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Brownsville Metro Title VI Program

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2019 2019 CITY OF BROWNSVILLE, TEXAS Brownsville Metro Title VI Program Submitted May 09, 2019 Prepared: City of Brownsville/Brownsville Metro 755 International Blvd Brownsville, TX 78520 (956) 541-4881 https://www.cob.us/281/Brownsville-Metro1 2 TABLE OF CONTENTS Resolution by City Commission Approving Brownsville Metro Title VI Program 2 Section 1 – Title VI Notice of Rights 5 Figure1/1B & Figure 2: Larger Examples of Notices 9 & 10 Section 2 – Title VI Complaint Procedures & Complaint Forms 11 Attachment: Procedures for Filing (Title VI) Discrimination Complaints (English/Spanish) 12 & 13 Attachment: Title VI Complaint Forms (English/Spanish) 14 - 17 Document 1: Internal Tracking Systems on Transit Related Public Comment & Complaints 18 Document 2: Suggestions, complaints, compliments, and ADA Reasonable Modification Accommodations Form 19 - 21 Document 3: Public Comment Card 22 Section 3 – List of Public Transit Related Title VI Investigations, Complaints or Lawsuits 23 Document 4: Record of Investigations, Lawsuits or Complaints Alleging Discrimination In A Public Transit Program or Activity City of Brownsville, Texas Form 25 Document 5: Complaint Log 26 Section 4 – Public Participation Plan 27 Purpose 30 Guidelines 30 METHODS FOR OBTAINING PUBLIC COMMENTS 30 - 32 CRITERIA FOR ESTABLISHING PUBLIC HEARINGS/FORUMS 32 DOCUMENTATION 32-33 CONTACT 33 SUMMARY OF OUTREACH EFFORTS MADE SINCE LAST SUBMISSION 33 - 39 Section 5 – Language Assistance Plan 40 FOUR FACTOR ANALYSIS 43 Factor 1 – Number and Proportion of LEP persons Served or Encountered in the Eligible Service Population 43 Task 1, Step 1: Examine prior experiences with LEP individuals 43 Task 1, Step 2: Become familiar with data from the U.S. Census 44 Task 1, Step 2A: Identify the geographic boundaries of the area that your agency serves 44 Task 1, Step 2B: Obtain Census data on the LEP population in your service area 44 Task 1, Step 2C: Analyze the data you have collected. 44 & 45 Task 1, Step 2D: Identify any concentrations of LEP persons within your service area. 45 Task 1, Step 3: Consult state and local sources of data 46 Task 1, Step 4: Community organizations that serve LEP persons 46 Factor 2 – The Frequency with Which LEP Individuals Come into Contact with Programs, Activities, and Services 46 Task 2, Step 1: Review the relevant programs, activities, and services you provide 46 Task 2, Step 2: Review information obtained from community organizations 47 Factor 3: The Importance to LEP Persons of Your Program, Activities and Services 47 Task 3, Step 1: Identify your agency’s most critical services 47 Task 3, Step 2: Review input from community organizations and LEP persons 48 3 Factor 4: The Resources Available to the Recipient and Costs 48 Task 4, Step 1: Inventory language assistance measures currently being provided, along with associated costs 48 & 49 Task 4, Step 2: Determine what, if any, additional services are needed to provide 49 Task 4, Step 3: Analyze your budget 49 APPENDIX 1 50 APPENDIX 2 52 APPENDIX 3 56 APPENDIX 4 59 LANGUAGE ASSISTANCE PLAN 62 Language Assistance Measures 62 Training Staff 62 Providing Notice to LEP Persons 63 Monitoring and Updating the LEP Plan 63 Section 6 – Minority Representation on Transit Related, Non-Elected Advisory Council 64 Section 7 – Sub-recipient Assistance & Monitoring 67 Section 8 – Title VI Equity Analysis for Facility Construction 70 Section 9 – Service Policies and Standards for the City of Brownsville Public Transit Service 72 PREFACE 75 SECTION 1 – GENERAL OPERATING PRINCIPLES 76 SECTION 2 – SERVICE STANDARDS 78 Transit Information 78 Bus Stop Locations and Amenities 79 Transit Planning 81 Vehicle Headway Standards 82 Vehicle Assignments 82 On-Time Performance / Schedule Adherence 83 Transit Safety and Security 83 System Image 83 Maintenance Standards 84 Regular Route Service Standards 85 Demand Response ADA Paratransit Service Standards 87 SECTION 3 – OPERATING REVENUE 88 SECTION 4 – MARKETING 89 GLOSSARY OF TERMS 90 4 Section 1 Title VI Notice of Rights 5 Title VI Notification of Rights Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that "no person in the United States shall, on the ground 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" (42 U.S.C. Section 2000d). The City of Brownsville, Texas is committed to ensuring that no person is excluded from participating in, or denied benefits of transit services on the basis of race, color, and national origin as protected by the Title VI of the Civil Rights Act of 1964 PURPOSE The purpose of this policy is to establish guidelines to effectively monitor and ensure that the City of Brownsville, transportation department Brownsville Metro, is in compliance with all requirements and regulations to carry out the provisions of the Department of Transportation’s (DOT) Federal Transit Administration (FTA) Circular 4702.1.A. POLICY The City of Brownsville/Brownsville Metro will ensure that all programs, policies, and activities comply with the Department of Transportation (DOT) Federal Transit Administration’s Title VI regulations. The City of Brownsville/Brownsville Metro is committed in creating and maintaining public transit service that is free of all forms of discrimination. The City will take whatever preventive, corrective and disciplinary action necessary for behavior that violates this policy or the rights and privileges it is designed to protect. PUBLIC INFORMATION The City of Brownsville/Brownsville Metro disseminates Title VI Program information to the general public, employees, contractors, and subcontractors. Brownsville Metro makes Title VI materials available to the general public by posting information in different locations as bulletin boards; reception areas at La Plaza at Brownsville Multimodal Terminal; the City’s website containing Brownsville Metro webpage (which includes Title VI/Civil Rights complaints procedures); on all revenue vehicles operated by the City of Brownsville; plus, publishes Title VI Policy Statements and informs about public meetings and/or hearings, service changes, and proposed projects have significant circulations in the community in the local newspaper. On the following pages are a variety of examples of how the City of Brownsville /Brownsville Metro provides the public with different notification means of Title VI protection laws: 6 - Notices Figure 1A/1B: Know Your Rights Notices (Posted in English and Spanish) Figure 1A/1B are the Know Your Rights notices that are printed on 11”x17” posters, which are placed inside all revenue vehicles operated by the City of Brownsville. In addition, Brownsville Metro broadcasts these English and Spanish notices found on the video display boards in the waiting area of the La Plaza at Brownsville Multimodal Terminal. *To view a larger sample of these notices, please turn to page 9. Figure 2: Texas Department of Transportation (TxDOT) Poster (Posted in English and Spanish) Figure 2 is the second set of bilingual Title VI notices utilized by Brownsville Metro to notify the public, employees, contractors, and subcontractors about Title VI regulations, which was borrowed from the Texas Department of Transportation. These notices are printed and placed on bulletin boards (i.e. the foyer and receptions areas of La Plaza at Brownsville Multimodal Terminal near to the entrance of the Brownsville Metro’s administrative offices), inside all revenue vehicles, and posted on Brownsville Metro’s web page. *To view a larger sample of this notice, please turn to page 10. 7 - Website Figure 3: The City of Brownsville website – Brownsville Metro’s web page site Figure 3 is a screenshot from Brownsville Metro’s web page from the City of Brownsville’s website that addresses Civil Rights – Title VI. This web page is located at the following web address: https://www.cob.us/705/Civil-Rights---Title-VI. It includes instructions on how to file a complaint as well as links to download the Title VI complaint form and the department’s Title VI program policy. - App Figure 4: Brownsville WebQA App Figure 4 is a screenshot of the free Brownsville WebQA application. The Brownsville WebQA app may be downloaded onto iPhones, Androids, and other electronic devices. This mobile application 8 enables users to submit requests for services, to ask questions, report concerns, file complaints, and/or provided information on how to contact the Help Desk. In addition, the general public is provided with current City information, quickly guided to the City’s website, and is informed on how to access Brownsville Metro’s web page. *Larger Sample Notices As stated earlier in the policy, below are the larger samples of Figure 1A/1B Title VI Know Your Rights Notices and the Title VI Texas Department of Transportation (TxDOT) Poster. Figure 1A: Know your Rights Notice (English) [Revised 01/24/2019] Figure 1B: Know Your Rights/Conozaca Sus Derechos (Spanish) [Corregido 24/1/ 2019] 9 Figure 2: The Texas Department of Transportation (TxDOT) Title VI Poster; for public domain at www.txdot.gov 10 Section 2 Complaint Procedures & Complaint Forms 11 Procedures for Filing Discrimination (Title VI) Complaints Individuals or organizations who believe they have been denied the benefits of, excluded from participation in, or subject to discrimination on the grounds of race, color, or national origin by Brownsville Metro may file a Title VI complaint with Brownsville Metro. Brownsville Metro investigates complaints received no more than 180 days after the alleged incident. Individuals and organizations may file a complaint by completing the attached Brownsville Metro Title VI Complaint Form. Complaints must be signed, include contact information, and hand delivered or mailed to: Brownsville Metro OR Brownsville Metropolitan Planning Organization (MPO) Attention: Tile VI Complaint Attention: Title VI Complaint – B Metro 755 International Blvd.
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