Meeting_Body
EXECUTIVE MANAGEMENT COMMITTEE
AUGUST 18, 2022
Subject
SUBJECT: SERVICE STANDARDS POLICIES FOR TITLE VI PROGRAM UPDATE
Action
ACTION: APPROVE RECOMMENDATION
Heading
RECOMMENDATION
Title
ADOPT Service Standards policies for Title VI Program Update presented in Attachment A.
Issue
ISSUE
Title VI of the Civil Rights Act of 1964 (Title VI) prohibits discrimination on the basis of race, color, and national origin in programs that receive federal funding. The Federal Transportation Administration (FTA) requires transportation agencies to demonstrate their compliance with Title VI by adopting policies in compliance with FTA Circular 4702.1B “Title VI Requirements and Guidelines for Federal Transit Administration Recipients,” issued October 1, 2012. FTA requires the Metro Board of Directors to review and approve the Metro Service Standards to be included in the Title VI Program Update due every three years.
Background
BACKGROUND
Section 601 of Title VI of the Civil Rights Act of 1964 (Title VI) states the following:
No person in the United States shall, on the ground 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.
FTA Circular 4702.1B, revised in 2012, requires transportation agencies to develop service standards and include them in the Title VI Program update due every three years. These service standards should be followed for the three year period until the next program update.
Discussion
DISCUSSION
Metro is required under FTA Circular 4702.1B to submit Board approved Service Standards. The Service Standards assist Metro in providing bus and rail service. The Service Standards must be approved by the Metro Board every three years. The Metro Board last approved the monitoring results in September 2019 and there have been no changes.
Determination_Of_Safety_Impact
DETERMINATION OF SAFETY IMPACT
The requested action in this report will have no direct impact on the safety of Metro’s employees or customers.
Financial_Impact
FINANCIAL IMPACT
Adoption of the Service Standards Policies has no direct impact upon Metro’s expenditures or revenues. Approval is consistent with the implementation of service included in the adopted FY2023 Budget. Failure to approve the Service Standards Policies could result in an incomplete Title VI Program Update which could potentially result in the loss of federal funding.
Impact to Budget
Adoption of the Title VI Equity Policies has no direct impact upon Metro’s expenditures or revenues. Approval is consistent with the implementation of service included in the adopted FY203 Budget. Failure to approve the Service Standards Policies today may result in an incomplete Title VI Program Update which may impact federal grants.
Equity_Platform
EQUITY PLATFORM
Title VI sets the minimum federal requirements to prevent discrimination or benefits from being denied to federally protected groups, as noted above. The Monitoring of Transit Service for Title VI purposes meets the federal requirements, as it ensures that Metro’s Service Standards are being applied consistently throughout the system. The monitoring also provides a means to measure and adjust for impacts and benefits to protected groups, which supports Metro’s goal to ensure that impacts to marginalized groups are considered in transportation decisions and service delivery.
Implementation_of_Strategic_Plan_Goals
IMPLEMENTATION OF STRATEGIC PLAN GOALS
The recommendation supports strategic plan goal # 5, “Provide responsive, accountable, and trustworthy governance within the Metro organization” by adhering to civil rights requirements mandated by Title VI of the Civil Rights Act of 1964.
Alternatives_Considered
ALTERNATIVES CONSIDERED
The alternative to not including Board approved Service Standards Policies which would have significant negative impacts to the agency. Failure to include Board approved Service Standards policies in the Title VI Program update may result in FTA, not concurring with Metro’s Title VI Program Update which may result in the suspension of federal grants by being non-compliant with civil rights requirements.
Next_Steps
NEXT STEPS
The Title VI Program Update will be scheduled for Board approval at the September 22, 2022 Board of Directors meeting. Upon Board approval, Metro’s Title VI Program Update will be submitted to FTA by the due date of October 1, 2022.
Attachments
ATTACHMENTS
Attachment A - Metro Service Standards
Prepared_by
Prepared by: Aida Berry, Senior Manager, Civil Rights Programs (Title VI),
(213) 922-2748
Joseph Forgiarini, Senior Executive Officer, Service Development, Scheduling & Analysis (213) 418-3034
Teyana Williams, Deputy Chief Civil Rights Officer (Interim), (213) 418-3168
Reviewed_By
Reviewed by: Nicole Englund, Chief of Staff, (213) 922-7950
