % Low-Income Tract Census Tract 49 2, % Low-Income Tract Census Tract 50 1, % Low-Income Tract Census Tract 51 2, % Low-Income Tract Census Tract 52 3, % Low-Income Tract Census Tract 53 1, % Low-Income Tract Census Tract 56 4, % Low-Income Tract Census Tract 59 3, % Low-Income Tract Census Tract 62 3, % Low-Income Tract Census Tract 63 1, % Low-Income Tract Census Tract 64 1, % Census Tract 65 2, % Low-Income Tract Census Tract 66 2, % Low-Income Tract Census Tract 68 1, % Low-Income Tract Census Tract 69 1, % Census Tract 70 2, % Census Tract 71 4, % Low-Income Tract Census Tract 74 1, % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract 77 3, % Low-Income Tract Census Tract 78 2, % Census Tract 79 1, % Census Tract 81 2, % TARC 2013 Title VI Program Update 42

43 Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract 82 3, % Census Tract 83 2, % Census Tract 84 3, % Census Tract 85 1, % Census Tract 87 3, % Census Tract 88 3, % Census Tract 89 3, % Census Tract 90 6, % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract 93 4, % Census Tract 94 6, % Census Tract 96 4, % Census Tract 97 2, % Census Tract 98 2, % Census Tract 99 2, % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract 105 3, % Census Tract , % TARC 2013 Title VI Program Update 43

44 Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract 108 3, % Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract 112 4, % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % TARC 2013 Title VI Program Update 44

45 Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract 118 2, % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract 131 1, % TARC 2013 Title VI Program Update 45

46 Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract % 0 Census Tract 702 1, % Low-Income Tract Census Tract , % Census Tract , % Census Tract 704 2, % Low-Income Tract Census Tract 705 2, % Low-Income Tract Census Tract 706 2, % Census Tract 707 2, % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract 712 1, % Census Tract 501 1, % Low-Income Tract Census Tract 502 2, % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % TARC 2013 Title VI Program Update 46

47 Census Tract Population for Whom Poverty Status is Determined Total Population for Whom Poverty Status is Determined Below Poverty Level Poverty % Low-Income Tract Census Tract , % Low-Income Tract Census Tract , % Census Tract 510 4, % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract , % Census Tract 203 4, % Census Tract 204 6, % Census Tract 205 5, % Census Tract , % Census Tract , % Census Tract , % Low-Income Tract Census Tract , % Census Tract 208 5, % Low-Income Tract Census Tract 209 2, % Census Tract , % Census Tract , % Census Tract 212 4, % Census Tract % Census Tract % Census Tract % Low-Income Tract Census Tract % Low-Income Tract Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % TARC 2013 Title VI Program Update 47

48 Minority Route Determination Route Miles Hours Route Non- Total Minority Determination Non- Minority Minority Minority Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Minority Route Miles Total Minority Total Non- Minority Hours Total Minority Total Non- Minority 47.24% 52.76% 43.86% 56.14% TARC 2013 Title VI Program Update 48

49 Service Monitoring Route Load Factor On-Time % 59.58% % % % % % % % % % % % % % On-Time Performance % Minority Routes 79.47% % Non-Minority Routes 78.15% % Total 80.09% % % % % Load Factor % Minority Routes % Non-Minority Routes % Total % % % % % % % % % % % % % % % % % % % *Note: Routes shaded in blue denotes minority routes TARC 2013 Title VI Program Update 49

50 Appendix B) Summary of Service and Fare Equity Analysis TARC - Service and Fare Equity Analysis for August 2012 Service & Fare Adjustments In March 2012, the Transit Authority of River City (TARC) began preparation for a service reduction to help close a projected $4.6 million shortfall in TARC s budget for fiscal year 2013, which begins July The initial public hearings for the service change proposal were held in the week of May 14 th. The proposal was based on system-wide route performance analysis and the major factors for analysis were: ridership, route efficiency/cost per boarding, other alternatives available to customers, and equity. The proposed service changes that were adopted after the public input period consisted of the following: Routing Changes Frequency Reductions Route Elimination Service restructuring in Southern Indiana A. Major Service Change Policy TARC defines a major service change as a change that has an impact of 25% or more of revenue service on any given route. The service changes that constitute a major service change and call for a service equity analysis are as follows: Route 22 Adjusted Route 37x Eliminated Route 38x Eliminated Route 49x Service Reduction Route 65x Eliminated Route 71 Adjusted Route 72 Adjusted Route 73x Eliminated Route 74 Eliminated Route 82 New Route The following routes had segment eliminations that did not constitute a major service change; however, they were included in the service equity analysis due to their proximity to minority and low-income areas. Route 18 Camp Taylor segment Route 50x Watson Lane segment TARC 2013 Title VI Program Update 50

51 B. Analysis Approach The datasets used to determine the minority populations were collected from the 2010 Census Summary File 1 - P5 with Race and Hispanic Origin as a base. The minority population was determined by subtracting White Non-Hispanic Origin persons from the total population. All remaining combinations of races and Hispanic Origin ethnicity (all single non-white races & all persons of Hispanic Origin, regardless of race without any double counting) were considered the minority population. The datasets used to determine the low-income populations were collected from the 2010 American Community Survey 5-year estimates. The low-income determination is as follows individuals below poverty level per census tract. For this analysis, the TARC service area is defined as all Census Tracts within a quarter-miles radius of TARC fixed route service within Jefferson, Oldham, Bullitt counties in Kentucky; and Clark and Floyd counties in Indiana, as defined in TARC s charter Census tracts were used as the geographic level of analysis and were overlaid with TARC s routes in a GIS geodatabase. Average Percentage of Minority Population per Census Tract in TARC Service Area 27.95% Average Percentage of Low-Income Population (%) per Census Tract in TARC Service Area 16.47% TARC defines a minority transit route as a route that has at least 1/3 of its total mileage in a census tract(s) or traffic analysis zone(s) with a percentage of minority population greater than the percentage of minority population in the transit service area. TARC defines a low-income transit route as a route that has at least 1/3 of its total mileage in a census tract(s) or traffic analysis zone(s) with a percentage of low-income population greater than the percentage of the low-income population in the transit service area. C. Service Equity Analysis The following GIS maps were overlaid upon demographic data to measure minority and low-income concentrations. TARC 2013 Title VI Program Update 51

52 Table 1. Analysis of service change by route Service Change Average minority proportion of population Average low-income proportion of population Tracts along route All tracts Tracts along route All tracts Route 18 (segment) 21.50% 27.95% 7.72% 16.47% Route % 27.95% 20.01% 16.47% Route % 27.95% 18.60% 16.47% Route 49 (reduction) 19.71% 27.95% 6.70% 16.47% Route 50 (segment) 8.31% 27.95% 13.50% 16.47% Route % 27.95% 12.98% 16.47% Route % 27.95% 14.29% 16.47% Route % 27.95% 14.20% 16.47% In the table above, TARC has analyzed the cumulative impacts of each route change on low-income and minority populations in its service area. The analysis is based on tract-level Census demographic data and therefore does not reflect ridership directly. TARC considers a disparate impact to occur when the concentration of minority or low-income populations affected by a type of service change exceeds the corresponding group s average concentration throughout the agency s service area by any percentage. TARC determined the concentrations of impacted low-income and minority populations according to the following formulas: Minority proportion along line = Minority population in tracts along affected Lines Total population in the same set of tracks Low-income proportion along lines = Low-income population in tracts Along affected lines Total population in the same set of tracts The average concentrations of minority and low-income populations throughout the entire service area were determined as follows: Minority proportion across all tracts = Total minority population in the service area Total service area population Low-income proportion across all tracts = Total low-income population in service area Total service area population This analysis was conducted by creating a quarter-mile buffer around each route s revenue service area (see maps, appendix), then calculating the minority and low-income populations of the Census tracts along those buffer zones. TARC 2013 Title VI Program Update 52

53 Routes 65 and 74 are limited stop routes that serve park & ride locations. For these routes a 1-mile and 2-mile buffer was created around the park & ride lots (2 miles for route 65 & 1 mile for route 74). Based on the agency s threshold for disparate impacts, the proposed service changes do not appear to have disparate impacts on minority and low-income populations. The Southern Indiana service restructuring was analyzed separately from the route eliminations above (65, 73, & 74). Although routes 22, 71, & 72 had changes that constituted a major service change individually, these changes occurred as a result of shifting service from one route to another. Part of route 22 shifted to route 71, and part of route 72 shifted to new route 82. These service changes did not result in a disparate impact for minority and low-income populations as there were no adverse effects through service reductions or eliminations. Route 82 provides more service for minority and low-income areas connecting to employment centers in Southern Indiana. Route 71 provides more frequent service with a higher span of service to minority and low-income Census tracts. D. Fare Equity Analysis TARC proposed a fare increase in April to help close a projected $4.6 million shortfall in TARC s budget for fiscal year 2013, which begins July 1. Following a public review process, the rate increase was approved by TARC s board of directors on May 22. Table 3. Fare Increase Table Current Fares Fares Effective Percent July 1, 2012 Increase Adult Cash Fare $1.50 $ % Student Ages cents 80 cents 6.67% *Senior Citizens 75 cents 80 cents 6.67% Citizens w/disabilities 75 cents 80 cents 6.67% *Medicare Card Holders 75 cents 80 cents 6.67% Circulators/Shoppers 50 cents 75 cents 50% *Circulators/Shoppers: Students, Senior Citizens, Citizens w/disabilities & 25 cents 30 cents 20% Medicare Card Holders TARC3 $2.50 $ % Monthly Pass $42.00 $ % Express Passes $80.00 $ % Express Fare $2.50 $ % 10-Ride Ticket $12.50 $ % Special 10-Ride $7.50 $ % One-day pass $3.00 $ % TARC 2013 Title VI Program Update 53

54 The fare increases were implemented across the entire system, affecting all fixed routes. Since TARC offers a reduced fare for Medicare card holders, these fare increases do not appear to have any disparate impacts on low-income transit riders. The vendor s locations for these media are located in areas that are convenient to impacted populations. Public comments received during the public meetings suggested a strong preference for fare increases over further service reductions. Alternative strategies to offset the budget shortfall would include a further reduction in service that would have had a more severe adverse effect than the preferred alternative. TARC 2013 Title VI Program Update 54

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58 Transit Authority of River City Service Equity Analysis June 2013 In compliance with Title VI of the Civil Rights Act of 1964, the Transit Authority of River City (TARC) includes a Service Equity Analysis as part of major service changes to assess the impacts on minority and low-income communities in the TARC service area. The Federal Transit Administration (FTA) is responsible for ensuring that applicants and recipients of FTA distribute federally supported transit services and related benefits assistance in a manner consistent with Title VI. Section 601 of the Civil Rights Act of 1964 states: No person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal assistance. TARC provides regional transit service to many diverse communities throughout the Louisville, KY region. Up to three times per year, TARC prepares service changes that may include major changes in response to changing conditions. Based on TARC s service standards, major service changes are those that change revenue service more than 25% on a route. These changes trigger a service equity analysis that requires approval by the TARC Board of Directors. Maps assessing the impacts to the Title VI communities for each service change are included in the appendix. The population of the Title VI communities as a percentage of the total population of the TARC service area is shown in the table below. Title VI Populations % TARC Service Area Population Minority 27.95% Low-Income 16.47% The scope of this analysis for each area related to the service change has been determined by the following methodology and outlines the following criteria: The datasets used to determine the minority population were collected from the 2010 Census Summary File 1 P5 with Race and Hispanic Origin as a base. The minority population was determined by subtracting White Non-Hispanic Origin persons from the total population. All remaining combinations of races and Hispanic Origin ethnicity (all single non-white races & all persons of Hispanic Origins, regardless of race without any double counting) were determined the minority population. The datasets used to determine the low-income populations were collected from the 2010 American Community Survey 5-Year estimates based on individuals below poverty lever per census tract. TARC adopts the recommended FTA approach for disparate impacts and disproportionate burden policies for major service changes and adjustments. TARC s ultimate goal is to minimize any adverse effects of service changes on minority or lowincome passengers. TARC has defined its disparate impact policy to be +/- 10% statistical difference between the effects on minority populations compared to the TARC 2013 Title VI Program Update 58

59 impacts borne by non-minority passengers. TARC has defined its disproportionate burden policy to be +/- 10% statistical difference between the effects on low-income populations compared to the impacts borne by non-low-income passengers. Each of these policies will be applied to system-wide demographics to a) individual routes and b) routes cumulatively. Based on the results of this analysis, when alternative service and other mitigating factors are taken into account, it does not appear that any of the service changes to be in effect on June 9, 2013 have a disparate impact or disproportionate burden on the Title VI populations in the TARC service area. Analysis by Route Route 2 Route 2 is a local route that operates between UPS, the airport and downtown Louisville, via Crittenden Drive and Second Street. The proposed changes would discontinue the route south of Louisville International Airport. Route 2 would be straightened to run from 1 st and 2 nd Streets to 3 rd Street, turn at Eastern Parkway, to Crittenden Drive. This routing would improve connections between Downtown, colleges and universities, and the airport. Weekday peak frequency would increase from hourly to 35 minutes, base frequency from 80 to 70 minutes and on weekends from 80 minutes to 70 minutes. Potential Impacts to Title VI Populations Residents potentially affected by this change living within the impacted area. Route 2 Service Adjustment Minority Population Low-Income Population Route 2 Impacted Area 37.08% 24.07% TARC Service Area 27.95% 16.47% The impacted area is defined as a ¼ mile buffer along the deleted route segment as outlined in the maps in the appendix. Residents in the impacted area did not have a greater than 10% statistical difference in both Title VI populations than the service area average. Thus, this proposed change indicates there are no disparate impacts or disproportionate burdens on Title VI populations. The following proposed alternative measures would mitigate any adverse effects from this service change: Adjust route 27 to cover portion of Preston St no longer served by route 2 service change. Adjust route 18 to serve UPS facility. TARC 2013 Title VI Program Update 59

60 Route 25 & 55 The consolidation of routes 25 and 55 did not result in a change in revenue service greater than 25% and therefore did not constitute a major service change. TARC analyzed the service change and found no indication of adverse effects on minority or low-income populations. TARC 2013 Title VI Program Update 60

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