"Exhibit A" El Mirage Title VI Program Plan

City of El Mirage — Regular Meeting (2022-05-17)

Extracted text (via pymupdf) 153760 characters

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Title VI Policy Statement | Title VI Implementation Plan

Title VI Implementation
Plan

May 3, 2022 to June 1, 2025

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Title VI Policy Statement | 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
What is Title VI? ......................................................................................................................................... 6
How do I file a complaint? .......................................................................................................................... 6
Customer Service ....................................................................................................................................... 7
Requesting Information ............................................................................................................................. 8
Tracking a Title VI Compliant ...................................................................................................................... 8
Investigating a Title VI Complaint............................................................................................................... 8
¿Qué es el Título VI? ................................................................................................................................. 10
¿Cómo registro una queja? ...................................................................................................................... 10
Servicio al Cliente ..................................................................................................................................... 11
Solicitando Información ........................................................................................................................... 12
Rastreando Una Queja del Título VI ......................................................................................................... 12
Investigando Una Queja del Título VI ....................................................................................................... 12
Title VI Complaint Forms ............................................................................................................................ 2
Title VI Investigations, Complaints, and Lawsuits ...................................................................................... 4
Public Participation Plan............................................................................................................................. 5
Limited English Proficiency Plan ................................................................................................................. 7
Non-elected Committees Membership Table .......................................................................................... 10
Title VI Equity Analysis ............................................................................................................................. 12
Regional System Standards and Policies .................................................................................................. 12
Service and Fare Policy Changes .............................................................................................................. 12
Board Approval for the Title VI Program .................................................................................................. 13

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Title VI Policy Statement | Title VI Implementation Plan

Title VI Policy Statement

The City of El Mirage and Valley Metro/RPTA 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/RPTA sponsored program or activity. There is no distinction between the sources
of funding.

City of El Mirage and Valley Metro/RPTA also assures 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, City of El Mirage and Valley Metro/RPTA will take reasonable steps
to provide meaningful access to services for persons with limited English proficiency.

When City of El Mirage and Valley Metro/RPTA distributes Federal-aid funds to another
entity/person, City of El Mirage and Valley Metro/RPTA will ensure all subrecipients fully comply with
City of El Mirage and Valley Metro/RPTA 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/RPTA

The City of El Mirage and Valley Metro/RPTA 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/RPTA.

For more information on the City of El Mirage and Valley Metro/RPTA’s civil rights program, and the
procedures to file a complaint, contact City Clerk, 623-876-2943, (TTY 1-800-877-8339); email
santes@elmirageaz.gov; or visit our administrative office at 10000 N. El Mirage Road, El Mirage, AZ
85335. For more information, visit https://www.elmirageaz.gov/168/City-Clerks-Office

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.

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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
Ciudad de El Mirage o Valley Metro

Ciudad de El Mirage o 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 o Valley Metro’s programa de derechos
civiles, y los procedimientos para presentar una queja, contacte Sharon Antes, Ciudad de El Mirage
City
Clerk/Title
VI
Coordinator,
623-876-2973,
(TTY
1-800-877-8339);
email
santes@cityofelmirage.org; o visite nuestra oficina administrativa en 10000 N. El Mirage Road, El
Mirage AZ 85335. Para obtener más información, visite https://www.elmirageaz.gov/168/City-Clerks-
Office

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

The above notice is posted in the following locations: City of El mirage’s Clerk’s Office, City of El
Mirage website, and City of EL Mirage Senior Center facility located at 14010 N. El Mirage Road, El
Mirage, AZ 85335.

This notice is posted online at https://www.cityofelmirage.org/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

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Investigating a Title VI Complaint | Title VI Implementation Plan

• Radio/Dispatch/OCC reports
• 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

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

response provided in CAS under the case number assigned.

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

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Servicio al Cliente | Title VI Implementation Plan

City of Phoenix Public Transit Department 302 N.
1st Avenue, Suite 900
Phoenix, AZ 85003
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.

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Investigando Una Queja del Título VI | Title VI Implementation Plan

• 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.

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
This form will be submitted annually. If no investigations, lawsuits, or complaints were filed, a
blank form will be submitted.

☑ City of El Mirage has not had any Title VI complaints, investigations, or lawsuits in
FY2021.City of El Mirage has not had any Title VI complaints, investigations, or lawsuits in
FY2021.

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
City of El Mirage/Valley
Metro
Public Participation
Plan

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Public Participation Plan | Title VI Implementation Plan

City of El Mirage/Valley Metro is engaging the public in its planning and decision-making processes,
as well as its marketing and outreach activities. 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.

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

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.

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.

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.

• 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.

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.

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.

7
Public Participation Plan | Title VI Implementation Plan

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

8
Public Participation Plan | Title VI Implementation Plan

City of El Mirage/Valley Metro has developed the following Limited English Proficiency Plan (LEP) 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 an 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

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

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

9
Public Participation Plan | Title VI Implementation Plan

(3) Outreach Materials
(4) Bus Schedules
(5) Route Changes
(6) Public Hearings

MEETING SUMMARY

Language Assistance Plan
Title VI Program

July 2021

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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 64 million riders annually. Valley Metro
provides fixed route bus service, light rail service, streetcar service (open in late 2021)
and complementary ADA 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, 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, and Valley Metro, Scottsdale and Glendale. There is a total of 893 fixed-route
vehicles and 50 light rail vehicles operating in the region. Of these vehicles, 95 are
circulators.
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 20
Express/RAPID routes, 21 community circulator routes, 1 rural connector route and 1 light
rail system. Valley Metro customers made over 64,000,000 boardings during fiscal year
2019.
Seven Four regional 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
1,134,014.
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.
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

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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.
1.1 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).”

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.

1.2 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.

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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, 2019 American Community Survey
(ACS) 5-year Sample. The 2019 ACS data were used because the 2020 decennial
census, at the time of this update, was not available.
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 American Community Survey (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 2019
ACS 5-year data (2015 to 2019).
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. 8.7 percent of residents in Maricopa County speak English less than “very well”,
while 9.6 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: 2019 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
4,050,301
2,957,214
737,917
355,170
8.7
Census Tracts
within service
areaa
3,530,687
2,501,110
690,264
339,349
9.6
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 2019 ACS data show the population self-identified as speaking
English less than “very well” was predominantly the Spanish language group,
encompassing 261,287 people, or 7.4 percent of the total population age five years and
over. Indo-European, Asian or Pacific Islander, and All Other Languages groups account
for 78,026 people, or 2.2 percent of the population. Of all those speaking English less
than “very well”, the Spanish group makes up 77 percent of the total population over age
five with limited English proficiency.

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TABLE 2: 2019 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
3,530,687
690,264
148,748
119,838
70,727
9.6
English
2,501,110
—
—
—
—
0.0
Spanish
788,929
527,642
100,211
97,690
63,386
7.4
Asian or Pacific
Islander
95,307
57,621
22,331
11,922
3,433
1.1
Indo-European
88,411
66,861
14,813
4,981
1,756
0.6
All other languages
56,930
38,140
11,393
5,245
2,152
0.5

The 2019 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 2019). In total, the 2019 ACS data identified 1,356,898 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: 2019 ACS DATA, BY LINGUISTICALLY ISOLATED HOUSEHOLDS
Language Category
Total
Households
Isolated
Households
Non-isolated
Households
Percentage
Isolated
Households
Census tracts in service
area
1,356,898
57,919
330,557
4.3
English
968,422
—
—
—
Spanish
276,605
41,125
235,480
3.0
Asian or Pacific Islander
41,622
7,956
33,666
0.6
Indo-European
46,362
4,648
41,714
0.3
All other languages
23,887
4,190
19,697
0.3

Within the transit service area, 4.2 percent of households are considered linguistically
isolated. Again, these are predominantly Spanish households, making up three percent
of the total. Remaining languages make up 1.2 percent of households that are classified
as linguistically isolated.
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.

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FIGURE 2: CENSUS TRACTS WITH LINGUISTICALLY ISOLATED HOUSEHOLDS

Figure 3 shows the ACS 2019 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.

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FIGURE 3: CENSUS TRACTS WITHIN SERVICE AREA

The 2019 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 2019
population by language and ability, sorted by percentage of LEP population.
Within the service area, the majority of the 2019 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 261,287
individuals within the service area. The Other Indo-European, Mandarin Chinese, and
Other and Unspecified speaking populations followed with 3.86 percent, 3.42 percent,
and 3.33 percent respectively. The Vietnamese, Other Asian and Pacific Island and
Arabic speaking populations follow with 2.87 percent, 2.85 percent and 2.27 percent,
respectively. This is followed by Russian and Filipino with 1.63 percent and 1.28 percent,
respectively, and then by Korean (0.8 percent), French (0.6 percent) and German (0.3
percent).

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TABLE 4: 2019 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
335,714
—
—
100
Spanish
261,287
527,642
788,929
77.83
French, Haitian or Cajun
2,115
7,666
9,781
0.63
German
988
9,765
10,753
0.29
Russian, Polish or Other Slavic
5,484
12,517
18,001
1.63
Other Indo-European languages
12,963
36,913
49,876
3.86
Korean
2,694
2,856
5,550
0.80
Mandarin Chinese
11,471
11,965
23,436
3.42
Vietnamese
9,649
6,936
16,585
2.87
Filipino
4,292
12,356
16,648
1.28
Other Asian Pacific Island
9,580
23,508
33,088
2.85
Arabic
7,623
11,563
19,186
2.27
Other and unspecified languages
11,167
26,577
37,744
3.33

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”

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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 USDOT “Policy Guidance Concerning Recipients’
Responsibilities to Limited English Proficient (LEP) Persons” (DOT 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.
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.
Transit Employee Surveys
During September and October of 2020, a voluntary survey of customer service and
transit employees was conducted regarding interaction with LEP persons and languages
spoken. A copy of the survey instrument can be found in Appendix A. Valley Metro

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Customer Service Representatives provide passenger assistance most commonly
through email, but also by phone. Several Customer Service Representatives that are
stationed at transit passenger facilities1 to provide assistance to passengers. Bus
operators at multiple locations were also surveyed. Employees surveyed were based at
one of the following locations:
• Customer Service and Mobility Center
• Central Station Transit Center
• Ed Pastor Transit Center
• Metrocenter Transit Center
• Sunnyslope Transit Center
• Tempe Transportation Center
• East Valley Bus Operations and Maintenance Facility
• Mesa Bus Operations and Maintenance Facility
• Phoenix Bus Operations and Maintenance Facility

In total, 218 respondents provided information about their experiences. Approximately 80
percent of those surveyed were transit operators. When asked if staff have had any
requests for materials in another language in the past two years, 23 percent responded
yes; see Figure 5. Of these, most interpretation or translation requests were for Spanish.
All but two of the locations received translation requests in the past two years: Sunnyslope
Transit Center and Metrocenter Transit Center.
Languages requested were predominantly Spanish (80 percent) followed by Arabic (5
percent) and Chinese (4 percent). Other languages made up 11 percent of requests.
These languages, which were each requested only once, were French, Russian, German,
Farsi, Hindi and Swahili. See Figure 6 for a graphic representation of the languages
requested.
These responses were categorized appropriately and cross-referenced with the language
requested. See Figure 7 for a comparison. Spanish was much more frequently requested
than any other language, and languages other than Spanish were requested at a
substantially less frequent rate.

1 Facilities operated by the City of Phoenix or City of Tempe

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This survey helped support the finding that multiple languages are encountered by transit
professionals, yet Spanish is the most common and most frequent of the languages
encountered.
Customer Service Interactive Voice Response Call Log
The Customer Service Center updated its automated phone system in mid-2014 to
establish the Interactive Voice Response (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:

0
2
4
6
8
10
12
14
16
More than once a week
Once a week
More than once a month
Once a month
Once every three months
Once every six months
Once a year
Once every few years
Number of Responses
Figure 7: Frequency of Languages
Requested as Reported by Front Line Transit
Employees
Languages other than Spanish
Spanish
50
167
0
20
40
60
80
100
120
140
160
180
Yes
No
Respondents
Figure 5: Requests for
Information or Materials
in Another Language
80%
5%
4%
11%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Spanish
Arabic
Chinese
Other
Figure 6: Languages
Requested

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• 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 7 shows the
distribution of calls by option selected, followed by the sum of calls by language for
calendar year 2019.

TABLE 7: 2019 CUSTOMER SERVICE CALL LOG
Call
Total Calls
% of Total Calls
ADA – English
20,672
1.79%
ADA – Spanish
2,457
0.21%
CR – English
166,893
14.45%
CR – Spanish
1,030
0.09%
Light Rail – English
113
0.01%
Light Rail – Spanish
2
0.00%
Lost and Found – English
16,419
1.42%
Lost and Found – Spanish
198
0.02%
TI – English
913,931
79.12%
TI – Spanish
33,462
2.90%
English (Total)
1,118,028
96.78%
Spanish (Total)
37,149
3.22%
Total Calls
1,155,177
100.00%

Figure 8 shows a pie chart of the calls by language. Approximately 97 percent of calls
were for English and three percent of calls were for Spanish. At the time of this report, 38
customer service representatives were on staff; of these, 8 were bilingual (21 percent).

When evaluating the customer service call logs, the bulk of calls received are through the
English phone lines with a small portion (3 percent) selecting a Spanish option.

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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. In 2019, the transit education staff made 427
public presentations, two of which were in Spanish.
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
presentations with refugee resettlement groups. Given the varied backgrounds of refugee
groups, the hosting organizations would generally provide 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 52 languages. Users have translated the Valley Metro website into 43
different languages using this feature. Approximately 99 percent of interactions with the
Valley Metro website used the default English setting. The remaining 1 percent used the
other languages. Table 8 lists the languages translated and the percentage of sessions
97%
3%
Figure 8: Customer Service
Calls by Language
English
Spanish

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in 2019. Note that only those languages accounting for at least 0.01 percent of the total
sessions are included; a full table of entries is available in Appendix B.

TABLE 8: 2019 WEBSITE SESSIONS BY LANGUAGE
Language
Number of Sessions
Percentage of Total Sessions
English
5,659,734
98.56
Spanish
55,257
0.96
Chinese
6,506
0.11
Japanese
4,837
0.08
French
3,293
0.06
German
3,167
0.06
Korean
1,750
0.03
Portuguese
1,297
0.02
Russian
898
0.02
Turkish
1,028
0.02
Arabic
557
0.01
Dutch
497
0.01
Italian
631
0.01
Vietnamese
580
0.01
Other
5,728
0.10

Once again, Spanish was overwhelmingly the most widely used language with the
website translation service, accounting for 0.96 percent of sessions, followed by Chinese
(0.11 percent), Japanese (0.08 percent), French (0.06 percent), German (0.06 percent),
Korean (0.03 percent, Portuguese (0.02 percent, Turkish (0.02 percent) and Other (0.10
percent). Figure 9 shows the number of translated sessions by language.

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The website was translated to 32 other languages that each accounted less than 0.01
percent of the sessions—collectively, these viewings account for 0.04 percent of all
sessions. These languages include:

•
Afrikaans
•
Arabic
•
Bulgarian
•
Catalan
•
Croatian
•
Czech
•
Danish
•
Dutch
•
Farsi
•
Filipino
•
Finnish
•
Greek
•
Hebrew
•
Hindi
•
Hungarian
•
Indonesian
•
Italian
•
Latin
•
Norwegian
•
Polish
•
Romanian
•
Russian
•
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 Transit Employee Survey revealed that 23 percent of all
respondents had encountered an LEP person; of those who had encountered a request
for assistance in another language, 80 percent of respondents reported requests for
Spanish. The Customer Service call log showed that a mere three percent of customers
used one of the five Spanish options. Information from the Transit Education team
qualitatively identified Spanish as the main language group. Finally, translation data from
-
10,000
20,000
30,000
40,000
50,000
60,000
Number of Sessions
Figure 9: Number of Translated Website
Session by Language (Excluding English)

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the Valley Metro website indicated 1.5 percent of sessions were translated—most of
which were translated to Spanish. The website was translated to 43 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 is to identify critical services. Next, input from community
organizations was used to identify ways to improve these services for LEP populations.
The USDOT “Policy Guidance Concerning Recipients‘ Responsibilities to Limited English
Proficient (LEP) Persons” (DOT 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 next bus and light rail specific services:

• Press Releases
• Public materials including, but not limited to:

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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
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) 2 that displays audio announcements on buses

• Light Rail specific services:

o Light rail transit vehicle signage including priority seating, code of conduct, and
other train information
o VMS3 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

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.

2 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
3 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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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.

Community Outreach
Valley Metro conducted interviews with six community organizations that encounter
various LEP populations. Organizations were identified to ensure that a wide variety of
cultural and language groups were reached over large service areas. In response to the
COVID-19 pandemic, all surveys were conducted by phone call or electronically. These
organizations were asked a series of questions from the FTA handbook, “Implementing
the Department of Transportation’s Policy Guidance Concerning Recipients’
Responsibilities to Limited English Proficient (LEP) Persons” (FTA 2007). These
organizations indicated that they serve populations speaking a broad range of languages,
including Spanish, Arabic, and Swahili. The organizations interviewed range from cultural
adult centers to refugee services organizations:
• Ability 360 – a local non-profit that provides services for people with disabilities
• Creighton School District – an elementary school district with 24 percent of students
who speak English as a second language
• International Rescue Committee – a refugee support and relocation non-profit
• Isaac Elementary School District – an elementary school district with the highest
percentage of English learners (33 percent of students)
• Literacy Volunteers of Maricopa County – a non-profit dedicated to improving adult
reading and writing in English
• Turn a New Leaf – a non-profit that provides support for people experiencing
homelessness, domestic violence and other challenges

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Listed below are key language-related findings from the outreach effort:
1. For populations served by these organizations, public transportation is the main
form of transportation to access jobs, medical appointments, social services,
grocery shopping and school.
2. Spanish was the most common language spoken among the LEP populations at
each organization. Swahili and Arabic were the second most common languages.
3. Organizations interviewed expressed needs of LEP populations regarding
language assistance including:

a. System Map Information: LEP populations have expressed a difficulty in
understanding and familiarizing themselves with system maps.
b. Transit Service Information: LEP populations have expressed the desire for
information, such as how to ride and fare payment information, be
communicated in an understandable format. Symbols could be used to
communicate messages to a wider audience. Also, offering orientation to
these populations, through their respective agencies, would familiarize them
with the transit system.

4. When asked who the LEP populations would most trust to deliver transit
messaging, most organizations responded that messaging should come from
ethnic community organizations or individuals that speak their languages.

Valley Metro continues to make improvements in language assistance for the LEP
population in the region in all areas including the three identified above. See Appendix
C for completed surveys from each community organization.

This valuable feedback provided a few opportunities for Valley Metro to reduce barriers
experienced by LEP riders. In regard to item 3, Valley Metro staff was able to introduce
the organizations that expressed this concern to Valley Metro’s Transit Education
Program. This program can help riders better understand the transit system and provide
useful transit service information. More research is needed to understand whether system
map and transit service information difficulties are truly language issues, or simply
educational issues.

Item 4 could be addressed through coordination with community organizations and the
Valley Metro Transit Education Program. Transit education staff should continue to
present materials to interested groups and should coordinate with the community
organization requesting the presentation to ensure that LEP populations are getting the
information they need.

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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
USDOT “Policy Guidance Concerning Recipients’ Responsibilities to Limited English
Proficient (LEP) Persons” (DOT 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

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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.
Valley Metro provides headsets to those wishing to hear the presentation in the translated
language. Recent public meetings for the South Central Light Rail Extension have taken
place in communities where the predominant language is Spanish. To accommodate
Spanish speakers, Valley Metro 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’s current contract for interpreters at public meetings costs approximately
$200 per meeting. Annually, $2,000 to $3,000 is spent to provide interpreters for staff
meetings and public hearings. In addition, $400 to $800 is spent annually for sign
language interpreters at meetings (as requested) and public hearings. Costs for
translating and producing materials such as meeting notices, display boards, news
releases, and project update sheets are also budgeted annually— approximately $30,000
to $35,000. In total, approximately $33,000 to $39,000 is contracted out directly in support
of language assistance services for interpreters, translation, and materials dependent on
the projects and programs implemented each year.
Additional costs include other staff time used on an ad hoc or regular basis to provide
translation or interpretive services. More than 30 percent of public relations and 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 valleymetro.org

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Strategies for consolidating the regional language assistance measures to achieve
efficiencies may include:
• Creating an 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.

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 that 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.

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5.4 Projected Costs
Requests for added services include expanded symbols to understand how to use transit
services, on-board messaging and system map information. With a commitment to
providing reasonable language assistance measures, Valley Metro will 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.
With expanded use of symbols, it is expected that the need for enhancing the on-board
messaging and system map information may be reduced. Furthermore, these could be
incorporated into the regular updates of this information and signage. 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.

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,

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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 52 languages (www.translate.google.com). 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.
6.2 Staff Training
Specific policies and procedures for interacting with LEP persons are not formally adopted
on a standalone 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 customer
assistance system 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
of the Civil Rights Act of 1964 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.

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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) Persons” (FTA 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 USDOT’s “Policy Guidance Concerning Recipients’ Responsibilities
to Limited English Proficient (LEP) Persons” (DOT 2005), and the FTA handbook
“Implementing the Department of Transportation’s Policy Guidance Concerning
Recipients’ Responsibilities to Limited English Proficient (LEP) Persons” (FTA 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.

APPENDIX A – TRANSIT EMPLOYEE INSTRUMENT

Language Assistance Program Survey 2021

Name: ________________________________________________________

1. Have you had any requests for information or materials in other languages in the past
two years?
a. Yes
b. No

If yes, please complete the remainder of the survey.
If no, thank you for your participation.

2. Which language(s) have been requested?

______________________________________________________________________

3. How often do you receive requests?
a. More than once a week
b. Once a week
c. More than once a month
d. Once a month
e. Once every three months
f. Once every six months
g. Once a year
h. Other: ________________________________________________________

4. Do you have the resources needed to help customers with language requests?

a. Yes

b. Sometimes

c. No

Language Assistance Plan
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Page 30

APPENDIX B – WEBSITE SESSIONS BY LANGUAGE

Language
Number of Sessions
Percent of Total Sessions
Afrikaans
35
0.00
Arabic
557
0.01
Bulgarian
33
0.00
Chinese
6,506
0.11
Croatian
63
0.00
Czech
220
0.00
Danish
17
0.00
Dutch
497
0.01
English
5,659,734
98.56
Farsi
29
0.00
Filipino
25
0.00
Finnish
200
0.00
French
3,293
0.06
German
3,167
0.06
Greek
90
0.00
Hebrew
77
0.00
Hindi
27
0.00
Hungarian
65
0.00
Indonesian
122
0.00
Italian
631
0.01
Japanese
4,837
0.08
Korean
1,750
0.03
Latin
119
0.00
Norwegian
198
0.00
Polish
243
0.00
Portuguese
1,297
0.02
Romanian
79
0.00
Russian
898
0.02
Samoan
38
0.00
Serbian
18
0.00
Slovak
58
0.00
Slovenian
114
0.00
Spanish
55,257
0.96
Swedish
288
0.01
Telugu
83
0.00
Thai
24
0.00
Tonga
22
0.00
Turkish
1,028
0.02
Ukrainian
30
0.00
Unknown
175
0.00
Vietnamese
580
0.01
Total
5,742,597
100

Language Assistance Plan
07/22/2021
Page 31

APPENDIX C – LEP COMMUNITY OUTREACH SURVEYS CONSOLIDATED
Ability 360
2/11/2021

1. What geographic area does your agency serve?

The Phoenix Metro area, although we have people that come as far as Payson. We cover near and far.
2. What kind of services does your organization provide?

Sports, fitness and health-related activity for total inclusion in the community. The main facility does handle
home-health, and community integration services.
3. How many people does your agency provide services to?
2,300-2800 was the last member count. The numbers have decreased due to the pandemic.
4. Has the size of the population you serve increased, stayed the same, or decreased over the past five
years?

Increased over the last five years.
5. What are the countries of origin from which your population has immigrated?

Iran, Iraq, Puerto Rico, Mexico, people from all around the world that are here using the gym on a regular
basis.
6. Does your population come from an urban or rural background?

I don’t know.
7. What are the languages spoken by the population you serve?

English
Spanish
Arabic
8. What is the age of your population?

No idea. Due to coronavirus, a lot of things have changed. We serve more adults right now than children. In
normal times, we cover the entire continuum.
9. What is the education and literacy level of the population you serve?

Here to there. The fact that our population has disabilities, it’s difficult to say. I myself don’t have that
knowledge and it’s not something we normally ask.

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10. What needs or expectations for public transportation services has this population expressed?

We are so thankful for the stop at the top of the hill. That’s made a huge difference in our client’s lives. Just
the other day, there was a man who took two buses and the light rail to get here. It’s been his lifeline.
11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?

I don’t know.
12. What are the most frequently traveled destinations?

Everywhere. They jump on the light rail. Most of our population do not drive.
13. Are there locations that the population has expressed difficulty accessing via the public transportation
system?

I don’t know.
14. Do the transit needs and travel patterns of the population vary depending on the age or gender of the
population members?

I don’t know.
15. What is the best way to obtain input from the population?

Survey. Either paper or electronic. All our registrations are done by app and website.
16. Who would the population trust most in delivering language appropriate messages?

I don’t know.
17. Does your agency take advantage of Valley Metro resources such as transit education or ridesharing tools?
Why or why not?

I don’t know.

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Creighton School District
1/27/2021

1. What geographic area does your agency serve?
Creighton School District serves the following geographical area: 16th ST – 32nd ST from N Van Buren to
Indian School and from 32nd ST - 40th ST from N Van Buren to Lincoln Drive.
2. What kind of services does your organization provide?
In addition to educational services, we offer transportation services to McKinney-Vento eligible families, which
are families experiencing homelessness. Our district is able to provide transportation assistance to families
experiencing homelessness thanks to our McKinney-Vento grant.
3. How many people does your agency provide services to?
As of January 25th, 2021, our school district serves 167 families in our transportation program. However, the
number of families requesting transportation assistance is increasing due to the COVID pandemic.
4. Has the size of the population you serve increased, stayed the same, or decreased over the past five
years?
For the past five years we have experienced a declined on our homeless population. However, the number
of families requesting transportation assistance is increasing due to the COVID pandemic.
5. What are the countries of origin from which your population has immigrated?
Creighton School District serves families who have immigrated from mostly México, South America, and
Africa.
6. Does your population come from an urban or rural background?
Most our families come from urban areas, but we do have a small percentage of families who come from
rural areas.
7. What are the languages spoken by the population you serve?
Our district serves families that speak over 26 languages, however Spanish is the most common language
in our community.
8. What is the age of your population?
Our district serves students between ages 3 to 14 years old (Preschool to 8th grade).
9. What is the education and literacy level of the population you serve?
We serve low-income families and commonly their level of literacy varies from each household from Middle
School to some High School education. A small percentage of our families have completed graduate and
undergraduate education.

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10. What needs or expectations for public transportation services has this population expressed?
Most of our families request transportation services for school, doctor appointments, counseling, or other
social services.
11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?
Yes, since we serve low income families, we do receive many transportation requests. However, our district
is able to provide transportation assistance to families experiencing homelessness thanks to our McKinney
Vento grant.
12. What are the most frequently traveled destinations?
Most of our families request transportation services for school, doctor appointments, counseling, or other
social services.
13. Are there locations that the population has expressed difficulty accessing via the public transportation
system?
Not at this time.
14. Do the transit needs and travel patterns of the population vary depending on the age or gender of the
population members?
Yes.
15. What is the best way to obtain input from the population?
Our community respond well to in person meetings, phone calls, email or texts.
16. Who would the population trust most in delivering language appropriate messages?
Our community trusts school officials or people who speak their native language.
17. Does your agency take advantage of Valley Metro resources such as transit education or ridesharing tools?
Why or why not?
Yes we used some, but we would like to have more information about the tools and resources you have
available for community members.

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International Rescue Committee
1/14/2021
1. What geographic area does your agency serve?
West Phoenix, I-17 corridor, Glendale, various others
2. What kind of services does your organization provide?
Refugee Resettlement: Employment, financial coaching and credit building, English language classes, case
management, school support, clinical therapy, immigration services
3. How many people does your agency provide services to?
1,200+
4. Has the size of the population you serve increased, stayed the same, or decreased over the past five years?
Decreased (COVID-19, public policy)
5. What are the countries of origin from which your population has immigrated?
Democratic Republic of the Congo, Myanmar, Afghanistan, Eritrea, Guatemala, Iraq, and more
6. Does your population come from an urban or rural background?
Predominately rural
7. What are the languages spoken by the population you serve?
Swahili, Kinyarwanda, Arabic, Dari, Burmese, Afar, Tigrinya, French, Rohingya, Spanish, and many smaller
tribal languages: Kinyabwisha, Chin, Kibembe, Lingala, etc.
8. What is the age of your population?
0-99
9. What is the education and literacy level of the population you serve?
Varies; predominantly below secondary school
10. What needs or expectations for public transportation services has this population expressed?
Wait times between buses, especially during hot summer months; reliability/timeliness
11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?
Refugees are dependent on public transportation

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12. What are the most frequently traveled destinations?
Apartment complexes, schools, grocery stores, DES at 43rd/Olive, warehousing/manufacturing between Van
Buren and Buckeye, between 35th and 91st Ave
13. Are there locations that the population has expressed difficulty accessing via the public transportation
system?
Employment around Buckeye and 83rd Ave
14. Do the transit needs and travel patterns of the population vary depending on the age or gender of the
population members?
No
15. What is the best way to obtain input from the population?
Engage with Ethnic Community Based Organizations, who can support listening sessions
16. Who would the population trust most in delivering language appropriate messages?
Ethnic Community Based Organizations, International Rescue Committee and other resettlement agencies
17. Does your agency take advantage of Valley Metro resources such as transit education or ridesharing tools?
Why or why not?
The agency passes out transit books and conducts internal transit training. Unaware of other opportunities
and resources.

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Literacy Volunteers of Maricopa County
1/14/2021
1. What geographic area does your agency serve?
City of Phoenix, 3 locations; and virtually.

2. What kind of services does your organization provide?
Free adult education services, two programs:
-Adult Basic/Secondary Education, and GED preparation to attain High School Equivalency Diploma.
-English Language Acquisition for Adults (formerly referred to as English as a Second Language ESL).

3. How many people does your agency provide services to?
Approximately 700.

4. Has the size of the population you serve increased, stayed the same, or decreased over the past five years?
Slight decrease

5. What are the countries of origin from which your population has immigrated?
All over the world; most recently African countries and Middle Eastern countries.

6. Does your population come from an urban or rural background?
City of Phoenix: urban

7. What are the languages spoken by the population you serve?
Many different languages; all instruction delivered only in English language.

8. What is the age of your population?
16-99; median about 40-50.

9. What is the education and literacy level of the population you serve?
Lower levels of literacy, compared to 4th grade level or lower.

10. What needs or expectations for public transportation services has this population expressed?
Not aware of any.

11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?
Unknown

12. What are the most frequently traveled destinations?
Unknown

13. Are there locations that the population has expressed difficulty accessing via the public transportation
system?
Unknown

14. Do the transit needs and travel patterns of the population vary depending on the age or gender of the
population members?

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07/22/2021
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Unknown

15. What is the best way to obtain input from the population?
Survey

16. Who would the population trust most in delivering language appropriate messages?
Their own community leaders

17. Does your agency take advantage of Valley Metro resources such as transit education or ridesharing tools?
Why or why not?
No. Unaware of services.

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Isaac Elementary School District
2/24/2021
1. What geographic area does your agency serve?
Isaac Elementary School District is located in West Phoenix
2. What kind of services does your organization provide?
Education
3. How many people does your agency provide services to?
3000 students
4. Has the size of the population you serve increased, stayed the same, or decreased over the past five
years?
Increased
5. What are the countries of origin from which your population has immigrated?
Many countries including but not limited to: Mexico, India, Tanzania, Democratic Republic of Congo,
Uganda, Pakistan, Nigeria, Kenya
6. Does your population come from an urban or rural background?
Both
7. What are the languages spoken by the population you serve?
1) Spanish (97% of English Learners), 2) Swahili (1%) 3) Kirundi (1%) 4) Other (1%)
8. What is the age of your population?
Youth 5-11 years old
9. What is the education and literacy level of the population you serve?
Elementary school
10. What needs or expectations for public transportation services has this population expressed?
Students and families use public transportation
11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?
Somewhat

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12. What are the most frequently traveled destinations?
Travel has decreased during COVID-19
13. Are there locations that the population has expressed difficulty accessing via the public transportation
system?
No
14. Do the transit needs and travel patterns of the population vary depending on the age or gender of the
population members?
Unsure
15. What is the best way to obtain input from the population?
Unsure
16. Who would the population trust most in delivering language appropriate messages?
People that speak their language
17. Does your agency take advantage of Valley Metro resources such as transit education or ridesharing
tools? Why or why not?
We have done this in the past but it has been a while

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Page 41

Turn a New Leaf
1/14/2021
1. What geographic area does your agency serve?
Maricopa County
2. What kind of services does your organization provide?
Housing, Shelter, Behavioral Health Services, Children Services
3. How many people does your agency provide services to?
Last year over 30,000
4. Has the size of the population you serve increased, stayed the same, or decreased over the past five years?
Increased
5. What are the countries of origin from which your population has immigrated?
Mexico
6. Does your population come from an urban or rural background?
Urban
7. What are the languages spoken by the population you serve?
Mostly English and Spanish
8. What is the age of your population?
We serve all ages groups from infants in our childcare centers to those over 62 in our shelter and
housing programs
9. What is the education and literacy level of the population you serve?
A majority or our participants have a GED
10. What needs or expectations for public transportation services has this population expressed?
Some of our clients have expressed more routes that run earlier and later than current hours and
more opportunities for discounted fares
11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?
A majority of those we serve to rely on public transportation and some that are new to the area due
struggle to operate the bus system

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12. What are the most frequently traveled destinations?
Mostly throughout mesa and phoenix
13. Are there locations that the population has expressed difficulty accessing via the public transportation
system?
East Mesa (towards apache junction) and the far west valley
14. Do the transit needs and travel patterns of the population vary depending on the age or gender of the
population members?
Not anything noticeable
15. What is the best way to obtain input from the population?
Simple surveys by email or paper surveys offered at the programs
16. Who would the population trust most in delivering language appropriate messages?
The case managers or support staff working with them in the individual programs
17. Does your agency take advantage of Valley Metro resources such as transit education or ridesharing tools?
Why or why not?
I can say for the program I oversee, (shelter and housing) I was not aware of these tools and I would
interested in receiving information. malberti@turnanewleaf.org

10
Non-elected Committees Membership Table | Title VI Implementation Plan

Non-elected Committees Membership Table

A sub recipient 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.
The following is a list of the City of El Mirage’s 2022 City Council Members

Title
Last Name First
Name
Term Ends
Ethnicity
1
Mayor
Hermosillo
Alexis
December 2022
Hispanic
2
Vice Mayor
Dorcey
Monica
December 2022
Caucasian
3
Councilmember
Delgado
Roy
December 2024
Hispanic/Native
American
4
Councilmember Norton
Anita
December 2022

5
Councilmember
Hutchinson
Michael
December 2024

6
Councilmember Shapera
David
December 2024
Caucasian
7
Councilmember
Winston
Donna
December 2022
Caucasian

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

11
| Title VI Implementation Plan

Monitoring for Subrecipient Title VI Compliance

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

12
Title VI Equity Analysis | Title VI Implementation Plan

Title VI Equity Analysis
A sub recipient 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 sub recipient organization
receives any FTA dollars, it must comply with this requirement.
A. Introduction
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national
origin in programs and activities receiving Federal financial assistance. Per 49 CFR 21.9(b)(3), recipients
may not select the site or location of facilities with the purpose or effect of excluding persons from,
denying the benefits of, or subjecting them to discrimination on the basis of race, color, or national
origin. Additionally, the location of projects requiring land acquisition and the displacement of persons
from their residences and business may not be determined on the basis of race, color, or national origin.
The City of El Mirage has no current or anticipated plans to develop new transit facilities covered by
these requirements.
The City of El Mirage has no current or anticipated plans to develop new transit facilities covered by
these requirements.

13
Regional System Standards and Policies | Title VI Implementation Plan

Regional System Standards and Policies
City of El Mirage does not operate its own transit system. Transit services provided locally are not
federally funded.

46
SECTION 3: SYSTEM-WIDE SERVICE STANDARDS AND
POLICIES
3.1 OVERVIEW
Valley Metro, as the regional transit authority, operates a majority of the fixed-route transit
service in Maricopa County, with the exception of the City of Phoenix’s service, City of
Glendale’s local circulator and City of Scottsdale’s trolley circulators. The fixed-route
transit service in the region consists of 61 local bus routes, 20 Express/RAPID routes,
21 community circulator routes, and 1 rural connector route. Valley Metro also operates
the region’s light rail system and will begin operating the first streetcar system in the City
of Tempe in 2021. The existing light rail system is a single route that operates in the cities
of Mesa, Tempe and Phoenix, and the streetcar system is a single line that will operate
within the City of Tempe. Valley Metro, in coordination with the City of Phoenix, is currently
constructing two additional light rail extensions: the South Central/Downtown Hub Project
is extending light rail service from Downtown Phoenix into South Phoenix and the
Northwest Extension Phase II Project is extending light rail from its current end of line on
Dunlap and 19th Avenue to the Metrocenter. These two extensions are anticipated to
open in 2024/2025. In addition, Valley Metro is coordinating with the City of Phoenix to
initiate preliminary engineering and an environmental assessment for a light rail extension
from Downtown Phoenix to the Arizona State Capitol. All will adhere to the standards and
policies outlined below.
Valley Metro, in coordination with the City of Phoenix and member cities, developed
regional Transit Standards and Performance Measures (TSPM) that fall in line with
federal and state requirements. The TSPM help manage our regionally funded transit
services and investments that include bus stops, park-and-ride facilities, transit centers
and future rail projects. The TSPM consists of four phases and can be found on the Valley
Metro website:
valleymetro.org/about/agency/transit-performance/standards-measures
Phase I
The first phase established service provision goals to guide the development of the
TSPM. Approved by the Board of Directors, this phase established standardized transit
service types, operating characterizes for each service type and bus stop spacing
standards.
Phase II
The second phase focuses on the development of transit service performance measures,
transit service thresholds, application principles and implementation standards for new
service.
Phase III
The third phase establishes standards and performance measures for regionally funded
transit vehicles such as buses and light rail vehicles and transit facilities including bus
stops and park-and-ride facilities.

47
Phase IV
The fourth phase combines the previous three phases into one report and adds new
service type definitions and standards. This combined Procedures Guide also includes
revisions to transit service performance measures and planning time periods.
The TSPMs are intended to assess the effectiveness of transit operations in achieving
the adopted service provision goals and to help identify whether performance
improvement actions taken to enhance performance and productivity are effective.
In addition to the TSPMs, Valley Metro, in coordination with the City of Phoenix,
established
system-wide
standards
and
policies,
in
accordance
with
FTA
Circular 4702.1B, for services that Valley Metro provides. These standards and policies
assist Valley Metro and the City of Phoenix in assessing the delivery of transit services
and to ensure that the delivery of services does not result in discrimination on the basis
of race, color or national origin. They establish the basis for monitoring and assessing
delivery of service and distribution of vehicles and amenities to identify whether any
disparities exist.
3.2 REGIONAL SERVICE POLICIES FOR BUS SERVICE
The regional service policies are meant to ensure that transit amenities are distributed
fairly throughout the system and vehicles are properly assigned on a route-by-route basis.
3.2.1 Vehicle Assignment
Service Policy
Vehicle assignment refers to the process by which transit vehicles are placed into revenue
service throughout the transit system. Vehicles will be assigned to the various bus
maintenance facilities on the basis of vehicle age, such that the vehicle age does not
exceed the system-wide average for the service type (local bus service, circulator service,
Express/RAPID service).
Vehicle assignments also consider the performance characteristics of service types, and
vehicle assignments are matched to the demand (vehicles with more capacity are
assigned to service types with higher ridership routes). Other bus assignments take into
consideration branded service, such as Express/RAPID routes, that has specific sub fleet
assignments.
Service Policy Elements
• Vehicle age
• Vehicle assignment records (dispatch bus pullout sheets). The contractor dispatch
staff assigns buses daily based on historical knowledge of the route.
Level of Service Assessment
• Calculate the average age of the entire bus fleet by service type.
• Calculate the average age of buses assigned to serve minority and non-minority
routes.

48
• Assessment compares minority to non-minority routes.
3.2.2 Distribution of Transit Amenities
Transit amenities refer to items such as seating, bus shelters, provisions of information,
waste receptacles, etc. FTA’s Title VI Circular states:
This policy does not apply to transit providers that do not have decision-making authority
over the siting of transit amenities. Transit providers are not responsible for setting a policy
for transit amenities that are solely sited by a separate jurisdiction (e.g., a city, town, or
county) unless the transit provider has the authority to set policies to determine the siting
of these amenities.
Although Valley Metro provides transit service, transit amenities for bus services are
locally funded and fall under the responsibility of the jurisdictions within which they are
sited. The service standard elements and level of service assessments will be the
responsibility of the individual municipalities. Valley Metro does, however, provide support
in the planning processes for these facilities.
3.3 REGIONAL SERVICE STANDARDS FOR BUS SERVICE
The regional service standards are quantitative performance standards meant to ensure
that fixed-route services are fairly applied throughout Valley Metro’s service area.
3.3.1 Vehicle Load
Vehicle Load Standard
Vehicle load (also known as maximum load) is the ratio of the number of passengers on
a vehicle to the number of seats. A load factor greater than 1.0 means that some
passengers are standing. Valley Metro and the City of Phoenix operate a number of local
fixed routes, express routes and circulator service in the region, with a number of different
bus configurations containing different numbers of seats and how many people can stand
on the bus. The vehicle load threshold is, therefore, broken down to the three main types
of service that are based on the average number of seats and the number of standing
passengers. The load thresholds are identified in Table 13.
Vehicle Load Data Collection Source
To determine the vehicle load, the following data are gathered:
• Annual random ride=check samples or Automatic Passenger Counter (APC) data
• Each ride check is one trip on a route.
• AM peak direction samples Monday through Friday
• PM peak direction samples Monday through Friday
• Samples collected annually throughout the year

49
TABLE 13: VEHICLE LOAD FACTOR, BY TRANSIT SERVICE TYPE
Service Type
Number of Seats
by Bus Length
Load Factor
(Peak and
Off-peak)
Peak
Number of
Passengers
Off-peak
Number of
Passengers
Valley Metro service
Local fixed-route
servicea
40-foot bus
35
1.25
44
44
60-foot bus
55
1.25
69
69
Express route
service
40-foot bus
35
1.25
44
44
45-foot bus
52
1.25
65
65
60-foot bus
55
1.25
69
69
Circulator service
25-foot bus
17
1.25
21
21
Rural connector
30-foot bus
22
1.25
28
28
36-foot bus
36
1.25
45
45
City of Phoenix service
Local fixed route
servicea
40-foot bus
35
1.25
44
44
60-foot bus
55
1.25
69
69
RAPID service
40-foot bus
32
1.25
40
40
45-foot bus
41
1.25
51
51
60-foot bus
54
1.25
68
68
Circulator service
25-foot bus
19
1.25
24
24
a Local fixed-route services, as defined in TSPM, are local bus, key local bus and limited stop all-day.

Vehicle Load Assessment
Using the data above, the following analysis determines the vehicle load:
• Determine number of minority and non-minority routes that have a maximum load ratio
of less than 1.25 for AM and PM peak times and calculate the percentages.
• Compare level of service between minority and non-minority routes.
3.3.2 Vehicle Headway
Vehicle headway standards are based on the TSPM for regionally funded routes. The
TSPM represent rules and guidelines by which the performance of the region’s transit
system may be evaluated, and decisions regarding transit investments may be prioritized
and measured.
Vehicle Headway Standard
Vehicle headway is the time interval between two vehicles traveling in the same direction
on the same route. Vehicle headways are measured in minutes (15 minutes [min], 30 min,
etc.). Table 14 shows the vehicle headway standards for the region’s bus system.

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TABLE 14: VEHICLE HEADWAY STANDARDS
Service Type
Minimum Headway
or Daily Tripsa
Minimum Span in
Hours (Weekday/
Saturday/Sunday)
Minimum
Operating Days
Rural connector
4 trips inbound/4 trips outbound
Not applicable
Monday–Friday
Limited stop peak
4 trips AM/4 trips PM
Not applicable
Monday–Friday
Commuter express
4 trips AM/4 trips PM
Not applicable
Monday–Friday
Community/circulator
30 min
12/0/0
Monday–Friday
Local bus
30 minb
16/14/12
Monday–Sunday
Key local bus
15 min peak/30 min baseb
16/14/12
Monday–Sunday
Limited stop all-day
Headways same as LRT, up to
2X peak
16/14/12
(same as LRT)
Monday–Friday
a Standards require service to be bi-directional unless otherwise noted.
b 60-minute frequency during off-peak hours (before 6 AM and after 6 PM)

For rural connector routes, limited stop peak and commuter express routes, service
availability is applied based on a number of daily trips rather than on frequency.
Vehicle Headway Data Collection Source
Local Fixed-route Service (Local Bus, Key Local Bus, Limited Stop All-Day)
• Measure standard using published fixed-route service schedules (no Express/RAPID,
limited stop peak or circulator routes)
Commuter Express/RAPID Service/Limited Stop Peak
• Measure standard using published Express, RAPID and limited stop peak service
schedules.
Circulator Service
• Measure standard using published circulator route service schedules.
Rural Connector
• Measure standard using published rural connector service schedules.
Vehicle Headway Assessment
• Identify several minority and non-minority routes for each service type and calculate
the percentage that are either meeting, exceeding or not meeting the headway
standard.
• Compare level of service between minority and non-minority routes.

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3.3.3 On-time Performance
On-time Performance Standard
On-time performance is a measure of bus runs for a particular route completed as
scheduled. The service standard threshold is defined as 92 percent or better of all trips
on a particular route completed within the allowed on-time window (departing the
timepoint less than one minute before or five minutes 59 seconds after the posted
schedule for that timepoint).
On-time Performance Data Collection Source
• Measure standard using Valley Metro-operated local fixed routes.
• Report data on a monthly basis.
• Use Clever Reports data. Clever equipment has been installed on all Valley Metro and
Phoenix vehicles except for those serving the Peoria On the Go circulator. Glendale
uses a separate system for GUS I, II, and III.
On-time Performance Assessment
• Determine the number of minority and non-minority routes that have an on-time
performance (OTP) of 92 percent or better on an annual basis and calculate the
percentages.
• Compare level of service between minority and non-minority routes.
3.3.4 Service Availability
Transit amenities are locally funded and fall under the responsibility of the jurisdictions
within which they are sited. The service availability and service availability assessments
are the responsibility of the individual municipalities.
Service Availability Standard
Service availability is measured by the distribution of bus stops within the regional service
area that afford residents accessibility to transit. The service standard is consistent with
the TSPM standard and has the following thresholds for each service:
Local Bus and Key Local Bus
• Bus stops are placed approximately 0.25 mile apart. Where development patterns are
of higher or lower density than typical within the region, an exception to the
recommended stop spacing standard may be warranted.
Limited Stop Peak and Limited Stop All-day
• Bus stops are placed approximately one mile apart. Where development patterns are
of higher or lower density than typical within the region, an exception to the
recommended stop spacing standard may be warranted.

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Express/RAPID Service
• Express/RAPID stops are strategically placed and are generally located at park-and-
ride facilities.
• No more than four inbound Express bus stops.
Community Circulator Service
• Bus stops within the designated stop area of each circulator route are placed no more
than 0.25 mile apart.
• In the flag stop zone area of each circulator route, passengers can be picked up
anywhere along the route.
Service Availability Data Collection Source
• Bus stop database
Service Availability Assessment
• Identify number of bus stop spacing gaps on each route.
• Calculate the number of bus stop spacing gaps that do not meet the standard as a
percentage of the total number of bus stop spacing gaps on a given route.
• Compare percentage of bus stop location gaps that do not meet the standard by
minority versus non-minority routes.
3.4 REGIONAL SERVICE POLICIES FOR RAIL SERVICE
3.4.1 Vehicle Assignment
Service Policy
The vehicle assignment service policy generally addresses the equitable assignment of
transit vehicles to depots and routes throughout the entire transit system in terms of
minority and low-income populations compared to non-minority and non-low-income
populations. This policy measures whether transit vehicles are equitably assigned
considering the age of the vehicle, type of fuel used, number of seats in the vehicle and
whether the vehicle is high or low floor. Valley Metro has one light rail route (28 miles)
with a single vehicle type consisting of 50 vehicles with the same design, passenger load,
amenities and age. The light rail vehicles are considered low floor at each of the four
doors to allow level boarding at each of the 38 light rail stations. Each light rail vehicle is
equipped with air conditioning and heating, automated stop announcements, a bike rack
that holds four bikes and folding seats to accommodate four wheelchairs. Valley Metro
has recently ordered 11 additional light rail vehicles from a different manufacturer and are
schedule for revenue service in 2022. The new vehicles will be configured differently and
will contain a different number of seats. However, the new vehicles will contain the same
equipment and amenities as the existing light rail vehicles. The new vehicles will be used
on the same single light rail line.

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Valley Metro also will begin operations in late 2021 with the region’s first streetcar system.
This system will contain six vehicles from the same manufacturer, will all contain the same
seating arrangement and amenities and will be used on the single streetcar line.
Service Assessment
All light rail vehicles put into service each day run along the one light rail route and have
the same amenities and quality for all passengers riding the system. Until new routes are
added to the system that contain different vehicles, no assessment of vehicle assignment
is warranted.
All streetcar vehicles put into service each day run along the one route and have the same
amenities and quality for all passengers riding the system. Until new routes are added to
the system that contain different vehicles, no assessment of vehicle assignment is
warranted.
3.4.2 Distribution of Transit Amenities
Service Standard
Transit amenities refer to items of comfort and convenience available to the general riding
public.
Light Rail
Valley Metro’s Design Criteria Manual includes a chapter on light rail station design. This
chapter provides standards for the design of each station and the amenities that will be
incorporated into each station. Each of the 38 stations within Valley Metro’s current light
rail system contain the following amenities:
• Shading and climate protection
• Seating
• Lighting
• Drinking fountain
• Trash receptacles
• Platform information maps
• Emergency call boxes
• Closed-circuit television cameras
• Public address system/variable message boards
• Ticket vending machines
• Double loading light rail station platforms (except where adequate pedestrian crossing
is not available)
In addition, each station has a securable rack for four bicycles located at street
intersections adjoining the station entrances. Although the Design Criteria Manual has
been developed as a set of general guidelines for planning and design of the light rail
system, deviations from these accepted criteria may be required in specific instances
based on community characteristics or other requests. Typically, new development is
compliant with the Design Criteria Manual.

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Streetcar
Valley Metro’s Streetcar Design Criteria Manual includes a chapter on streetcar stop
design. This chapter provides standards for the design of each station and the amenities
that will be incorporated into each station. Each of the 14 stops within Valley Metro’s
current streetcar system contains the following amenities:
• Shading and climate protection
• Seating
• Lighting
• Trash receptacles
• Platform information maps
• Emergency call boxes
• Closed-circuit television cameras
• Public address system/variable message boards
• Double loading platforms (except where adequate pedestrian crossing is not
available)
Service Assessment
Valley Metro will conduct field observations once a year to determine whether each light
rail station still contains the following amenities in good operational order:
• Information maps and public announcements at each station in English and Spanish
• Ticket vending machines at each station entrance
• Seating
• Drinking fountain
• Waste receptacles
• Bike racks
• Lighting
• Emergency call boxes
Valley Metro will conduct field observations once a year to determine whether each
streetcar stop still contains the following amenities in good operational order:
• Information maps and public announcements at each station in English and Spanish
• Seating
• Waste receptacles
• Lighting
• Emergency call boxes
3.5 REGIONAL SERVICE STANDARDS FOR RAIL SERVICE
3.5.1 Vehicle Load
Vehicle Load Standard
Vehicle load (also known as maximum load) is the ratio of the number of passengers on
a vehicle to the number of seats. A load factor greater than 1.0 means that some

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passengers are standing. Valley Metro currently operates one light rail system that
contains 50 light rail vehicles. Valley Metro has ordered 11 new light rail vehicles from a
different manufacturer that will contain a different number of seats and a scheduled for
revenue service in 2022. Both light rail vehicles will be operating on a fixed route from
Mesa through Tempe and into Phoenix. Valley Metro has also order six streetcar vehicles
that will start revenue service in the Winter of 2021. The streetcar vehicles will have a
different configuration and a different number of seat than the light rail vehicles. The
streetcar will also be operating on a fixed route within the city of Tempe. The vehicle load
threshold is, therefore, broken down to the three different vehicles and is based on the
number of seats and the number of standing passengers. The load thresholds are
identified in Table 15.
TABLE 15: VEHICLE LOAD FACTOR FOR LIGHT RAIL
VEHICLES AND STREETCARS
Service Type
Number
of Seats
by
Vehicle
Load
Factor
(Peak and
Off-peak)
Peak
Number of
Passengers
Off-peak
Number of
Passengers
Load
Factor
(Special
Events)
Special
Event
Number of
Passengers
Light Rail vehicles
Kinki Sharyo –
50 vehicles
66
2.12
146a
146a
2.60
172b
Siemens –
11 vehicles
62
2.12
138a
138a
2.60
161b
Streetcar vehicles
Brookville –
6 vehicles
40
2.47
99a
99a
2.95
118b
a Number is based on the effective standee passengers, calculated at 3 passengers per square meter.
b Number is based on the effective standee passengers, calculated at 4 passengers per square meter.

Vehicle Load Data Collection Source
Average weekday loads on the light rail will be determined by the following:
• Ride check the light rail route using the APC data
• AM in the peak direction (6 to 9 a.m.) Monday through Friday
• PM in the peak direction (3 to 6 p.m.) Monday through Friday
• Off-peak direction Monday through Friday
Samples will be collected semi-annually during the months of April and November to
determine whether the standard vehicle’s load is exceeded.
Vehicle Load Assessment
Valley Metro currently has one light rail line operating in the region with a single light rail
vehicle. However, in 2022 the second light rail vehicle will be in service and will have a
slightly different seating capacity. With only one light rail route, the data collected above
for each vehicle type will be used to determine the vehicle load.

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Valley Metro will have one streetcar line operating in the region in the Winter of 2021, and
the data collected above will be used to determine the vehicle load.
3.5.2 Vehicle Headway
Vehicle Headway Standard
Vehicle headway is the time interval between two vehicles traveling in the same direction
on the same line. Table 16 shows the vehicle headway thresholds for the light rail and
streetcar system.
TABLE 16: VEHICLE HEADWAY STANDARDS
Service
Type
Minimum
Operating Days
Headway
– Peak
Headway
– Off-peak
Minimum
Service Span
(hours)
Light rail
Monday–Thursday
12 min
20 min
19
Friday
12 min
20 min
22
Saturday
20 min
22
Sunday/Holiday
20 min
19
Streetcar
Monday–Thursday
12 min
20 min
20.5
Friday
12 min
20 min
23.5
Saturday
15 min
20 min
22
Sunday/Holiday
20 min
19

Vehicle Headway Data Collection and Service Assessment
Valley Metro currently has one light rail route under operation with 28 stations, and the
headway is monitored on a daily basis. As new extensions are added to the current light
rail ends of line (extending light rail from current end-of-line at Sycamore and Montebello),
the service assessment will be for this route in its entirety. As new routes to the system
are brought into service, the service assessment will be by individual routes. Headways
are monitored at the Operations Center and will be assessed by the following:
• AM in the peak direction (6 to 9 a.m.) weekdays
• PM in the peak direction (3 to 6 p.m.) weekdays
• AM in the peak direction (6 to 9 a.m.) weekends
• PM in the peak direction (3 to 6 p.m.) weekends
3.5.3 On-time Performance
On-time Performance Standard
On-time performance for light rail is a measure of a trip (end-of-line Gilbert Rd station to
the end-of-line 19th Ave/Dunlap station) completed as scheduled. On-time performance
for the streetcar is a measure of a trip (end-of-line Dorsey Station to the end-of-line Marina
Heights) completed as scheduled. The service standard threshold is defined as

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93 percent or better of all trips on light rail route completed within the allowed on-time
window (zero minutes early and five minutes late of scheduled arrival times).
On-time Performance Data Collection and Assessment
Valley Metro currently has one light rail route with 38 stations and one streetcar route with
14 stops in operation. Valley Metro monitors the OTP on an annual basis and makes
year-to-year comparisons. As new routes to the system are brought into service, the
service assessment will be by individual routes. OTP is monitored at the Operations
Center and is assessed through the SCADA network by the following:
• AM in the peak direction (6 to 9 a.m.) weekdays
• PM in the peak direction (3 to 6 p.m.) weekdays
• AM in the peak direction (6 to 9 a.m.) weekends
• PM in the peak direction (3 to 6 p.m.) weekends
3.5.4 Service Availability
Service Availability Standard
Service availability is measured by the distribution of light rail stations along the light rail
route that afford residents accessibility to the regional transit system. The service
standard has two thresholds:
• Light rail stations are placed approximately one mile apart. Where development
patterns are of higher or lower density than typical within the region, an exception to
the recommended stop spacing standard may be warranted.
• General considerations for light rail stations are based on the following criteria:
o Density of population and employment
o Mix of land uses
o Connection to other transit services
o Pedestrian accessibility to the station
o Planning and design characteristics that support transit-oriented development and
transit access
Service Availability Assessment
Valley Metro will assess the light rail service availability through the following:
• Identify light rail station-to-station spacing using the light rail station database.
• Identify the minority and low-income populations served within 0.5 mile of each station.
• Estimate the number of transit connections at each station.

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Service and Fare Policy Changes | Title VI Implementation Plan

Service and Fare Policy Changes
For all Service and fare changes, the City of El Mirage follows Valley Metro’s regional process.

There have been no Service or Fare changes in El Mirage since the last Title VI update.

15
Board Approval for the Title VI Program | Title VI Implementation Plan

Board Approval for the Title VI Program

16
| Title VI Implementation Plan

ATTACH A COPY OF THE BOARD MEETING MINUTES HERE