Title VI Implementation Plan
Extracted text (via pymupdf)
141994 characters
1
Title VI Policy Statement | Title VI Implementation Plan
Title VI Implementation
Plan
January 2025
2
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
Title VI Complaint Form ……….………………………………………………………………………………………………………….19
Title VI Investigations, Complaints, and Lawsuits ................................................................................. 20
Public Participation Plan ....................................................................................................................... 21
Limited English Proficiency Plan............................................................................................................ 23
Non-elected Committees Membership Table ....................................................................................... 26
Title VI Equity Analysis ........................................................................................................................... 28
Board Approval for the Title VI Program .............................................................................................. 33
3
Title VI Policy Statement | Title VI Implementation Plan
Title VI Policy Statement
The City of Glendale Transit 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
Glendale Transit sponsored program or activity. There is no distinction between the sources of
funding.
City of Glendale Transit 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 Glendale Transit will take reasonable steps to provide
meaningful access to services for persons with limited English proficiency.
As a sub-recipient of Federal-aid funds from another entity/person, City of Glendale Transit
will ensure full compliance with Title VI Nondiscrimination Program requirements. Glendale
Transit will oversee and implement FTA Title VI requirements.
Kevin R. Phelps, City Manager
ATTEST:
Julie K. Bower, City Clerk (seal)
APPROVED AS TO FORM:
Michael D. Bailey, City Attorney
E-SIGNED by Jamsheed Mehta
on 2025-00-00 00:00:00 MST
E-SIGNED by Julie K. Bower
on 2025-00-00 00:00:00 MST
E-SIGNED by Michael D. Bailey
on 2025-00-00 00:00:00 MST
4
Title VI Notice to the Public | Title VI Implementation Pl
Title VI Notice to the Public
Notifying the Public of Rights Under Title VI
City of Glendale Transit
The City of Glendale Transit 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 Glendale’s transit services contractor, Valley Metro Customer
Service Care center.
For more information on the City of Glendale’s civil rights program, and the procedures to file a
complaint, contact 602-253-5000, (TTY 602-251-2039); email csr@valleymetro.org; or visit the
administrative office at 4600 E. Washington St., Suite 101, Phoenix, AZ 85034. For more
information, visit www.ValleyMetro.org.
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 Valley Metro at 602-253-5000. Para
información en Español llame: Title VI Program Coordinator, City of Phoenix, 602-534-3026 or
Christina.Hernandez@phoenix.gov.
The above notice is posted in the following locations: City of Glendale Transit, 6210 W. Myrtle
Ave., Building S., Glendale, AZ 85301 and on City of Glendale Transit buses.
This notice is posted online at www.GlendaleAZ.com/Transit
5
Title VI Notice to the Public -Spanish | Title VI Implemen
Title VI Notice to the Public -Spanish
Aviso al Público Sobre los Derechos Bajo el Título VI
La Ciudad de Glendale
La Ciudad de Glendale (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 Glendale’s programa de derechos civiles, y los
procedimientos para presentar una queja, contacte 602-253-5000, (TTY 602-251-2039); correo
electronico csr@valleymetro.org o visite nuestra oficina administrativa en 4600 E. Washington St.,
Suite 101, Phoenix, AZ 85034. Para obtener más información, visite www.ValleyMetro.org.
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 Glendale Transit, 6210 W. Myrtle
Ave., Building S., Glendale, AZ 85301 and on City of Glendale Transit buses.
This notice is posted online at www.GlendaleAZ.com/Transit
6
Title VI Complaint Procedures | Title VI Implementation Pl
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
7
Title VI Complaint Procedures | Title VI Implementation Pl
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
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.
8
Title VI Complaint Procedures | Title VI Implementation Pl
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
9
Title VI Complaint Procedures | Title VI Implementation Pl
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.
10
Title VI Complaint Procedures | Title VI Implementation Pl
“Respondent” is not confined to the transit vehicle operator. “Respondent” is defined as any
source of information that can contribute to the investigation, such as:
• Complainant
• Operator
• Radio/Dispatch/OCC reports
• 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
11
Title VI Complaint Procedures | Title VI Implementation Pl
TSP Complaint Resolution(s):
• Must include specific complaint resolutions for each valid violation noted.
• Document a follow-up action plan, where applicable.
• If no valid violations are found, note policies, procedures, etc. reviewed during the
investigation and with transit operator.
• Documented complaint information should always include staff initials, title, and dates.
Response to Customer
TSP will respond to the Customer in the manner identified and will document the response
provided in CAS under the case number assigned.
12
Procedimientos de Quejas del Titulo VI | Title VI Implemen
Procedimientos de Quejas del Titulo 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
13
Procedimientos de Quejas del Titulo VI | Title VI Implemen
Para registrar una queja directamente con la Ciudad de Phoenix:
Attention: Title VI Coordinator
City of Phoenix Public Transit Department
302 N. 1st Avenue, Suite 900
Phoenix, AZ 85003
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.
14
Procedimientos de Quejas del Titulo VI | Title VI Implemen
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.
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.
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
15
Procedimientos de Quejas del Titulo VI | Title VI Implemen
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.
16
Procedimientos de Quejas del Titulo VI | Title VI Implemen
PASO DOS: Entrevistas y recolecciones de los hechos.
• 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
17
Procedimientos de Quejas del Titulo VI | Title VI Implemen
PASO CUATRO: Determinación de la queja.
• El proveedor TSP compara cada hecho de “hallazgos de hechos” con la lista de
regulaciones, reglas, etc.
• El proveedor TSP hace una determinación basada en hechos de la/s presunta/s
infracción/es.
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.
18
Title VI Complaint Forms | Title VI Implementation Plan
Title VI Complaint Forms
19
Title VI Complaint Forms | Title VI Implementation Plan
Title VI Complaint Forms
20
Title VI Investigations, Complaints, and Lawsuits | Title
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.
The City of Glendale Transit will investigate any Title VI complaints, investigations, or lawsuits
related to Glendale Urban Shuttle (GUS Bus Routes 1, 2 & 3) and Glendale Dial-A-Ride.
The City of Phoenix operates the City of Glendale’s fixed route local service and Valley Metro
operates the City of Glendale’s express service and Regional Dial-A-Ride. See route profile below.
ROUTES UNDER CONTRACT
WITH THE CITY OF PHOENIX
ROUTES UNDER CONTRACT
WITH VALLEY METRO
Route 51 – 51st Ave.
Route 83 – 83rd Ave.
Express 573 – West Glendale
Route 59 – 59th Ave.
Route 90 – Olive/Dunlap
Express 575 – North Glendale
Route 60 – Bethany Home
Route 106 – Peoria Ave.
Grand Avenue Limited (GAL)
Route 67 – 67th Ave.
Route 138 - Thunderbird
Route 70 – Glendale Ave.
Route 170 – Bell Road
Route 80 – Northern Ave.
Route 186 – Union Hills
Complaint
Number
Incident
Date
Route(S)
Primary
Category
Subcategory
Action Taken
472613
9/10/2021 83
Operator Discrimination
Video is unavailable for review. Report
forwarded to Operations Manager for further
review.
482821
1/24/2022 138
Operator Discrimination
No action required. No violation.
490234
5/12/2022 50
Operator Discrimination
None needed operator following protocol.
496811
8/31/2022 51
Operator Discrimination
Complaint found to be undetermined; Report has
been forwarded to the Operations Department
for further investigation. Police Department may
be involved for this threat made towards the
operator.
517257
8/14/2023 170
Operator Discrimination
No action required, no evidence this incident
occurred.
537779
6/22/2024 70
Operator Policy
No further action required.
542148
8/29/2024 186
Operator Discrimination
No further action required.
544536
9/29/2024 50
Fares
Fare Policy
No further action required.
Eight Title VI complaints was filed in the CAS system for the time frame of September
2021 – December 2024. There are no investigations or lawsuits on record.
21
Public Participation Plan | Title VI Implementation Plan
Public Participation Plan
City of Glendale Transit
Public Participation
Plan
22
Public Participation Plan | Title VI Implementation Plan
City of Glendale Transit 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.
City of Glendale Transit has adopted Valley Metro’s Title VI Public Participation Plan. (Attachment
“A”)
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 Glendale Transit 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.
23
Limited English Proficiency Plan | Title VI Implementation
Limited English Proficiency Plan
City of Glendale
Transit
Limited English Proficiency Plan
24
Limited English Proficiency Plan | Title VI Implementation
City of Glendale Transit has adopted Valley Metro’s Limited English Proficiency Plan (LEP)
(Attachment “B”) to help identify reasonable steps to provide language assistance for LEP persons
seeking meaningful access to City of Glendale Transit 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 Glendale Transit’s extent of obligation to provide LEP services, the City of Glendale Transit
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 Glendale Transit service area
who may be served or likely to encounter by City of Glendale Transit program, activities, or
services;
2) The frequency with which LEP individuals come in contact with any City of Glendale Transit
services;
3) The nature and importance of the program, activities or services provided by the City of
Glendale Transit to the LEP population; and
4) The resources available to City of Glendale Transit 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. All public outreach notices
will include the statement indicating that LEP individuals may contact Valley Metro at 602-253-5000,
(TTY 602-251-2039); email csr@valleymetro.org or visit the administrative office at 4600 E.
Washington St., Suite 101, Phoenix, AZ 85034 to receive the information in an alternate language.
25
Limited English Proficiency Plan | Title VI Implementation
Safe Harbor Provision
City of Glendale Transit 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
(3) Outreach Materials
(4) Bus Schedules
(5) Route Changes
(6) Public Hearings
26
Non-elected Committees Membership Table | Title VI Impleme
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.
Table Depicting Membership of Committees, Councils, Broken Down by Race
Body
Caucasian
African
American
Native
American
Asian
American
Other
Multi-
Racial
Population
51%
8%
2%
5%
18%
16%
Citizens
Transportation
Oversight
Commission
(CTOC)
66%
0%
0%
17%
17%
0%
The Glendale City Council appoints Boards and Commission members to serve on the Citizens
Transportation Oversight Commission (CTOC). The CTOC consists of 11 members who are Glendale
residents: 6 are appointed by each Councilmember and 1 is a Mayoral appointee. The remaining 4
are appointed at large by any member of the Glendale City Council. A three-hour basic training
program is required for those who have expressed a desire to serve and who have completed an
application. Once training is completed, their application is considered as vacancies occur.
The City of Glendale will continue to make every effort to encourage participation of minorities on
CTOC through increased outreach by advertising vacant positions in media outlets that reach the
minority population.
Additionally, the City Charter requires that redistricting be done at least every ten years following the
U.S. Census. Any changes to voting districts are required to be approved by the United States
Department of Justice.
27
City of Glendale Transit does not have nor monitor subrecipi
Monitoring for Subrecipient Title VI Compliance
City of Glendale Transit does not have nor monitor subrecipients.
28
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.
The City of Glendale has no current or anticipated plans to develop new transit facilities covered by these
requirements.
29
Regional System Wide Standards and Policies | Title VI Imp
Regional System Wide Standards and Policies
Fixed route: Public transit service (other than by aircraft) provided on a repetitive, fixed-schedule basis
along a specific route, with vehicles stopping to pick up passengers.
A subrecipient providing fixed route service, as defined above, must determine the distribution of transit
amenities or the vehicle assignments for each mode in a non-discriminatory manner. The subrecipient
must develop policies to ensure service is not distributed on the basis of race, color, or national origin.
Effective practices to fulfill the Service Standards requirements include developing written policies
covering each of the following service indicators:
1) Vehicle Load for Each Mode
1.1
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. The City of Glendale directly operates 3 circulator routes contracting out other fixed
routes with the City of Phoenix and Valley Metro.
The load thresholds are identified below:
Two different configurations are used;
On Route 1 the buses can seat up to 33 passengers and hold comfortably 47 passengers with an
expressed ratio of 1.42. This means that all seats are filled and there are 14 standees.
On Routes 2 and 3 the buses can seat up to 19 passengers and hold comfortably 27 passengers with
an expressed ratio of 1.42. This means that all seats are filled and there are 8 standees.
1.2
Vehicle Load Data Collection
To determine the vehicle load the following data is gathered:
•
Annual random ride check samples or 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
1.3
Vehicle Load Assessment
Using the data above the following analysis is done to determine the vehicle load:
Community Circulator Service
•
Determine number of minority and non-minority routes that have a max load ratio of less than
1.0 for AM and PM Non-Peak times – calculate percentage
•
Determine number of minority and non-minority routes that have a max load ratio of less than
1.40 for AM and PM Peak times – calculate percentage
•
Repeat the calculations for low-income and non-low-income routes
30
Regional System Wide Standards and Policies | Title VI Imp
•
Compare level of service between minority and non-minority routes and low income and non-
low-income routes
2) Vehicle Headway for Each Mode
Vehicle headway standards are based on the Transit Standards and Performance Measures (TSPM) for
regionally funded routes. Transit service standards and performance measures 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.
2.1
Vehicle Headway Standard
Vehicle headway is the time interval between two vehicles traveling in the same direction on the same
route. The following are the vehicle headway standards for the City of Glendale’s Circulators
Service Type
Minimum Headway or
Daily Trips
Minimum Span
Week / Sat / Sun
Minimum
Circulator 1
30 min
11 hrs. / 11 hrs. / 10 hrs.
Mon - Sun
Circulator 2
45 min
9 hrs. / 0 / 0
Mon – Fri
Circulator 3
60 min
9 hrs. / 0 / 0
Mon - Fri
3) On Time Performance for Each Mode
3.1
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 90% or better of all trips on a particular route completed within
the allowed on-time window (no more than 0 minutes early and 5 minutes 59 seconds late, compared to
scheduled arrival/departure times as published time points).
3.2
On Time Performance Data Collection
Measure standard using Valley Metro operated local fixed routes.
4) Service Availability for Each Mode
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 will be the responsibility of
the individual municipalities.
31
| Title VI Implementation Plan
4.1
Service Availability Standard
Service availability is measured by the distribution of bus stops within the regional service area that
affords residents accessibility to transit. The service standard is consistent with the TSPM standard and
has the following thresholds for each service.
Community Circulator Service
•
Bus stops within the designated stop area of each circulator route are placed no more than one-
quarter mile apart
4.2
Service Availability Data collection
•
Bus stop database
Effective qualitative practices to fulfill the Service Policy requirements include developing written
policies covering each of the following service indicators:
1) Transit amenities for each mode
Bus stop furniture such as bus shelters, benches and trash receptacles are placed at high ridership areas.
Ridership is determined by the number of passengers boarding and de-boarding at bus stops along the
route.
2) Vehicle assignments for each mode
Vehicle assignments are determined by the amount of ridership per run. Per run indicates the number
of passengers boarding the circulator within one complete trip. Starting at point “A” completing one
circuit, returning to point “A”.
Regional System-wide Service Standards and Policies (Attachment “C”)
32
Service and Fare Policy Changes | Title VI Implementation
Service and Fare Policy Changes
For all Service and Fare changes, the city of Glendale follows Valley Metro’s regional process.
There have been no Service or Fare changes in Glendale since the last Title VI update.
33
Board Approval for the Title VI Program | Title VI Impleme
Board Approval for the Title VI Program
34
Title VI Attachment “A” | Title VI Implementation Plan
Title VI Attachment “A”
Public Participation Plan
Valley Metro Public Participation Plan 2021
Introduction
The regional transit public input/outreach process is conducted by Valley Metro for various
transit-related activities and actions. Throughout the year, Valley Metro conducts public
outreach activities related to capital projects, transit service changes, fare changes, and other
transit-related events. This Title VI Public Participation Plan was established to ensure
inclusion of the public throughout the Phoenix metropolitan community in accordance with
the content and considerations of Title VI of the Civil Rights Act of 1964. Federal regulations
state that recipients of federal funding must “promote full and fair participation in public
transportation decision-making without regard to race, color or national origin.” Valley Metro
uses this Plan to ensure involvement of low-income, minority and limited English proficient
(LEP) populations, following guidance from the Title VI Requirements and Guidelines for
Federal Transit Administration Recipients Circular1 (Circular).
Involving the public in Valley Metro practices and decision-making processes provides helpful
information to improve the transit system to better meet the needs of the community. Although
public participation methods and extent may vary with the type of plan, program and/or
service under consideration, as well as the resources available, a concerted effort to involve
all affected parties will be conducted in compliance with this Plan along with federal
regulations. To include effective strategies for engaging low-income, minority and LEP
populations, the Circular suggests that the following may be considered:
• Scheduling meetings at times and locations that are convenient and accessible for minority
and LEP communities.
• Employing different meeting sizes and formats.
1 United States Department of Transportation, Federal Transit Administration, Circular 4702.1B.
35
Title VI Attachment “A” | Title VI Implementation Plan
• 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.
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.
36
Title VI Attachment “A” | Title VI Implementation Plan
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.
37
Title VI Attachment “A” | Title VI Implementation Plan
• 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.
38
Title VI Attachment “A” | Title VI Implementation Plan
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.
39
Title VI Attachment “A” | Title VI Implementation Plan
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.
40
Title VI Attachment “B” | Title VI Implementation Plan
Title VI Attachment “B”
Limited English Proficiency Plan
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, Valley Metro, Scottsdale and Glendale. There is a total of 872 fixed-route buses,
61 light rail vehicles and 6 streetcar vehicles operating in the region.
The regional transit system has 61 local bus routes that consist of the following: 45 local
bus routes, 15 key local bus routes and 1 limited-stop peak route. The region also has 19
Express/RAPID routes, 17 community circulator routes, 1 rural connector route, 1 light rail
line and one streetcar line. Valley Metro customers made over 36.8 million boardings during
fiscal year 2023.
Four entities in the region provide Dial-a-Ride service for seniors and persons with
disabilities, as well as Americans with Disabilities Act (ADA) paratransit service for those
who are unable to use fixed-route bus service. Annual regional ridership for ADA paratransit
and regional ridership for non-ADA general Dial-a-Ride was over 900,000.
41
Title VI Attachment “B” | Title VI Implementation Plan
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 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.
42
Title VI Attachment “B” | Title VI Implementation Plan
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.
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.
43
Title VI Attachment “B” | Title VI Implementation Plan
2.0 LIMITED ENGLISH PROFICIENT POPULATION (FACTOR 1)
Factor 1 assesses the number and proportion of persons with limited English speaking
proficiency likely to be encountered within the region’s service area, which is defined as a
three-quarter mile radial buffer around all fixed route services and a three-mile buffer around
park-and-ride and transit facilities for express bus service. The LEP population is those
individuals who reported to the Census Bureau that they speak English “less than very well.”
2.1 Evaluation Methods and Data Source
In accordance with FTA’s policy guidance, the initial step for providing meaningful access to
services for LEP persons and maintaining an effective LEP program is to identify LEP
populations in the service area and their language characteristics through an analysis of
available data. The presence of LEP populations in the regional service area was
determined by analyzing the U.S. Census Bureau, 2022 American Community Survey
(ACS) 5-year Sample.
2.2 LEP Population Identification
FTA describes LEP persons as having a limited ability to read, write, speak, or understand
English. For this LEP analysis, those who reported to the Census Bureau that they speak
English “less than very well” were used to tabulate the LEP population for the regional service
area.
2.3 American Community Survey
The ACS is a continuous nationwide survey conducted monthly by the U.S. Census Bureau to
produce annually updated estimates for the same small area (census tracts and block
groups) formerly surveyed through the decennial census long-form survey. It is intended to
measure changing socioeconomic characteristics and conditions of the population on a
recurring basis. It is important to note that the ACS does not provide official counts of the
population between each decennial census, but instead provides weighted population
estimates. This analysis uses the 2022 ACS 5-Year data (2018 to 2022).
ACS data include the number of persons ages five and above who self-identified their ability
to speak English as “very well,” “well,” “not well,” and “not at all.” Figure 1 depicts Valley
Metro’s service area. Table 1 shows the number of LEP people within Valley Metro’s service
area in comparison to Maricopa County. There are over 4 million residents in Maricopa
County, and 3.5 million reside within Valley Metro’s service area. The incidence of LEP
persons within Valley Metro’s service area is slightly higher than in the county. 8.3 percent of
residents in Maricopa County speak English less than “very well,” while 9.3 percent of
residents within Valley Metro’s service area speak English less than “very well.”
44
Title VI Attachment “B” | Title VI Implementation Plan
FIGURE 1: VALLEY METRO SERVICE AREA
TABLE 1: 2022 ACS DATA, BY LOCATION
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
45
Title VI Attachment “B” | Title VI Implementation Plan
Table 2 shows English proficiency for the census tracts within the service area population age five years
and above by the linguistic categories identified by the U.S. Census Bureau. This includes English,
Spanish, Indo-European, Asian or Pacific Islander, and all other languages. The 2022 ACS data show
the population self-identified as speaking English less than “very well” was predominantly the Spanish-
language group, encompassing 251,891 people, or 7.37 percent of the total population age five years
and over. Indo-European, Asian or Pacific Islander, and all other languages groups account for 67,459
people, or 1.9 percent of the population. Of all those speaking English less than “very well,” the Spanish
group makes up 79 percent of the total population over age five with limited English proficiency.
TABLE 3: 2022 ACS DATA, BY LINGUISTICALLY ISOLATED HOUSEHOLDS
46
Title VI Attachment “B” | Title VI Implementation Plan
Within the transit service area, 4 percent of households are considered linguistically
isolated. Again, these are predominantly Spanish households, making up 2.6 percent of the
total. Remaining languages make up 1.36 percent of households that are classified as
linguistically isolated.
Figure 2 shows concentrations of linguistically isolated households in census tracts within
the service area. Most areas throughout the region are mixed, although a few pockets of
census blocks have concentrations of linguistically isolated households, thus identified as
persons with limited English proficiency.
FIGURE 2: CENSUS TRACTS WITH LINGUISTICALLY ISOLATED HOUSEHOLDS
47
Title VI Attachment “B” | Title VI Implementation Plan
Figure 3 shows the ACS 2022 census tracts within the three-quarter mile buffer of local fixed
route service and a three-mile buffer around park-and-ride and transit facilities for express
bus service. Census tracts encapsulated within this area are included in the estimates,
although they may not be within one-quarter mile of a fixed route.
FIGURE 3: CENSUS TRACTS WITHIN SERVICE AREA
The 2022 ACS data show 12 languages or language groups with 1,000 or more LEP persons.
Only one LEP population exceeds both the 1,000 or more individuals and the five percent of
the total population of persons eligible to be served or likely encountered. Table 4 shows the
populations that meet either of these thresholds using ACS 2022 population by language and
ability, sorted by percentage of LEP population.
48
Title VI Attachment “B” | Title VI Implementation Plan
Within the service area, the majority of the 2022 LEP populations is the Spanish speaking
population; this is the only language group to exceed both 1,000 individuals and five percent
of the LEP population. The Spanish LEP population consists of 251,606 individuals within the
service area. The Other Indo-European, Mandarin Chinese, and Other and Unspecified
speaking populations followed with 3.90 percent, 3.06 percent, and 2.76 percent respectively.
The Vietnamese, Other Asian and Pacific Island and Arabic speaking populations follow with
2.51 percent, 3.02 percent and 1.90 percent, respectively. This is followed by Russian and
Filipino with 1.37 percent and 1.08 percent, respectively, and then by Korean (0.8 percent),
French (0.7 percent) and German (0.2 percent).
TABLE 4: 2022 ACS DATA, BY LANGUAGE WITHIN ONE-HALF
MILE OF FIXED ROUTE SERVICE
49
Title VI Attachment “B” | Title VI Implementation Plan
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.
FIGURE 4: POPULATION SPEAKING ENGLISH “LESS THAN VERY WELL”
50
Title VI Attachment “B” | Title VI Implementation Plan
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.
51
Title VI Attachment “B” | Title VI Implementation Plan
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:
• Americans with Disabilities Act (ADA)
• Customer Relations (CR)
• Light Rail
• Lost and Found
• Transit Information (TI)
This system allows Spanish-speaking callers to be automatically transferred to a bilingual
representative, reducing the time it takes to be served in the preferred language. Currently,
eight bilingual customer service representatives are employed by Valley Metro. The phone
system prioritizes selection of Spanish calls received. Table 5 shows the distribution of calls
by option selected, followed by the sum of calls by language for calendar year 2022.
TABLE 5: 2022 CUSTOMER SERVICE CALL LOG
52
Title VI Attachment “B” | Title VI Implementation Plan
Figure 5 shows a pie chart of the calls by language. Approximately 90 percent of calls were
for English and nine percent of calls were for Spanish. At the time of this report, 24 customer
service representatives were on staff; of these, six were bilingual (25 percent).
When evaluating the customer service call logs, the bulk of calls received are through the
English phone lines with a small portion (9 percent) selecting a Spanish option.
Transit Education Program
Valley Metro has a Transit Education program that presents information to various groups to
teach about public transit, benefits of transit and how to use the system. Staff members visit
schools, businesses, social service agencies and present to new residents and refugee
groups, senior citizens and persons with disabilities. Additionally, transit information and
assistance are provided at community or special events including environmental advocacy
events, transportation or vehicle days, career days and more. This team also conducts
general presentations by request to any group who wants to learn more about Valley Metro
services.
53
Title VI Attachment “B” | Title VI Implementation Plan
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 100 languages. As of 2024, users have translated the Valley Metro website into
80 different languages using this feature. Approximately 99 percent of interactions with the
Valley Metro website used the default English setting. Note only partial statistics are
available for 2023 due to an error in the Google content management system responsible
for collecting this data. In Table 6, the following data from 2022 offers a complete insight
into the languages translated and the percentage of sessions in 2022. Note that only those
languages accounting for at least 0.01 percent of the total sessions are included.
TABLE 6: 2022 WEBSITE SESSIONS BY LANGUAGE
54
Title VI Attachment “B” | Title VI Implementation Plan
Once again, Spanish was overwhelmingly the most widely used language with the website
translation service, accounting for 1.80 percent of sessions, followed by Chinese (0.10
percent), Japanese (0.07 percent), German (0.07 percent), Korean (0.04 percent), French
(0.04 percent), Russian (0.03 percent, Portuguese (0.02 percent and Other (0.20 percent).
Figure 6 shows the number of translated sessions by language.
Historically, the website has been translated to over 80 other languages that collectively
accounted for 0.2 percent of all sessions. These languages include:
• Afrikaans
• Arabic
• Bulgarian
• Catalan
• Croatian
• Czech
• Danish
• Farsi
• Filipino
• Finnish
• Greek
• Hebrew
• Hindi
• Hungarian
• Indonesian
• Latin
• Norwegian
• Polish
• Romanian
• Samoan
• Serbian
• Slovak
• Slovenian
• Swedish
• Telugu
• Thai
• Thai
• Tonga
• Ukrainian
• Vietnamese
FIGURE 6: NUMBER OF TRANSLATED WEBSITE SESSIONS, BY LANGUAGE
(EXCLUDING ENGLISH)
55
Title VI Attachment “B” | Title VI Implementation Plan
Many documents on Valley Metro’s website are translated into Spanish since they are
disseminated as paper materials to the public. Individuals may use these documents without
translating the website into Spanish. Some of these documents include project updates, route
maps and schedules, instructions and applications for a Reduced Fare ID, service change
information, policies, brochures, and forms.
Conclusion
The Factor 2 analysis revealed that there is regular contact between the LEP population and
Valley Metro personnel. The Customer Service call log showed that nine percent of
customers used one of the five Spanish options. Information from the Transit Education
team qualitatively identified Spanish as the main language group. Finally, translation data
from the Valley Metro website indicated 2.4 percent of sessions were translated—most of
which were translated to Spanish. Historically, the website has been translated to over 80
different languages. Overall, there is broad diversity in the Phoenix region population that
accesses regional transit services; however, most people using the Valley Metro system
speak English or Spanish.
4.0 NATURE AND IMPORTANCE OF THE PROGRAM, ACTIVITY OR
SERVICE PROVIDED (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.
56
Title VI Attachment “B” | Title VI Implementation Plan
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:
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 (LRT) 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
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
57
Title VI Attachment “B” | Title VI Implementation Plan
Critical Services
Public transit is a key means of mobility for persons with limited English proficiency. Of those
services identified above, a subset of critical services was prioritized to ensure that those
services imperative to use Valley Metro public transportation options are available to all users.
Basic trip information is available both printed and electronically in Spanish, including service
hours, tickets, trip planning, airport and transit connections, parking, bicycles and services for
persons with disabilities. Also available in Spanish is information regarding how to use transit,
acceptable user conduct, priority seating, caution signs and exit locations on vehicles. Ticket
vending is available in both Spanish and Braille. Many documents are available in Braille
upon request. Emergency notification measures are also translated, including audio VMS
Announcements on vehicles (bus and rail), operator call boxes, emergency call boxes and
Safe Place notices.
Bilingual customer service representatives are available during regular call center hours.
Representatives use the same procedures for comments and note that the inquiry was in
Spanish so that a bilingual representative is assigned in any follow-up response if needed.
Outside of customer service hours, the website is available for translation to most languages
at any time. For public meetings and hearings, a Spanish translator is usually available;
additional translators are available upon request or in the appropriate context. Typically,
additional translation services requested are provided for American Sign Language through
an on-call contract.
58
Title VI Attachment “B” | Title VI Implementation Plan
5.0 CURRENT RESOURCES AVAILABLE AND THE COSTS TO PROVIDE
LANGUAGE ASSISTANCE SERVICES (FACTOR 4)
The final step of the four-factor LEP analysis was an evaluation of the current and projected
financial and personnel resources available to meet the current and future needs for language
assistance. The first component of the Factor 4 analysis was to identify current language
assistance measures and associated costs. The next step was to determine what additional
services may be needed to provide meaningful access. The 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 duties. These costs are not tracked,
although most of the formal interpretation services are contracted.
59
Title VI Attachment “B” | Title VI Implementation Plan
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. In FY24 the cost for
language interpreter services at public meetings in total was $20,545. Costs for translating
and producing written materials such as meeting notices, display boards, news releases
and project update sheets are also budgeted annually. In FY24 the cost for this service was
$25,502. The total for all translation services therefore in FY24 was $48,853.
Additional costs include other staff time used on an ad hoc or regular basis to provide
translation or interpretive services. Exactly 25 percent of Customer Service representatives
are bilingual, assisting both Spanish- and English-speaking customers. Being bilingual is a
preferred qualification when hiring Customer Service staff, although not required. Bilingual
employees also may assist on an informal, ad hoc basis to communicate with LEP
individuals in other departments.
5.2 Cost-effective Practices
Valley Metro will continue to evaluate ways to improve the cost-effectiveness and the quality
of its language services. Additional strategies for saving costs or improving quality may
include developing internal and external language services, with the opportunity to coordinate
across multiple agencies in the region. Current measures to ensure services are cost effective
include:
• Bilingual staff trained to act as interpreters and translators
• Shared customer service center and other information for combined translation and
interpretation resources
• Some standardized common documents with transit and other public agencies
• Using the free Google Translate service on the Valley Metro website
• Translated vital documents currently posted on valleymetro.org
60
Title VI Attachment “B” | Title VI Implementation Plan
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.
61
Title VI Attachment “B” | Title VI Implementation Plan
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, the interactive voice
response system will automatically ask if Spanish is the preferred language prior to being
connected with a representative.
62
Title VI Attachment “B” | Title VI Implementation Plan
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 100 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.
63
Title VI Attachment “B” | Title VI Implementation Plan
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.
64
Title VI Attachment “B” | Title VI Implementation Plan
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
65
Title VI Attachment “B” | Title VI Implementation Plan
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
66
Title VI Attachment “B” | Title VI Implementation Plan
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.
67
Title VI Attachment “B” | Title VI Implementation Plan
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.
68
Title VI Attachment “B” | Title VI Implementation Plan
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).
69
Title VI Attachment “B” | Title VI Implementation Plan
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.
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.
70
Title VI Attachment “B” | Title VI Implementation Plan
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
71
Title VI Attachment “B” | Title VI Implementation Plan
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
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.
72
Title VI Attachment “B” | Title VI Implementation Plan
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.
73
Title VI Attachment “B” | Title VI Implementation Plan
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?
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.
74
Title VI Attachment “B” | Title VI Implementation Plan
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
75
Title VI Attachment “B” | Title VI Implementation Plan
11. Has the population inquired about how to access public transportation or expressed a need for public
transportation service?
Somewhat
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
76
Title VI Attachment “B” | Title VI Implementation Plan
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
77
Title VI Attachment “B” | Title VI Implementation Plan
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
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
78
Title VI Attachment “C” | Title VI Implementation Plan
Title VI Attachment “C”
Regional System Wide Standards and Policies
3.1 Overview
Valley Metro, as the regional transit authority, operates the majority of transit service in
Maricopa County with the exception of the City of Phoenix, City of Glendale’s local
circulator and City of Scottsdale’s downtown trolley. Valley Metro coordinated with the
City of Phoenix to develop a Regional System-Wide Service Standards and Policies that
applies to all services that both entities provide, but they can be also adopted by the cities
of Glendale and Scottsdale. Valley Metro also operates the region’s light rail transit
system and has developed a separate set of System-Wide Standards and Policies for
light rail. Valley Metro, in coordination with the City of Mesa, is currently constructing a
light rail extension further into their community. In Tempe, Valley Metro is coordinating
with the City to complete the design for a streetcar project and are currently relocating
utilities. In addition, Valley Metro is coordinating with the City of Phoenix for the final
design of three light rail extensions further into their community. 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
79
Title VI Attachment “C” | Title VI Implementation Plan
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 refersto 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.
• Calculate the average age of the buses assigned to serve minority and low-
income routes and for non-minority and non-low-income routes.
• Assessment compares minority to non-minority routes and low income to non-
low-income 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
80
Title VI Attachment “C” | Title VI Implementation Plan
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. Valley Metro and the City of Phoenix operates 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
81
Title VI Attachment “C” | Title VI Implementation Plan
TABLE 13: VEHICLE LOAD FACTOR, BY TRANSIT SERVICE TYPE
Vehicle Load Assessment
Using the data above, the following analysis is done to determine 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.
82
Title VI Attachment “C” | Title VI Implementation Plan
TABLE 14: VEHICLE HEADWAY STANDARDS
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.
83
Title VI Attachment “C” | Title VI Implementation Plan
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.
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 85 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. 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 85 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.
84
Title VI Attachment “C” | Title VI Implementation Plan
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.
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.
85
Title VI Attachment “C” | Title VI Implementation Plan
3.4 Regional Service Policies for Light 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 or not the vehicle is high or low floor. Valley Metro has one light rail route
(30miles) served by 61 vehicles of two different types with similar design, passenger load
and amenities. The light rail vehicles are considered low floor at each of the four doors to
allow level boarding at each of the 41 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.
Service Assessment
All 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 28 stations within Valley Metro’s current
light rail system contain the following amenities:
86
Title VI Attachment “C” | Title VI Implementation Plan
• 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)
• Elevators (only at stations not at grade)
• Escalators (only at statins not at grade)
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.
Service Assessment
Valley Metro will conduct field observations once a year to determine if each station still
contains the following amenities in good operational order:
• Information maps and public announcements at each station are in English and
Spanish
• Ticket vending machines at each station entrance
• Seating
• Waste receptacles
• Bike racks
• Lighting
• Emergency call boxes
87
Title VI Attachment “C” | Title VI Implementation Plan
3.5 Regional Service Standards for Light 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 passengers
are standing. Valley Metro currently operates one light rail system that contains 60 light rail
vehicles. Valley Metro has two types of light rail vehicles and both operate on a fixed route
from Mesa through Tempe and into Phoenix. Valley Metro also operates one streetcar line
which has six streetcar vehicles that started revenue service in the May 2022. 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
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 (6–9 a.m.) Monday through Friday
• PM in the peak direction (3–6 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
88
Title VI Attachment “C” | Title VI Implementation Plan
determine if the standard vehicles load is exceeded.
Vehicle Load Assessment
Valley Metro operates one light rail system that contains 60 light rail vehicles. Valley Metro
has two types of light rail vehicles and both operate on a fixed route from Mesa through
Tempe and into Phoenix. Valley Metro also operates one streetcar line that has six streetcar
vehicles which started revenue service in May 2022. The data collected above for each
vehicle type 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
2.0
Vehicle Headway Data Collection and Service Assessment
Valley Metro currently has one light rail route under operation with 41 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 (6–9 a.m.) weekdays
89
Title VI Attachment “C” | Title VI Implementation Plan
• PM in the peak direction (3–6 p.m.) weekdays
• AM in the peak direction (6–9 a.m.) weekends
• PM in the peak direction (3–6 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 Metrocenter 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 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 41 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 (6–9 a.m.) weekdays
• PM in the peak direction (3–6 p.m.) weekdays
• AM in the peak direction (6–9 a.m.) weekends
• PM in the peak direction (3–6 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:
90
Title VI Attachment “C” | Title VI Implementation Plan
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