REQUEST FOR CITY COUNCIL ACTION
DATE: 05/17/2023
TO: Honorable Mayor and City Council Members
FROM: Community Services Department
SUBJECT:
Title
CITY COUNCIL APPROVAL OF THE 2024-2026 CITY OF CORONA TRANSIT SERVICE TITLE VI PROGRAM IN COMPLIANCE WITH THE FEDERAL TRANSIT ADMINISTRATION CIVIL RIGHTS ACT OF 1964
End
EXECUTIVE SUMMARY:
This staff report asks the City Council to approve and adopt the 2024-2026 City of Corona Transit Service Title VI Program. As a recipient of Federal Transit Administration funds, transit agencies must prepare a Title VI Program every three years. The proposed 2024-2026 Title VI Program has been revised and updated in compliance with Federal Transit regulations Circular 4702.1B and must be approved and adopted by the City Council and submitted to the federal regional civil rights office by June 1, 2023.
RECOMMENDED ACTION:
Recommended action
That the City Council approve and adopt the 2024-2026 City of Corona Transit Title VI Program in accordance with Federal Transit Administration Circular 4702.1b.
Body
BACKGROUND & HISTORY:
Title VI of the Civil Rights Act of 1964 is a federal law that prohibits recipients and sub-recipients of federal financial assistance (e.g., states, local governments, transit providers) from discriminating based on race, color, or national origin in their programs or activities and obligates federal funding agencies to enforce compliance. Under Title VI, the United States Department of Transportation has the responsibility to provide oversight of recipients and to enforce their compliance with Title VI.
On February 11, 1994, Executive Order (EO) 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,” was enacted by President Clinton. The Presidential memorandum accompanying EO 12898 identified Title VI of the Civil Rights Act of 1964 as one of several federal laws that should be applied “to prevent minority communities and low-income communities from being subject to disproportionately high and adverse environmental effects.” This executive order added regulations to provide meaningful access for persons with limited English proficiency.
Per the Federal Transit Administration’s (FTA) Title VI Circular 4702.1B dated October 12, 2012, recipients of FTA funds must prepare and submit a Title VI Program to their FTA regional civil rights office once every three years. Title VI additionally requires recipients of federal assistance to monitor and evaluate federally assisted programs for compliance.
The City of Corona receives federal assistance for the provision of public transit services and must comply with the Civil Rights Act of 1964 and the provision of Title VI.
ANALYSIS:
The current 2021-2023 Title VI Program was approved and adopted by the City Council on September 9, 2020, and is valid through September 30, 2023. In compliance with the three-year cycle, staff must prepare and adopt its City of Corona Transit Service (CCTS) Title VI Program. Accordingly, the 2024-2026 CCTA Title VI Program has been prepared in compliance with Title 49 of the Code of Federal Regulations (CFR) Section 21.9(b) and the FTA.
Summary of Required Content
Pursuant to FTA Circular 4702.1B - Title VI Guidelines for FTA Recipients, the program includes the following General and Transit-specific requirements:
General Requirements:
1. Title VI Notice to the Public - A copy of the agency’s notice to the public that the agency complies with Title VI, and instructions to the public on how to file a discrimination complaint (Figure 2; pg. 9 of Title VI Program).
2. Title VI Complaint Procedures and Complaint Form - CCTS complaint procedures and guidelines for filing Title VI complaints (Appendix A of the Title VI Program).
3. List of transit-related Title VI investigations, complaints, and lawsuits - A list of any Title VI investigations, complaints, or lawsuits filed with the agency since the time of the last submission.
4. Public Participation Plan - A public participation plan that includes an outreach plan to engage minority and limited English proficient populations as well as a summary of outreach efforts undertaken since the last Title VI submission.
5. Limited English proficiency (LEP) - A copy of the agency’s plan for providing language assistance to persons with limited English proficiency, based on the Department of Transportation (DOT) Limited English Proficiency (LEP) Guidance.
6. Racial Breakdown of Non-elected Advisory Council - Information regarding the racial breakdown of transit-related policy boards or committees.
7. Subrecipient Monitoring - Narrative or description of efforts to ensure the subrecipient is complying with Title VI and a schedule of the subrecipient Title VI Program Submissions.
8. Title VI equity analysis - An equity analysis if the recipient has constructed a facility (such as a garage, maintenance facility, or operation center) using FTA funds since the last Title VI program update.
9. Board of Directors Resolution or Meeting Minutes - A copy of board meeting minutes or other appropriate documentation showing the Board of Directors or appropriate governing entity or official(s) responsible for policy decisions reviewed and approved the Title VI Program.
Transit-specific Requirements:
10. System-wide standards and policies that address:
a. Vehicle load
b. Vehicle headway
c. On-time performance
d. Service availability
11. Service policies that address:
a. Provision of transit amenities
b. Vehicle assignment
These requirements and guidelines apply to all FTA recipients. The FTA ensures that its recipients fully comply with Title VI of the Civil Rights Act of 1964.
Below is a summary list of revisions and updates; revisions included language clean-up throughout. For a complete review of the 2024-2026 Title VI Program, the public may reference the attached full-text copy in redline format and a clean copy for comparison.
Summary of Updates
Section I. Overview:
• Provided additional details about Title VI requirements pursuant to FTA Circular 4702.1B
Section II. City of Corona Transit Service
• Updated the City’s demographics and provided additional information about the City’s transit routes, the Blue Line and the Red Line.
Section III. General Requirements:
Public Participation
Added information about outreach efforts for the Comprehensive Operations Analysis (COA).
Limited English Proficiency (LEP) Plan
• Updated language proficiency table for the CCTS service area using the data from the most recent American Community Survey (ACS) (2017-2021).
• Updated the Four Factor Analysis for the Limited English Proficiency (LEP) Plan to reflect the data from the ACS and the onboard rider survey.
• Updated contact information to reflect Community Services; changed from Public Works.
Section IV. Program Specific Requirements:
Service Standards
• Provided additional details about on-time performance and service availability based on information available from the COA.
Service Policies
• Updated transit amenities section to reflect details regarding the distribution of amenities at the bus stops.
The City of Corona’s transit services are partially funded and dependent on the federal funds provided by the FTA. To remain in good standing and in compliance with the FTA Title VI of the Civil Rights Act of 1964, staff recommends City Council approval of the updated 2024-2026 City of Corona Transit Service Title VI Program.
FINANCIAL IMPACT:
Approval of the CCTS 2024-2026 Title VI Program is needed for continued eligibility for federal assistance to support current and future capital projects and operating costs.
ENVIRONMENTAL ANALYSIS:
This action is exempt pursuant to Section 15061(b)(3) of the Guidelines for the California Environmental Quality Act (CEQA), which states that a project is exempt from CEQA if the activity is covered by the commonsense exemption that CEQA applies only to projects that have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA. This action merely approves the Title VI Plan. There is no possibility that this action will have a significant effect on the environment. Therefore, no environmental analysis is required.
PREPARED BY: SUDESH PAUL, TRANSIT PROGRAM MANAGER & CYNTHIA LARA, COMMUNITY ASSISTANCE MANAGER
REVIEWED BY: ANNE K. TURNER, COMMUNITY SERVICES DIRECTOR
Attachments:
1. Exhibit 1 - REDLINE VERSION of the updated 2024-2026 City of Corona Transit Service Title VI Program
2. Exhibit 2 - CLEAN VERSION of the updated 2024-2026 City of Corona Transit Service Title VI Program