Exhibit A Title VI Implementation Plan

City of El Mirage — Regular Meeting (2025-05-06)

Extracted text (via pymupdf) 100608 characters

Title VI Implementation
Plan

May 6, 2025, to May 31, 2028

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Contents | Title VI Implementation Plan

Contents

Title VI Policy Statement............................................................................................................... 3
Title VI Notice to the Public .......................................................................................................... 4
Title VI Notice to the Public – Spanish .......................................................................................... 5
Title VI Complaint Procedures ...................................................................................................... 6
Title VI Complaint Forms ............................................................................................................ 15
Title VI Investigations, Complaints, and Lawsuits ...................................................................... 17
Public Participation Plan ............................................................................................................. 18
Limited English Proficiency Plan ................................................................................................. 26
Non-Elected Committees Membership Table ............................................................................ 52
Monitoring for Subrecipient Title VI Compliance ....................................................................... 53
Title VI Equity Analysis ................................................................................................................ 54
Regional System-Wide Standards and Policies .......................................................................... 55
Service and Fare Policy Changes ................................................................................................ 56
Board Approval for the Title VI Program .................................................................................... 57

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Title VI Policy Statement | Title VI Implementation Plan

Title VI Policy Statement

The City of El Mirage and the Valley Metro Regional Public Transportation Authority (Valley
Metro) policy assures full compliance with Title VI of the Civil Rights Act of 1964 and related
statutes and regulations in all programs and activities. Title VI states that “no person shall on the
grounds of race, color or national origin be excluded from participation in, be denied the benefits
of, or be otherwise subjected to discrimination” under any City of El Mirage and Valley Metro-
sponsored program or activity. There is no distinction between the sources of funding.

The City of El Mirage and Valley Metro also assure that every effort will be made to prevent
discrimination through the impacts of its programs, policies, and activities on minority and low-
income populations. Furthermore, the City of El Mirage and Valley Metro will take reasonable
steps to provide meaningful access to services for persons with limited English proficiency.

When the City of El Mirage / Valley Metro distributes Federal-aid funds to another entity/person,
the City of El Mirage and Valley Metro will ensure all subrecipients fully comply with the City of El
Mirage and Valley Metro’s Title VI Nondiscrimination Program requirements. The City Manager
has delegated the authority to the City Clerk, Title VI Program Coordinator, to oversee and
implement FTA Title VI requirements.

_______________________
J. Crystal Dyches, City Manager

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Title VI Notice to the Public | Title VI Implementation Plan

Title VI Notice to the Public

Notifying the Public of Rights Under Title VI
City of El Mirage and Valley Metro

The City of El Mirage / Valley Metro operates its programs and services without regard to race, color, or
national origin in accordance with Title VI of the Civil Rights Act of 1964. Any person who believes she or
he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with
the City of El Mirage and Valley Metro.

For more information on the City of El Mirage and Valley Metro’s civil rights program, and the procedures
to file a complaint, contact the El Mirage City Clerk, 623-876-2943, (TTY 623-933-3258); email
jboltz@elmirageaz.gov; or visit our administrative office at 10000 N. El Mirage Road, El Mirage, AZ 85335.
For more information, visit https://elmirageaz.gov/404/Dial-A-Ride.

A complainant may file a complaint directly with the City of Phoenix Public Transit Department or the
Federal Transit Administration (FTA) by filing a complaint directly with the corresponding offices of Civil
Rights: City of Phoenix Public Transit Department: ATTN: Title VI Coordinator, 302 N. 1st Ave., Suite 900,
Phoenix AZ 85003 FTA: ATTN: Title VI Program Coordinator, East Building, 5th Floor-TCR 1200 New Jersey
Ave., SE Washington DC 20590

If information is needed in another language, contact 1-800-752-6096. Para información en Español
llame: 1-800-752-6096

The above notice is posted in the following locations: City of El Mirage City Hall, 10000 N. El
Mirage Road, El Mirage, AZ 85335; the City of El Mirage Senior Center, 14010 N. El Mirage Road,
El Mirage, AZ 85335; and all FTA grant-funded transit vehicles.

This notice is posted online at https://elmirageaz.gov/404/Dial-A-Ride.

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Title VI Notice to the Public – Spanish | Title VI Implementation Plan

Title VI Notice to the Public – Spanish

Aviso al Público Sobre los Derechos Bajo el Título VI
City of El Mirage and Valley Metro

La Ciudad de El Mirage / Valley Metro (y sus subcontratistas, si cualquiera) asegura complir con el Título VI
de la Ley de los Derechos Civiles de 1964. El nivel y la calidad de servicios de transporte serán provehidos
sin consideración a su raza, color, o pais de origen.

Para obtener más información sobre la Ciudad de El Mirage and Valley Metro’s programa de derechos civiles,
y los procedimientos para presentar una queja, contacte Ciudad de El Mirage City Clerk, 623-876-2943, (TTY
623-933-3258); o visite nuestra oficina administrativa en 10000 N. El Mirage Road, El Mirage, AZ 85335. Para
obtener más información, visite https://elmirageaz.gov/404/Dial-A-Ride.

El puede presentar una queja directamente con City of Phoenix Public Transit Department o Federal Transit
Administration (FTA) mediante la presentación de una queja directamente con las oficinas correspondientes
de Civil Rights: City of Phoenix Public Transit Department: ATTN Title VI Coordinator 302 N. 1st Ave., Suite
900, Phoenix AZ 85003 FTA: ATTN Title VI Program Coordinator, East Building, 5th Floor –TCR 1200 New
Jersey Ave., SE Washington DC 20590

This notice is posted online at https://elmirageaz.gov/404/Dial-A-Ride.

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Title VI Complaint Procedures | Title VI Implementation Plan

Title VI Complaint Procedures

What is Title VI?
Title VI is a section of the Civil Rights Act of 1964 which requires 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.”
How do I file a complaint?
Any person who believes that he or she has been excluded from participation in, been denied the benefits of,
or otherwise subjected to unlawful discrimination under any Valley Metro or City of Phoenix service, program
or activity, and believes the discrimination is based upon race, color or national origin, may file a formal
complaint with Valley Metro Customer Service or directly with the City of Phoenix. This antidiscrimination
protection also extends to the activities and programs of Valley Metro’s and City of Phoenix’s third- party
Transit Service Provider (TSP) contractors. Valley Metro and the City of Phoenix use the Customer
Assistance System (CAS) to capture all complaints received for the regional transit system. Any such
complaint must be filed within 180 days of the alleged discriminatory act (or latest occurrence).
To submit a complaint online, complete the online complaint form at the following link:
www.valleymetro.org/form/title-vi-complaint-form

Complaints can also be submitted in writing using the Title VI complaint form, or by calling Customer Service
at (602) 253-5000, TTY: (602) 251-2039. Completed and signed forms should be mailed to:

Regional Public Transportation Authority 4600
East Washington Street, Suite 101
Phoenix, AZ 85034
Email:
csr@valleymetro.org
Phone: (602) 253-5000
TTY: (602) 251-2039

The compliant form is located on our website:
https://www.valleymetro.org/about/civil-rights

To file a complaint directly with the City of Phoenix:

Attention: Title VI Coordinator
City of Phoenix Public Transit Department 302 N.
1st Avenue, Suite 900
Phoenix, AZ 85003
Email:
PHXTransitEO@phoenix.gov
Phones: (602) 262-7242
https://www.phoenix.gov/publictransit/title-vi-notice

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Customer Service | Title VI Implementation Plan

Individuals may also file complaints directly with the Federal Transit Administration (FTA) within the 180-
day timeframe:

Federal
Transit
Administration
(FTA)
Attention: Title VI Coordinator
East Building, 5th Floor –TCR 1200
New Jersey Avenue, SE Washington,
D.C. 20590
Customer Service
Complaints received by Valley Metro Customer Service representatives or by the City of Phoenix Title VI
Coordinator will be documented and assigned to the appropriate Transit Service Provider (TSP) (operator
or administrator of the service) responsible for investigation in accordance with federal standards (28 CFR
Part 35 and FTA Circular 4702.1B). The TSP has 30 days to investigate each complaint. If more information
is needed to resolve the case, the TSP may contact the complainant and request additional information.
Complainants must provide additional information within 10 days of the request or the complaint may be
deemed undeterminable and will be administratively closed. Cases may also be administratively closed if a
complainant informs Valley Metro or the City of Phoenix that they no longer wish to pursue the complaint.
Requests to close a complaint can be requested by phone, email or in writing (see contact information above).
Complaints may be administratively closed for non-responsiveness by the complainant.
Following the investigation, all complaints shall be concluded with a determination entered in the CAS
system. The determination entry shall state the investigation determined the complaint was valid1, invalid2,
or undeterminable3. If the investigation determines the alleged Title VI complaint violations of race, color
or national origin discrimination are valid, a detailed corrective resolution to remedy the situation shall be
provided to the complainant. If the investigation results determine there was no alleged Title VI
discrimination based on race, color or national origin, the case will be closed. The complainant shall be
notified of the investigation results in the manner identified (email or phone). A complainant can appeal the
decision within 60 days of notification of the investigation results. Appeals must be submitted to Valley Metro
or the City of Phoenix.
All Title VI complaints and investigations are reviewed by Valley Metro, the Customer Service Administrator
(CSA), and City of Phoenix staff.
For more information on Valley Metro’s Title VI Program and procedures by which to file a complaint,
contact the Title VI Coordinator at (602) 322-4514.
For more information on the City of Phoenix’s Civil Rights Program and the procedures by which to file a
complaint, contact the Title VI Coordinator at (602) 262-7242.

1 Valid: fact based, binding, acceptable, enforceable
2 Invalid: null and void, unacceptable, unenforceable
3 Undeterminable: incapable of being decided, settled, or fixed; not determinable

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Requesting Information | Title VI Implementation Plan

Requesting Information
Note: To request information in alternative formats, please contact Customer Service at csr@valleymetro.org
or phone: (602) 253-5000 or City of Phoenix (602) 262-7242, TTY: (602) 251-2039
Tracking a Title VI Compliant
As complaints are received, they are logged into the CAS system. Within 24 to 48 hours of logging the
complaint, Valley Metro CSA assigns the complaint to the appropriate TSP for investigation and
documentation.
The TSP has 30 days to complete their investigation, including obtaining additional information needed from
the complainant to investigate or to resolve the case. The investigator will follow the complaint process, and
once the investigation is concluded, the case resolution will be documented in the CAS.
The CAS system is programmed to notify the CSA if a complaint has not been responded to within the
required time frame. Upon system notification, the CSA will send out a reminder notice to the appropriate
TSP that the case is not yet resolved or closed out.
Once the case has been resolved the complainant will receive a response in the manner identified.
Valley Metro and the City of Phoenix monitors the process monthly to ensure Title VI complaints are fully
investigated, adequately documented, and that the complainant was responded to in the manner requested.
Should an inaccuracy be found, Valley Metro and/or the City of Phoenix will work with CSA and the
appropriate TSP to reopen the complaint for further investigation until resolution or completion.
Investigating a Title VI Complaint
Each documented Title VI investigative report must address each of the “Five Federal Investigative” steps
found in 28 CFR, Part 35 and FTA Circular 4702.IA. The seven steps are:
STEP ONE: The TSP will review the complaint information entered into CAS by Valley Metro Customer
Service staff. Any new issues identified during the investigation should also be documented in CAS.
STEP TWO: Interviews and collections of facts.
• TSP identifies respondents to interview, if needed.
• TSP interviews respondents identified and documents details from the interviews in CAS.
• Investigate every “issue” (stated in the “statement of issues noted in step one).
• Separate facts from opinions.
“Respondent” is not confined to the transit vehicle operator. “Respondent” is defined as any source of
information that can contribute to the investigation, such as:
• Complainant
• Operator
• Radio/Dispatch/OCC reports

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Investigating a Title VI Complaint | Title VI Implementation Plan

• Maintenance staff
• City Transit staff
• Witnesses
• Other transit employees
The TSP identified, collects, and reviews other information and/or documents that provide facts for the
investigation. Any applicable information is to be documented in CAS. Documents to review can include:
• GPS tracking software and programs
• Maintenance records
• Spotter reports
• Video (camera) and/or audio recordings
• Courtesy cards
• Incident reports (supervisor, transit police, fare/security inspectors)
• Route history
• Other documents deemed appropriate by the TSP
STEP THREE: TSP documents pertinent regulations, rules, policies, and procedures that apply to the
investigation in CAS under the case number assigned.
Pertinent regulations, rules, policies, and procedures may include:
• Title VI requirements
• Company rules and procedures
• Valley Metro and City of Phoenix policies and service standards
• Contractual requirements
STEP FOUR: Complaint Determination.
• TSP compares each fact from “findings of fact” to the list of regulations, rules, etc.
• TSP makes a fact-based determination of alleged violation(s).
STEP FIVE: Description of resolution for each valid violation.
• TSP describes specific corrective actions for each violation found
• TSP documents follow-up action, if applicable
• TSP documents the complaint resolution in CAS
TSP Complaint Resolution(s):
• Must include specific complaint resolutions for each valid violation noted.
• Document a follow-up action plan, where applicable.
• If no valid violations are found, note policies, procedures, etc. reviewed during the
investigation and with transit operator.
• Documented complaint information should always include staff initials, title, and dates.
Response to Customer
TSP will respond to the Customer in the manner identified and will document the response provided in CAS
under the case number assigned.

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¿Qué es el Título VI? | Title VI Implementation Plan

Procedimientos de Quejas del Título VI
¿Qué es el Título VI?
El Título VI es una sección del Decreto de los Derechos Civiles de 1964 que requiere que “ninguna persona
en los Estados Unidos deberá, basándose en su raza, color u origen nacional, ser excluida de participar en, ser
denegada de los beneficios de, o verse sujeta a discriminación bajo cualquier programa o actividad recibiendo
asistencia financiera federal.”
¿Cómo registro una queja?
Cualquier persona que crea que ha sido excluida de la participación en, se le hayan denegado los beneficios
de, o de otra manera se haya visto sujeta a discriminación ilegal bajo cualquier servicio, programa o actividad
de Valley Metro o de la Ciudad de Phoenix, y crea que la discriminación se basa en raza, color u origen
nacional, puede registrar una queja formal con el Servicio al Cliente de Valley Metro o directamente con la
Ciudad de Phoenix. Esta protección antidiscriminatoria también se extiende a las actividades y los programas
de los contratistas terceros Proveedores de Servicios de Transporte (TSP por sus siglas en inglés) de Valley
Metro y la Ciudad de Phoenix. Valley Metro y la Ciudad de Phoenix usan el Sistema de Asistencia al Cliente
(CAS por sus siglas en inglés) para capturar todas las quejas recibidas por el sistema regional de transporte.
Cualquier queja de este tipo debe registrarse dentro de los 180 días del presunto acto discriminatorio (o de la
última vez que haya ocurrido).
Para enviar una queja en línea, llene la forma de quejas en línea en el siguiente enlace:
www.valleymetro.org/form/title-vi-complaint-form

Las quejas también se pueden registrar por escrito usando la forma de quejas del Título VI, ó llamando a
Servicio al Cliente al (602) 253-5000, TTY: (602) 251-2039. Las formas llenas y firmadas se deben enviar por
correo postal a:

Regional Public Transportation Authority 4600
East Washington Street, Suite 101
Phoenix, AZ 85034
Correo
electrónico:
csr@valleymetro.org
Teléfono: (602) 253-5000
TTY: (602) 251-2039

La forma de la queja se encuentra en nuestro sitio web:
https://www.valleymetro.org/about/civil-rights

Para registrar una queja directamente con la Ciudad de Phoenix:

Attention: Title VI Coordinator
City of Phoenix Public Transit Department 302 N.
1st Avenue, Suite 900
Phoenix, AZ 85003

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Servicio al Cliente | Title VI Implementation Plan

Correo electrónico: PHXTransitEO@phoenix.gov Teléfono:
(602) 262-7242 https://www.phoenix.gov/publictransit/title-
vi-notice
Los individuos también pueden registrar quejas directamente con la Administración Federal de Transporte
(FTA por sus siglas en inglés) dentro de un período de tiempo de 180 días:

Federal
Transit
Administration
(FTA)
Attention: Title VI Coordinator
East Building, 5th Floor –TCR 1200
New Jersey Avenue, SE Washington,
D.C. 20590
Servicio al Cliente
Las quejas recibidas por los representantes de Servicio al Cliente de Valley Metro o por el Coordinador del
Título VI de la Ciudad de Phoenix serán documentadas y asignadas al Proveedor de Servicios de Transporte
(TSP por sus siglas en inglés) (operador o administrador del servicio) apropiado responsable de la
investigación en conformidad con los estándares federales (28 CFR Parte 35 y Circular 4702.1B de la
administración FTA). El proveedor TSP tiene 30 días para investigar cada queja. Si se necesita más
información para resolver el caso, el proveedor TSP puede ponerse en contacto con el/la reclamante y solicitar
información adicional. Los reclamantes deben proporcionar la información adicional dentro de los 10 días
posteriores a la solicitud o la queja puede considerarse indeterminable y se cerrará administrativamente. Los
casos también se pueden cerrar administrativamente si un/a reclamante informa a Valley Metro o a la Ciudad
de Phoenix que ya no desea continuar con la queja. Las solicitudes para cerrar una queja se pueden hacer por
teléfono, por correo electrónico o por escrito (vea arriba la información de contacto). Las quejas se pueden
cerrar administrativamente si el/la reclamante falle en responder.
Después de la investigación, todas las quejas deberán ser concluidas con una determinación ingresada al
sistema CAS. La entrada de la determinación deberá indicar que la investigación determinó que la queja era
válida1, inválida2 ó indeterminable3. Si la investigación determina que las presuntas infracciones de la queja
bajo el Título VI de discriminación por raza, color u origen nacional son válidas, se deberá proveer al/la
reclamante una resolución correctiva detallada para remediar la situación. Si los resultados de la investigación
determinan que no hubo una presunta discriminación bajo el Título VI basada en raza, color u origen
nacional, el caso se cerrará. El/la reclamante deberá ser notificado/a de los resultados de la investigación en
la forma identificada (correo electrónico o teléfono). Un/a reclamante puede apelar la decisión dentro de los
60 días siguientes a la notificación de los resultados de la investigación. Las apelaciones se deben enviar a
Valley Metro o a la Ciudad de Phoenix.

1 Válida: basadas en los hechos, vinculante, aceptable, ejecutable
2 Inválida: nula e inválida, inaceptable, inejecutable
3 Indeterminable: incapaz de llegar a una decisión, asentada, o solucionada; no es determinable

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Solicitando Información | Title VI Implementation Plan

Todas las quejas e investigaciones del Título VI son revisadas por Valley Metro, el Administrador de Servicio
al Cliente (CSA por sus siglas en inglés), y el personal de la Ciudad de Phoenix.
Para más información sobre el Programa del Título VI de Valley Metro y los procedimientos para registrar
una queja, llame al Coordinador del Título VI al (602) 322- 4514.
Para más información sobre el Programa de Derechos Civiles de la Ciudad de Phoenix y los procedimientos
para registrar una queja, llame al Coordinador del Título VI al (602) 262-7242.
Solicitando Información
Nota: Para solicitar información en formatos alternativos, por favor comuníquese con Servicio al Cliente en
csr@valleymetro.org o por teléfono: (602) 253-5000 ó con la Ciudad de Phoenix al (602) 262-7242, TTY:
(602) 251-2039
Rastreando Una Queja del Título VI
A medida que se van recibiendo las quejas, éstas son ingresadas al sistema CAS. Dentro de 24 a 48 horas de
registrar la queja, el administrador CSA de Valley Metro asigna la queja al proveedor TSP apropiado para su
investigación y documentación.
El proveedor TSP tiene 30 días para completar su investigación, incluyendo la obtención de la información
adicional necesaria del/la reclamante para investigar o para resolver el caso. El investigador seguirá el proceso
de quejas, y una vez que concluya la investigación, la resolución del caso se documentará en el sistema CAS.
El sistema CAS está programado para notificarle al administrador CSA si una queja no ha sido contestada
dentro del plazo requerido. Tras la notificación del sistema, el administrador CSA enviará un aviso de
recordatorio al proveedor TSP correspondiente de que el caso aún no se ha resuelto o cerrado.
Una vez resuelto el caso, el/la reclamante recibirá una respuesta en la forma identificada.
Valley Metro y la Ciudad de Phoenix monitorean el proceso mensualmente para asegurar que las quejas del
Título VI se investiguen a fondo, se documenten adecuadamente, y se le conteste al/la respondiente de la
manera solicitada. En caso de que se encuentre un error, Valley Metro y/o la Ciudad de Phoenix trabajarán
con el administrador CSA y el proveedor TSP apropiado para volver a abrir la queja para una investigación
adicional hasta su resolución o finalización.
Investigando Una Queja del Título VI
Cada reporte de investigación documentado del Título VI debe abordar cada uno de los “Cinco Pasos de
Investigaciones Federales” que se encuentran en 28 CFR, Parte 35 y la Circular 4702.IA de la administración
FTA. Los siete pasos son:
PASO UNO: El proveedor TSP revisará la información de la queja ingresada al sistema CAS por el personal
de Servicio al Cliente de Valley Metro. Cualquier nuevo asunto identificado durante la investigación también
se debe documentar en el sistema CAS.
PASO DOS: Entrevistas y recolecciones de los hechos.

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Investigando Una Queja del Título VI | Title VI Implementation Plan

• El proveedor TSP identifica a los respondientes a ser entrevistados, si es necesario.
• El proveedor TSP entrevista a los respondientes identificados y documenta los detalles de
las entrevistas en el sistema CAS.
• Se investiga cada “asunto” (indicado en la declaración de asuntos que se indica en el paso
uno).
• Se separan los hechos de las opiniones.
El/la “respondiente” no se limita al/la conductor/a del vehículo de transporte. El/la “respondiente” se
define como cualquier fuente de información que pueda contribuir a la investigación, tal como:
• Reclamante
• Conductor/a
• Reportes de radio/despacho/OCC
• Personal de mantenimiento
• Personal de Transporte de la Ciudad
• Testigos
• Otros empleados de transporte
El proveedor TSP identifica, recopila, y revisa otra información y/o documentos que provean los hechos
para la investigación. Cualquier información aplicable se debe documentar en el Sistema CAS. Los
documentos por revisar pueden incluir:
• Software y programas de rastreo GPS
• Registros de mantenimiento
• Reportes de observador “Spotter”
• Grabaciones de video (cámara) y/o audio
• Tarjetas de cortesía
• Reportes de incidentes (supervisor, policía de transporte, inspectores de
pasajes/seguridad)
• Historial de la ruta
• Otros documentos que el proveedor TSP considere apropiados
PASO TRES: El proveedor TSP documenta las regulaciones, reglas, normas, y procedimientos
pertinentes que sean aplicables a la investigación en el sistema CAS bajo el número de caso asignado.
Las regulaciones, reglas, normas y procedimientos pertinentes pueden incluir:
• Requerimientos del Título VI
• Reglas y procedimientos de la compañía
• Normas y estándares de servicio de Valley Metro y la Ciudad de Phoenix
• Requerimientos contractuales
PASO CUATRO: Determinación de la queja.
• El proveedor TSP compara cada hecho de “hallazgos de hechos” con la lista de
regulaciones, reglas, etc.
• El proveedor TSP hace una determinación basada en hechos de la/s presunta/s
infracción/es.

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Investigando Una Queja del Título VI | Title VI Implementation Plan

PASO CINCO: Descripción de la resolución para cada infracción válida.
• El proveedor TSP describe las acciones correctivas específicas para cada infracción que
haya sido encontrada
• El proveedor TSP documenta la acción de seguimiento, si es aplicable
• El proveedor TSP documenta la resolución de la queja en el sistema CAS
Resolución/es de Quejas del Proveedor TSP:
• Debe incluir resoluciones específicas a las quejas para cada infracción válida anotada.
• Documentar un plan de acción de seguimiento, cuando sea aplicable.
• Si no se encuentran infracciones válidas, anotar las normas, los procedimientos, etc.
revisados durante la investigación y con el/la conductor/a de transporte.
• La información documentada de la queja siempre debe incluir las iniciales del personal, el
título, y las fechas.
Respuesta al/la Cliente
El proveedor TSP le contestará al/la Cliente de la manera identificada y documentará la respuesta provista
en el sistema CAS bajo el número de caso asignado.

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Title VI Complaint Forms | Title VI Implementation Plan

Title VI Complaint Forms

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Title VI Complaint Forms | Title VI Implementation Plan

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Title VI Investigations, Complaints, and Lawsuits | Title VI Implementation Plan

Title VI Investigations, Complaints, and
Lawsuits

☒ The City of El Mirage has not had any Title VI complaints, investigations, or lawsuits from
May 1, 2021, through January 9, 2025.

Description/Name
Date (Month,
Day, Year)
Summary
(include basis of
complaint: race,
color, national
origin or
disability)
Status
Action(s) Taken
(Final findings?)
Investigations

Lawsuits

Complaints

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Public Participation Plan | Title VI Implementation Plan

Public Participation Plan

The City of El Mirage /
Valley Metro
Public Participation Plan

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Public Participation Plan | Title VI Implementation Plan

The City of El Mirage is adopting the Valley Metro Public Participation Plan to engage the public
in transit-related activities and actions. Valley Metro conducts the regional transit public
input/outreach process. The public will be invited to participate in the process, whether through
public meetings or surveys.

Public Meetings
(1) Public meetings are scheduled to increase the opportunity for attendance by stakeholders
and the general public. This may require scheduling meetings during non-traditional
business hours, holding more than one meeting at different times of the day or on
different days, and checking other community activities to avoid conflicts.

(2) When a public meeting or public hearing is focused on a planning study or program
related to a specific geographic area or jurisdiction within the region, the meeting or
hearing is held within that geographic area or jurisdiction.

(3) Public meetings are held in locations accessible to people with disabilities and are located
near a transit route when possible.

The City of El Mirage / Valley Metro submits an application for funding to the Arizona
Department of Transportation annually. Part of the application is a public notice, which includes
a 30-day public comment period.

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Public Participation Plan | Title VI Implementation Plan

Valley Metro Public Participation Plan 2021
Introduction

The regional transit public input/outreach process is conducted by Valley Metro for various
transit-related activities and actions. Throughout the year, Valley Metro conducts public
outreach activities related to capital projects, transit service changes, fare changes, and other
transit-related events. This Title VI Public Participation Plan was established to ensure
inclusion of the public throughout the Phoenix metropolitan community in accordance with
the content and considerations of Title VI of the Civil Rights Act of 1964. Federal regulations
state that recipients of federal funding must “promote full and fair participation in public
transportation decision-making without regard to race, color or national origin.” Valley Metro
uses this Plan to ensure involvement of low-income, minority and limited English proficient
(LEP) populations, following guidance from the Title VI Requirements and Guidelines for
Federal Transit Administration Recipients Circular1 (Circular).
Involving the public in Valley Metro practices and decision-making processes provides
helpful information to improve the transit system to better meet the needs of the community.
Although public participation methods and extent may vary with the type of plan, program
and/or service under consideration, as well as the resources available, a concerted effort to
involve all affected parties will be conducted in compliance with this Plan along with federal
regulations. To include effective strategies for engaging low- income, minority and LEP
populations, the Circular suggests that the following may be considered:

• Scheduling meetings at times and locations that are convenient and accessible
for minority and LEP communities.
• Employing different meeting sizes and formats.
• Coordinating with community- and faith-based organizations, educational
institutions and other organizations to implement public engagement strategies
that reach out specifically to members of affected minority and/or LEP
communities.

• Considering transit information in publications and through communication
channels that serve LEP populations.
• Providing opportunities for public participation through means other than written
communication, such as personal interviews or use of audio or video recording
devices to capture oral comments.

1 United States Department of Transportation, Federal Transit Administration, Circular 4702.1B.

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Valley Metro currently practices all these strategies, in compliance with federal regulations, so
that minority, low-income and LEP populations have ready access to information and
meaningful opportunities to engage in planning activities and provide input as part of the
decision-making process.

Typical Public Participation Opportunities
Valley Metro provides opportunities to share information or receive public input through a variety
of methods for public participation utilized to engage low-income, minority and LEP populations
through many outlets.
Meeting Planning: For planning efforts, including fare and service changes, public meeting
locations are held at a centralized location near the affected route or project area and bilingual
staff is available. Public notices and announcements are published in minority-focused
publications— some examples include: the Arizona Informant (African American community),
Asian American Times (Asian American community), La Voz and Prensa Arizona (Hispanic
community). Press releases are also sent to these media sources regarding fare changes,
service changes and other programs. All printed materials are available in English and Spanish
and translated, as requested, in any other languages.
Rider Satisfaction Survey: A key participation effort, the Rider Satisfaction Survey, is
conducted approximately every two years. This survey is administered on transit routes across
the region, reaching transit riders living in minority and/or low-income communities. The survey,
administered in English and Spanish, measures rider satisfaction with transit services and
captures comments for improvements.
Valley Metro Customer Service: Throughout the year, minority, low-income and LEP
populations have access to information through the Valley Metro Customer Service. Valley
Metro Customer Service is open 5 a.m. - 10 p.m., Monday through Friday; 6 a.m.
- 8 p.m. on Saturdays; and 8 a.m. - 5 p.m. on Sundays and designated holidays. Customer
Service staff is multilingual.
Website: Information including meeting announcements, meeting materials and other program
information is available on valleymetro.org in both English and Spanish. If users would like
information in another language, Valley Metro features Google Translate on its website. This
allows Valley Metro to reach citizens in five languages with information on transportation
services, proposed service changes and other programs.

Public Participation Methods
Valley Metro uses several specific public involvement techniques to ensure that minority, low-
income and LEP persons are involved in transit decisions. Using public involvement, media
outlets and print or electronic materials, Valley Metro disseminates information regarding
planning efforts. These efforts include the activities described below.
A full list of potential outreach methods is found in Appendix A.

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Common Best Practices:
• Public meetings, hearings and open houses are held regularly at community- familiar and
centralized locations with public transportation access and at convenient times, in
collaboration with city partners. These meetings provide an opportunity to meet with
citizens and receive their comments and questions on proposed service changes and
other programs. For each program, Valley Metro varies its meeting format to best engage
the targeted population.
• Valley Metro has staff available at public meetings, hearings, events and open houses to
answer questions and receive comments in both English and Spanish. Valley Metro also
uses court reporters to record verbal comments at public hearings.
• Outreach for biannual service changes and other programs are conducted at or near the
affected area— for example, along an affected bus route or at an affected transfer
location— thus targeting the population that may be most affected by proposed changes
to service or routes. Often, these efforts are also executed at transit stops, community
centers, civic centers or major transfer locations.
• Coordination with community- and faith-based organizations, educational institutions and
other organizations occurs regularly. These coordination efforts assist Valley Metro in
executing public engagement strategies that reach out to members of the population that
may be affected.
• All public meeting notices for biannual service changes and other programs are translated
to Spanish. Notices regarding Valley Metro projects and programs are widely distributed
to the public through multiple methods as established by the project team. A full list of
potential outreach methods is found in Appendix A.
• Valley Metro publishes advertisements of any proposed service or fare change in minority
publications to make this information more easily available to minority populations.
Additionally, Valley Metro sends press releases regarding service changes and other
programs to Spanish-language media. Depending on the level of impact, a formal
media/communications plan can be developed to coordinate overall messaging across
multiple stakeholders.
• Valley Metro offers online participation via social media, webinar and email input as an
alternative opportunity for comment. Online meetings or hearings are recorded and
uploaded to the Valley Metro YouTube channel and/or website.
• Major surveying efforts are conducted in both English and Spanish to ensure that the data
collected is representative of the public.
• Valley Metro Customer Service is multilingual

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• All comments are documented in a centralized database. Comment summary
information is provided to Valley Metro’s city partners for review and is also
presented to the Valley Metro Board of Directors for consideration when acting upon
proposed service changes.
• A public hearing is a formal presentation to the public on specific proposal or
subject. Public testimony is recorded into the official record. The rules governing a
public hearing are more formal than that of a public meeting, where a variety of tools
and techniques may be used to gather feedback from the public. A public hearing
may take place in-person, via teleconference, or online. Public comment must be
recorded and transcribed, either via electronic means or a court reporter.
A public hearing is required during:
o The development of an Environmental Impact statement.\
o A Major Service Change, as defined by the Major Service Change & Service
Equity Policy.
Conclusion
Valley Metro conducts public outreach throughout the year to involve the public with agency
activities and transit planning processes. Using a variety of communication techniques such
as facilitating meetings at varied times and locations, using multiple formats, placing print and
digital materials across multiple channels and providing opportunities via phone and online to
share or collect input, Valley Metro ensures that outreach efforts include opportunities for
minority, low-income and LEP populations who may be impacted by the activity or transit
planning process are integrated into the decision-making process. Valley Metro will continue
to involve all communities to be inclusive of all populations throughout the metropolitan
Phoenix area and to also comply with federal regulations. Valley Metro will continue to monitor
and update this Inclusive Public Participation Plan as part of the Title VI Program, which is
updated triennially

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Appendix A

Valley Metro reviews public outreach needs with the project/initiative team as part of the
initial development of the designated Public Involvement Plan. Major tactics are outlined to
develop the overall timeline. Depending upon the scope of the project, program or
announcement, public participation methods are customized to ensure that the public is
involved in the decision-making process.
A list of commonly used outreach tools, as well as their definition and associated Valley Metro
standard of best practice, is listed below.

Outreach Tool
Definition and Best Practices
Public Hearing
A formal meeting with a set agenda during which a
presentation is given, and public testimony/feedback is heard
and recorded. Can take place in-person, via teleconference,
or online. For public hearings, adequate notice to the public is
defined as a minimum of 30 days to the hearing date. A
hearing is advertised with an appropriate outreach tactic at
least four times within 30 days of the meeting date. Public
comment must be recorded and transcribed, either via
electronic means or via a court reporter.
Public Meeting
A meeting during which material is presented and public
comment is heard and recorded. The material may be offered
via a presentation, workshop or “open house.” Can take place
in-person, via teleconference, or as a webinar online. For
public meetings, adequate notice to the public is defined as a
minimum of 15-days prior to the meeting date. A meeting is
advertised at least twice via an appropriate outreach tactic
within 15 days of the meeting date.
Display Ads in Print
Media
A paid advertisement in the newspapers or other print media
to alert readers about an upcoming event or action.
Website/Online Social
Media
Information on projects or initiatives located on the Valley
Metro website or Valley Metro social channels (Instagram,
Facebook, Twitter)
Stakeholder meetings
Information provided to local, targeted individuals or groups
particularly affected by project. The presentation may be
formal, a workshop or in “open house” style. Typically,
stakeholder meetings are invitation-only and so do not need to
be publicly advertised beforehand. Can take place in-person,
via teleconference, or as a webinar online.

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Mobile Device Alerts
Electronic push notifications to alert customers to important
information on projects or service changes via Valley Metro-
owned mobile apps (AlertVM, ConstructVM, mobile fare app).
Signs
Signs on buses, bus stop locations, transit centers or other
locations frequented by stakeholders. This includes temporary
signs, A-frames or kiosk posters.
Rider Alerts
Notifications regarding immediate rider information on impacts
to frequency, routing or schedule. Rider Alerts may be web-
based, printed on signs and/or submitted as a memo to
Customer Service & Operations.
Direct Mailings
Mail sent to an affected group or area to educate, notify, or
request input.
Surveys
A list of questions to solicit opinions or preferences by a
selected group of individuals. The survey mechanism may be
electronic and/or in-person. The survey population may be
intercepted or self-selected. For surveys, the feedback
collection period is defined as a minimum of 15 days.
Static Display
Table or sign display at a trafficked event or area in an
identified area where a targeted stakeholder group may be
present. The display may be manned or unmanned and will
have specific information on the project/initiative. This may
also include a feedback mechanism, such as comment cards.
Door Hanger/Flyer
Canvassing
Print notice distributed to local businesses and residents in
project/affected area.
E-mail/E-blast
Digital messaging to an established Valley Metro email list.
Stakeholders may opt-in or out of this list based on their
needs.

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Limited English Proficiency Plan | Title VI Implementation Plan

Limited English Proficiency Plan
City of El Mirage /
Valley Metro
Limited English Proficiency Plan

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The City of El Mirage / Valley Metro has developed the following Limited English Proficiency Plan
(LEP) / Language Assistance Plan to help identify reasonable steps to provide language assistance
for LEP persons seeking meaningful access to City of El Mirage / Valley Metro services as required
by Executive Order 13166. 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.

This plan details procedures on how to identify a person who may need language assistance, the
ways in which assistance may be provided, training to staff, notification to LEP persons that
assistance is available, and information for future plan updates. In developing the plan while
determining the City of El Mirage / Valley Metro’s extent of obligation to provide LEP services,
the City of El Mirage / Valley Metro 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 City of El Mirage / Valley Metro
service area who may be served or likely to encounter by City of El Mirage / Valley
Metro program, activities, or services;

2) The frequency with which LEP individuals come in contact with City of El Mirage / Valley
Metro services;

3) The nature and importance of the program, activities or services provided by the City of
El Mirage / Valley Metro to the LEP population; and

4) The resources available to City of El Mirage / Valley Metro and overall costs to provide
LEP assistance. A brief description of these considerations is provided in the following
section.

A statement in Spanish will be included in all public outreach notices. Every effort will be made
to provide vital information to LEP individuals in the language requested.

Safe Harbor Provision
The City of El Mirage / Valley Metro complies with the Safe Harbor Provision, as evidenced by
the number of documents available in the Spanish language. With respect to Title VI
information, the following shall be made available in Spanish:

(1) Title VI Notice
(2) Complaint Procedures
(3) Complaint Form

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In addition, we will conduct our marketing (including using translated materials) in a manner
that reaches each LEP group. Vital Documents include the following:

(1) Notices of free language assistance for persons with LEP
(2) Notice of Non‐Discrimination and Reasonable Accommodation
(3) Outreach Materials
(4) Bus Schedules
(5) Route Changes
(6) Public Hearing

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Title VI Program
August 2024
Language Assistance Plan

VALLEY METRO
AUGUST 2024

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1.0 INTRODUCTION

In 1993, the Valley Metro Regional Public Transportation Authority (RPTA) board
adopted the name “Valley Metro” as the identity for the regional transit system in the
Phoenix metropolitan area. Under the Valley Metro brand, local governments joined to
fund the Valley-wide transit system that serves more than 36 million rides annually.
Valley Metro provides fixed-route bus service, light rail service, streetcar service and
complementary paratransit service across the region. Valley Metro provides services
with and distributes transit funds from the countywide transit sales tax to its member
agencies including Maricopa County and the cities of Tempe, Mesa, Glendale, Phoenix,
Buckeye, Tolleson, Wickenburg, Surprise, Peoria, Chandler, Gilbert, El Mirage,
Avondale, Goodyear, Scottsdale, Fountain Hills, Queen Creek, and Youngtown. For the
most part, Valley Metro and its member agencies use private service providers for the
operation of bus, light rail and paratransit services. The Cities of Glendale, Scottsdale,
Peoria and Phoenix contract some of their service directly to service providers.

Currently, fixed-route transit service in the metropolitan area is operated by the City of
Phoenix, Valley Metro, Scottsdale and Glendale. There is a total of 872 fixed-route
buses, 61 light rail vehicles and 6 streetcar vehicles operating in the region.

The regional transit system has 61 local bus routes that consist of the following: 45 local
bus routes, 15 key local bus routes and 1 limited-stop peak route. The region also has
19 Express/RAPID routes, 17 community circulator routes, 1 rural connector route, 1
light rail line and one streetcar line. Valley Metro customers made over 36.8 million
boardings during fiscal year 2023.

Four entities in the region provide Dial-a-Ride service for seniors and persons with
disabilities, as well as Americans with Disabilities Act (ADA) paratransit service for
those who are unable to use fixed-route bus service. Annual regional ridership for ADA
paratransit and regional ridership for non-ADA general Dial-a-Ride was over 900,000

In addition, Valley Metro’s Commute Solutions team supports Valley organizations in
the mandatory Maricopa County Travel Reduction Program. Toward that goal, the team
provides a multipurpose platform at www.ShareTheRide.com that allows commuters to
search for carpools, vanpools, transit and bike buddies. In addition to providing this
multimodal support, it provides pollution and commute information. In an ongoing effort
to educate, the team also provides online training, informational webinars, special
promotions for the general public and transportation coordinators.

In 2002, Valley Metro Rail, Inc., a nonprofit agency, was created and charged with the
design, construction, and operation of the region’s 57-mile high-capacity transit system.
Valley Metro Rail Board member cities include Phoenix, Tempe, Mesa and Chandler.
The Board establishes overall policies and provides general oversight of the agency and
its responsibilities.

In November 2004, Maricopa County voters passed Proposition 400, which provides
funding from a portion of a half-cent sales tax to fund transit projects in the Regional

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Transportation Plan. The 20-mile light rail starter line (Central Phoenix/East Valley)
became operational within the cities of Phoenix, Tempe and Mesa on December 27,
2008. Since 2008, the completion of four light rail extensions have increased the length
of the light rail system to 30 miles. The Mesa Dr/Main St. extension, a 3.1-mile project
that brought light rail into downtown Mesa, began operations in 2015. In March 2016,
the 19th Ave/Dunlap extension in Phoenix opened—adding 3.2 miles to the system. The
Gilbert Road Extension, a 1.9-mile project on Main Street to Gilbert Road in Mesa,
began operations in 2019. And the Northwest Phase II extension, a 1.6-mile project
extending the system northwest from 19th Ave/Dunlap to Metro Center, opened in
January 2024. In addition, Valley Metro and the City of Tempe opened a 3-mile
streetcar project in May 2022, running through Downtown Tempe and the Arizona State
University-Tempe campus. Valley Metro and the City of Phoenix are progressing
construction of the South Central Extension/Downtown Hub, a 5.5-mile extension of
light rail on Central Avenue to Baseline Road, which is expected to open in mid-2025.
Valley Metro and the region support the goal of the U.S. Department of Transportation
(USDOT) limited English proficient (LEP) guidance to provide meaningful access to its
services by LEP persons. The Federal Transit Administration (FTA) notes that transit
agencies that provide language assistance to LEP persons in a competent and effective
manner will help ensure that their services are safe, reliable, convenient, and accessible
to those persons. These efforts may attract riders who would otherwise be excluded
from using the service because of language barriers and, ideally, will encourage riders
to continue using the system after they are proficient in English and/or have more
transportation options.

1. Regulatory Guidance

Title VI of the Civil Rights Act of 1964, provides 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 otherwise subjected to discrimination under any
program or activity that receives federal financial assistance.
Executive Order 13166, “Improving Access to Services for Persons with Limited English
Proficiency,” issued on August 11, 2000, directs each federal agency to publish
guidance for its respective recipients to assist with its obligations to LEP persons under
Title VI. The Executive Order states that recipients must take reasonable steps to
ensure meaningful access to their programs and activities by LEP persons. Providing
English- only services may constitute national origin discrimination in violation of Title VI
and its implementing regulations.
The FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit
Administration Recipients”, issued in October 2012 reiterates this requirement. Chapter
III states that “…FTA recipients must take responsible steps to ensure meaningful
access to the benefits, services, information, and other important portions of their
programs and activities for individuals who are Limited English Proficient (page III-6).”

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In the Phoenix Metropolitan Area, there are more than sixty different languages
identified in households where English is not the predominate language. Using the
“Four Factor Analysis” prescribed by FTA, this plan was developed to ensure that all
transit providers effectively communicate with all users of the public transportation
agency’s services provided.

1.1 Four Factor Analysis

FTA Circular 4702.1B identifies four factors that recipients of federal funds should follow
when determining what reasonable steps should be taken to ensure meaningful access
for LEP persons.

The four-factor analysis involves the following:

1. Identify the number or proportion of LEP persons eligible to be served or likely to be
encountered with transit service.

2. Determine the frequency with which LEP individuals come in contact with transit
service.

3. Determine the nature and importance of transit service provided to LEP individuals.

4. Assess the resources available to the recipient for LEP outreach, as well as costs
associated with that outreach.

This document describes Valley Metro’s four-factor analysis and summarizes its LEP
efforts, including staff training, followed by a description of how the plan will be
monitored and updated.

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2.0
LIMITED ENGLISH PROFICIENT POPULATION (FACTOR 1)

Factor 1 assesses the number and proportion of persons with limited English speaking
proficiency likely to be encountered within the region’s service area, which is defined as
a three-quarter mile radial buffer around all fixed route services and a three-mile buffer
around park-and-ride and transit facilities for express bus service. The LEP population
is those individuals who reported to the Census Bureau that they speak English “less
than very well.”

2.1
Evaluation Methods and Data Source

In accordance with FTA’s policy guidance, the initial step for providing meaningful
access to services for LEP persons and maintaining an effective LEP program is to
identify LEP populations in the service area and their language characteristics through
an analysis of available data. The presence of LEP populations in the regional service
area was determined by analyzing the U.S. Census Bureau, 2022 American Community
Survey (ACS) 5-year Sample.

2.2
LEP Population Identification

FTA describes LEP persons as having a limited ability to read, write, speak, or
understand English. For this LEP analysis, those who reported to the Census Bureau
that they speak English “less than very well” were used to tabulate the LEP population
for the regional service area.

2.3
American Community Survey

The ACS is a continuous nationwide survey conducted monthly by the U.S. Census
Bureau to produce annually updated estimates for the same small area (census tracts
and block groups) formerly surveyed through the decennial census long-form survey. It
is intended to measure changing socioeconomic characteristics and conditions of the
population on a recurring basis. It is important to note that the ACS does not provide
official counts of the population between each decennial census, but instead provides
weighted population estimates. This analysis uses the 2022 ACS 5-Year data (2018 to
2022).

ACS data include the number of persons ages five and above who self-identified their
ability to speak English as “very well,” “well,” “not well,” and “not at all.” Figure 1 depicts
Valley Metro’s service area. Table 1 shows the number of LEP people within Valley
Metro’s service area in comparison to Maricopa County. There are over 4 million
residents in Maricopa County, and 3.5 million reside within Valley Metro’s service area.
The incidence of LEP persons within Valley Metro’s service area is slightly higher than
in the county. 8.3 percent of residents in Maricopa County speak English less than “very
well,” while 9.3 percent of residents within Valley Metro’s service area speak English
less than “very well.”

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FIGURE 1: VALLEY METRO SERVICE AREA
TABLE 1: 2022 ACS DATA, BY LOCATION
County or Area
Total Population
Age 5 and Over
Speaks
English Only
Speaks English
Percentage
Less than
Very Well
Very Well
Less than
Very Well
Maricopa County
4,171,400
3,068,856
756,667
345,877
8.29
Census tracts within
service areaa
3,418,601
2,420,722
678,529
319,350
9.34
a Service area is defined as a ¾-mile buffer within local fixed-route service and a 3-mile buffer within park-and-
ride and transit facilities for express bus service.

Table 2 shows English proficiency for the census tracts within the service area population age
five years and above by the linguistic categories identified by the U.S. Census Bureau. This
includes English, Spanish, Indo-European, Asian or Pacific Islander, and all other languages.
The 2022 ACS data show the population self-identified as speaking English less than “very
well” was predominantly the Spanish-language group, encompassing 251,891 people, or 7.37
percent of the total population age five years and over. Indo-European, Asian or Pacific
Islander, and all other languages groups account for 67,459 people, or 1.9 percent of the
population. Of all those speaking English less than “very well,” the Spanish group makes up
79 percent of the total population over age five with limited English proficiency.

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TABLE 2: 2022 ACS DATA, BY LANGUAGE CATEGORY
Language
Category
Total
Population
Age 5 and
Over
Speaks English
Percentage
Less than
Very Well
Very Well
Well
Not Well
Not At
All
Total
3,418,601
678,529
148,286
115,239
55,825
9.34
English
2,420,722
—
—
—
—
—
Spanish
774,086
522,195
104,440
96,515
50,936
7.37
Asian or
Pacific
Islander
88,365
55,237
20,420
9,973
2,735
0.97
Indo-
European
84,788
65,337
13,667
4,844
940
0.57
All other
languages
50,640
35,760
9,759
3,907
1,214
0.44

The 2022 ACS data also provide information on linguistically isolated households: “A
linguistically isolated household is one in which no member 14 years old and over
(1) speaks only English and (2) speaks a non-English language and speaks English ‘very
well.’ In other words, all members 14 years old and over have at least some difficulty with
English” (ACS 2022). In total, the 2022 ACS data identified 1,448,742 households to be
linguistically isolated. The entire membership of a linguistically isolated household would
be considered LEP. Table 3 details those data for linguistically isolated and non-
linguistically isolated households by language category within the service area.

TABLE 3: 2022 ACS DATA, BY LINGUISTICALLY ISOLATED HOUSEHOLDS

Language Category
Total
Households
Isolated
Households
Non-isolated
Households
Percentage
Isolated
Households
Census tracts in service
area
1,448,742
58,003
365,330
4
English
1,007,048
—
—
—
Spanish
301,679
38,366
263,313
2.6
Asian or Pacific Islander
45,200
7,767
37,433
0.54
Indo-European
71,129
4,745
43,983
0.33
All other languages
23,686
7,125
20,601
0.49

Within the transit service area, 4 percent of households are considered linguistically
isolated. Again, these are predominantly Spanish households, making up 2.6 percent of
the total. Remaining languages make up 1.36 percent of households that are classified
as linguistically isolated.

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Figure 2 shows concentrations of linguistically isolated households in census tracts within
the service area. Most areas throughout the region are mixed, although a few pockets of
census blocks have concentrations of linguistically isolated households, thus identified as
persons with limited English proficiency.

Figure 3 shows the ACS 2022 census tracts within the three-quarter mile buffer of local
fixed-route service and a three-mile buffer around park-and-ride and transit facilities for
express bus service. Census tracts encapsulated within this area are included in the
estimates, although they may not be within one-quarter mile of a fixed route.

FIGURE 2: CENSUS TRACTS WITH LINGUISTICALLY ISOLATED HOUSEHOLDS

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FIGURE 3: CENSUS TRACTS WITHIN SERVICE AREA

The 2022 ACS data show 12 languages or language groups with 1,000 or more LEP
persons. Only one LEP population exceeds both the 1,000 or more individuals and the
five percent of the total population of persons eligible to be served or likely encountered.
Table 4 shows the populations that meet either of these thresholds using ACS 2022
population by language and ability, sorted by percentage of LEP population.

Within the service area, the majority of the 2022 LEP populations is the Spanish-speaking
population; this is the only language group to exceed both 1,000 individuals and five
percent of the LEP population. The Spanish LEP population consists of 251,606
individuals within the service area. The other Indo-European, Mandarin Chinese, and
other and unspecified speaking populations followed with 3.90 percent, 3.06 percent and
2.76 percent respectively. The Vietnamese, other Asian and Pacific Island and Arabic
speaking populations follow with 2.51 percent, 3.02 percent and 1.90 percent,
respectively. This is followed by Russian and Filipino with 1.37 percent and 1.08 percent,
respectively, and then by Korean (0.8 percent), French (0.7 percent) and German (0.2
percent).

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TABLE 4: 2022 ACS DATA, BY LANGUAGE WITHIN ONE-HALF MILE OF FIXED-
ROUTE SERVICE

Language
Speak English
Total
Population
Percentage of
Language LEP
of Total LEP
Population
Less Than
Very Well
Very Well
All languages
319,427
—
—
100
Spanish
251,606
522,128
773,734
78.77
French, Haitian or Cajun
2,072
8,077
10,149
0.65
German
692
8,819
9,511
0.22
Russian, Polish or Other Slavic
4,370
12,051
16,421
1.37
Other Indo-European languages
12,462
36,475
48,937
3.90
Korean
2,425
2,995
5,420
0.76
Mandarin Chinese
9,785
11,285
21,070
3.06
Vietnamese
8,023
7,458
15,481
2.51
Filipino
3,463
10,932
14,395
1.08
Other Asian Pacific Island
9,648
22,228
31,876
3.02
Arabic
6,080
10,820
16,900
1.90
Other and unspecified languages
8,801
24,971
33,772
2.76

Figure 4 shows concentrations of populations speaking English less than very well
throughout the service area. Most areas throughout the region are mixed, although there
are a few pockets of Census blocks with concentrations of persons with limited English
proficiency.

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FIGURE 4: POPULATION SPEAKING ENGLISH “LESS THAN VERY WELL”

3.0 FREQUENCY OF CONTACT WITH LIMITED ENGLISH PROFICIENT
POPULATION (FACTOR 2)

The first step of the four-factor LEP needs assessment revealed that the largest language
group is overwhelmingly Spanish, followed by the ACS language categories of other Indo-
European, Mandarin Chinese and other and unspecified. Factor 2 is intended to assess
the frequency with which LEP persons interact with Valley Metro programs, activities or
services. The DOT Policy Guidance Concerning Recipients’ Responsibilities to Limited
English Proficient (LEP) Persons (2005) advises that:
Recipients should assess, as accurately as possible, the frequency with which they have or
should have contact with LEP individuals from different language groups seeking assistance, as
the more frequent the contact, the more likely enhanced language services will be needed
(emphasis added). The steps that are reasonable for a recipient that serves an LEP person on a
one-time basis will be very different than those expected from a recipient that serves LEP persons
daily.
The frequency of use was evaluated by assessing current resources, available data and
a short survey of transit employees.

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Limited English Proficiency Plan | Title VI Implementation Plan

3.1 Evaluation Methods and Data Sources
To determine the frequency with which LEP persons interact with Valley Metro, both
quantitative and qualitative methods were used to analyze access to services. Anecdotal
information regarding interactions with LEP persons, garnered through conversations
with Valley Metro employees, is also included in this section. More structured analysis is
included using several sources of information:

• Transit employee surveys
• Customer Service Interactive Voice Response (IVR) call log
• Transit education program
• Valley Metro website translation data
• Together, these sources provide a picture of the interaction of LEP persons with
programs, activities or services provided by the agency.

3.2 Frequency of Contact Analyses
Valley Metro recognizes the value of providing convenient and efficient information to
transit riders. Understanding how often LEP persons are using services will assist in
serving customers better in the future with quality services, programs and activities.

Customer Service Interactive Voice Response Call Log
The Customer Service Center updated its automated phone system in mid-2014 to
establish the IVR feature. With this expansion, the system is able to provide a log listing
the frequency with which line callers have requested to be transferred. Available are five
topic categories, each in English and Spanish, for ten total options. The topics available
include:

• Americans with Disabilities Act (ADA)
• Customer Relations (CR)
• Light Rail
• Lost and Found
• Transit Information (TI)
•
This system allows Spanish-speaking callers to be automatically transferred to a bilingual
representative, reducing the time it takes to be served in the preferred language.
Currently, eight bilingual customer service representatives are employed by Valley Metro.
The phone system prioritizes selection of Spanish calls received. Table 5 shows the
distribution of calls by option selected, followed by the sum of calls by language for
calendar year 2022.

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Limited English Proficiency Plan | Title VI Implementation Plan

TABLE 5: 2022 CUSTOMER SERVICE CALL LOG

Call
Total Calls
% of Total Calls
ADA – English
328
0.38
ADA – Spanish
934
1.08
CR – English
8,522
9.89
CR – Spanish
135
0.15
Light Rail – English
8
0.01
Light Rail – Spanish
0
0.00
Lost and Found – English
259
0.30
Lost and Found – Spanish
0
0.00
TI – English
69,124
80.28
TI – Spanish
6,685
7.76
English (Total)
78,339
91.00
Spanish (Total)
7,754
90.99
Total Calls
86,095
100.00
FIGURE 5: CUSTOMER SERVICE CALLS BY LANGUAGE
Figure 5 shows a pie chart of the calls by
language. Approximately 90 percent of calls
were for English and nine percent of calls
were for Spanish. At the time of this report,
24 Customer Service representatives were
on staff; of these, six were bilingual (25
percent).When evaluating the Customer
Service call logs, the bulk of calls received
are through the English phone lines, with a
small portion (9 percent) selecting a Spanish
option.
Transit Education Program
Valley Metro has a Transit Education program that presents information to various groups
to teach about public transit, benefits of transit and how to use the system. Staff members
visit schools, businesses, social service agencies and present to new residents and
refugee groups, senior citizens and persons with disabilities. Additionally, transit
information and assistance are provided at community or special events including
environmental advocacy events, transportation or vehicle days, career days and more.
This team also conducts general presentations by request to any group who wants to
learn more about Valley Metro services.
The many Spanish-speaking passengers are accommodated because much of the transit
information is available in Spanish. Additionally, a bilingual Valley Metro staff member will
generally give the transit education presentation in Spanish upon request. Prior to the
COVID-19 pandemic, the transit education staff would also conduct monthly

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Limited English Proficiency Plan | Title VI Implementation Plan

presentations with refugee resettlement groups. Given the varied backgrounds of refugee
groups, the hosting organizations would generally provide the necessary interpreters.
Valley Metro staff members have developed training materials that are mostly images to
help bridge the language issues.
Website Translation
Apart from accessing information from transit employees—whether by phone, email, in
person or another method—many customers use the www.valleymetro.org website for
information. The website is equipped with the Google Translate feature, which allows
translation into over 100 languages. As of 2024, users have translated the Valley Metro
website into over 80 different languages using this feature. Approximately 99 percent of
interactions with the Valley Metro website used the default English setting. Note only
partial statistics are available for 2023 due to an error in the Google content management
system responsible for collecting this data. In Table 6, the following data from 2022 offers
a complete insight into the languages translated and the percentage of sessions in 2022.
Note that only those languages accounting for at least 0.01 percent of the total sessions
are included.
TABLE 6: 2022 WEBSITE SESSIONS, BY LANGUAGE

Language
Number of Sessions
Percentage of Total Sessions
English
2,792,742
97.59
Spanish
51,481
1.80
Chinese
2,958
0.07
Japanese
2,116
0.10
French
1,532
0.06
German
1,996
0.07
Korean
1,148
0.04
Portuguese
550
0.02
Russian
816
0.03
Dutch
406
0.01
Italian
429
0.01
Other
5,595
0.2

Once again, Spanish was overwhelmingly the most widely used language with the
website translation service, accounting for 1.80 percent of sessions, followed by Chinese
(0.10 percent), Japanese (0.07 percent), German (0.07 percent), Korean (0.04 percent),
French (0.04 percent), Russian (0.03 percent, Portuguese (0.02 percent and Other (0.20
percent). Figure 6 shows the number of translated sessions by language.

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Limited English Proficiency Plan | Title VI Implementation Plan

FIGURE 6: NUMBER OF TRANSLATED WEBSITE SESSIONS,
BY LANGUAGE (EXCLUDING ENGLISH)

Historically, the website has been translated to over 80 other languages that collectively
accounted for 0.2 percent of all sessions. These languages include:

• Afrikaans
• Arabic
• Bulgarian
• Catalan
• Croatian
• Czech
• Danish
• Farsi
• Filipino
• Finnish
• Greek
• Hebrew
• Hindi
• Hungarian
• Indonesian
• Latin
• Norwegian
• Polish
• Romanian
• Samoan
• Serbian
• Slovak
• Slovenian
• Swedish
• Telugu
• Thai
• Tonga
• Ukrainian
• Vietnamese

Many documents on Valley Metro’s website are translated into Spanish since they are
disseminated as paper materials to the public. Individuals may use these documents without
translating the website into Spanish. Some of these documents include project updates, route
maps and schedules, instructions and applications for a Reduced Fare ID, service change
information, policies, brochures and forms.
Conclusion
The Factor 2 analysis revealed that there is regular contact between the LEP population and
Valley Metro personnel. The Customer Service call log showed that nine percent of
customers used one of the five Spanish options. Information from the Transit Education

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team qualitatively identified Spanish as the main language group. Finally, translation data
from the Valley Metro website indicated 2.4 percent of sessions were translated—most of
which were translated to Spanish. Historically, the website has been translated to over 80
different languages. Overall, there is broad diversity in the Phoenix region population that
accesses regional transit services; however, most people using the Valley Metro system
speak English or Spanish.

4.0 NATURE AND IMPORTANCE OF THE PROGRAM, ACTIVITY OR
SERVICE PROIVDED (FACTOR 3)

The third step in the four-factor LEP needs assessment is an evaluation of the importance of
Valley Metro services to persons with limited English proficiency. The first component of the
Factor 3 analysis was to identify critical services. Next, input from community organizations
was used to identify ways to improve these services for LEP populations. The DOT Policy
Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP)
Persons (2005) advises that:
The more important the activity, information, service, or program, or the greater the possible
consequences of the contact to the LEP individuals, the more likely language services are
needed. The obligations to communicate rights to an LEP person who needs public
transportation differ, for example, from those to provide recreational programming. A recipient
needs to determine whether denial or delay of access to services or information could have
serious or even life-threatening implications for the LEP individual . . . 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, education,
or access to employment.
With assistance from Valley Metro’s Community Relations and Marketing departments, a list
of services provided was prepared and prioritized. Input from community organizations and
LEP persons was incorporated to ensure views of the importance of services provided are
adequately prioritized.
4.1 Services Provided
In cooperation with Valley Metro’s Communications and Operations departments, services
currently provided to LEP persons were queried. All printed materials are translated into
Spanish, and materials in both English and Spanish are available on both bus and light rail
services. Below is a list of available materials and services in Spanish that includes bus- and
light rail-specific services:
• Press releases
• Public materials including, but not limited to
o Route Scout (announcements on buses and light rail)
o Ride Guide and Destinations Guide
o Service changes materials
o Transit Book
o Website
o COVID-19 updates
o Project updates

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Limited English Proficiency Plan | Title VI Implementation Plan

o Title VI forms
o Large special events materials (for example, Super Bowl public materials)
• Direct mailers or door hangers for targeted outreach
• Ticket vending machines (Spanish and Braille)
• Bilingual Customer Service staff
• Email list messages
• Bus-specific services:
o Car cards (on-board advertisements)
o Bus signage (priority seating, caution signs, entry/exit, etc.)
o Variable message sign (VMS)6 that displays audio announcements on buses
• Light rail-specific services:
o Light rail transit (LRT) vehicle signage, including priority seating, code of
conduct, and other train information
o VMS1 announcements on vehicles and at stations
o System maps and auxiliary information
o Operator call boxes on trains
o Emergency call box at stations
o Safe place notices

4.2 Critical Services
Public transit is a key means of mobility for persons with limited English proficiency. Of those
services identified above, a subset of critical services was prioritized to ensure that those
services imperative to use Valley Metro public transportation options are available to all
users.

Basic trip information is available both printed and electronically in Spanish, including service
hours, tickets, trip planning, airport and transit connections, parking, bicycles and services for
persons with disabilities. Also available in Spanish is information regarding how to use transit,
acceptable user conduct, priority seating, caution signs and exit locations on vehicles. Ticket
vending is available in both Spanish and Braille. Many documents are available in Braille
upon request. Emergency notification measures are also translated, including audio VMS
announcements on vehicles (bus and rail), operator call boxes, emergency call boxes and
safe place notices.

Bilingual Customer Service representatives are available during regular call center hours.
Representatives use the same procedures for comments and note that the inquiry was in
Spanish so that a bilingual representative is assigned in any follow-up response if needed.
Outside of Customer Service hours, the website is available for translation to most languages
at any time. For public meetings and hearings, a Spanish translator is usually available;
additional translators are available upon request or in the appropriate context. Typically,
additional translation services requested are provided for American Sign Language through
an on-call contract.

1 Variable message signs are audio announcements that occur on transit services to inform riders
of relevant information and updates. Light rail stations and vehicles are equipped with VMS
announcements; most ﬁxed- route vehicles are also equipped with VMS capabilities.

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Limited English Proficiency Plan | Title VI Implementation Plan

5.0 CURRENT RESOURCES AVAILABLE AND THE COSTS TO
PROVIDE LANGUAGE ASSISTANCE SERVICES (FACTOR 4)

The final step of the four-factor LEP analysis was an evaluation of the current and projected
financial and personnel resources available to meet the current and future needs for language
assistance. The first component of the Factor 4 analysis was to identify current language
assistance measures and associated costs. The next step was to determine what additional
services may be needed to provide meaningful access. The DOT Policy Guidance
Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Persons (2005)
advises that:
A recipient’s level of resources and the costs imposed may have an impact on the nature of the
steps it should take in providing meaningful access for LEP persons. Smaller recipients with more
limited budgets are not expected to provide the same level of language services as larger
recipients with larger budgets. In addition, ‘reasonable steps may cease to be reasonable where
the costs imposed substantially exceed the benefits.
Valley Metro has a strong commitment to reducing the barriers encountered by LEP persons
in accessing its services and benefits, to the extent resources are available. Valley Metro
currently does not break down all cost expenditures related to providing language assistance;
however, language assistance costs are evaluated on a triennial basis to include in Title VI
reporting.

5.1 Current Measures and Costs
Costs incurred by Valley Metro for the language assistance measures currently being
provided include:
• Translation of materials
• Printing, advertising or other marketing costs
• Interpretation services
• Staff costs associated with Title VI efforts in adhering to language assistance
measures
Typically, an amount is embedded into the project costs by activity (logged under printing or
other direct expenses) for translation and production of any materials. Agency-wide, there is
an on-call contract for any interpretation needs. Any production costs are included in printing
and public meetings budgets. Furthermore, bilingual employees provide intermittent language
assistance needs as part of their other duties. The Valley Metro community outreach team
hires with a preference towards bilingual speakers, especially for projects where LEP
residents are prominent. Multiple employees in the community outreach team are fluent in
Spanish. These employees may be assigned to prepare press releases or media events with
Spanish-speaking publications in addition to their typical duties. These costs are not tracked,
although most of the formal interpretation services are contracted.
Interpreters are contracted on a case-by-case basis for public meetings or hearings to ensure
that any language assistance needs are met so that public relations staff can focus on
facilitating the event. All hearings are staffed with interpreters while public meetings are staffed
depending on the anticipated number of persons reached and upon request.

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Limited English Proficiency Plan | Title VI Implementation Plan

Valley Metro provides headsets to those wishing to hear the presentation in the translated
language. To accommodate Spanish speakers, Valley Metro has held some events fully in
Spanish, with an English translator. Those wishing to listen to the presentation in English used
headphones and printed materials in English.
Valley Metro currently contracts for interpreters at public meetings. In FY24 the cost for
language interpreter services at public meetings in total was $20,545. Costs for translating
and producing written materials such as meeting notices, display boards, news releases and
project update sheets are also budgeted annually. In FY24 the cost for this service was
$25,502The total for all translation services therefore in FY24 was $48,853.
Additional costs include other staff time used on an ad hoc or regular basis to provide
translation or interpretive services. Exactly 25 percent of Customer Service representatives
are bilingual, assisting both Spanish- and English-speaking customers. Being bilingual is a
preferred qualification when hiring Customer Service staff, although not required. Bilingual
employees also may assist on an informal, ad hoc basis to communicate with LEP individuals
in other departments.

5.2 Cost-effective Practices
Valley Metro will continue to evaluate ways to improve the cost-effectiveness and the quality
of its language services. Additional strategies for saving costs or improving quality may include
developing internal and external language services, with the opportunity to coordinate across
multiple agencies in the region. Current measures to ensure services are cost-effective
include:
• Bilingual staff trained to act as interpreters and translators
• Shared Customer Service center and other information for combined translation and
interpretation resources
• Some standardized common documents with transit and other public agencies
• Using the free Google Translate service on the Valley Metro website
• Translated vital documents currently posted on www.valleymetro.org
• Strategies for consolidating the regional language assistance measures to achieve
efficiencies may include:
• Further development of a LEP information center for Valley Metro employees
• Surveying Valley Metro staff to determine any additional existing multilingual resources
• Conducting outreach to various community organizations to secure volunteers for
translation and interpretation services that are currently contracted or completed in-
house
• Consolidating contract services for oral and written translation to secure the most cost-
effective rates
Valley Metro continues to use qualified translators and interpreters to uphold the quality of
language assistance measures. Valley Metro strives to provide basic informational training for
volunteer staff on its language assistance measures.

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Limited English Proficiency Plan | Title VI Implementation Plan

5.3 Additional Services and Budget Analysis
Valley Metro is committed to reducing the barriers encountered by LEP persons in accessing
its services to the extent funding is available. While Valley Metro currently does break down
contracted cost expenditures related to providing language assistance, expenditures of efforts
for translation and interpretation completed in-house are less well- documented. As part of the
Language Assistance Plan, Valley Metro will better monitor efforts in the future. Valley Metro
will further evaluate how to consolidate its language assistance measures to deliver the most
cost-effective services.
The information received from community organizations provided some insight on additional
services that may ease access for LEP persons to regional transit services. Services
requested were centered on service expansions that included increased frequencies and later
services at night. However, these would be improvements for consideration and prioritization
of the system rather than specific services for LEP persons. Therefore, they were excluded
here and assigned to the general public process for service requests.
Other requests included using more symbols to depict messaging and system routes. Audio
messaging using VMS could potentially show messaging in another language as well. The
light rail system VMS currently shows messages in English and Spanish. Bus messaging is
typically location data and in close proximity, depending on stop locations. Some audio
messages on buses are announced in Spanish. The feasibility and helpfulness of VMS
translation should be evaluated.
As applicable and through the annual budget process, additional services requested or
identified may be considered for implementation. In 2015, Valley Metro shifted to a zero-
based budget that is approved by two boards of directors: Valley Metro Rail Board and the
Valley Metro RPTA Board. The budgets are developed and approved annually as appropriate
to the unique needs and demands of each agency at that point in time.

5.4 Projected Costs
With a commitment to providing reasonable language assistance measures, Valley Metro
would assess current symbols used on vehicles, at station locations and elsewhere to
determine the sort of improvements that could be made so that the system is more easily
understood visually. Biannually, in coordination with the service changes, updated system
maps are produced.
Other improvements would be considered after analyzing the staff costs, third-party contract
costs and costs related to volunteer or community organization coordination. These would be
evaluated in comparison with anticipated benefits to the LEP population. Other considerations
may include operational issues and implementation time.

6.0 LANGUAGE ASSISTANCE MEASURES

Valley Metro is committed to full compliance with Title VI and Executive Order 13166 to
provide meaningful access and reduce barriers to services and benefits for persons with
limited English proficiency.

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Limited English Proficiency Plan | Title VI Implementation Plan

6.1 Current Language Assistance Measures
Spanish Language Assistance
As discussed earlier, Valley Metro currently provides both oral and written language
assistance in Spanish. Oral language assistance includes bilingual customer service
representatives, speaking Spanish. Additionally, Spanish interpreters are available at public
meetings. On vehicles and at stations, VMS announcements are provided in Spanish.
Written Spanish language assistance includes signs, press releases, list serve messages,
service change materials, Title VI complaint forms, policies and procedures. Additional
translation of some vital documents is provided, such as schedules, maps, Ride and
Destination Guides, route scouts and more. Meeting notices and public input surveys at public
meetings are translated.
Notices to the public of language assistance measures are typically provided side-by-side with
an English version of the document. For example, Ride Guide documents are provided in both
English and Spanish and are available together wherever disseminated. Where available,
documents are printed on both sides with an English version and a Spanish version on each
side of the paper. When calling into the Customer Service line, the interactive voice response
system will automatically ask if Spanish is the preferred language prior to being connected
with a representative.

Languages Other Than Spanish
Valley Metro provides oral and written translations into other languages when applicable. For
written translations, the Valley Metro website is equipped with the Google Translate feature,
which allows translation into over 100 languages. For oral translations, the agency uses an
existing contract that can provide translations into all languages identified in the Language
Assistance Plan, as well as American Sign Language. Translators under this contract are
used for public meetings, canvassing and other community outreach as needed. Valley Metro
also provides sign language interpreters for public meetings when requested, and provides
Braille translations on fare vending machines and for printed documents upon request.
As the region grows and diversifies the agency will translate vital documents into languages
other than English and Spanish as practicable for language populations over 1,000 that speak
English less than very well. These vital documents include:
• Title VI Notice to the Public
• Title VI complaint forms
• Title VI procedures
• Notices to public
• Service and Fare Changes
• Bus and Rail Schedules
These items are currently translated into Spanish as well as English. The agency will continue
to monitor the demographics of the region as these printed offerings are expanded to meet
federal requirements.

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Limited English Proficiency Plan | Title VI Implementation Plan

6.2 Staff Training
Specific policies and procedures for interacting with LEP persons are not formally adopted on
a stand-alone basis. These policies and procedures are, in essence, for all customers and
have been embedded into multiple documents (including the Title VI Plan, trainings,
instructions, etc.).
Using the Customer Service Center as an example, Spanish calls are assigned directly to a
Spanish-speaking representative through the phone system. In the CAS, a note is made that
the customer speaks Spanish so that if Customer Service cannot respond to the query
immediately, any future response is assigned to a bilingual representative. This training is
integrated into general customer assistance staff training to ensure cost- effective practices
and efficient use of training resources. Title VI is distributed to new Customer Service
employees and, where applicable, employees are expected to know how to file discrimination
claims based on race, color or national origin. Additionally, there are related trainings available
including quarterly Civil Rights Workshops, training sessions for conducting complaint
investigations according to federal guidelines and streamlining the complaint investigative
process.
Training for employees who regularly encounter the public may also include:
• Type of language services available
• How staff and/or LEP customers can obtain these services
• How to respond to LEP callers
• How to respond to correspondence from LEP customers
• How to respond to LEP customers in person
• How to document LEP needs
Valley Metro continues to consider opportunities to provide quality services for LEP persons
throughout the service area.

6.3 Future Language Assistance Services
With the development of subsequent Language Assistance Plans, the monitoring, evaluation
and update process would identify additional services to be considered for feasibility of
implementation. Valley Metro strives to serve LEP populations adequately with an equal
opportunity to use transportation options available. Section 7 provides more information about
the plan’s monitoring and update process.

7.0 MONITORING AND UPDATING THE LANGUAGE ASSISTANCE PLAN

Triennially, Valley Metro will review, monitor and update the language assistance plan.
Feedback from agency staff and community members will be accepted throughout the year
at the email address: TitleVICoordinator@ValleyMetro.org. Additional community feedback
may be elicited during the update process. Internal monitoring will be conducted using the
template provided from the FTA handbook Implementing the Department of Transportation’s
Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP)

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Limited English Proficiency Plan | Title VI Implementation Plan

Persons (2007). Using this checklist, stations, vehicles, Customer Service, community
outreach and public relations are periodically monitored.
Using this information, changes may be made to the language assistance plan recognizing
any cost implications and resources available. Depending on cost and resource evaluation,
language assistance measures may be expanded, modified or eliminated based on their
effectiveness.
As the transit service area is modified through service changes, the demographics served will
be reviewed to ensure that those areas with high concentrations of LEP persons are reflected
accurately in an effort to provide language assistance measures to areas with expanded
transit services.
Throughout the monitoring period, Valley Metro will continue to follow the recommendations
and use the resources provided by Executive Order 13166, FTA Circular 4702.1B, the DOT’s
Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP)
Persons (2005), and the FTA handbook Implementing the Department of Transportation’s
Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP)
Persons (2007). Valley Metro will be better able to apply the DOT LEP guidance’s four-factor
framework and will continue to determine an appropriate mix of language assistance in the
preparation of language assistance implementation plans.

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Non-Elected Committees Membership Table | Title VI Implementation Plan

Non-Elected Committees Membership Table

A subrecipient who selects the membership of transit-related, non-elected planning boards,
advisory councils, or committees must provide a table depicting the membership of those
organizations broken down by race. Subrecipients also must include a description of the efforts
made to encourage participation of minorities on these boards, councils, and committees.
Table Depicting Membership of Committees, Councils, Broken Down by Race
Body
Caucasian
Latino
African
American
Asian
American
Native
American
Population

☒ The City of El Mirage does NOT select the membership of any transit-related committees,
planning boards, or advisory councils.

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Monitoring for Subrecipient Title VI Compliance | Title VI Implementation Plan

Monitoring for Subrecipient Title VI Compliance

☒The City of El Mirage does NOT monitor subrecipients for Title VI compliance.

The City of El Mirage does NOT currently have subrecipients and, therefore, does NOT monitor
subrecipients for Title VI compliance. In the event subrecipients come under the control of the
City of El Mirage, the city will adopt and implement a policy that ensures all subrecipients
comply with their obligations under Title VI and any other applicable federal and state laws,
regulations, and rules.

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Title VI Equity Analysis | Title VI Implementation Plan

Title VI Equity Analysis

A subrecipient planning to acquire land to construct certain types of facilities must not
discriminate on the basis of race, color, or national origin, against persons who may, as a result
of the construction, be displaced from their homes or businesses. “Facilities” in this context
does not include transit stations or bus shelters, but instead refers to storage facilities,
maintenance facilities, and operation centers.
There are many steps involved in the planning process prior to the actual construction of a
facility. It is during these planning phases that attention needs to be paid to equity and non-
discrimination through equity analysis. The Title VI Equity Analysis must be done before the
selection of the preferred site.
Note: Even if facility construction is financed with non-FTA funds, if the subrecipient
organization receives any FTA dollars, it must comply with this requirement.
The City of El Mirage has no current or anticipated plans to develop new transit facilities
covered by these requirements.

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Regional System-Wide Standards and Policies | Title VI Implementation Plan

Regional System-Wide Standards and Policies

The City of El Mirage does not operate its own transit system. Transit services in El Mirage are
operated by Valley Metro, in accordance with their Regional System-Wide Service Standards
and Policies. Transit services provided locally are not federally funded.

Distribution of Transit Amenities
Although Valley Metro provides transit services, transit amenities for bus services are locally
funded and fall under the responsibility of the jurisdictions within which they are sited. Transit
amenities refer to items such as seating, bus shelters, provisions of information, waste
receptacles, etc.

The City of El Mirage provides the following transit amenities at all four bus stops located within
its boundaries:
• Bus shelter with gabion basket column
• Two six-foot benches
• Waste receptacle
• Three bike racks
• Porous aggregate pavement
• Concrete pavers
• Steel screen fencing

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Service and Fare Policy Changes | Title VI Implementation Plan

Service and Fare Policy Changes

The City of El Mirage follows Valley Metro’s policy for all service and fare changes.

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Board Approval for the Title VI Program | Title VI Implementation Plan

Board Approval for the Title VI Program
ATTACH A COPY OF THE BOARD MEETING MINUTES HERE