Title VI Program
Transcription
Title VI Program
LexTran - Transit Authority of Lexington Fayette Urban County Government and Lexington Kentucky 109 West Loudon Avenue Lexington, Kentucky 40508 Title VI Program SEPTEMBER 17, 2010 1 | P a g e CONTENTS Introduction .................................................................................................................................................. 5 Policy Statement ........................................................................................................................................... 5 1. Requirement to provide An Annual Title VI Certification and Assurance (Chapter IV, part 1) ............. 5 2. Requirement to Develop Title VI Complaint Procedures (Chapter IV, part 2) ...................................... 5 3. Requirement to record Title VI Investigations, complaints, and lawsuits (Chapter IV, part 3) ............ 6 4. Requirement to Provide Meaningful Access to LEP Persons (Chapter IV, part IV) ............................... 7 Introduction .............................................................................................................................................. 7 Basis for LEP .............................................................................................................................................. 7 Covered individuals ................................................................................................................................... 7 Who is a limited English proficient individual? ......................................................................................... 7 Requirements ............................................................................................................................................ 8 1. Four‐factor analysis ............................................................................................................................... 8 2. The frequency with which LEP persons come into contact with the program ............................... 16 3. The nature and importance of the program, activity, or service provided by the program; ......... 16 4. The resources available and costs to the recipient. ....................................................................... 17 Develop a Language Access Plan (LAP) ............................................................................................... 17 a. Identifying LEP individuals who need language assistance; ............................................................... 17 b. Developing language assistance measures; ...................................................................................... 17 Limited English Proficiency Procedure (LEP) ....................................................................................... 18 Process .................................................................................................................................................... 19 c. Training staff ....................................................................................................................................... 20 d. Providing notice to LEP persons .......................................................................................................... 20 e. Monitoring and updating the plan. ..................................................................................................... 20 3. Provide appropriate language assistance. .......................................................................................... 21 Dissemination of the Limited English Proficiency Plan ........................................................................... 21 5. Requirement to Notify beneficiaries of their rights under Title VI (Chapter IV, part V) ..................... 22 On our buses under the fare information ............................................................................................... 22 At our Training Center, Transit Center and at our Administrative Office ............................................... 23 On Our Website ...................................................................................................................................... 23 On our schedules .................................................................................................................................... 24 6. Requirement to Provide Additional Information Upon Request (Chapter IV, part VI) ....................... 24 2 | P a g e 7. Requirement to Prepare and Submit a Title VI Program (Chapter IV, part VII) .................................. 24 Summary of public outreach ................................................................................................................... 24 Guidance on Conducting an Analysis of Construction Projects (Chapter IV, part VII) ................................ 26 Guidance on Promoting Inclusive Public Participation (Chapter IV, part IX) .............................................. 27 1. Requirement to Collect Demographic Data (Chapter V, part I) .......................................................... 28 2. Requirement to Set System Wide Service Standards (Chapter V, part II) .......................................... 29 Overall Fixed Route Design ..................................................................................................................... 29 Operating Environment .......................................................................................................................... 30 Service Area ............................................................................................................................................ 30 Passenger Stops ...................................................................................................................................... 30 Hours of Operation ................................................................................................................................. 30 Service Levels .......................................................................................................................................... 31 Frequency of Service (Vehicle Headway) ................................................................................................ 31 Transfers and Timed Transfers ............................................................................................................... 31 Layover .................................................................................................................................................... 32 Loading Standard (Vehicle Load) ............................................................................................................ 32 PASSENGER AMENITIES AND INFORMATION ..................................................................................... 32 Bus Shelters and Benches ....................................................................................................................... 32 Public Timetable Availability ............................................................................................................... 32 Bus Color and Logo ............................................................................................................................. 33 Vehicle Identification Sign....................................................................................................................... 33 Vehicle Accessibility ................................................................................................................................ 33 PERFORMANCE STANDARDS ............................................................................................................... 33 Passenger Productivity ............................................................................................................................ 33 Schedule Adherence (On time Performance) ......................................................................................... 34 Monitoring Time points ...................................................................................................................... 35 Time Point checks: .................................................................................................................................. 35 On‐Going Evaluation ............................................................................................................................... 35 New Services ........................................................................................................................................... 36 Service Expansion Policy ......................................................................................................................... 36 3. Requirement to Set System Wide Service Policies (Chapter V, part III) ............................................. 37 Vehicle assignment ................................................................................................................................. 37 3 | P a g e Transit Security ....................................................................................................................................... 37 4. Requirement to Evaluate Service and Fare Changes (Chapter V, part III) .......................................... 38 Fare Changes ........................................................................................................................................... 38 Service Changes ...................................................................................................................................... 38 5. Requirement to Monitor Transit Service (Chapter V, part IV) ............................................................ 38 On‐Board Survey ..................................................................................................................................... 38 Ridership ................................................................................................................................................. 40 Ridership Comparison 2004 and 2009 ................................................................................................... 40 Appendix ..................................................................................................................................................... 41 4 | P a g e INTRODUCTION LexTran (The Transit Authority of the Lexington-Fayette Urban County Government) Lexington's public transportation system has been in existence in its current form since December 1, 1973. LexTran operations are located on approximately 159,114 square feet of land located at 109, 105 and 101 Loudon Avenue in Lexington, KY 40508. LexTran also rents offsite office space at 105 Spruce Street Suite 125 Lexington KY 40507. LexTran’s service area is Fayette County Kentucky. POLICY STATEMENT LexTran, assures that no person shall on the grounds of race, color, national origin, or sex as provided by Title VI of the Civil Rights Act of 1964, and the Civil Rights Restoration Act of 1987 (P.L. 100.259) be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity. LEXTRAN further assures every effort will be made to ensure nondiscrimination in all of its programs and activities, whether those programs and activities are federally funded or not. In the event that LEXTRAN distributes federal assistance funds to another governmental entity or contractor, LEXTRAN will include Title VI language in all written agreements and will monitor for compliance. 1. REQUIREMENT TO PROVIDE AN ANNUAL TITLE VI CERTIFICATION AND ASSURANCE (CHAPTER IV, PART 1) This requirement is fulfilled when LexTran submits its annual certification and assurance to the FTA. 2. REQUIREMENT TO DEVELOP TITLE VI COMPLAINT PROCEDURES (CHAPTER IV, PART 2) Title VI Complaint Process If an individual would like to file a complaint, LexTran will follow the process detailed below: 1. RIGHT TO FILE A COMPLAINT. Any person who believes himself or any specific class of persons to be subjected to discrimination prohibited by Title VI may by himself or by a representative file a written complaint with LexTran. A complaint must be filed no later than 180 days after the date of the alleged discrimination. 5 | P a g e 2. COMPLAINT ACCEPTANCE. Once a complaint has been accepted by LexTran for investigation, LexTran strives to complete a Title VI complaint investigation within 90 days of the date that LexTran accepts the complaint for investigation. 3. INVESTIGATIONS. The investigation will include, where appropriate, a review of the pertinent practices and policies of the organization, the circumstances under which the possible noncompliance occurred, and other factors relevant to a determination as to whether LexTran has failed to comply with Title VI. 4. LETTERS OF FINDING AND RESOLUTION. After the investigation has been completed LexTran will transmit to the complainant one of the following two letters based on its findings: a. A letter of resolution that explains the steps LexTran has taken or promises to take to come into compliance with Title VI. b. A letter of finding that states that the complaint is unfounded and that LexTran is indeed in compliance with Title VI. This letter will include a detailed explanation of why LexTran has determined that the issue in question is not a violation of Title VI. The letter will also include notification of the complainant’s appeal rights. 5. APPEALS PROCESS. The letter of finding will offer the complainant the opportunity to provide additional information that would lead LexTran to reconsider its conclusions. The parties in the complaint must provide this additional information within 60 days of the date the letter of finding was transmitted. After reviewing this information, LexTran will respond either by issuing a revised letter of resolution or finding to the appealing party, or by informing the appealing party that the original letter of resolution or finding remains in force. LexTran will transmit these letters within 60 days of receiving the appeal. 3. REQUIREMENT TO RECORD TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS (CHAPTER IV, PART 3) There are no current or past investigations, lawsuits or complaints against or involving LexTran with respect to Title VI. 6 | P a g e 4. REQUIREMENT TO PROVIDE MEANINGFUL ACCESS TO LEP PERSONS (CHAPTER IV, PART IV) LIMITED ENGLISH PROFICIENCY PLAN Introduction Most individuals in the United States read, write, speak and understand English. However, there are many individuals whose primary language is not English. Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak or understand English can be limited English proficient, or “LEP.” This language barrier may prevent individuals from accessing services and benefits. For purposes of Title VI and the LEP Guidance, persons may be entitled to language assistance with respect to a particular service, benefit, or encounter. Basis for LEP There are two pieces of legislation that provide the foundation for the development of an LEP plan: Title VI of the Civil Rights Act of 1964, and Executive Order 13166. In some circumstances, failure to ensure that LEP persons can effectively participate in federally assisted programs may constitute discrimination based on national origin under Title VI. In order to comply with Title VI, agencies should take reasonable actions for competent language assistance. Executive Order 13166 clarifies requirements for LEP persons under Title VI. The Executive Order requires the agency to examine the services it provides and develop and implement a system by which LEP persons can meaningfully access those services. Covered individuals United States citizenship does not determine whether a person is LEP. It is possible for a person who is a United States citizen to be LEP. It is also possible for a person who is not a United States citizen to be fluent in the English language. Title VI is interpreted to apply to citizens, documented non-citizens, and undocumented non-citizens. Who is a limited English proficient individual? Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English can be limited English proficient. Households where no one over age 14 speaks English “very well” are linguistically isolated. 7 | P a g e Requirements The U. S. Department of Transportation (DOT) issued its Policy Guidance Concerning Recipient’s Responsibilities to Limited English Proficient (LEP) Persons [Federal Register: December 14, 2005 (Volume 70, Number 239)]. This policy states that DOT recipients are required to take reasonable steps to ensure meaningful access to programs by LEP persons. This coverage extends to the recipient’s entire program. To do this, the recipient should: (1) Conduct the four-factor analysis; (2) Develop a Language Access Plan (LAP); and (3) Provide appropriate language assistance. There are four factors for agencies to consider when assessing language needs and determining what steps they should take to ensure access for LEP persons: 1) The number or proportion of LEP persons eligible to be served or likely to be encountered by a program, activity or service of the recipient; 2) The frequency with which LEP individuals come in contact with the program; 3) The nature and importance of the program, activity or service provided by the recipient to people’s lives; and 4) The resources available to the recipient and costs. A brief description of the self-assessment undertaken in each of these areas follows. 1. Four-factor analysis 1. The number or proportion of LEP persons served or encountered in the eligible service population ("served or encountered" includes those persons who would be served or encountered by the recipient if the persons received adequate education and outreach and the recipient provided sufficient language services) 8 | P a g e Fayette County, Kentucky Total Population and Race Breakdown Race White Black or African American American Indian & Alaska Native Asian Native Hawaiian and Other Islander Hispanic Source: www.census.gov 2008 282,114 227,833 41,439 1,665 9,864 0 8,179 % 100% 80.80% 14.70% 0.60% 3.50% 0 2.90% 2006 270,789 214,535 37,362 298 8,849 91 14,376 % 100% 79% 14% 0.11% 3% 0.03% 5% 2000 260,512 211,120 35,116 507 6,407 83 8,561 % 100% 81% 13% 0.19% 2% 0.03% 3% (http://factfinder.census.gov/servlet/ADPTable?_bm=y&geo_id=05000US21067&-qr_name=ACS_2008_1YR_G00_DP5&-context=adp&-ds_name=&-tree_id=308&_lang=en&-redoLog=false&-format=) Population 5 years and over English only Language other than English Speak English less than "very well" Spanish Speak English less than "very well" Other Indo‐European languages Speak English less than "very well" Asian and Pacific Islander languages Speak English less than "very well" Other languages Speak English less than "very well" 262,420 236,360 90.10% 26,060 9.90% 12,697 4.80% 14,502 5.50% 8,792 3.40% 4,610 1.80% 1,084 0.40% 6,003 2.30% 2,588 1.00% 945 0.40% 233 0.10% Spanish speakers are the primary LEP persons likely to be encountered by LexTran. In Fayette County the 2008 American Community Survey 1-Year Estimates shows that the total population of individuals 5 and over was 236,360. Of the total population 4.80% or 12,697 persons spoke English less than “very well”. Of the total population 5.5% of the population, 14,507 persons spoke Spanish. Of the 14,507 persons, 61% or 8,792 persons reported speaking English less than very well.” These Spanish-speaking LEP persons comprise 3.4% of the total population of Fayette County in 2008. Of the other languages spoken 3,905 individuals, 1.5% reported speaking English less than very well. According to the Kentucky Refuge Ministries, a non-profit charitable resettlement agency authorized by the US State Department to assist refugees legally admitted 9 | P a g e to the US 979 refugees from other countries have arrived in Lexington from 20002010. Refugee Arrivals for KRM-Lexington KY 2000 - May 2010 Albania 51 Azerbaijan 1 Bangladish 1 Belarus 2 Benin 4 Bhutan 100 Bosnia 26 Burma 4 Burundi 70 Central Africian Republic 2 Congo 150 Democratic Republic Congo 247 Cuba 35 Dominican Republic 1 Ethiopia 4 Iraq 127 Lebanon 1 Liberia 90 Martinique 5 Republic Moldooa 3 Russian Federation 13 Rawanda 3 Sierra Leone 2 Sudan 2 Togo 6 Uzbekistan 25 Vietnam 4 979 The English as a second language program for the same time frame reports: Language Language Count Spanish 2284 Japanese 204 Arabic 136 Chinese, Mandarin 131 Swahili 93 10 | P a g e French 73 Nepali 51 Korean 41 Vietnamese 41 Russian 30 Kirundi 30 Ukrainian 22 Gujarati 22 Tagalog 19 Creole 18 Telugu 18 Albanian 18 Urdu 17 Hindi 16 Twi 15 Cambodian (Khmer) 11 Tamil 11 Farsi 11 Portuguese 10 Krahn-Liberian English 9 11 | P a g e Bosnian 9 Bulgarian 9 Lingala 9 Marathi 7 Malayalam 7 Amahric 7 Bengali 7 Indonesian 6 German 5 Turkish 5 Ewe 4 Luganga 4 Pohnpeians 3 Fanti 3 Mandingo 3 Oriya 3 Hungarian 2 Thai 2 Ghanaian 2 Uzbek 2 Konkani 2 12 | P a g e Afrikaans 2 Yoruba 2 Chinese, Yue (Cantonese) 2 Swedish 2 Akan 2 Tigriga 2 Romanian 2 Kannada 2 Burmese 2 Indian 2 Shona 2 Kiswahili 2 Panjabi 2 Mende 1 Mandinka 1 Waray-Waray 1 Khmer 1 Lombard 1 Sunda 1 Sinhala 1 Other 1 13 | P a g e Croatian 1 Kissi 1 Punjabi 1 Greek 1 Tagee 1 Luganda 1 Armenian 1 Haitian, Creole French 1 Italian 1 Persian 1 Lithuanian 1 Grand Total 3477 These are the 55 languages that have been served by Saint Joseph Health System, one of the Major Hospitals in the city, since the year 2000. AFR Afrikaans BEN Bengali CHI Chinese ALB Albanian BOS Bosnian CRO Croatian AMH Amharic BUL Bulgarian DAN Danish ARA Arabic CAM Cambodian (Khmer) FAR Farsi ARM Armenian ASL American Sign Language 14 | P a g e CAN Cantonese CEB Cebuano FIN Finnish FLE Flemish FRE French LAO Laotian SIN Sinhalese FRC French Creole LIN Lingala SOM GER German MAM Mam SPA Spanish GUJ Gujarati MAN Mandarin SWA Swahili HAI MIX Mixteco TAG Tagalog (Philippines) Haitian Creole HEB Hebrew NEP Nepalí HIN Hindi PAN JAP Japanese PAS Pashto KAN PER Persian Kanjobal POL Polish KOR Korean POR Portuguese KOS Kosovo PUN Punjabi KUN RUS Russian Kunama TAI Taiwanese Pangasinan KIR Kirundi Somali TUR Turkish TWI Twi UKR Ukrainian URD Urdu VIE Vietnamese Top five Language Usage (Saint Joseph Hospital Lexington KY 2005-2009) 2005 % 2006 % 2007 % 2008 % 2009 % 1 Spanish 93.5 Spanish 91.2 Spanish 86.9 Spanish 77.1 Spanish 75.3 2 Japanese 2 French Creole 1.3 Arabic 0.8 Chinese 1.3 Ukranian 2.6 3 Russian 1.1 Russian 1.2 Japanese 0.6 Swahilli 0.7 Russian 1.7 4 French 0.8 Arabic 0.8 German 0.6 Japanese 0.5 Arabic 1.2 5 Vietnamese 0.6 Japanese 0.8 Mandarin 0.5 Albanan 0.5 Mandarin 0.7 Phone system statistics January 1st - December 31st 15 | P a g e 2. The frequency with which LEP persons come into contact with the program As we have service every day, LEP persons may come into contact with LexTran 24 hours a day 7 days a week. The greatest opportunity for LEP individuals to come in contact with our systems is on the bus, at our customer service office and on the phone. This includes using are phone systems after hours when all our offices are closed. Based on the information above the greatest potential is for our personnel to come in contact with a Spanish speaking LEP person. To date, the most frequent contact between LEP persons is with bus drivers. Translated documents have included postings on the buses related to fares and transit rules written in Spanish and information request also in Spanish as illustrated below. 3. The nature and importance of the program, activity, or service provided by the program; Public transportation is vital to many people’s lives. According to the Department of Transportation’s Policy Guidance Concerning Recipient ‘s Responsibilities to Limited English Proficient (LEP,) Persons, “Providing public transportation access to LEP persons is crucial. An LEP person’s inability to utilize effectively public transportation may adversely affect his or her ability to obtain health care, or education, or access to employment.” 16 | P a g e 4. The resources available and costs to the recipient. LexTran assessed their available resources that could be used to provide language assistance. This included identifying bilingual staff, reviewing existing items that involve professional translation services, determining which documents should be translated, and deciding what level of staff training is needed. After analyzing the four factors outlined in U. S. DOT policy guidance, LexTran developed the following plan for providing language assistance to LEP persons. Develop a Language Access Plan (LAP) a. Identifying LEP individuals who need language assistance; We track some LEP individuals via our daily operations report with a code called (FLE) foreign language event – when operators have passengers who speak little or no English. Our customer service agents and our receptionist also have the ability to document when these calls come in. b. Developing language assistance measures; LexTran has activated a contract with a firm to serve as a telephone service line interpreter. We have a language translator via Babel fish on our website. We have a RFP out for a new website and have asked for a more robust translation mechanism to be added. We will also contract with a company akin to our interpreter service for printing services beyond the translated documents we currently have. 17 | P a g e Limited English Proficiency Procedure (LEP) The purpose of this policy is to provide assistance to LEP passengers. This procedure includes operators, Customer Service Representatives, street supervisors and dispatchers. LexTran’s operations program falls under the direct supervision of the Director of Operations and includes all operators and supervisors. LexTran Customer Service falls under the Director of Community Affairs. LexTran policy is that whenever a passenger with LEP boards the bus the bus operator is responsible for presenting a flash card to the passenger to help identify which language the passenger speaks. Customer service representatives are responsible for assisting passengers with language barriers by contacting the interpreter operator for assistance in communicating with passenger. It is the responsibility of the dispatcher to dispatch a street supervisor to assist the bus operator whenever he/she calls in with an LEP request. The dispatcher is also responsible for logging the occurrence on the daily operations report. 18 | P a g e Process All operators will be equipped with a language identification flash card. When a passenger boards their bus and the passenger cannot speak English the operator will use the flash card to help identify the passenger’s language. After the operator identifies the language the passenger speaks he/she will contact dispatch, let them know the language and request that a street supervisor meet them en-route. If the operator is near the Transit Center he/she will take the passenger to the customer service window and a CSR will assist. Once the street supervisor or CSR makes contact with passenger he/she will follow the following protocol. Contact Optimal Phone Interpreters at 1-877-746-4674. Tell the operator what language is needed and your location. At this point the operator will return with an interpreter. Stay on the line and follow the instructions provided. The interpreter will need the street supervisor or customer service representative, as well as the passenger, as part of the conversation. 19 | P a g e Once the interpreter completes the translation assist passengers to their proper bus and communicate instructions to the bus operator. c. Training staff We are in the process of identifying means of training staff such as with frequently used words. d. Providing notice to LEP persons Presently some of our signage and print material is already produced in Spanish. We will be able to print documents in other languages via the written translation services at a later date. Additionally we have the Census’s I speak card for use. e. Monitoring and updating the plan. This plan is designed to be flexible, and should be viewed as a work in progress. As such, it is important to consider whether new documents and services need to be made accessible for LEP persons, and also to monitor changes in demographics and types of services, and to update the LEP plan when appropriate. At a minimum, LexTran will follow the Title VI Program update schedule for the LEP plan. Each update should examine the following: • How many LEP persons were encountered? • Is the existing language assistance meeting the needs of LEP persons? • Has there been a change in the types of languages where services are needed? • Have available resources, such as technology, staff and finances changed? • Were any complaints received? • Do staff members understand the LEP plan policies and procedures? There are several methods that can be used to assist in answering these questions. One method is to review customer comments and complaints to determine if services are accessible to Spanish speakers. Census data will also be reviewed as it becomes available to determine changes in the LEP population. Future considerations for the LEP plan include: • Translating other brochures (Bike and Ride) into Spanish • Providing group travel training to LEP persons by working with bilingual staff 20 | P a g e This plan outlines five key areas of an effective LEP strategy: Identifying LEP individuals who need language assistance, primarily through Census data; Language assistance measures, including written and oral language services, and responding to LEP persons on the telephone, in writing and in person; Training staff, including coach operators, customer service representatives and management employees; Providing notice to LEP persons through both oral and written communications; and Monitoring and updating the LEP plan through a variety of means. 3. Provide appropriate language assistance. As mentioned above this is to be handled via telephone interpretation services and via print media, some of which is currently in place. We will install a real-time IVR in the next two years that will also provide information in Spanish. Though the percentages are small we know that there are other languages spoken in the area besides Spanish. We are attempting to determine those languages. • When open houses or public meetings are held, set up a sign-in table, and have a staff member greet and briefly speak to each attendee, in order to informally gauge his/her ability to speak and understand English. • Have the Census Bureau’s “I Speak Cards” at various events. While staff may not be able to provide translation assistance at the time, the cards are an excellent tool to identify language needs for future events/meetings. • Post a notice of available language assistance at open houses/public meetings to encourage LEP persons to self-identify. Dissemination of the Limited English Proficiency Plan LexTran will post the LEP Plan on its website at www.lextranonthemove.org. Copies of the plan will be provided to any person or agency requesting a copy. LEP persons may obtain copies/translations of the plan upon request. Any questions or comments regarding this plan should be directed to: Jared A. Forte Assistant General Manager LexTran – Transit Authority of Lexington, Kentucky 21 | P a g e 109 West Loudon Avenue Lexington KY, 40508 Phone: (859) 255-7756 ext: 205 Fax: (859) 233-9446 www.lextran.com [email protected] 5. REQUIREMENT TO NOTIFY BENEFICIARIES OF THEIR RIGHTS UNDER TITLE VI (CHAPTER IV, PART V) LexTran notifies beneficiaries of their rights under Title VI via the following: On our buses under the fare information The Transit Authority of Lexington, Kentucky, LEXTRAN, assures that no person shall on the grounds of race, color, national origin, or sex as provided by Title VI of the Civil Rights Act of 1964, and the Civil Rights Restoration Act of 1987 (P.L. 100.259) be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity. LEXTRAN further assures every effort will be made to ensure nondiscrimination in all of its programs and activities, whether those programs and activities are federally funded or not. Customer complaints and or request for more information about this and Title VI may be directed to LexTran through direct mail, electronic mail, web-site customer comment form, customer comment card and by telephone. En nuestros autobuses conforme a la información del precio La autoridad del tránsito de Lexington, Kentucky, LEXTRAN, asegura que ninguna persona sobre la base de la raza, del color, del origen nacional, o del sexo en la manera prevista por Title VI del acto de las derechas civiles de 1964, y el acto de la restauración de las derechas civiles de 1987 (P.L. 100.259) se excluya de la participación adentro, se niegue las ventajas de, o se sujete de otra manera a la discriminación bajo cualquier programa o actividad. LEXTRAN más futuro asegura todo lo posible será hecho para asegurar el nondiscrimination en todas sus programas y actividades, si esos programas y actividades federal están financiados o no. Las quejas del cliente y o la petición más información sobre este y el título VI se pueden dirigir a LexTran a través del correo directo, correo electrónico, forma de comentario del cliente del Web site, tarjeta del comentario del cliente y por el teléfono. 22 | P a g e At our Training Center, Transit Center and at our Administrative Office LexTran, The Transit Authority of the Lexington Fayette Urban County Government and Lexington Kentucky hereby gives public notice that it is the policy of the Authority to assure full compliance with Title VI of the Civil Rights Act of 1964, the Civil Rights Restoration Act of 1987, Executive Order 12898 on Environmental Justice, and related statutes and regulations in all programs and activities. Title VI requires that no person in the United States of America shall, on the grounds of race, color, sex, or national origin, be excluded from the participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity for which LexTran receives federal financial assistance. Any person who believes they have been aggrieved by an unlawful discriminatory practice under Title VI has a right to file a formal complaint with LexTran. Customer complaints and or request for more information about this and Title VI may be directed to LexTran through direct mail, electronic mail, web-site customer comment form, customer comment card and by telephone. En nuestro centro de formación, centro del tránsito y en nuestra oficina administrativa LexTran, la autoridad del tránsito del gobierno urbano del condado de Lexington Fayette y Lexington Kentucky da por este medio el aviso público que es la política de la autoridad para asegurar conformidad completa con el título VI del acto de las derechas civiles de 1964, el acto de la restauración de las derechas civiles de 1987, el decreto 12898 en justicia ambiental, y los estatutos relacionados y las regulaciones en todos los programas y actividades. El título VI requiere que ninguna persona en los Estados Unidos de América, sobre la base de la raza, color, sexo, u origen nacional, para ser excluido de la participación adentro, se niegue las ventajas de, o se sujete de otra manera a la discriminación bajo cualquier programa o actividad para los cuales LexTran reciba ayuda económica federal. Cualquier persona que crea que han sido agraviados por una práctica discriminatoria ilegal bajo título VI tiene una derecha de archivar una demanda oficial con LexTran. Las quejas del cliente y o la petición más información sobre este y el título VI se pueden dirigir a LexTran a través del correo directo, correo electrónico, forma de comentario del cliente del Web site, tarjeta del comentario del cliente y por el teléfono. On Our Website LEXTRAN - service LexTran is committed to providing non-discriminatory service. To obtain more information about this and TitleVI or to file a discrimination complaint: Click here 23 | P a g e On our schedules Non-Discriminatory Service LexTran is committed to providing non-discriminatory service. Customer complaints or request for information about this and Title VI may be directed to LexTran through direct mail, electronic mail, web-site customer comment form, customer comment card and by telephone. En nuestros horario Servicio no discriminatorio LexTran está confiado a proporcionar servicio no discriminatorio. Las quejas o la solicitud de información del cliente sobre este y el título VI se pueden dirigir a LexTran a través del correo directo, correo electrónico, forma de comentario del cliente del Web site, tarjeta del comentario del cliente y por el teléfono. (Spanish to be added at the next printing) 6. REQUIREMENT TO PROVIDE ADDITIONAL INFORMATION UPON REQUEST (CHAPTER IV, PART VI) This requirement is acknowledged. 7. REQUIREMENT TO PREPARE AND SUBMIT A TITLE VI PROGRAM (CHAPTER IV, PART VII) Summary of public outreach LEXTRAN SEEKS PUBLIC INPUT ON DOWNTOWN CIRCULATOR Monday, November 5, 12:00-1:00 pm at the Lexington Public Library, 140 East Main Street Friday, November 9, 12:00-1:00 pm at the Government Center Ballroom, 200 East Main Street Monday, November 12, 5:30-7:00 pm, Commerce-Lexington, 330 East Main Street The scheduled public meetings will incorporate the use of remote keypad technology acquired through a federal grant by UK and LexTran . This technology will allow participants to “key-in” responses to various questions for instantaneous viewing. --------------------------------------Have a route suggestion? Ever wonder why LexTran operates the way it does? Or, do you just have questions about riding the bus? Here’s your chance to meet face 24 | P a g e to face with LexTran General Manager Rocky Burke and let him know your ideas for staying “On the Move.” WHEN: Wed., July 23, 2008, 6:00-7:00 pm WHERE: Lexington Public Library, 140 E. Main Meeting Room “C” 4th Floor WHEN: Tuesday, Nov. 18, 2008, 6:00-7:00 pm WHERE: Northside Lexington Public Library, 1733 Russell Cave Rd Reservations not needed. For more info, call 253-INFO. LEXTRAN PUBLIC MEETING: SOUTHSIDE CIRCULATOR WHEN: THURSDAY, AUGUST 21, 2008, 6:00-7:00 pm WHERE: Anchor Baptist Church, --------------------------------------------------Public Meetings Scheduled to Discuss Transit Planning LEXINGTON, KY: April 20, 2009- Preliminary findings of a comprehensive operational analysis will be presented to the general public during a series of scheduled public meetings: • Monday April 27, 12-1:30 pm- Lexington Public Library Eagle Creek Branch 101 North Eagle Creek Drive • Monday April 27, 5-7 pm- Lexington Public Library Village Branch 2185 Versailles Rd. • Wednesday, April 29, 5-7 pm- Lexington Public Library Central Library 140 E. Main Street • Tuesday, May 12, 5-7 pm- Forcht Bank, 2404 Sir Barton Way • Wednesday, May 13, 12-1:30 pm- Lexington Public Library Northside Branch 1733 Russell Cave Rd. • Thursday, May 14, 12-1:30 pm-, Lexington Public Library Beaumont Branch 3080 Fieldstone Way The operational analysis performed by R.L.S. & Associates is based on results of passenger surveys, rider counts and stakeholder interviews. Members of the public will be given an opportunity to review results and recommendations and provide input of their own. 25 | P a g e Public meetings regarding COA March 2010 • Monday March 1st—2:00 Tates Creek Library • Tuesday March 2nd—2:00 Downtown Central Library • Thursday March 4th—6:00 Northside Russell Cave Library th • Tuesday March 9 —6:00 KY Blood Center Beaumont GUIDANCE ON CONDUCTING AN ANALYSIS OF CONSTRUCTION PROJECTS (CHAPTER IV, PART VII) When completing construction projects we prepare the documentation for a categorical exclusion. 26 | P a g e GUIDANCE ON PROMOTING INCLUSIVE PUBLIC PARTICIPATION (CHAPTER IV, PART IX) When conduction public outreach and public involvement activities LexTran seeks input from minority, low-income, disabled and LEP populations. LexTran widely broadcast information about our public activities (the city’s government information channel, flyers on buses, notices on the website, notices in multiple papers including non-English publications, etc.) LexTran also schedules public involvement meetings in transit-accessible locations to ensure the widest possible participation from all groups. LexTran partnered with the University of Kentucky in a grant program and purchased over two hundred key pads from turning point 27 | P a g e with the related computer and equipment to allow for live anonymous surveying during public meetings. 1. REQUIREMENT TO COLLECT DEMOGRAPHIC DATA (CHAPTER V, PART I) LexTran Currently makes use of Option C via a combination of Options A & B: Demographic and Service Profile Maps, Charts and survey. 1. BASE MAP The base map is found in the appendix. 28 | P a g e 2. DEMOGRAPHIC MAP The demographic map is in the appendix. 3. CENSUS CHART The census tract information is in the appendix. 4. SURVEYS The results from the last survey are in the appendix. 2. REQUIREMENT TO SET SYSTEM WIDE SERVICE STANDARDS (CHAPTER V, PART II) LexTran provides fixed route service within the Lexington urban area and ADA paratransit service throughout Fayette County. Its route structure is intended to address transportation needs resulting from a dispersed development pattern with a multi-centered regional transit system that includes connections between neighborhoods and communities within the urban area and Fayette County. LexTran asked the consultant who completed our last Comprehensive Operational Analysis to help us develop service standards. These Service Standards provide a tool for the guidance of those responsible for planning and operating the LexTran system, and can be used to evaluate performance once the routes comprising this system are in operation. Overall Fixed Route Design The LexTran fixed route system should have elements that are consistent throughout the system. This consistency is important for the public to understand how the system can be used. The following are basic parameters of the design of the system. ♦ Routes should be separated into functional categories. The level of service on individual routes will vary by its function. ♦ LexTran routes should be divided into four categories for the purpose of determining route design and performance standards. These are Radial routes, Express routes, Cross-town routes, and Community Circulator services. 29 | P a g e ♦ Routes should be predominantly bi-directional in nature. Large one-way loops should be avoided if possible. ♦ Travel times between major destinations should be minimized by providing some routes that operate on the fastest and most direct route, and by scheduling timed transfers between routes to minimize wait times. These Service Standards follow these general guidelines. They provide a tool for the guidance of those responsible for planning and operating the LexTran system, and can be used to evaluate performance once the routes comprising this system are in operation. In some cases, all design and performance standards may not be met because of cost, personnel, equipment, or other constraints. Every effort should be made to provide service that is in conformance with these standards. The process of identifying routes or portions of routes that either exceed or do not reach these standards should be used to guide decisions in response to decreases or increases in funding for LexTran service. Operating Environment LexTran routes should operate primarily along major arterials. It should also run on some residential collector streets that are suitable for operation of LexTran buses, and in some cases limited access highways. Because of the need to minimize the impact of buses in residential areas, the use of smaller sized buses will be considered on certain routes that circulate through residential areas. Service Area Service coverage should be defined as the area within 1/3 mile walking distance of the nearest bus stop. LexTran shall serve to the extent feasible, all major employers, hospitals, schools, and public housing within the Lexington urban area. Passenger Stops In order to provide a safe environment for passenger boarding and alighting, LexTran has a policy of formally designating bus stop locations. All bus stops will have signs indicating their location. Efforts will be made to include route and schedule information at bus stops. The spacing of bus stops will vary by location, but as a general rule, they should be located every 0.2 miles. Hours of Operation The hours of operation should be based on demand and relate to the route’s function. The maximum span of service is from 5:30 a.m. to 12:00 a.m. on weekdays and Saturdays, and from 5:30 a.m. to 9:00 p.m. on Sundays. 30 | P a g e Service Levels Service levels for each route should be based on demand. To foster a systematic approach, two levels of service are defined for different operating time periods. The service level should be consistent through each time period. ♦ Peak service is generally between the hours of 6:00 a.m. and 9:00 a.m., and between 3:00 p.m. and 6:00 p.m. ♦ Off-peak service is provided at all other times including the mid-day period between 9:00 a.m. and 3:00 p.m. and in the evenings and weekends. Every effort should be made to provide coverage throughout most of the service area during the offpeak service periods. But since lower ridership is experience during these times, a reduced number of routes may be operated. Frequency of Service (Vehicle Headway) Each route’s frequency should correspond to demand. Some routes may only operate during the weekday peak period while others may run at all times with relatively high frequencies. Maximum policy headways for Radial, and Express routes are listed below. The maximum headway for crosstown and community circulator routes is 60 minutes. Maximum Headways by Time Period Peak Off-Peak 30 minutes 60 minutes This maximum headway in the off-peak periods should not be exceeded if the route is to be operated. Headways should conform to regularly recurring clock intervals. Transfers and Timed Transfers Scheduled arrival and departure times for LexTran routes having common transfer points should be coordinated to the maximum extent feasible. Dwell time should be avoided on routes for mid-route transfer points. Routes should be designed to link in patterns that are consistent with consumer needs and desires, but also meet acceptable travel times. Free transfers are provided by LexTran drivers upon request by passengers when boarding buses. 31 | P a g e The main transfer location is the downtown transit center. Transfers are accepted at other locations where routes intersect. The transfer ticket is only valid on the next scheduled trip to which the passenger is transferring. Transfers cannot be used for return trips. Layover The amount allocated for layover time will be a minimum of 7 percent of the total cycle time. Additional layover time may be provided as necessary to achieve clock headways. Layover should be avoided at locations where through passengers are expected. This includes mid-route locations and along one-way loops. Loading Standard (Vehicle Load) Maximum loading standards are to ensure that most passengers will have a seat for at least the majority of their trip. The maximum average load factor is calculated by dividing the total number of passengers passing the maximum load point by the number of seats passing the maximum load point during the operating period being considered. Since this is an average, individual trips may exceed the standard. The loading standard for LexTran routes should be a maximum average load factor of 1.2 during the weekday peak periods, and 1.0 at all other time periods. For individual trips, this should not be exceeded for time periods greater than 10 minutes. PASSENGER AMENITIES AND INFORMATION Bus Shelters and Benches Bus stops with more than 25 passengers boarding on a daily basis should have a bus shelter. Benches should be provided at bus stops with more than 15 passengers per day. In addition, since a large percentage of LexTran passengers transfer, passenger amenities should be provided at all major transfer locations. These key bus stops should have bus shelters or other means of weather protection for passengers. Schedule information for all routes should be displayed or available to passengers. Public Timetable Availability Route and schedule brochures will be available upon request from bus drivers and from LexTran office clerks. They will also be displayed and made available at the downtown transit center and a number of other employment and activity centers throughout the City as determined appropriate by LexTran staff. 32 | P a g e Bus Color and Logo For easy identification of LexTran services, a LexTran color scheme and logo will be designed and updated from time to time. This will be used consistently on LexTran buses, letterheads, tickets, bus stop signs, and other printed materials or objects. Vehicle Identification Sign Identification signs will display the route the bus is traveling on at all times. When routes are interlined at the downtown transit center, the signs will be changed upon entering the downtown area and before reaching the transit center. Vehicle Accessibility All LexTran vehicles should be wheelchair lift equipped and all LexTran vehicles and facilities will be accessible to disabled persons as required by the Americans with Disabilities Act. PERFORMANCE STANDARDS Passenger Productivity LexTran should regularly evaluate the performance of individual bus routes based upon the revenue to cost ratio, passengers per revenue hour and passengers per revenue mile. It will assure that each route performs at a rate equal to at least 50% of the system wide average for that transit mode. Other performance standards, such as on-time performance, should also be monitored. Standards for individual route productivity should be based on actual experience. Current productivity levels should be used to determine the category that each route is placed in. The “good” category is all routes above the system average. The “satisfactory” category is all routes about 75 percent of the system average. The “marginal” category is all routes between 50 and 75 percent of the system average. The “unsatisfactory” category is all routes under 50 percent of the system average. These should be refined based on actual experience after the proposed route changes are implemented. Separate standards are created for radial routes, crosstown/circulator routes, and express routes. Performance Standards Radial Routes Category 33 | P a g e Passengers/ Passengers/ Farebox Good Satisfactory Marginal Unsatisfactory Revenue Hour >22 16-22 11-16 <11 Revenue Mile >1.5 1.1-1.5 0.8-1.1 <0.7 Recovery Rate >15% 10-15% 5-10% <5% Crosstown/Circulator Routes Category Good Satisfactory Marginal Unsatisfactory Passengers/ Revenue Hour >15 10-15 7-10 <7 Passengers/ Revenue Mile >1.2 0.7-1.2 0.4-0.7 <0.4 Revenue/Cost Passengers/ Revenue Hour >10 7-10 4-7 <4 Passengers/ Revenue Mile >1.0 0.6-1.0 0.3-0.6 <0.3 Revenue/Cost >10% 7-10% 4-7% <4% Express Routes Category Good Satisfactory Marginal Unsatisfactory >8% 5-8% 3-5% <3% Those routes performing marginal or unsatisfactory will be scrutinized for ways to improve productivity. Routes significantly exceeding the “good” standard will be considered for improved service. Schedule Adherence (On time Performance) It is expected that a critical success factor for LexTran routes will be providing convenient and reliable transfers. Therefore, on-time performance will be closely monitored. The routes with unsatisfactory performance will be candidates for corrective action. On‐Time Performance Category Good Satisfactory Marginal Unsatisfactory 34 | P a g e Percent Between 0 and 5 minutes Late >90% 85‐90% 80‐85% <80% Monitoring Time points Time Point checks: • Daily each LexTran street supervisor select at least 15 to 20 time point locations throughout the system to conduct checks. • The supervisor will sit and wait at the schedule time point and will log in the actual time the bus arrives and departs. • Buses are considered late if they depart a time point more than 5 minutes late. • LexTran on time performance goal is 95% On-Going Evaluation Data determining the total number of passengers, the number of passengers per vehicle mile and vehicle hour, and the revenue/cost ratio, for each route and service should be collected on a monthly basis using farebox-operating records. Other performance indicators such as schedule adherence should also be monitored. Performance information for the system and for each individual route should be produced on a monthly basis. This report should show the actual productivity measures for that particular month and be the basis of an on-going evaluation of individual LexTran bus routes. Route evaluation should follow a two-step process. The first step is to identify how each route performs in terms of ridership and cost effectiveness compared with the performance standards. Once this screening process is completed, the second step is a detailed evaluation of each route that is either not performing up to standard or is performing well above average. These routes could be subject to a number of actions including frequency reduction, service span revision, realignment, rescheduling, route consolidation or other restructuring, extensive marketing efforts, or elimination. The period of time that performance indicators are calculated will relate to internal and external reporting requirements. Typically, they should be compiled on a monthly basis. Comparisons with the previous month, the same month for the previous year, and with a two or three year running average should be included to identify trends. The performance achieved by LexTran routes should be used to modify the performance standards. For example, routes categorized as “good” can be those that exceed the system average for the particular measure. Acceptable routes are those falling between 75 and 100 percent of the system average. Marginal routes are between 50 and 75 percent of the system average, while unacceptable routes are below 50 percent of the system average. Routes that fall in the unacceptable 35 | P a g e category in two of the three principle measures will be subject to a detailed analysis. Unacceptable routes should receive a more detailed analysis in step two. At this level in the performance evaluation process, a route’s performance in all standards is analyzed. This detailed evaluation should examine performance by time period, day of week, and route segment. A variety of measures should be considered for action including redesign, schedule reduction, schedule increase, marketing activity, and other actions. Each route should be reviewed annually. Routes should be reviewed more often if ridership trends are negative, special requests for services are received, or other special circumstances are noted. The evaluation process should also include routes with good performance. These should be candidates for more frequent service or some other kind of service increase. New Services Newly established transit routes, after having operated for two years, should operate with performance standards at no less than 50% of the system wide average in two of the three performance measures for its functional category. If a newly established transit route or service fails to operate at the specified level for three consecutive months, following the initial two year period, then LexTran should evaluate alternative means to achieve the productivity standard or the route shall be terminated. Service Expansion Policy Improvements to and expansion of the LexTran system will be based on the LexTran Comprehensive Operational Analysis and the Lexington Area Metropolitan Planning Organization Long Range Transportation Plan. However, the following standard will be used when evaluating a new area for fixed route service: • The combined employment and population density for each census tract to be served should be at least 1,500 per square mile for the majority of the new service area. The evaluation process should also include routes with good performance. These should be candidates for more frequent service or some other kind of service increase. 36 | P a g e 3. REQUIREMENT TO SET SYSTEM WIDE SERVICE POLICIES (CHAPTER V, PART III) Vehicle assignment These are the following procedures that LexTran dispatcher uses when assigning buses: • Due to load capacity the following routes requires 40 foot buses (3 Tates Creek, 4 Newtown, 5 Nicholasville Rd, 6 North Broadway, 7 North Limestone, 8 Versailles Rd, 10 Hamburg Pavilion, 14 UK Commonwealth Stadium and 15 Red Mile Rd). • Due to maneuverability problems the following route requires a 35 foot bus. (1 Georgetown Rd). LexTran assigns buses daily based on the position that the buses are parked the night before the next morning pull out. These buses are assigned to routes from the front roll back until all buses are assigned. Transit Security LexTran has deployed security cameras at our Transit Center and our Administrative/Maintenance Facility. LexTran also contracts with the Local police to have officers stationed at our Transit Center based on the following schedule. Monday- Wednesday 0800-1 200 (4) 1600-2200 (6) Thursday - Saturday 0800-1 200 (4) 1500-2330 (8.5) Sunday 1300-1 700 (4) Total Hours 71.5 We have also deployed cameras on our 55 of our fixed route vehicles. The entire fleet will be outfitted and updated via ARRA funds. LexTran has not 37 | P a g e on a continual basis identified one corridor over another in terms of security and have found that it is in our best interest to cover our entire system; for our passengers, our operators and the Authority itself. 4. REQUIREMENT TO EVALUATE SERVICE AND FARE CHANGES (CHAPTER V, PART III) Fare Changes The last fare increase initiated by LexTran was on July 1, 2001, the regular adult fare was .80 and it was increased to a $1.00. The last service decrease occurred in 2003. This was prior to the passage of a tax referendum providing LexTran with a dedicated source of local funding. We have discussed a fare increase in the future. Service Changes For LexTran a major service change is defined as changes in service that would cause a 25% or greater change in service miles or hours in service. We have only had one service change that met the major service reduction requirement and it was on a non minority route. 5. REQUIREMENT TO MONITOR TRANSIT SERVICE (CHAPTER V, PART IV) The information below is in addition to the Demographic maps/data based on Census Tract information that we use. A Comprehensive Operational Analysis (COA) was initiated in November 2008 and completed in 2009. A ridecheck, which included an on/off passenger count and a running time check, was conducted and tabulated in January 2009. An onboard passenger survey was also conducted during this time, as was demographic research and a compilation of LexTran operational and historical ridership data. A series of stakeholder interviews were also conducted in December 2008 and January 2009. An on-site analysis of each of the LexTran routes was done during the week of March 9, 2009. On-Board Survey A total of 1,238 surveys were completed and verified to create a database that is representative of the total daily weekday ridership. About 25 percent of the ridership, or 3,203 passengers, uses a student fare, down from 41 percent in 2004. Of the total survey respondents, eighty (80) percent reported walking to the bus stop. The next greatest percentage of passengers reported driving to a parking lot, then taking the bus. This group makes up thirteen (13) percent of the passengers. 38 | P a g e Six (6) percent reported getting a ride with someone else, and only one (1) percent reported riding a bicycle to get to the bus stop. Exhibit E- 1 depicts the methods by which passengers reported arriving at the bus stop. Exhibit E-1 Access to the Bus Exhibit E-2 shows the trip purpose for LexTran passengers. The greatest percentage of passengers reported using LexTran service to get to and from work. This makes up thirty-eight (38) percent of the total respondents. Traveling to and from school and college were the second largest percentages of trip purposes. Both of these categories represented fifteen (15) percent each of the total trips for LexTran. Exhibit E-2 39 | P a g e Trip Purpose Ridership On weekdays, Route 9 – Stadium/Greg Page had the highest weekday ridership of all LexTran routes with 2,295 boardings. The second highest was Route 4 – Versailles with 1,224 passengers. Route 3S – Nicholasville Road also has over one thousand passenger boardings on weekdays. The three lowest routes with less than 50 boardings are the Routes 33 – Northside Circulator, 41X – Commuter Express, and 36 – Southside Circulator. The Route 41X – Commuter Express has only two morning inbound and two afternoon outbound trips. On Saturdays, Routes 3S – Nicholasville Road and 4S – Versailles Road have the highest ridership with over 700 passenger boardings. Route 6N – Leestown Road has the lowest Saturday passenger levels among the regular daytime routes. Also on Sundays, Routes 3S – Nicholasville Road and 4S – Versailles Road have the highest ridership. The table below shows the comparison of ridership for each route in the LexTran system in 2004 and currently in 2009. As shown, weekday ridership increased significantly on all routes except for Route 9 – Stadium/Greg Page and Route 31 – True Blue Express. All other routes increased since 2004. Route 7 – Hamburg increased by 121.5 percent, or more than double the 2004 level. RIDERSHIP COMPARISON 2004 AND 2009 40 | P a g e APPENDIX The appendix includes separate attachments for the demographic maps and onboard surveys. 41 | P a g e