City of Culver City, California
Agenda Item Report
RECOMMENDATION:
Staff recommends the City Council adopt a resolution to approve and adopt the
Culver City Transportation Department Title VI Program Update and the Limited
English Proficiency Implementation Plan to comply with the provisions of the Civil
Rights Act of 1964 and the requirements established by the Federal Transit
Administration (FTA) for recipients of Federal funding.
BACKGROUND:
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, or be denied the benefits of, or be subjected to discrimination under any program
or activity receiving federal financial assistance.” To fulfill this basic civil rights
mandate, each federal agency that provides financial assistance for any program is
authorized and directed by the United States Department of Justice to apply
provisions of Title VI to each program by issuing generally applicable rules,
regulations, or requirements.
Since 1972 the Federal Transit Administration (FTA) has required recipients of
Federal assistance to certify compliance with the requirements of Title VI as part of
the funding eligibility process. The Culver City Transportation Department, on behalf
of the City of Culver City, is a recipient of Federal funding and, therefore, must have a
Title VI Program in place.
Meeting Date: 06/09/14 Item Number: _C-7______
CITY COUNCIL AGENDA ITEM: Adoption of a Resolution to Approve and Adopt the
Culver City Transportation Department Title VI Program Update and Limited
English Proficiency (LEP) Implementation Plan
Contact Person/Dept.:
Jane Leonard / Transportation
Phone Number:
310-253-6523
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Public Hearing: [] Action Item: [] Attachments: [X]
Commission Action Required: Yes [] No [X]
Public Notification: Agenda and Meetings – City Council (06/04/14)
Department Approval:
Art Ida (5/20/14)
City Attorney Approval:
Carol Schwab (by H. Baker) (06/03/14)
Chief Financial Officer Approval:
Jeff Muir (06/02/14)
City Manager Approval:
John M. Nachbar (06/03/14) City of Culver City, California
Agenda Item Report
DISCUSSION:
The Culver City Transportation Department has developed procedures for its Culver
CityBus Title VI Program to meet the general reporting requirement which include
procedures for filing civil rights complaints; Title VI investigations, complaints, and
lawsuits; plans for providing access to persons with limited English language
proficiency; protection notifications; information distribution and outreach to ensure
access to programs and services.
The specific Title VI Program Update and Limited English Proficiency Implementation
Plan address each of the required elements. These documents are included as
Attachments to this report.
FISCAL ANALYSIS:
There are no fiscal impacts to implement these Title VI Program elements; rather,
lack of compliance with the Civil Rights Act of 1964, including the need for an
updated Title VI Program and LEP Implementation Plan, would preclude the City of
Culver City from receiving federal funding for capital projects and operating
assistance.
ATTACHMENTS:
Title VI Program Update and Limited English Proficiency Implementation Plan
2014.
MOTION:
That the City Council:
1. Adopt a Resolution approving and adopting the Title VI Program Update and
Limited English Proficiency Plan dated May 2014 as they pertain to Culver
CityBus and the Culver City Transportation Department; and,
2. Authorize the City Attorney to review/prepare the necessary documents; and,
3. Authorize the City Manager to execute such documents on behalf of the City.
MEETING DATE: 6/9/2014
AGENDA ITEM: Adoption of a Resolution to Approve and Adopt the
Culver City Transportation Department Title VI Program
Update and Limited English Proficiency (LEP)
Implementation Plan
ATTACHMENTS
Pages
1. Resolution No. 2014-R 1-2
2. EXHIBIT A: Culver City Transportation
Department Title VI Program Update (includes the
LEP Implementation Plan) 3-51
Attachment Page 1Attachment Page 2Culver City Municipal Bus Lines
Title VI Report
2014 Information Update
Prepared By:
DIVERSIFIED
TRANSPORTATION
SOLUTIONS
In Association With:
Jeremy Bailey Consulting
Kam Research
MAY 2014
Attachment Page 3TABLE OF CONTENTS
I. OVERVIEW ----------------------------------------------------------------------------------------------------------- 1
A. Purpose ---------------------------------------------------------------------------------------------------------- 1
B. Background of the Service Area --------------------------------------------------------------------------- 1
C. Culver City Municipal Bus Lines ---------------------------------------------------------------------------- 2
D. Culver City General Plan: Circulation Plan -------------------------------------------------------------- 3
II. GENERAL REPORTING REQUIREMENTS --------------------------------------------------------------------- 7
A. Public Notification of GMBL’s Title VI Protections --------------------------------------------------- 7
B. Culver CityBus Procedures for Investigating and Tracking Title VI Complaints --------------- 7
C. List of Active Lawsuits ---------------------------------------------------------------------------------------- 7
D. Compliance Review Activities ------------------------------------------------------------------------------ 7
E. Signed Assurances --------------------------------------------------------------------------------------------- 8
F. Construction Impact Analysis ------------------------------------------------------------------------------ 8
G. Information Dissemination --------------------------------------------------------------------------------- 9
H. Limited English Proficiency Implementation Plan --------------------------------------------------- 10
I. Public Participation Plan ------------------------------------------------------------------------------------ 11
J. Minority Representation on Decision Making Bodies ----------------------------------------------- 12
III. PROGRAM SPECIFIC REQUIREMENTS ---------------------------------------------------------------------- 14
A. Service Standards and Policies --------------------------------------------------------------------------- 14
Service Standards -------------------------------------------------------------------------------------------- 14
Vehicle Load ------------------------------------------------------------------------------------------------ 14
Vehicle Headway ----------------------------------------------------------------------------------------- 14
On-Time Performance ----------------------------------------------------------------------------------- 14
Service Availability --------------------------------------------------------------------------------------- 15
Service Policies ------------------------------------------------------------------------------------------------ 15
Distribution of Transit Amenities--------------------------------------------------------------------- 15
Vehicle Assignment -------------------------------------------------------------------------------------- 15
IV. CONCLUSION ----------------------------------------------------------------------------------------------------- 17
Attachment Page 4APPENDICES
APPENDIX A: Culver City Municipal Bus Lines FTA Title VI Certifications and Assurances
APPENDIX B: Culver City Municipal Bus Lines Title VI Complaint Investigation Procedures
APPENDIX C: Methodology to Analyze Service and Fare Changes
APPENDIX D: LEP Assessment and Implementation Plan for Culver City Municipal Bus Lines
Attachment Page 5
1
I. OVERVIEW
A. Purpose
The Federal Transit Administration (FTA), managed by the U.S. Department of Transportation,
requires that federally funded transit agencies submit a triennial report to ensure compliance
with Title VI of the Civil Rights Act of 1964. Title VI regulations were set forth to assure equal
access to transit services regardless of race, ethnicity, gender, or income. To demonstrate
compliance with these provisions, Culver CityBus is submitting this report in accordance with FTA
Circular 4702.1B.
B. Background of the Service Area
Culver CityBus serves several local communities that include: Culver City and Los Angeles (West
Los Angeles, Westwood, Venice, Marina Del Rey, Mar Vista, Palms, Rancho Park, Westchester,
and Century City). Culver City is 5 square miles and situated on the west side of metropolitan Los
Angeles between Santa Monica to the north, Westchester and Inglewood to the south, Los
Angeles to the east, with Venice and Marina Del Rey to the west. The Culver CityBus total service
area encompasses 40 square miles with a population of about 325,621 people.|1010|
Culver City was incorporated in 1917 and the U.S. Census Bureau estimates the 2012 population
at 39,313,|1010| while the median age of residents is 41.5|1010| years, and the median household income
is $67,736.|1010| Culver City represents 0.4% of Los Angeles County’s total population.|1010| The
breakdown of the population in terms of race for the Culver CityBus service area is as follows:
Table 1: Culver City Municipal Bus Lines Service Area Community Ethnicities
|1010| U.S. Census Bureau, 2010. American Community Survey |1010| U.S. Census Bureau, 2012 Culver City Quick Facts http://quickfacts.census.gov/qfd/states/06/0617568.html |1010| SCAG, 2012. Profile of Culver City. http://www.scag.ca.gov/Documents/CulverCity.pdf |1010| Ibid |1010| Ibid
Attachment Page 6
2
Culver CityBus serves several large local employment centers in Culver City and near Los Angeles
International Airport (LAX), West Los Angeles, and UCLA while supplying linkages to transit
services and regional employment hubs through MTA’s Metro Expo and Green Lines.
C. Culver CityBus
Fixed-route Revenue Service
Culver CityBus has operated weekday service continuously since 1928 in response to a
disagreement over passenger fares between the city and the Pacific Electric Railway that
operated trolley car service from Los Angeles to Venice at the time. Since its inception, Culver
CityBus, as one of the oldest municipal bus lines in the state, has provided consistently reliable
and user-friendly public transportation services in the area.
Culver CityBus provides transportation to area residents with fixed bus routes that service many
local communities and provide access to Metro Rail, West Los Angeles, and nearby coastal
communities.
Beginning in June 2014, the Department’s total fleet is comprised of 54 New Flyer 40-foot low-
floor compressed natural gas (CNG) buses and two (2) 30-foot low-floor CNG buses in a
contingency fleet.|1010| Culver CityBus coordinates its service schedules with surrounding transit
providers like the MTA, Santa Monica’s Big Blue Bus, and LADOT in a joint effort to develop a
functional regional transportation plan and provide riders with an easy commute throughout the
west side of Los Angeles and to a variety of surrounding locations. Culver CityBus operates 43
peak hour buses and provides low cost, easily accessible public transportation for 5.6 million
unlinked passenger trips annually.|1010| Culver CityBus accrues about 18 million annual passenger
miles and 1.6 million annual vehicle revenue miles.|1010| Table 2 provides the peak frequencies of
service by day for all Culver CityBus routes.
Paratransit Services
The Culver City Transportation Department oversees operation of the City's Paratransit Program
that provides transportation services for senior and disabled residents. The paratransit program
consists of a dial-a-ride service and a taxi coupon program. These services are not funded by
Federal funds, but by revenues from other local funding sources issued to the City of Culver City.
Dial-a-Ride service operates within the City of Culver City as well as the Kaiser-Permanente
medical facilities located at 6041 Cadillac Ave. and 5620 Mesmer Ave. The service operates
Monday thru Friday 8:30 a.m. - 4:15 p.m.; donation fares are accepted. The dial-a-ride service is
operated with three City vehicles, and has two City employees assigned as drivers.
|1010| Jane Leonard, Sr. Management Analyst, Culver City Transportation Department |1010| Culver CityBus, 2013 Short Range Transit Plan |1010| National Transit Database, 2013. Culver City Municipal Bus Lines Transit Profile
Attachment Page 7
3
The taxi coupon program supplements the dial-a-ride program for approved participants. By
working with local taxicab companies, the program allows participants to book trips at a
subsidized rate, allowing for lower costs and more flexibility. Participants can travel on trips
originating or ending in Culver City, or in the nearby unincorporated communities of View Park,
Windsor Hills, or Ladera Heights. Participants purchase coupons for use on taxicab trips. Each
coupon is worth $1.00, and taxi drivers are required to accept a maximum of $10.00 in taxi
coupons per trip. If the fare exceeds the $10.00 coupon limit, the balance of the fare must be
paid by the participant.
In addition to these services, Access Services provides federally-mandated complementary
paratransit services throughout Los Angeles County.
Table 2: Service Days and Operating Frequencies by Route
Culver City General Plan: Circulation Plan
To demonstrate its commitment to equitable transit service regardless of race, ethnicity, or
income, Culver City reiterated its pledge to improve the city’s circulation and subsequent bus
service through their 1995 (30-year) General Plan Update - Circulation Plan. The purpose of the
Circulation Plan was to plan, design, and improve the transportation infrastructure to meet
projected future needs. Any proposed changes to the circulation system promoted the safe and
efficient movement of both people and goods through the City. The policies implemented, as
part of the plan, have and will continue to develop and maintain the circulation system and
Attachment Page 8
4
enhance the efficiency of all transportation modes, as well as support proposed land use patterns
as part of the plan. The resulting congestion control efforts have and will directly affect the
efficiency and comfort of local transit service. Any reduction in auto congestion also benefits and
improves other modes of transportation and impacts bus transit service directly.
As documented in the Circulation Plan, the local county transportation commission, the Los
Angeles County Metropolitan Transportation Commission (Metro), is responsible for monitoring
the compliance of local transportation networks to the state Congestion Management Plan
(CMP). Culver City was found to be in conformance with the state CMP as stated in the 1995
General Plan Update.
In addition to the CMP, Culver City’s General Plan update also included policies and programs
that supported transportation and air quality goals included in the Southern California
Association of Governments Regional Transportation Plan (RTP) and the South Coast Air Quality
Management Plan.
The Circulation Plan also identifies several transportation demand management programs to
reduce overall automobile travel in the city. The plan labels and identifies all types of
transportation infrastructure that exists in the city such as: local arteries, local streets, feeder
streets, transit corridors, bus routes, and bike lanes. All of the planning elements mentioned in
the Circulation Plan have and will work together to form a more efficient multi-modal
transportation network for the city in subsequent and future years.
The following are selected General Plan Goals and Policies that affected public transit, bicycle,
pedestrian, and local surface auto congestion and are included below:
Goal - Integrate local and regional transportation systems that serve residential and business
needs:|10 10|
? Objective 1: Improved Traffic Flow. Reduce traffic congestion throughout the city.
10
o Policy 1.A- Facilitate movement of vehicles at intersections and along roadway
links by increasing capacity, improving operation, and reducing volumes as
appropriate and feasible.
11
o Policy 1.E- Improve traffic flow in areas of high traffic volume by assigning high
priority to roadway improvements, transit links, and bikeways which serve these
areas.
12
|10 10| Culver City General Plan, 1995. Circulation Element
10
Ibid
11
Ibid
12
Ibid
Attachment Page 9
5
? Objective 2: Public Transit. Expand public transit services and ridership.
13
o Policy 2.A- Support with conditions, development of fixed guideway transit in the
Transit Corridors.
14
o Policy 2.B- Support design and operation of public transit systems that ensure the
comfort and safety of all transit passengers.
15
o Policy 2.C- Maintain levels of transit service that are adequate to meet and
encourage ridership demand.
16
o Policy 2.D- Expand Culver CityBus routes and service levels to address new
potential markets and levels of demand.
17
o Policy 2.F- Increase transit service to enhance central Culver City’s pedestrian
oriented character.
18
o Policy 2.H- Encourage public transit links to sites of high trip generating uses to
maximize transit use by patrons and employees.
19
o Policy 2.K- Support MTA funding to enhance feeder service to MTA rail stations.
20
? Objective 3: Bikeways. Provide a system of safe and enjoyable bikeways and support
facilities.
21
o Encourage the inclusion of a bike path within the Exposition Right-of-Way and
any future transit corridors with adequate right-of-way to safely support both
uses.
22
13
Culver City General Plan, 1995. Circulation Element
14
Ibid
15
Ibid
16
Ibid
17
Ibid
18
Ibid
19
Ibid
20
Ibid
21
Ibid
22
Ibid
Attachment Page 10
6
? Objective 4: Pedestrian Access. Provide convenient and pleasant pedestrian access.
23
.
o Policy 4.B- Enhance the user friendliness of pedestrian staging areas at transit
links (bus stops and possible future rail stations) throughout the city.
24
23
Culver City General Plan, 1995. Circulation Element
24
Ibid
Attachment Page 11
7
II. GENERAL REPORTING REQUIREMENTS
There were no sub-recipients for this reporting period that received Federal financial assistance
from the FTA through Culver CityBus.
A. Public Notification of Culver CityBus Title VI Protections
Part of Culver CityBus Title VI responsibilities is to inform the public of its obligations through a
public notice that details their Title VI complaint procedures. Please see the example
announcement from the Culver CityBus web page below:
“In accordance with Title VI of the 1964 Civil Rights Act, Culver CityBus is committed to ensuring
that no person shall be excluded from the equal distribution of its services and amenities on the
basis of race, color, national origin, language proficiency, or economic status. If you believe that
you have been subjected to discrimination under Title VI, you may call or file a written complaint
with Culver CityBus at (310) 253-6500 or 4343 Duquesne Avenue, Culver City, CA 90232.”
The following notice was created and made available to the public on July 30
th
2011 and is
available in Spanish and posted in every Culver CityBus, at the service counter of the
Transportation Department, in the lobby of City Hall and on the Culver CityBus website under
“Culver CityBus – Contact Us – Non-Discrimination” at the following address:
“http://www.culvercity.org/Government/Transportation/Bus/AboutUs.aspx.”
Culver CityBus is in the process of updating the Title VI notice to include the website address and
general instructions on procedures for filing a Title VI complaint.
B. Culver CityBus Procedures for Investigating and Tracking Title VI Complaints
Please refer to Appendix B for a full copy of the Culver CityBus Title VI complaint form and Title
VI investigation and compliance procedures.
C. List of Active Lawsuits
There are currently no active lawsuits or complaints against Culver CityBus alleging discrimination
on the basis of race, color or national origin arising from the service provided.
25
D. Compliance Review Activities
No local, state or federal agency (other than the FTA during the triennial review process) has
conducted a civil rights review on Culver CityBus in the last 3 years.
26
25
Personal Contact: Jane Leonard, Sr. Management Analyst: Culver CityBus, 2014.
26
Personal Contact: Jane Leonard, Sr. Management Analyst: Culver CityBus, 2014.
Attachment Page 12
8
E. Signed Assurances
The signed FTA assurances were submitted through the FTA’s web-based grants administration
system, TEAM-Web, on March 4, 2014 in compliance with current reporting requirements.
27
F. Construction Impact Analysis
Title VI requires a fixed facility (transit centers, operations facility or yard) impact analysis for
construction projects to assess any impacts to minority communities. If this information has been
prepared as a result of an environmental impact statement, the application recipient, or
subrecipient, should reference the relevant information by documenting page numbers and date
of submission to FTA.
A Title VI Equity Analysis should also be conducted during the planning stages to assess where a
project is located or sited to ensure the location is selected without regard to race, color, or
national origin. Recipients shall engage in outreach to persons potentially impacted by the
placement of facilities. The Title VI equity analysis must compare the equity impacts of various
site alternatives, and the analysis must occur before the selection of the preferred site.
28
Additional environmental justice principles are reflected in the DOT Order on Environmental
Justice (DOT Order 5610.2(a)), address Environmental Justice in Minority Populations and Low-
Income Populations. The order describes the process the Department and its modal
administrations (including FTA) use to incorporate environmental justice principles into
programs, policies, and activities.
29
As a result of FTA requirements, environmental impact analyses for fixed facilities shall include:
? A Title VI Equity Analysis conducted during planning stages to assess if or how the location
will impact minority communities and provides alternatives analysis.
? A project history and background for each construction project or service plan within the
document.
? A discussion of the potential impacts on minority communities and minority-owned
businesses during and after construction.
? A discussion on all potential negative environmental impacts, such as traffic congestion,
noise, air or water pollution;
? A list of minority owned businesses and households affected by construction projects;
27
Personal Contact: Jane Leonard, Sr. Management Analyst: Culver CityBus, 2014.
28
Federal Transit Administration, Title VI Circular FTA C 4702.1B, 2012.
29
Federal Transit Administration, Title VI Circular FTA C 4702.1B, 2012.
Attachment Page 13
9
? A description of other significant impacts on minority communities, such as: increased
traffic, reduction in parking availability, etc.; and
? A description of the relocation program and/or other measures adopted by the applicant
used to mitigate identified adverse social, economic, or environmental effects of the
proposed construction project or service plan all of which should include an
environmental justice component.
During the reporting period, Culver CityBus had no projects in this category.
G. Information Dissemination
All announcements for public hearings are given wide distribution through the use of updated
mailing and e-mail address listings inclusive of community groups and concerned individuals. In
addition, these notices are posted as “take-ones” in all Culver CityBuses and at City Hall. The
public can also dial the City’s telephone number or access the City’s website to get updated
information regarding City business affairs.
Culver CityBus also submits a service change proposal to the Los Angeles County Metropolitan
Transportation Authority (LACMTA) for review if the change (1) involves in excess of 25% of the
revenue service provided on a bus route; (2) duplicates in excess of 2% of another operator’s
service; or (3) will be funded with Proposition A or C Local Return funds.
As stated above, when Culver CityBus proposes any major service changes, the system must meet
formal notification and public hearing requirements. To briefly summarize the requirements,
Culver CityBus must provide formal notification of what changes are proposed to each
jurisdiction affected by service changes and allow each respective jurisdiction 90 days to respond.
A public hearing must also be held to provide public input and feedback on the proposed service
changes.
These and further requirements are contained in:
The Los Angeles County Metropolitan Transportation Authority “Service Notification
Policy – Measures and Public Sharing Procedures for Major Service or Fare Changes”
U.S. Department of Transportation, Federal Transit Administration, Circular C 9030.1B
Urbanized Area Formula program: Grant Application Chapter 5.5 (O), “Public comment of
Fare and Service Changes”
U.S. Department of Transportation, Federal Transit Administration Triennial Review
Guidelines “Public Comment on Fare and Service Changes.” Washington, DC, 1997
Attachment Page 14
10
During this dissemination period, Culver CityBus staff are confident that all the system riders,
including minorities, senior citizens and the disabled, and limited English proficiency populations,
will be thoroughly apprised of any proposed service changes and will have opportunities to
influence service-planning decisions as they arise.
Under the new Title VI guidance, transit providers with 50 or fewer peak period service buses are
not required to conduct a fare equity or service change analysis. However, any impacts of these
types of changes to persons of minority or low-income status as defined by the FTA are
considered. Culver CityBus provides opportunity for public comment and this feedback is
considered prior to the implementation of any fare or service changes as detailed in their future
fare and service change methodology (see Appendix C).
H. Limited English Proficiency Implementation Plan
As with any public announcements and customer service information Culver CityBus is well
informed of the many languages used by its customer base. In November 2011 Culver CityBus
created a Limited English Proficiency Assessment and Implementation (LEP) Plan to ensure
“meaningful” access to transit services and programs. This plan was updated in May 2014.
The assessment discovered, according to the 2010 census, 14% of residents in the Culver CityBus
service area spoke English “less than very well.” The data indicated that this was particularly the
case for both the Spanish and Japanese languages (see Table 3).
As a result, Culver CityBus is implementing several language assistance measures to aid these
limited English proficient individuals. The measures are aimed at those language groups with the
largest population percentages in the service area that included Spanish, Japanese and Persian
(Farsi) languages.
To assist its LEP patrons, Culver CityBus has implemented the following measures:
1.) The City of Culver City (of which Culver CityBus is a department) has employees who
may help translate in languages including Spanish, Chinese dialects, Japanese, and
Vietnamese (but only Spanish translation services are paid).
2.) Bus schedules, maps, fare/service change announcements, information for the Rider
Relief Transportation Program and other transit publications will be made available in
an alternative language for the Spanish speaking LEP population.
3.) Staff fluent in Spanish are available in the Culver CityBus administrative offices to
handle inquiries and complaints from Spanish speaking callers.
Culver CityBus also trains its staff by providing copies of the language assistance measures
contained in Culver CityBus’ LEP Implementation Plan to all Culver CityBus employees and new
hires.
Attachment Page 15
11
Part of the LEP Implementation also details notifying LEP persons of all Culver CityBus services
that are available. Special notices of route changes, public hearings, and holiday schedules are
also posted in Culver CityBus buses in both English and Spanish.
Part of the plan commits to an annual monitoring regime in order to assure that it is up to date
and improved upon as needed. A copy of the entire LEP Assessment and Implementation Plan is
available in Appendix D.
I. Public Participation Plan
Culver CityBus recognizes the importance of involving the public in the planning and
implementation of transit services. The goals of the Culver CityBus public involvement plan are
to ensure that:
? Residents are given the opportunity to participate in the transportation planning process
? The issues and concerns of residents are given consideration in the selection of
transportation investments
? Transportation investments do not disproportionately burden any population with
adverse impacts
Public Participation Principles
The following principles are used to develop the Public Involvement Plan for Culver CityBus
projects and programs:
? Culver CityBus will determine what non-English languages and other barriers may exist to
public participation within the service area
? Culver CityBus will provide a general notification of meetings, particularly forums for
public input, in a manner that is understandable to all populations in the area
? Public meetings will be held in locations that are accessible to transit riders and people
with disabilities, and will be scheduled at times that are convenient for members of the
public
? Public meetings and hearings will be broadly advertised in the community in non-English
languages identified in the updated LEP Plan (Appendix D) through printed materials
onboard buses (e.g., interior cards, flyers, and/or comment cards) describing the
proposed changes as well as at major transit stops, local print media, and local community
centers such as the Culver City Senior Center
Attachment Page 16
12
? Culver CityBus will provide notification regarding the availability of language assistance at
public meetings as described in the LEP Plan
Targeted Public Outreach to Minority and Limited English Proficient (LEP) Populations
When planning for public engagement, Culver CityBus will incorporate strategies intended to
promote involvement of minority and LEP individuals in public participation activities, as
appropriate for the plan, project, or service in question, and consistent with federal Title VI
regulations, Executive Order 13166 on Limited English Proficiency, and the U.S. Department of
Transportation LEP Guidance.
At a minimum, Culver CityBus staff will implement strategies such as holding public meetings in
locations that are accessible to transit riders and people with disabilities, scheduling meetings at
times that are convenient for members of the public, advertising meetings and hearings in the
primary languages spoken in the service area as identified in the updated LEP Plan, and providing
notice of the availability of language assistance.
J. Minority Representation on Decision Making Bodies
Culver City does not have any exclusive commission or body directed towards Culver CityBus
operations. City Council meetings provide the public venue for comments and feedback regarding
any fare, service changes, or any other aspect of transit delivery. The City Council meetings are
held twice per month and create a venue for our riders and members of the public at large to
have an opportunity to comment publically regarding Culver CityBus services. The City Council is
an elected body and racial breakdown is therefore not provided.
30
Table 3: Culver CityBus Service Area Languages
30
Personal Contact: Jane Leonard, Sr. Management Analyst: Culver CityBus, 2014.
Attachment Page 17
13
Attachment Page 18
14
III. PROGRAM SPECIFIC REQUIREMENTS
Culver CityBus operated 44 peak hour fixed route buses during the reporting period and as a
result is mandated by FTA Circular (FTA C 4702.1B) to only detail the system-wide service
standards and policies as part of Section III of the report.
A. Service Standards and Policies
Culver CityBus has adopted quantitative system-wide service standards for its fixed route
services. These standards, which are summarized below, were developed and implemented to
help Culver CityBus better achieve equity for all its transit customers in service design and
operations decisions. There have been no changes to Culver CityBus service standards during the
past three years. These standards are assessed every three years and were reviewed with the
most recent transit system Line-by-Line Analysis completed in February 2012.
Service Standards
Vehicle Load
Vehicle load is the ratio of passengers on the vehicle to the number of seats on the bus. Culver
CityBus measures the vehicle load at the maximum load point on each route during peak and off-
peak periods. The Culver CityBus policy is to maintain vehicle load factors at or below 125%.
31
To prevent the load factors from being exceeded, Culver CityBus has created three trippers to
ease any overcrowding on their busiest lines.
32
Vehicle Headway
Vehicle headway is the measurement of time between buses on a line. Culver CityBus generally
operates fixed-route service with vehicle headways between 12-60 minutes during weekday peak
periods, and between 15-60 minutes during weekday off-peak periods and weekends.
33
On-Time Performance
Culver CityBus defines on-time performance for fixed route bus trips as those trips that arrive at
a time point location no earlier than 1 minute before the time listed on printed schedules, and
arrives at the time point no later than 5 minutes from the scheduled time. Culver CityBus
identified their on-time performance standard in the 2012 Line-by-Line Analysis.
31
Culver CityBus, 2012 Short Range Transit Plan
32
Ibid
33
Ibid
Attachment Page 19
15
Service Availability
Service availability generally corresponds to the provision of transit service on major traffic
corridors in the service area and access to high population centers and trip generators in
urbanized areas. Culver CityBus provides fixed-route service primarily to people who reside
within one-half to one-quarter mile of the stops along the routes. Due to the large and varied
number of municipal operators that include Santa Monica’s Big Blue Bus, LADOT, and the Los
Angeles County Metropolitan Transportation Authority (Metro), who also provide services at or
near many Culver CityBus stops, patrons have many options to access public transportation and
Culver CityBus. The many operators in the region also coordinate regularly to reduce unnecessary
duplication of routes and increase a more even distribution of transit services. Culver CityBus
provides riders with many opportunities to access the more regional transit systems and hubs for
a seamless transit experience.
Service Policies
Culver CityBus has adopted quantitative system-wide service policies for its fixed-route services.
These policies, which are summarized below, were developed and implemented to help Culver
CityBus better achieve equity for all its transit customers in service design and operations
decisions. There have been no changes to Culver CityBus service policies during the past three
years.
Distribution of Transit Amenities
Transit amenities such as bus benches are provided as a convenience to passengers. The
placement of transit amenities is guided by the Culver CityBus Standards for New and Existing
Bus Stops (February 2005). These standards govern the spacing, location, design and operational
aspects of bus stops and bus furniture placed at Culver CityBus stop locations. Generally, bus
stops are placed no more than 1,000 feet apart (stops may be closer in commercial and
downtown Culver City areas). Benches are placed at high-volume bus stops within the Culver
CityBus service area as well as bus stops where there is less frequent service and identified high
levels of usage by senior and disabled patrons. At bus stops outside the City of Culver City, the
local jurisdictions determine the placement of transit amenities.
Vehicle Assignment
With regards to vehicle assignment, Culver CityBus assigns vehicles on an “available” basis with
no specifically assigned vehicles to specific routes. The exception is the eight (8) buses designated
for Line 6 Rapid services; these buses are identified with a specific paint scheme to indicate they
are providing service to that line only. This ensures that no geographic location is preferred over
another.
Attachment Page 20
16
Culver CityBus strives to supply its customer base with well-maintained, clean burning CNG
vehicles that are ADA compliant by intending to replace all buses after their 12-year life span.
34
This ensures that riders are supplied with newer vehicles for the near future. To demonstrate
commitment to its policy, Culver CityBus is placing six new fixed route forty-foot CNG vehicles
into service beginning in June 2014.
35
Characteristics of the Culver CityBus fleet are listed in Table
4.
Table 4: Fleet Characteristics
36
Culver City Municipal Bus Lines Fleet Inventory as of April 2014
Year Built Manufacturer Seats Length
Total
Vehicles
2001
New Flyer
40 40' 12
2004
New Flyer
40 40' 8
2009
New Flyer
41 40' 6
2011 New Flyer 41 40' 20
2014 New Flyer 40 40’ 6
Totals 54
34
Ibid
35
Personal Contact: Jane Leonard, Sr. Management Analyst: Culver CityBus, 2014.
36
Bus Fleet List, Culver City Municipal Bus Lines, 2014.
Attachment Page 21
17
IV. CONCLUSION
This report fulfills the compliance reporting requirements for Title VI as detailed in FTA Circular
4702.1B. The report detailed the Culver CityBus services, long-range planning efforts, and general
reporting requirements mentioned in the circular. The program specific requirements were
addressed with a profile of their service standards and policies along with a description of the
Culver CityBus fleet. The results demonstrate that Culver CityBus services a diverse population
and supplies public transportation equitably to all classified races, ethnicities, and income levels.
Attachment Page 22
18
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Attachment Page 23
APPENDIX A:
CULVER CITYBUS FTA TITLE VI CERTIFICATIONS
AND ASSURANCES
Attachment Page 24
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Attachment Page 25
FEDERAL FISCAL YEAR 2014 FTA CERTIFICATIONS AND ASSURANCES
SIGNATURE PAGE
(Required of all Applicants for FTA funding and all FTA Grantees with an active Capital
or Formula Project)
AFFIRMATION OF APPLICANT
Name of the Applicant: CULVER CITY, CITY OF
Name and Relationship of the Authorized Representative: Martin R Cole
BY SIGNING BELOW, on behalf of the Applicant, I declare that it has duly authorized me to make these
Certifications and Assurances and bind its compliance. Thus, it agrees to comply with all Federal statutes
and regulations, and follow applicable Federal guidance, and comply with the Certifications and Assurances
as indicated on the foregoing page applicable to each application its Authorized Representative makes to
the Federal Transit Administration (FTA) in Federal Fiscal Year 2014, irrespective of whether the individual
that acted on his or her Applicant’s behalf continues to represent it.
FTA intends that the Certifications and Assurances the Applicant selects on the other side of this document
should apply to each Project for which it seeks now, or may later seek FTA funding during Federal Fiscal
Year 2014.
The Applicant affirms the truthfulness and accuracy of the Certifications and Assurances it has selected in
the statements submitted with this document and any other submission made to FTA, and acknowledges
that the Program Fraud Civil Remedies Act of 1986, 31 U.S.C. 3801 et seq., and implementing U.S. DOT
regulations, “Program Fraud Civil Remedies,” 49 CFR part 31, apply to any certification, assurance or
submission made to FTA. The criminal provisions of 18 U.S.C. 1001 apply to any certification, assurance,
or submission made in connection with a Federal public transportation program authorized by 49 U.S.C.
chapter 53 or any other statute.
In signing this document, I declare under penalties of perjury that the foregoing Certifications and
Assurances, and any other statements made by me on behalf of the Applicant are true and accurate.
Signature Martin R Cole Date: 3/4/2014
Name Martin R Cole
Authorized Representative of Applicant
AFFIRMATION OF APPLICANT’S ATTORNEY
For (Name of Applicant): CULVER CITY, CITY OF
As the undersigned Attorney for the above named Applicant, I hereby affirm to the Applicant that it has
authority under State, local, or tribal government law, as applicable, to make and comply with the
Certifications and Assurances as indicated on the foregoing pages. I further affirm that, in my opinion, the
Certifications and Assurances have been legally made and constitute legal and binding obligations on it.
I further affirm that, to the best of my knowledge, there is no legislation or litigation pending or imminent
that might adversely affect the validity of these Certifications and Assurances, or of the performance of its
FTA Project or Projects.
Signature: Carol Schwab Date: 2/11/2014
Name: Carol Schwab
Attorney for Applicant
Each Applicant for FTA funding and each FTA Grantee with an active Capital or Formula Project must
provide an Affirmation of Applicant’s Attorney pertaining to the Applicant’s legal capacity. The Applicant
may enter its signature in lieu of the Attorney’s signature, provided the Applicant has on file this Affirmation,
signed by the attorney and dated this Federal fiscal year.
Attachment Page 26
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Attachment Page 27
APPENDIX B:
CULVER CITYBUS TITLE VI COMPLAINT
INVESTIGATION PROCEDURES
Attachment Page 28
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Attachment Page 29
CULVER CITYBUS
TITLE VI COMPLAINT PROCEDURES
This section outlines the Title VI complaint procedures related to providing programs, services, and
benefits of Culver CityBus. However, it does not deny the complainant the right to file formal
complaints with the State of California, Federal Transit Administration, or seek private counsel for
complaints alleging discrimination, intimidation or retaliation of any kind that is prohibited by law.
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national
origin in programs receiving federal financial assistance.
GENERAL
Any person who believes that he or she, individually, or as a member of any specific class of persons,
has been subjected to discrimination on the basis of race, color, or national origin as noted below may
file a written complaint with Culver CityBus, 4343 Duquesne Avenue Culver City, California 90232.
Complainants have the right to complain directly to the appropriate federal agency. Every effort will
be made to obtain early resolution of complaints. The option of informal meeting(s) between the
affected parties and the Title VI Coordinator (Senior Management Analyst) may be utilized for
resolutions. The Title VI Coordinator will notify the Culver CityBus Transportation Director of all
Title VI related complaints as well as all resolutions.
PROCEDURE
1. The complaint must meet the following requirements:
a. Complaint shall be in writing and signed by the complainant(s). In cases where the complainant is
unable or incapable of providing a written statement, a verbal complaint may be made. The Title VI
Coordinator will interview the complainant and assist the person in converting verbal complaints to
writing. All complaints must, however, be signed by the complainant or his/her representative.
b. Include the date of the alleged act of discrimination date when the complainants became aware of
the alleged act of discrimination; or the date on which that conduct was discontinued or the latest
instance of conduct
c. Present a detailed description of the issues, including names and job titles of those individuals
perceived as parties in the complaint.
d. Federal and state law requires complaints be filed within 180 calendar days of the alleged incident.
2. Upon receipt of the complaint, the Transportation Director will determine its jurisdiction,
acceptability, need for additional information, as well as assign the complaint to the Title VI
Coordinator to investigate the merit of the complaint.
3. The complainant will be provided with a written acknowledgement that Culver CityBus has either
accepted or rejected the complaint.
4. A complaint must meet the following criteria for acceptance:
a. The complaint must be filed within 180 days of the alleged occurrence.
b. The allegation must involve a covered basis such as race, color or national origin.
c. The allegation must involve a Culver CityBus service of a Federal-aid recipient, sub-recipient or
contactor.
Attachment Page 30
5. A complaint may be dismissed for the following reasons:
a. The complainant requests the withdrawal of the complaint.
b. The complainant fails to respond to repeated requests for additional information needed to process
the complaint.
c. The complainant cannot be located after reasonable attempts.
6. Once Culver CityBus decides to accept the complaint for investigation, the complainant will be
notified in writing of such determination. The complaint will receive a case number and will then be
logged in a database identifying: complainant's name, basis, alleged harm, race, color and national
origin of the complainant.
7. In cases where Culver CityBus assumes the investigation of the complaint, within 90 calendar days
of the acceptance of the complaint, Culver CityBus’ Title VI Coordinator will prepare an investigative
report for review by the Transportation Director. The report shall include a narrative description of the
incident, identification of persons interviewed, findings and recommendations for disposition.
8. The investigative report and its findings will be reviewed by the Transportation Director and in some
cases the investigative report and findings will be reviewed by the Culver City City Attorney’s Office.
The report will be modified as needed.
9. The Transportation Director will make a determination on the disposition of the complaint.
Dispositions will be stated as follows:
a. In the event Culver CityBus is in noncompliance with Title VI regulations remedial actions will be
listed.
10. Notice of Director's determination will be mailed to the complainant. Notice shall include
information regarding appeal rights of complainant and instructions for initiating such an appeal.
Notice of appeals is as follows:
a. Culver CityBus will reconsider this determination if new facts, come to light.
b. If complainant is dissatisfied with the determination and/or resolution set forth by Culver CityBus,
the same complaint may be submitted to the FTA for investigation. Complainant will be advised to
contact the Federal Transit Administration, Office of Civil Rights, 201 Mission Street Suite 1650 San
Francisco, CA 94105-1839.
11. A copy of the complaint and Culver CityBus’ investigation report/letter of finding and final
remedial action plan, if appropriate, will be issued to FTA within 120 days of the receipt of the
complaint.
12. A summary of the complaint and its resolution will be included as part of the Title VI updates to
the FTA.
RECORDKEEPING REQUIREMENT
The Transportation Director will ensure that all records relating to Culver CityBus’ Title VI complaint
process are maintained with department records. Records will be available for compliance review
audits.
Attachment Page 31
CITY OF CULVER CITY
TRANSPORTATION DEPARTMENT
4343 DUQUESNE AVENUE, CULVER CITY, CA 90232
(310) 253-6500 ? FAX (310) 253-6513
Art A. Ida
Transportation Director
Title VI Complaint Form
Name: __________________________________________________________________
Address: ________________________________________________________________
City: _________________________ State: _____________ Zip Code: _____________
Home Telephone Number: (___) ________________
Work Telephone Number: (___) ________________
Cell Telephone Number: (___) ________________
Were you discriminated against because of:
( ) Race ( ) National Origin
( ) Color
( ) Other _______________________________________________________________
Date of Alleged Incident: ______________________________
Explain as clearly as possible what happened and how you were discriminated against. Indicate
who was involved. Be sure to include the names and contact information of any witnesses. If
more space is needed, please use the back of the form.
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
Attachment Page 32
Have you filed this complaint with any other federal, state or local agency or with any federal or
state court? ( ) Yes ( ) No
If yes, check all that apply:
( ) Federal agency ( ) Federal court ( ) State agency ( ) State court
( ) Local agency
Please provide information about a contact person at the agency/court where the complaint was
filed.
Name: __________________________________________________________________
Address: _______________________________________________________________
City, State and Zip Code: __________________________________________________
Telephone Number: (___) _____________
Please sign below. You may attach any written materials or other information that you think is
relevant to your complaint.
_________________________________________________________ _____________
Signature Date
Please mail this form to:
Culver CityBus
Title VI Coordinator
4343 Duquesne Avenue
Culver City, CA 90232
Attachment Page 33
APPENDIX C:
METHODOLOGY TO ANALYZE SERVICE AND FARE
CHANGES
Attachment Page 34
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Attachment Page 35
Methodology to Analyze the Impacts on Minority and Low-income Riders
Of Future Fare and Major Service Changes
Fare Change
Under the new Title VI rules, transit agencies with fewer than 50 peak hour service vehicles are
not required to do a fare equity analysis. When considering a raise in fare, Culver CityBus will
notify (in both English and Spanish) the public per its established public notification process (i.e.
information on bus, email notifications, etc.) to encourage the public to submit their comments.
The comments received will be taken into consideration, along with the fiscal situation of the
agency. Culver CityBus is a small agency that does not have many financial resources, and the
financial sustainability of the service operation must be taken into serious consideration when
determining a fare change. To assist the low-income riders, the agency provides information and
promotes the availability of subsidy program for low-income riders, such as the Rider Relief
Transportation Program (RRTP), to help minimize the impacts of the fare change.
Service Change
Under the new Title VI rules, transit agencies with fewer than 50 peak hour service vehicles are
not required to do a service equity analysis. However, any potential impacts to the minority and
low-income riders, to the best of Culver CityBus’ knowledge, will be considered in the
implementation of the reduction in service. Culver CityBus will notify the public of any planned
addition in service. In the case of the reduction in service, Culver CityBus will notify (in both
English and Spanish) and solicit comments from the public per our established public notification
process (i.e. information on bus, email notifications, etc.). Information obtained from the
comments received will be taken into consideration in the final implementation of reduction in
service.
REVISED: February 25, 2013
Attachment Page 36
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Attachment Page 37
APPENDIX D:
LEP ASSESEMENT AND IMPLEMENTATION PLAN
FOR CULVER CITYBUS
Attachment Page 38
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Attachment Page 39
1
LIMITED ENGLISH PROFICIENCY [LEP] PLAN
CULVER CITY MUNICIPAL BUS LINES
CITY OF CULVER CITY, CALIFORNIA
Introduction
This Limited English Proficiency (LEP) Plan has been prepared to address Culver City Municipal
Bus Lines’ (Culver CityBus) responsibilities as a recipient of federal financial assistance as they
relate to the needs of individuals with limited English language skills. The plan has been prepared
in accordance with Title VI of the Civil Rights Act of 1964 which prohibits discrimination on the
basis of race, color or national origin in programs and activities receiving Federal financial
assistance. Specifically, Title VI provides 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 subjected to
discrimination under any program or activity receiving Federal financial assistance.”
Culver CityBus is committed to ensuring that no person is excluded from participation in or
denied the benefits of its transit services on the basis of race, color, or national origin.
This plan was developed to guide Culver CityBus in its administration and management of Title
VI related activities.
Plan Summary
Culver CityBus has developed this Limited English Proficiency Plan to help identify reasonable
steps for providing language assistance to persons with limited English proficiency [LEP] who wish
to access services provided. As defined in Executive Order 13166, LEP persons are those who do
not speak English as their primary language and have limited ability to read, speak, write or
understand English. This plan outlines how to identify a person who may need language
assistance, the ways in which assistance may be provided, staff training that may be required,
and how to notify LEP persons that assistance is available. In order to prepare this plan, Culver
CityBus undertook the U.S. Department of Transportation’s four-factor LEP analysis which
considers the following factors:
1. The number or proportion of LEP persons in the service area who may be served or are
likely to encounter a Culver CityBus program, activity or service.
2. The frequency with which LEP persons come in contact with Culver CityBus programs,
activities or services.
3. The nature and importance of programs, activities or services provided by Culver CityBus
to the LEP population.
4. The resources available to Culver CityBus and overall cost to provide LEP assistance.
A summary of the results of the four-factor analysis is in the following section.
Attachment Page 40
2
Four-Factor Analysis
1. The number or proportion of LEP persons in the service area who may be served or are
likely to encounter a Culver CityBus program, activity or service.
Culver CityBus reviewed 2010 U.S Census tract level data. Those census tracts that were within
¼ mile of a Culver CityBus route were considered part of the Culver CityBus service area. The
review indicated that the total service area has a population of 325,621 that are five years of age
or older. Of those persons, 45,777 (14.1%) speak English “not well” or “not at all.” Of those
persons with limited English proficiency, 25,068 (54.8%) speak Spanish. The next languages listed
with the highest number of persons that speak English “not well” or “not at all” is Japanese at
3,399 persons (7.4%) and Persian at 3,140 persons (6.9%). A number of other language groups
make up the remainder of limited English speaking persons in the service area.
As detailed in Figures 1 through 4, census tracts with the majority of limited English speaking
persons of Spanish descent were located primarily in the Mar Vista area west of the 405 Freeway,
and the eastern end of the Culver CityBus service area. Limited English speaking persons of
Japanese descent were concentrated near Westwood and Century City, the Playa Vista area and
the eastern end of the Culver CityBus service area. Areas in which limited English speaking
persons speaking Persian languages (i.e. Farsi) were located in the northern and eastern ends of
the Culver CityBus service area, and near Westchester. These tracts had a population of limited
English speaking persons ranging from a low of 4% to over 50%.
2. The frequency with which LEP persons come in contact with Culver CityBus programs,
activities or services.
Culver CityBus reviewed the frequency with which staff and drivers have, or could have, contact
with LEP persons. This includes reviewing phone inquiries and surveying bus operators. To date,
Culver CityBus staff has had infrequent requests for assistance in languages other than English.
In an optional survey of bus operators, sixty-two (62) bus operators indicated a fairly high level
of interaction with LEP persons. Approximately 70% of all bus operators surveyed indicated that
they have daily interaction with LEP persons. Approximately 29% of bus operators surveyed
interact with LEP persons 10 or more times a day. Lines 1 (Washington Blvd.) and 6 (Sepulveda
Blvd.) were the routes most cited by bus operators for interaction with limited English speaking
passengers. The predominate language encountered by bus operators is Spanish, with bus
operators reporting some interaction with passengers possibly speaking Chinese dialects. Given
the results of the census language assessment, many of these passengers may have been in the
Japanese language category if operators were unable to distinguish between language
differences. There have also been very few requests made to bus operators for language
translation of public information, with 87% of operators indicating that passengers do not
request translated materials.
Attachment Page 41
3
Figure 1: Percentage of English Language Speakers by Census Tract
Attachment Page 42
4
Figure 2: Percentage of Spanish Language Speakers with Little or No English Proficiency by Census Tract
Attachment Page 43
5
Figure 3: Percentage of Japanese Language Speakers with Little or No English Proficiency by Census Tract
Attachment Page 44
6
Figure 4: Percentage of Persian Language Speakers with Little or No English Proficiency by Census Tract
Attachment Page 45
7
3. The nature and importance of programs, activities or services provided by Culver CityBus
to the LEP population.
As detailed in Figures 1 through 4, census tracts with the majority of limited English speaking
persons were located primarily in the northern and eastern portions of the Culver CityBus service
area, and in Mar Vista and Westchester. Culver CityBus services in the Washington Blvd. corridor
and the Sepulveda Blvd. corridor provide service to the largest geographic concentrations of LEP
individuals in the Culver CityBus service area. In some areas along these corridors from 50% to
75% or more of persons speaking Spanish, Japanese or Persian (Farsi) languages have little or no
English proficiency. The Culver City Senior Center, located near Culver CityBus Lines 1, 3 and 7,
provides educational, recreational and social services to community residents. In speaking with
the City’s Senior and Social Services Manager, Armando Abrego, the center hosts a variety of
cultural and language groups that meet on a regular basis including the Latino Group, Chinese-
American Group, and language clubs for Spanish, German, and French speaking persons. Staff at
the center have contact with LEP persons on a daily basis, particularly with the various groups
meeting at the center. The senior center is also contacted by up to five new persons each day
with limited English proficiency to inquire about services and information.
Mr. Abrego estimates that about 15% of senior center attendees access the facility by transit,
particularly regular paratransit riders. Senior center staff has received comments on specific
transportation needs of center attendees including a desire for more paratransit service, a desire
for paratransit service to travel further than the city limits, and a transit routing that links the
senior center, Downtown Culver City and various local activity centers. Mr. Abrego also
suggested it may be helpful for seniors and the limited English speaking community for area
transit providers to periodically visit the center and set up information tables to assist persons in
understanding transit services and to sign up for available services.
4. The resources available to Culver CityBus and overall cost to provide LEP assistance.
Culver CityBus reviewed its available resources that could be used for providing LEP assistance,
which of its documents would be the most valuable to be translated if the need should arise, and
evaluated resources that could be used for outreach and translation efforts. Based on the four-
factor analysis, Culver CityBus developed its LEP Plan as outlined in the following sections.
Language Assistance
A person who does not speak English as their primary language and who has a limited ability to
read, write, speak or understand English may be a Limited English Proficient person and may be
entitled to language assistance with respect to Culver CityBus programs and activities. Language
assistance can include interpretation, which means oral or spoken transfer of a message from
one language into another language and/or translation, which means the written transfer or a
message from one language into another language. Culver CityBus will determine when
interpretation and/or translation are needed and are reasonable. How the Culver CityBus staff
may identify an LEP person who needs language assistance is outlined below:
Attachment Page 46
8
? Examine records to see if requests for language assistance have been received in the past,
either at meetings or over the phone, to determine whether language assistance might
be needed at future events.
? When Culver CityBus sponsors an event, have a staff person greet participants as they
arrive. By informally engaging participants in conversation it is possible to gauge each
attendee’s ability to speak and understand English.
? Have Census Bureau Language Identification Flashcards available at Culver CityBus events
near the registration table. Individuals self-identifying as persons not proficient in English
may not be able to be accommodated with translation assistance at the event, but it will
assist the sponsoring agency in identifying language assistance needs for future events.
? Network with local community service centers, such as the Culver City Senior Center, that
provide services to LEP individuals and seek opportunities to provide information on
transit services.
? Vehicle operators and other front-line staff, including bus operators, supervisors,
customer service representatives, clerical staff and dispatchers will be informally
surveyed periodically on their experience concerning any contacts with LEP persons
during the previous year.
? Add a question to the Culver CityBus Line-by-Line Analysis survey that is conducted every
three years, which asks passengers to indicate the primary language spoken in their
household. This will provide another means to accurately identify LEP levels in the service
area.
Language Assistance Measures - Culver CityBus will strive to offer the following measures to LEP
individuals, that is, persons who speak English “not well” or “not at all”,:
? The Culver CityBus Title VI Policy and Culver CityBus staff will take reasonable steps to
provide the opportunity for meaningful access to LEP clients who have difficulty
communicating in English.
? If a client asks for language assistance and Culver CityBus determines that the client is an
LEP person and that language assistance is necessary to provide meaningful access,
reasonable efforts will be made to provide free language assistance. If reasonably
possible, Culver CityBus will provide the language assistance in the LEP client’s preferred
language. Culver CityBus has the discretion to determine whether language assistance is
needed, and if so, the type of language assistance necessary to provide meaningful access.
? Culver CityBus will periodically assess client needs for language assistance based on
requests for interpreters and/or translation, as well as the literacy skills of the clients.
? The City of Culver City (of which Culver CityBus is a department) has employees who can
help translate in languages other than Spanish, for example, Chinese dialects, Japanese,
Vietnamese and American Sign Language, but only Spanish translation services are paid.
? When an interpreter is needed, in person or on the telephone, staff will attempt to
determine what language is required and then access language assistance at one or more
of the available resources identified under the section “Formal Interpreters” on Page 10.
Attachment Page 47
9
? Consider the use of a computerized translation tool that can help translate the Culver
CityBus website into any language LEP persons are fluent in.
Safe Harbor Stipulation
Federal law provides a “Safe Harbor” stipulation so that recipients can ensure with greater
certainty that they comply with their obligations to provide written translations in languages
other than English. A “safe harbor'' means that if a recipient provides written translations under
certain circumstances, such action will be considered strong evidence of compliance with the
recipient's written-translation obligations under Title VI.
The failure to provide written translations under the circumstances does not mean there is
noncompliance, but rather provides a guide for recipients that would like greater certainty of
compliance than can be provided by a fact-intensive, four-factor analysis. For example, even if a
safe harbor is not used, if written translation of a certain document(s) would be so burdensome
as to defeat the legitimate objectives of its program, it is not necessary. Other ways of providing
meaningful access, such as effective oral interpretation of certain vital documents, might be
acceptable under such circumstances.
Strong evidence of compliance with the recipient's written-translation obligations under ‘safe
harbor’ includes providing written translations of vital documents for each eligible LEP language
group that constitutes 5% or 1,000, whichever is less, of the population of persons eligible to be
served or likely to be affected or encountered. Culver CityBus’ translation of other documents,
if needed, can be provided orally.
This safe harbor provision applies to the translation of written documents only. It does not affect
the requirement to provide meaningful access to LEP individuals through competent oral
interpreters where oral language services are needed and are reasonable.
In the Culver CityBus service area, the Spanish-speaking, Japanese-speaking and Farsi-speaking
LEP language groups constitute the 5% or 1,000 persons of population threshold for which
written translations of vital documents should be provided meet the safe harbor standard. Also,
while persons speaking the Chinese Mandarin and Cantonese dialects and the Korean language
group constitutes less than the 5% threshold (4.0%, 3.9% and 4.2%, respectively), the
concentration of these language groups in the service area would suggest the inclusion of these
language group for written translations of vital documents. To meet the safe harbor standard,
Culver CityBus will translate vital documents such as the Title VI Report, the LEP Plan and public
notices of changes to transit service into the languages listed above. Culver CityBus staff will
utilize features such as Google Translate and multi-lingual staff from the City of Culver City to
translate vital documents for eligible LEP language groups. Culver CityBus will also proceed with
oral interpretation options for compliance with LEP regulations.
Attachment Page 48
10
Staff Training
The following training will be provided to Culver CityBus staff:
• Information on the Title VI Policy and LEP responsibilities.
• Description of language assistance services offered to the public.
• Use of the Language Identification Flashcards.
• Documentation of language assistance requests.
• How to handle a potential Title VI/LEP complaint.
• Bus operators are trained to seek translation assistance from other passengers onboard
the bus when they are either unable to understand or communicate with an LEP person.
Information will be distributed to all Culver CityBus staff.
Culver CityBus may incorporate the training video developed by the FTA on Title VI requirements
into the Bus Operator Training Program. The video explains the language access requirement of
Title VI, and teaches our employees how to appropriately handle the requests from LEP persons.
In addition, City personnel who are paid to provide assistance with Spanish translation are
required to pass a test administered by the City of Culver City in order to demonstration their
language proficiency.
Translation of Documents
• In those cases where the need arises for LEP outreach, Culver CityBus will consider the
following options:
o When staff prepares a document, or schedules a meeting, for which the target
audience is expected to include LEP individuals, then documents, meeting notices,
flyers, and agendas will be printed in an alternative language based on the known
LEP population.
o Bus schedules, maps, fare/service change announcements, information for the
Rider Relief Transportation Program and other transit publications will be made
available in an alternative language for the known LEP population.
Formal Interpreters
• When necessary to provide meaningful access for LEP clients, Culver CityBus will provide
qualified interpreters, including any bilingual staff of the City of Culver City, if available.
At important stages that require one-on-one contact, written translation and verbal
interpretation services will be provided consistent with the four-factor analysis used
earlier.
• Culver CityBus may require a formal interpreter to certify to the following:
o The interpreter understood the matter communicated and rendered a competent
interpretation.
Attachment Page 49
11
o The interpreter will maintain private information. Non-public data will not be
disclosed without written authorization from the client.
o Bilingual City employees, when available, can provide limited assistance to Culver
CityBus staff and LEP clients as part of their regular job duties. Currently, Culver
CityBus has two full-time staff members (one of which provides customer service
assistance daily) that can provide language assistance to LEP persons.
Informal Interpreters
• Informal interpreters may include the family members, friends, legal guardians, service
representatives or advocates of the LEP client. Culver CityBus staff will determine
whether it is appropriate to rely on informal interpreters, depending upon the
circumstances and subject matter of the communication. However, in many
circumstances, informal interpreters, especially children, are not competent to provide
quality and accurate interpretations. There may be issues of confidentiality, competency,
or conflict of interest.
• An LEP person may use an informal interpreter of his or her own choosing and at their
expense, either in place of or as a supplement to the free language assistance offered by
Culver CityBus. If possible, Culver CityBus should accommodate an LEP client’s request to
use an informal interpreter in place of a formal interpreter.
• If an LEP client prefers an informal interpreter, after Culver CityBus has offered free
interpreter services, the informal interpreter may interpret.
• If an LEP client wants to use his or her own informal interpreter, Culver CityBus reserves
the right to also have a formal interpreter present.
Monitoring
Monitoring and Updating the LEP Plan - Culver CityBus will update the LEP as required by U.S.
DOT. At a minimum, the plan will be reviewed and updated if demographic information indicates
that higher concentrations of LEP individuals are present in the Culver CityBus service area.
Updates will include the following:
? The number of documented LEP person contacts encountered annually
? How the needs of LEP persons have been addressed
? Determination of the current LEP population in the service area
? Determination as to whether the need for translation services has changed
? Determine whether local language assistance programs have been effective and sufficient
to meet the need
? Determine whether transit system’s financial resources are sufficient to fund language
assistance resources needed
? Determine whether Culver CityBus fully complies with the goals of this LEP Plan
? Determine whether complaints have been received concerning the agency’s failure to
meet the needs of LEP individuals
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Dissemination of the Culver CityBus LEP Plan
? A link to the Culver CityBus LEP Plan and the Title VI Plan will be included on the City of
Culver City website listed below:
http://www.culvercity.org/Government/Transportation/Bus/AboutUs.aspx
? Any person or agency with internet access will be able to access and download the plan
from the City of Culver City website. Alternatively, any person or agency may request a
copy of the plan via telephone, fax, mail, or in person, and shall be provided a copy of the
plan at no cost. LEP individuals may request copies of the plan in translation which Culver
CityBus will provide, if feasible.
? Questions or comments regarding the LEP Plan may be submitted to Culver CityBus, 4343
Duquesne Avenue, Culver City, CA 90232, phone number (310) 253-6500.
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