Metro Transit – Title VI Plan 2013

Table of Contents

1. Introduction …………………………………………………………………………………………………..Page 1 2. Title VI Notice to Public ………………………………………………………………………………….Page 1 a. Public Protections Under Title VI…………………………………………………………Page 1 a. Statement of Policy b. Notice Postings……………………………………………………………………………………Page 2 a. Copy of Notice b. List of Posted Locations c. Filing a Title VI Complaint……………………………………………………………………Page 3 a. Instructions and Procedures b. Complaint Form

3. Title VI Complaints, Investigations and Lawsuits………………………………...…………Page 10

4. Public Participation Plan………………………………………………………..………….…………..Page 11 a. Outreach to Minorities b. Outreach to Limited English Proficiency Populations c. Summary of Outreach Since Last Submission

5. Language Assistance Plan…………………………………………………………..…….…………..Page 28 a. Providing Access to LEP Persons a. Four Factor Analysis b. Language Assistance Plan c. Safe Harbor

6. Minority Representation on Transit Advisory Committee and Board of Directors…………………………………………………………………..……….……Page 51 a. Table of Membership Characteristics

7. Providing Assistance to and Monitoring Sub-Recipients…………….….……………..Page 53

8. Facility Equity Analysis…………….………………………………………………………..………….Page 55

9. Service Equity Analysis…………………………………………………………………………….……Page 59 Metro Transit – Title VI Plan 2013

10. Fare Equity Analysis ………………………………………………………………….…………….……Page 62

11. Public Engagement for Major Service Change Policy…………………………………...Page 93

12. Title VI Policies……………………………………………………………………………….….…………Page 98 a. Major Service Change Policy b. Fare Equity Policy c. Disproportionate Burden Policy d. Disparate Impact Policy 13. Service Standard…………………………………………………………………………………………..Page 111

14. Demographic and Service Profile Maps and Charts………………………….………….Page 137 a. Base Map of Service Area a. Overlay of Census Tracts, Blocks, Traffic Analysis Zone (TAZ) b. Overlay of Transit Routes, Transit Centers, Garage, Major Activity Centers, Major Streets and Highways, etc.

15. Demographic Ridership and Travel Patterns………………………………….……………Page 153 a. Survey Analysis

16. Monitoring Program ……………………………………………………………………….………….Page 157

17. Board Awareness and Board Approval of Title VI Program……………….…………Page 170

Metro Transit – Title VI Plan 2013

Introduction

The Transit Authority of the City of Omaha, a political subdivision of the State of Nebraska d/b/a Metro is a direct recipient of Federal Transit Administration (FTA) financial assistance, a transit provider located in an Urbanized Area of 200,000 or more in population, and operates more than fifty vehicles in peak service.

Collectively the Metro Transit System includes 33 bus routes: 24 fixed (operating at various levels of service 7 days a week) and during weekday peak hours: 7 express/commuter and 2 downtown circulators. Additionally, Metro operates Americans with Disabilities Act (ADA) Complementary Paratransit (MOBY) service. The peak hour fleet includes 114 buses and 23 ADA vehicles. Title VI Notice to Public

Public Protections Under Title VI/Statement of Policy

Title VI of the Civil Rights Act of 1964, as amended, states 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.

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

Metro Transit – Title VI Plan 2013

Metro’s Notice to the Public informs the public on how to file a complaint or request additional information by calling 402-341-0800 (TDD 402-341-0807), emailing [email protected], visiting our administrative office at 2222 Cuming Street, Omaha, NE 68102, or connecting online at www.ometro.com.

Notice Postings

The following Title VI policy statement is posted in English and Spanish on the Metro website and in public areas of Metro’s headquarters.

Notifying the Public of Notificación al Público de los Rights Under Title VI Derechos Bajo el Título VI

The Transit Authority La Autoridad de Tránsito of the City of Omaha (Metro) de la ciudad de Omaha (Metro)

• The Transit Authority of the City of Omaha • La Autoridad de Tránsito de la ciudad de Omaha (Metro) operates its programs and services (Metro) opera sus programas y servicios sin distinción without regard to race, color, and national origin de raza, color, y origen nacional, de conformidad con in accordance with Title VI of the Civil Rights el Título VI del Acta de Derechos Civiles de 1964 Act of 1964 as amended. Any person who según enmendada. Cualquier persona que cree o que believes she or he has been aggrieved by any ha sido perjudicada por una práctica discriminatoria unlawful discriminatory practice under Title VI ilegal bajo el Título VI puede presentar una queja con may file a complaint with Metro. Metro.

• For more information on Metro’s civil rights • Para obtener más información sobre la programa de program, and the procedures to file a complaint, derechos civiles del Metro, así como los contact 402-341-0800, (TDD 402-341-0807); procedimientos para presentar una queja, email [email protected]; or visit our comuníquese con 402-341-0800 (TDD 402-341- administrative office at 2222 Cuming Street, 0807), por correo electrónico [email protected], o Omaha, NE 68102-4392. For more information, visite nuestra oficina administrativa en 2222 Cuming visit www.ometro.com Street, Omaha, NE 68102-4392. Para obtener más información, visite www.ometro.com • A complainant may file a complaint directly with the Federal Transit Administration by filing a • Un demandante puede presentar una queja complaint with the Office of Civil Rights, directamente con la Administración Federal de Attention: Title VI Program Coordinator, East Tránsito mediante la presentación de una queja ante la Building, 5th Floor-TCR, 1200 New Jersey Ave., Oficina de Derechos Civiles, Atención: Title VI SE, Washington, DC 20590 Program Coordinator, East Building, 5th Floor-TCR, 1200 New Jersey Ave, SE, Washington, DC. 20590 • If information is needed in another language, please contact 402-341-0800, ext. 2700. • Si se necesita información en otro idioma, por favor póngase en contacto con 402-341-0800, ext. 2700.

Metro Transit – Title VI Plan 2013

The condensed statement below is printed on all transit schedules and posted in each bus.

Title VI: Metro is committed to ensuring that no Título VI: Metro se compromete a garantizar que person is excluded from participation in or ninguna persona sea excluida de participar o denegar denied the benefits of its services on the basis of los beneficios de sus servicios sobre la base de raza, race, color, or national origin, as provided by color u origen nacional, conforme a lo dispuesto en Title VI of the Civil Rights Act of 1964 as el Título VI del Acta de Derechos Civiles de 1964 amended. To file a Title VI complaint or get según enmendada. Para presentar una queja del more information on your rights, call Título VI u obtener más información sobre sus 402.341.0800 TDD 402.341.0807. derechos, llame 402.341.0800 TDD 402.341.0807.

Filing a Title VI Complaint

Instructions and Procedures

Any person who believes she or he has been discriminated against on the basis of race, color, or national origin by Metro may file a Title VI complaint by completing and submitting Metro’s Title VI Complaint Form. Metro investigates complaints within 180 days after the alleged incident. Complaint forms must be complete with contact information and a signature. Forms may be submitted via email to [email protected] or by mail to:

Metro Transit Title VI Coordinator 2222 Cuming Street Omaha, NE 68102-4392

A copy of the Title VI Complaint Form is available for download at www.ometro.com.

A Title VI Complaint Form may also be obtained by calling 402-341-0800, (TDD 402-341-0807); by email at [email protected]; or by visiting Metro’s administrative office at 2222 Cuming Street, Omaha, NE 68102-4392. The next three pages contain a copy of Metro’s Title VI Complaint Form.

Metro Transit – Title VI Plan 2013

Complaint Assistance

 Should a Complainant be unable or incapable of providing a written statement, a verbal complaint of discrimination may be made to the Title VI Coordinator. Under these circumstances, the Complainant will be interviewed and the Title VI Coordinator will assist the Complainant in converting the verbal allegations to writing.

 Metro will also provide appropriate assistance to Complainants who are limited in their ability to communicate in English, e.g., language or sign interpreter.

 Metro assistance is available Monday – Friday 8:00 AM – 4:30 PM, excluding scheduled holidays. If a member of the general public requires assistance at a time or day other than those published, a mutually agreeable appointment will be scheduled.

Investigation Procedures

Once the complaint is received, Metro will review it to determine if Metro has jurisdiction over the incident. The complainant will receive an acknowledgement letter informing her/him whether the complaint will be investigated by Metro.

Metro has 60 days to investigate the complaint. If more information is needed to resolve the case, Metro may contact the complainant. The complainant has 30 business days from the date of the letter to send requested information to the investigator assigned to the case. If the investigator is not contacted by the complainant or does not receive the additional information within 30 business days, Metro can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case.

After the investigator reviews the complaint, she/he will issue one of two letters to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed. A Letter of Finding summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff member or other action will occur. If the complainant wishes to appeal the decision, she/he has 10 days after the

Metro Transit – Title VI Plan 2013 date of the Letter of Finding/Closure Letter to do so by contacting the Executive Director at 2222 Cuming Street, Omaha NE 68102.

Sample Complaint Form

A sample Complaint Form is contained on the next four pages. Additionally, this form is available in Spanish.

Metro Transit – Title VI Plan 2013

Title VI Complaints, Investigations and Lawsuits

Background

All recipients shall prepare and maintain a list of any of the following that allege discrimination on the basis of race, color, or national origin:

 Active investigations conducted by FTA and entities other than FTA;  Lawsuits; and  Complaints naming the recipient.

Investigations, Lawsuits and Complaints

Metro is committed to ensuring that no person is excluded from participation in or denied the benefits of its services as provided for by Title VI of the Civil Rights Act of 1964 as amended. Metro maintains a list of any active investigations, lawsuits and complaints that allege discrimination on the basis of race, color, or national origin.

From 2009 to 2013, Metro did not receive any customer complaints or lawsuits alleging a Title VI violation. During this same period, Metro received (2) two Equal Employment Opportunity Commission (EEOC) complaints alleging race/color discrimination. The status of these (2) two complaints is shown in the following table. Alleged Charging Party Date Filed Agency Comments Discrimination

Shirdeen Davis- 10/6/2009 Race/Color Nebraska EEOC Finding: No Reese US EEOC reasonable cause

Jerry Collins 3/6/2013 Race/Color Nebraska EEOC Finding: No reasonable cause

Metro Transit – Title VI Plan 2013

Public Participation Plan

Background

Recipients must develop a Public Participation Plan (PPP), including information about outreach methods to engage minority and limited English proficient populations (LEP), as well as a summary of outreach efforts made since the last Title VI Program submission.

Metro supports and promotes a proactive and open approach in reaching out to the public for comments on proposed transit issues such as service or any fare changes, construction projects, technology upgrades, and other important decisions affecting the customer experience. Transparency in decision making and open lines of communication ensure that all members of the community have an opportunity to contribute to the process.

This document outlines the public involvement strategies for the general public as well as those strategies targeted towards minority and limited English proficient (LEP) populations, as well as efforts to engage other constituencies that are traditionally underrepresented and underserved. Underserved populations include, but are not limited to, persons with mental and physical challenges, seniors, low-income populations, and those with lower literacy skills.

Outreach Philosophy

Metro emphasizes involvement of the public in its planning process and seeks inclusive and collaborative citizen participation in decision making. It is Metro’s goal to make decisions about plans, projects, and service/fare changes only after providing opportunities for public comment and analyzing any feedback received. All views should be heard and as such Metro conducts proactive and open ongoing outreach as well as project or proposal specific outreach.

Metro Transit – Title VI Plan 2013

Early, Continuous, and Meaningful Public Engagement

Efforts are made on a regular basis to maintain clear, continues and meaningful lines of communication between Metro and the local community. With the service area both dynamic and diverse, Metro’s engagement of public in transit planning and development is the forefront of being a responsive operation.

Open and continuous communication is vital to maintain strong working relationships with area stakeholders and intermediary groups who facilitate participation by LEP, minority, and other underserved groups. Stakeholders and intermediary groups include community and advocacy groups, social service and health agencies, major employers, schools, community colleges/universities, interested persons and local leaders. Communication with these stakeholders ensures that Metro remains cognizant of the issues, needs, and priorities of LEP, minority, and the underserved population in the community and is also vital in encouraging the participation of LEP, minority and other underserved groups. A representative sample of those groups is listed at the end of this section.

In addition to engaging community groups, Metro solicits continuous feedback from the general public. Comments can be submitted at any time through the Metro website, by phone through a customer service agent or other staff member, or by mail to Metro’s headquarters. Metro’s website, which features the Google language translator, is updated regularly with information and projects in order to encourage public comment. Metro has also added a text line to receive customer questions, complaints, and comments. When feasible, Metro also seeks information from current and prospective riders through on-board or online surveys.

However, just opening the participation process to the public is not enough. There are populations unlikely to become involved unless special efforts are made to reach out to them.

Metro Transit – Title VI Plan 2013

To reach out specifically to members of the affected LEP and/or minority communities, Metro identified community and advocacy groups serving large numbers of LEP and minority populations. Metro’s partnership with these groups assisted in developing strategies to engage their clients/members in becoming more involved with Metro’s public engagement activities. Examples of this is evidenced by Metro’s incorporation of strategies such as simplified messaging and visualization enhancements such as color graphs and maps in handouts and presentations. Additionally, Metro utilizes these resource agencies to help disseminate information about Metro’s services and the availability of special accommodations including language assistance in order to access Metro’s services. When available Metro publishes information and promotes engagement opportunities through newsletters, email groups, and community bulletins of the intermediary groups include those that serve minority, LEP, low- income and other special interest groups.

Intermediary Groups that work closely with minority and LEP individuals include:  Catholic Social Services  Lutheran Refugee Services  Southern Sudan Community Association  South Omaha Business Association  South Omaha Neighborhood Alliance  South Omaha Development Project  Department of Health and Human Services, Refugee Coordinator  Vietnamese Alliance Church of Omaha  Latino Center of the Midlands  Omaha Together One Community  Omaha Refugee Task Force  One World Health Center  International Center of the Heartland  Somali Bantu Association of Nebraska  Empowerment Network  Sudanese National Community  South Omaha Business Alliance  Chicano Awareness Center  Juan Diego Center

Metro Transit – Title VI Plan 2013

Metro seeks to maintain open dialogue with these organizations as well as conducts targeted outreach to them in conjunction with public participation efforts. A more inclusive public engagement contact list can be found at the end of the public participation plan.

Metro regularly participates in numerous cross-agency committees including the Coordinated Transit Committee hosted by the Metropolitan Area Planning Agency (MAPA). This committee develops the Coordinated Public Transit and Human Services plan and Metro’s active participation in this committee also provides an ongoing venue for feedback and representative stakeholder input.

Input is also sought through the citizens Technical Advisory Committee (TAC). TAC Members are appointed by the City of Omaha Mayor and Council Members, Metro Transit Board Members and the Mayors of Council Bluffs, IA, Bellevue, NE, Papillion, NE and LaVista, NE. TAC members must be bus riders and/or complementary paratransit clients. TAC has met continuously on the second Wednesday of the month, 12 months a year since the 1978. TAC is charged with addressing passenger comments, e.g., complaints, suggestions, compliments, etc. This includes being the first step on occasion in addressing Title VI complaints; final approval / disapproval of ADA certifications appeals. They also review all proposed service changes, fare structures and attend and assist at public hearings, community forums, etc. Additionally, Metro’s Board of Directors meetings are held monthly and in compliance with the “Open Meeting Laws” of Nebraska. The general populace is invited to attend and to provide input on matters under consideration by the Board.

Outreach Regarding Fare or Major Service Changes

When preparing for significant changes to Metro’s fare structure or transit service, it is vital to gather input from a broad range of sources and through a variety of methods. No singular means of outreach can effectively gather feedback from all perspectives. As such, Metro relies on traditional outreach methods such as public meetings as well as other non-traditional

Metro Transit – Title VI Plan 2013 outreach methods. Metro conducts outreach and seeks public input on service changes including those that are not significant enough to meet the ‘major service change’ threshold. Outreach and participation efforts are stressed with environmental justice communities in order to: 1. Ensure full and fair participation by all potentially affected communities; and 2. Avoid, minimize or mitigate disproportionately high and adverse effects on minority and low-income populations; and 3. Prevent the denial of, reduction of, or significant delay in receipt of transportation benefits by minority, LEP, low-income, and underseved populations.

Metro continually seeks to involve organizations and individuals that may have potential interest in proposed changes. Metro consults with organizations and agencies that serve environmental justice populations and seeks out populations who may be affected so that they may voice their opinion. Public input is documented, considered, and incorporated into the decision-making process.

Stakeholder Meetings

Metro seeks to capitalize on existing community resources to gather input and feedback on proposed changes. Metro often meets with stakeholders from public schools, universities, healthcare institutions, social service agencies, and other local groups to better understand community needs and seeks to include representatives of minority, low-income, and LEP populations in stakeholder meetings and committees. These community experts often have localized knowledge that can guide Metro staff when developing proposals for the general public.

Public Meetings

As the primary method of seeking community input, there is significant planning and preparation in advance of every public gathering. The following considerations assure that minority, LEP, individuals with disabilities, and low income populations can attend and actively participate in the decision making process.

Metro Transit – Title VI Plan 2013

Location: Scheduled in locations within transit access near the routes or communities affected by the proposed changes, with additional considerations for members of the population with limited accessibility, such as LEP, minority, underserved populations in North Omaha, South Omaha, and the Downtown area. All hosting facilities are fully ADA accessible and are familiar and convenient to the public, including the Metro headquarters, local libraries, community centers, social service organizations, or schools.

Time: Scheduled, at a minimum twice (preferably on two different days) during day time and evening hours to allow for varied work and school schedules. Start and end times are planned around the nearby transit schedules and hours of operation to facilitate participation for transit dependent individuals.

Publicity: Before public meetings are held, the following procedures shall be followed: a. Public meeting notices in both English and Spanish posted in major Transit Centers and the Metro Headquarters. b. Rider Alerts in both English and Spanish distributed on transit vehicles and published on the Metro website. c. Notice published in the following newspapers as appropriate:

Bellevue Leader Council Bluffs Nonpareil Douglas County Post-Gazette Nuestro Mundo Omaha Star Omaha World Herald Papillion Times Ralston Recorder d. Press releases sent to the news media. e. All meeting announcements shall inform the public of the availability of oral / sign language interpretation, large format handouts and other special needs assistance upon 48 hour request in advance. f. Intermediary and stakeholder groups including those that frequently work with traditionally underrepresented populatins including minorities, low-income, LEP, senior, and individuals with disabilities, are contacted in order to disseminate information about the meetings and are asked to encourage participation.

Metro Transit – Title VI Plan 2013

Format: Public meetings follow an informal structure to allow for dialogue, comments, and questions throughout the meeting. Key elements are presented visually through paper handouts, large print display boards, and/or electronic projection. Attendees are free to participate according to their comfort level, and comments can be submitted verbally or in print at the time of the meeting, and may also be submitted by mail or online for at least a 10 day period following the last meeting.

Bilingual staff members are in attendance for Spanish translation assistance. Metro also seeks to accommodate lower literacy skills through clear and concise language to the greatest degree possible. Special accommodations are available upon advanced request, such as sign language, translation to other languages, or special seating for the hearing impaired.

Resources: Following the meetings, key documents and other presentation materials are made available on the Metro website or in print at Metro’s Headquarters. Additionally, comments may be received by phone, online, or by mail for at least 10 days following the last public meeting.

Non-Traditional Outreach

Metro understands that while necessary and effective, public meetings do not always provide the most convenient method of outreach to all members of the community. As such, Metro seeks to utilize existing networks such as regularly scheduled meetings of neighborhood associations, civic advisory councils, and local business, advocacy, or special interest groups. Special effort is made to reach out to minority, LEP, and other underserved populations through non-traditional outreach that may include attending existing regularly scheduled meetings, soliciting feedback through intermediary groups, special outreach to gather information about travel patterns and needs such as interviews and surveys, and publication in newsletters and other formats in English and other languages as appropriate. Hosting mobile workshops at community events has been another effective means of public outreach to create awareness.

Social Media is increasingly used and Metro has added Quick Response (“QR”) Code access to published / posted information. Metro continues to explore a higher use of digital media such as Facebook, Mindmixer (commonly called an “online town hall meeting”), or texting as a convenient supplement to traditional outreach measures.

Metro Transit – Title VI Plan 2013

Public Participation in Recent Planning Activities

The following is a list of all public involvement initiatives conducted by Metro since the previous Title VI Program submission.

Early, Continuous, and Meaningful Public Engagement

Metro has continued to work closely with many local organizations, community groups, and civic departments to stay current on pertinent local issues. Staff members have participated in regular cross-agency committee meetings, planning studies, and community workshops. From large format presentations at regional conferences to one-on-one meetings with local leaders, Metro has maintained open communication with the community. Monthly Board meetings, corporate “lunch and learn” sessions, and bike rack demonstrations at community events are all examples of ongoing efforts to increase public participation. Metro staff is continually seeking new ways to engage the public including minority and LEP populations and ensure a high level of involvement with the local community.

In August of 2010, Metro launched a new website as part of a corporate rebranding process. Features included enhanced language translation capabilities, a simplified process for viewing rider alerts and other information, an improved comment submission tool, and a more user- friendly interface compatible with mobile devices. In addition to the website, Metro continues to communicate with passengers through bilingual messaging such as rider alerts and other print materials distributed on buses, postings in transit centers, and by phone through Metro’s customer service department. All essential documents are provided in both English and Spanish.

Passenger Surveys

Metro conducted several on-board surveys during the review period to gather information on rider demographics, travel patterns, customer satisfaction, unmet transportation needs, and other useful feedback.

Metro Transit – Title VI Plan 2013

A spring 2011 survey of Express riders gathered detailed travel information from 258 passengers, including one visually impaired passenger, one LEP passenger, and two passengers with reading difficulty (in each case, surveys were conducted verbally and recorded by the surveyor). Origin, boarding, alighting, and destination locations were requested, as well as work hours, frequency of use, method of arrival at bus stop (ex. Park & Ride), satisfaction with service, and other comments. Responses were used for general service planning. In conjunction with the Central Omaha Transit Alternatives Analysis (February 2012 – Current), Metro conducted an on-board transit passenger survey in October 2012 that gathered information about passengers and their one-way transit trips across the entire Metro network of local and express bus routes. Metro collected 4,391 surveys during the weekdays and 2,110 weekend surveys. The surveys were available in English and Spanish and offered to all passengers on selected trips distributed across the system as a self-administered survey. Surveyors assisted passengers with the completion of the survey as requested. The information was gathered for use in service planning, market analysis, travel demand modeling, regional visioning, and other outreach efforts.

In the summer of 2013, a self-administered survey was distributed on all local and express routes to measure the effectiveness of the Ozone Awareness Reduced Bus Fare Campaign. Surveys were available in both English and Spanish, and over 1,000 completed surveys were returned. Responses will be used to plan for future Ozone Awareness Campaigns.

Outreach for Service and Fare Changes

Although no service changes during the review period met Metro’s Major Change threshold, staff worked with stakeholders, community groups, and local agencies to publicize several service changes and one modest fare adjustment.

Council Bluffs Service Change

The City of Council Bluffs, Iowa, restructured the five local routes operated by contract with Metro in the spring of 2011. Metro staff coordinated with a consulting team hired by the City

Metro Transit – Title VI Plan 2013 of Council Bluffs to develop a fiscally constrained transit plan based on input from bus drivers, stakeholder interviews, on-board rider surveys, online surveys, two public meetings, and extensive field work throughout the community including stakeholder meetings which included community and advocacy groups serving LEP and minority populations. These groups included the American Red Cross, Boys & Girls Clubs, Micah House, Heartland Family Services, Visiting Nurses Association, Salvation Army, and Chicano Awareness. All meetings were widely advertised in English and Spanish with notification given of the availability of oral / sign language interpretation, large format handouts and other special needs assistance upon 48 hour request. Broadcast and print media included Spanish speaking stations and newspaper. English and Spanish Rider Alerts were distributed on all buses and complementary Paratransit services and posted at transit centers.

2012 Fare Adjustment

A modest fare adjustment was implemented on January 1, 2012, the first increase in 11 years. An equity analysis revealed no disparate impact or disproportionate burden to protected populations. Three public hearings were conducted in November of 2011, publicized in the Omaha World Herald and Omaha Star Newspapers, as well as TV stations KETV, WOWT, and Fox News. Information was posted at transit centers and also distributed to passengers through Rider Alerts on all bus routes in English and Spanish. A total of 40 comments were received regarding the change. Prior to and during the public engagement process, stakeholder meetings were held and included community and advocacy groups serving LEP and minority populations including outreach to the Department of Health and Human Services, Refugee Coordinator, Vietnamese Alliance Church of Omaha, Latino Center of Midlands, Omaha Together One Community, Omaha Refugee Task Force, One World Health Center, International Center of the Heartland, Somali Bantu Association of Nebraska, South Omaha Development Project, South Omaha Business Alliance, Sudanese National Community of Nebraska, United Way of the Midlands, and Empowerment Omaha.

Metro Transit – Title VI Plan 2013

All meetings were widely advertised in English and Spanish with notification given of the availability of oral / sign language interpretation, large format handouts and other special assistance upon 48 hours request. English and Spanish rider alerts were distributed on all buses and complementary Paratransit services and bilingual notices were posted at all transit centers.

Bellevue Service Change

A public hearing was held by the Bellevue City Council on January 28, 2013, to consider the elimination of route 48 serving Bryan Middle and High Schools. As a result, route 48 (operated by contract with the City of Bellevue) was voted by the Bellevue City Council to be discontinued effective June 1, 2013. While an equity analysis identified no LEP or minority populations were affected by the elimination of Route 48, stakeholder meetings with community and advocacy groups serving LEP and minority populations were conducted to review the proposed route elimination. These groups included the Stephen Center, One World Community Health Center, John L. Hoich Recovery Center, LaFern Williams South Omaha YMCA, Salvation Army Kroc Center, Christie Heights Community Center, Boys and Girls Club of the Midlands, Girls, Inc. Metropolitan Community College, South Omaha Campus, Omaha Public Library, Latino Center of the Midlands, Juan Diego Center, and Catholic Charities.

These community groups distributed information in English and Spanish to their clients/members and encouraged comments on the proposed route elimination. Additionally, meetings were held with Bryan Middle and High School counselors and English as Second Language (ESL) instructors to further encourage participation at the public hearing. Bilingual rider alerts were distributed by Metro advising passengers of the hearing date and comment process, as well as a separate bilingual alert announcing the outcome of the hearing. Metro staff received two customer comments by phone to retain the service, both of which were noted and forwarded to staff at the City of Bellevue.

Metro Transit – Title VI Plan 2013

Outreach through Planning Studies

Metro is currently working on two planning studies that have ongoing public participation components. The Alternatives Analysis (AA) is a partnership between Metro and the City of Omaha that is evaluating options for a higher level of service including enhanced bus, Bus Rapid Transit, and streetcar. This process includes four large public meetings at various stages throughout the study which allow the public to comment on proposed technologies, alignments, evaluation metrics, and the results of the comparative evaluation of alternatives. Public feedback plays an important role in shaping the direction of this project. In addition to public meetings, the AA hosts an online town hall that provides an ongoing and interactive discussion between Metro, the City of Omaha, and the public. To date, over 450 comments or suggestions on the study have been received. In addition to the general public, the plan also engages community stakeholders and leaders through a project management team and stakeholder team to provide input from community and civic leaders. The stakeholder team includes representatives serving LEP and minority populations. All meetings were widely advertised in English and Spanish newspapers with notification given of the availability of oral / sign language interpretation, large format handouts, and other special needs assistance upon 48 hour request. English and Spanish rider alerts were distributed on all buses and complementary Paratransit vehicles and were posted at transit centers.

Metro is also engaged in a Regional Transit Vision (RTV), a technical study, through a partnership between Metro and the Metropolitan Area Planning Agency (MAPA). This study involves a Comprehensive Operations Analysis (COA) regarding Metro’s service as well as the creation of vision scenarios for future growth including the study of developing a regional transit authority. Key stakeholders that are actively involved in shaping the project include activists, social service providers, employers, elected officials, city staff, the chamber of commerce, Department of Health, Department of Housing, nonprofit staff members and members of the community at large. The aforementioned includes representatives serving LEP and minority populations. This involvement is through regular stakeholder meetings and smaller focus area meetings. The RTV will be incorporated into MAPA’s Heartland 2050 study 22

Metro Transit – Title VI Plan 2013 which will involve future extensive public outreach that will include the RTV proposed vision scenarios in conjunction with proposed development scenarios.

For each of these studies, Metro has also provided updates to the Board of Directors and general public at Metro board meetings. These updates were scheduled as agenda items and publicized for the general public in the Omaha World Herald.

Outreach Regarding Construction Projects

In 2012 Metro began a construction project to renovate the 15 year old North Omaha Transit Center (NOTC) located at 4308 N. 30th Street. Prior to initiating construction, Metro staff conducted outreach on the proposed design and functionality of the renovated facility as well as on any potential inconveniences to the public related to construction.

A public meeting was held on August 22, 2012 at the Northeast Precinct Station of the Omaha Police Department. The meeting was hosted as an open house and invited comment on the proposed redesign of the center. The meeting was publicized through the Omaha Star newspaper, a minority woman owned and operated publication that is primarily distributed within the North Omaha community, Metro’s website, and bilingual rider alerts. The open house included large format displays of the proposed design. Images and a description of the proposed redesign were also posted on Metro’s website. Metro accepted comments via mail, fax, and Metro’s website. Only one comment was received which was related to the placement of the passenger waiting shelter. Metro opened a temporary transit center across the street from NOTC during construction. This change was communicated to passengers via rider alerts in advance of the change and posted on Metro’s website. Letters were also mailed to nearby property owners and current residents inviting comments on both the proposed redesign and any issues related to construction. Contact information for the project manager was provided to residents for any issues or inconveniences related to the construction process.

Metro Transit – Title VI Plan 2013

Metro continues to communicate with the public regarding the status of this project with photos and updates posted regularly to Metro’s website.

Metro Transit – Title VI Plan 2013

Public Engagement Contact List

Activate Omaha American Red Cross Bellevue Human Services Department Black Men United Boys & Girls Clubs Catholic Charities Chicano Awareness Center City of Bellevue, NE City of Council Bluffs, IA City of La Vista, NE City of Omaha, NE City of Papillion, NE City of Ralston, NE Chicano Awareness Center Community Alliance Community Centers Council Bluffs Chamber of Commerce Council Bluffs Special Transit Department of Health and Human Services Disabled American Veterans Douglas County Housing Authority Easter Seals Eastern Nebraska Human Services Agency Eastern Nebraska Office on Aging Empowerment Network Encore Family Housing Services, Inc. Goodwill Industries Greater Omaha of Commerce Greater Omaha Community Action Greater Omaha Workforce Development Greater Omaha Young Professionals Green Omaha Coalition Habitat Omaha Heartland Family Services Heartland Hope Mission International Center of the Heartland Iowa Department of Transportation Iowa West Foundation Juan Diego Center Latino Center of the Midlands

Metro Transit – Title VI Plan 2013

League of Human Dignity Lutheran Family Services Madonna School Mayor’s Commission for Citizens with Disabilities Metropolitan Area Planning Agency Metropolitan Community College Micah House Millard Good Samaritan Center ModeShift Omaha Mosaic Omaha Nebraska Department of Roads Nebraska Health & Human Services Nebraska Statewide Independent Living Council Nebraska Workforce Development Neighborhood Center for Greater Omaha Omaha Association of the Blind Omaha by Design Omaha Housing Authority Omaha Opportunities Industrialization Center Omaha Public Libraries Omaha Public Schools Omaha Refugee Task Force Omaha Together One Community Open Door Mission Paralyzed Veterans of America Salvation Army Siena Francis House Somali Bantu Association of Nebraska South Omaha Business Association South Omaha Development Project through the Chamber of Commerce South Omaha Neighborhood Alliance Southern Sudanese Community Association Southwest Iowa Transit Authority Stephen Center Sudanese National Community of Nebraska United Way of the Midlands University of Nebraska Medical Center University of Nebraska - Omaha Urban League of Nebraska Veterans Administration Veterans Hospital Vietnamese Alliance Church of Omaha Visiting Nurses Association

Metro Transit – Title VI Plan 2013

Vocational Rehabilitation Workforce Development YMCA

Metro has participated in and provided information in the following types of outreach events since its last Title VI submission:

• Farmer Markets • School registration days • Employer sponsored job, transit, and health fairs • Community events, such as parades and street parties  Mobile Workshops • School presentations • Coordinators on buses and at transit hubs • Take One brochures • Car Cards inside buses • Web postings  On-Board Surveys • Media press releases • Senior housing presentations • Mass mailings to targeted audiences • Local radio announcements • Print advertisements and notices • Television commercials • Community meetings (e.g. Chamber of Commerce)

Metro Transit – Title VI Plan 2013

Language Assistance Plan

Introduction

This Language Assistance Plan (LAP) is one component of Metro’s efforts to provide an appropriate level of language assistance to meet the needs of individuals within Metro’s service area who are “limited English proficient”. Limited English proficient (LEP) individuals are those who have limited ability to read, write, speak, or understand English. The plan includes a summary of language assistance measures currently provided by Metro transit and additional measures proposed for the future. Background

Title VI of the Civil Rights Act of 1964, as amended, 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. Title VI regulations have been interpreted to hold that Title VI prohibits actions that have a disproportionate effect on LEP persons because such conduct constitutes a form of national origin discrimination. Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency” directs each federal agency to examine the services it provides and implement a system by which LEP persons can meaningfully access those services, and to publish guidance for their respective recipients to assist them in meeting their obligations to LEP persons under Title VI.

Metro has prepared this LAP using the “Four-Factor Framework” outlined in the U.S. Department of Transportation’s Policy Guidance.

Metro Transit – Title VI Plan 2013

Analysis using the Four-Factor Framework

Task 1: The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient

Task 1, Step 1: Examine prior experiences with LEP individuals.

Customer Service

Metro interviewed customer service staff, the receptionist for the administrative facility, and the MOBY (Paratransit) certification staff and found that the only interactions with LEP individuals have been in Spanish. Phone calls are transferred to a Spanish speaking employee. A very small number of LEP individuals who speak languages other than Spanish have asked for information in person, but have been accompanied by translators who speak English. Customer service staff documented phone calls from LEP individuals and noted the languages requested over a two week period. During this period, no calls were received in languages other than English. The most common questions asked by LEP individuals are regarding MOBY (ADA Complementary Paratransit service), bus schedule and route information, and fare payment.

Public Meetings

Metro has bilingual Spanish speaking staff attend public meetings and hearings. To date, utilization of Spanish speaking interpretation has been extremely limited. Metro has not received any requests for translation services at public meetings for other languages.

On-Board Survey

Metro conducted an onboard survey in October 2012 that was offered in both English and Spanish. 1.6% of the responses were in Spanish. Of these, the majority of the Spanish surveys were completed on routes 32, 7, 34, 11 and 9.

Metro Transit – Title VI Plan 2013

Task 1, Step 2A: Identify the geographic boundaries of the area your agency serves.

Metro’s service area: As can be seen in Map 1, Metro’s service area is located primarily within the City of Omaha. Service beyond the limits of the City of Omaha is limited and comprised of contracted ‘turn-key’ service that is planned and paid for by other jurisdictions, but operated by Metro. As such, the service area does have limited extent beyond the city limits. For the purposes of this language assistance plan and the four factor analysis, Metro analyzed demographic data from the service area outlined below in Map 1.

Map 1: Base Map Showing Metro Service Area in Blue Outline

Metro Transit – Title VI Plan 2013

Task 1, Step 2B: Obtain Census data on LEP population in your service area.

476,674 people live in Metro’s service area. Of those 350,116 or 73% speak only English. 41,092 speak Spanish (or Spanish Creole) and 55% of those who speak Spanish, speak English less than “very well”. The cumulative total of all populations who do not speak English very well (except those who speak Spanish) is 8,271 persons or 1.7% of the population.

Table 1: Language Spoken at Home for Metro’s service area

Speak language Speak Spanish other than Total Population Speak English Speak Only and Speak Spanish and in Metro’s Less than very English English less than Speak English service area Well Very Well less than Very Well 476,674 350,116 30,750 22,479 8,271 Source: 2008-2012 American Community Survey, U.S. Census

Table 2: Top Ten languages Spoken at home in Metro’s service area Metro Language Service Area English Only 350,116 Spanish 41,092 Other African languages 3,060 Other Asian languages 2,507 French 1,951 Vietnamese 1,229 Chinese 1,159 German 1,157 Arabic 935 Italian 856 Source: 2008-2012 American Community Survey, U.S. Census

Metro Transit – Title VI Plan 2013

Table 3: All Residents 5 Years and Older Speaking English “Less Than Very Well”

Metro Language Spoken Service Area Estimate Spanish or Spanish Creole 22,479 Other Asian language 1,586 Other African language 1,335 Vietnamese 845 French 797 Chinese 699 Other Indic 591 Arabic 454 Italian 208 Japanese 172 Urdu 171 Russian 169 Korean 168 Thai 131 Hindi 122 Tagalog 107 German 97 Other Native American 88 Other Indo-European 71 Persian 54 Polish 53 Serbo-Croatian 50 Gujarati 50 Greek 46 Portuguese 43 Other (unspecified) 39 Mon Khmer Cambodian 30 Scandinavian 29 Other Pacific Islander 24 Other Slavic 22 Yiddish 20 Source: 2008-2012 American Community Survey, U.S. Census

Metro Transit – Title VI Plan 2013

Task 1, Step 2C: Analyze the data you have collected.

As seen in Table 3, the top four (4) languages in the service area with persons who speak English less than very well are Spanish, other Asian languages, other African languages, and Vietnamese. Metro analyzed census date for each of these four languages/language categories.

Spanish:

The 2008-2012 American Community Survey data (ACS) identified 41,092 individuals in Metro’s service area who speak Spanish, of these 22,479 speak English less than very well.

Other Asian Languages:

The U.S. Census aggregates thirty-one (31) languages in the category of “Other Asian Languages”. The 2008-2012 American Community Survey data identified 2,507 individuals in Metro’s service area who speak other Asian Languages, of these 1,586 speak English less than very well.

African Languages:

The U.S. Census aggregates twenty (20) languages in the category of “African Languages”. The 2008-2012 American Community Survey data identified 3,060 individuals in Metro’s service area who speak African languages, of these 1,135 speak English less than very well.

Vietnamese:

The 2008-2012 American Community Survey data identified 1,229 individuals within the service area who speak Vietnamese, of these 845 speak English less than very well. As seen on the map in Task 1, Step 2D, additional Vietnamese speaking individuals live in the urbanized area outside of Metro’s service area, primarily to the southwest of the City of Omaha including in the Cities of Bellevue, La Vista and Gretna.

Metro Transit – Title VI Plan 2013

Task 1, Step 2D: Identify any concentrations of LEP persons within your service area.

Metro identified concentrations of LEP persons within the service area for each of the four most common languages/language categories: Spanish, other Asian languages, other African languages, and Vietnamese.

Spanish:

Map 2 shows the distribution of Spanish speakers who speak English less than very well. As seen on the map and verified through input from community organizations, Spanish speaking persons can be found throughout the City of Omaha and Omaha-Council Bluffs UZA, but are concentrated primarily in South Omaha. In particular, high concentrations of Spanish Speaking population are centered near South 24th Street, south of downtown within Metro’s service area.

Metro Transit – Title VI Plan 2013

Map 2: Distribution of Spanish Speaking Individuals who Speak English Less than Very Well

Other Asian Languages:

Individuals who speak other Asian languages are dispersed throughout the City of Omaha and Metro’s service area. No large concentrations of individuals speaking other Asian languages within Metro’s service area have been identified through census data or consultation with intermediary groups.

African Languages:

Individuals who speak African languages are dispersed throughout the City of Omaha and urbanized area. 3,060 individuals in Metro’s service area speak other African languages at home, but 1,725 or 56% of them speak English very well. 1,335 individuals who speak African languages and speak English less than very well are located within Metro’s service area. Research with community organizations and individuals reveals that many of these LEP individuals are refugees that are placed in housing through refugee resettlement programs. In many cases, these housing units are located in small clusters of several families within the same

Metro Transit – Title VI Plan 2013 area, but dispersed throughout the City and service area without large concentrations in any one area. The refugee resettlement programs provide many opportunities to learn English as a second language and provide translation service which is evidenced by the high percentage of individuals who speak an African language at home, but speak English very well.

Vietnamese:

Map 3 shows the distribution of Vietnamese speakers who speak English less than very well. As previously noted in Task 1, Step 2C and shown on Map 3, many of the Vietnamese speaking individuals within the Omaha Council Bluffs UZA are located to the west and southwest of the City of Omaha and reside outside Metro’s service area.

Map 3: Distribution of Vietnamese Speaking Individuals who Speak English Less than Very Well

Metro Transit – Title VI Plan 2013

Task 1, Step 3: Consult state and local sources of data

Local sources of data on LEP persons in the Metro service area include statistics from the Omaha Public School District (OPS) as well as information regarding refugee resettlement in the area. The exact number of LEP refugees in Omaha is unknown, but the U.S. Department of Health and Human Services Office of Refugee Resettlement estimates that 738 refugees settled directly in Nebraska in 2011 (Note: not all of these refugees have settled in Omaha). Of these 738 refugees to Nebraska, the largest group of refugees in 2011 was 427 from Burma.

Refugees in Omaha and Nebraska come from a number of countries including, but not limited to Southern Sudan, Afghanistan, Bhutan, Burma, Burundi, Congo, Kenya, Rwanda, Tanzania, Ethiopia, Iraq, Iran, Liberia, Somalia and Sudan.

Table 4: OPS Data on Home Language of Students

Total % of Non-English Languages Speakers Speakers Spanish 11,727 80.5% Karen/Karenni/Chin 840 5.8% Nuer 375 2.6% Somali (includes Maay- 355 2.4% Maay) Arabic 169 1.2% Other Languages 1,107 7.6% Students with Home Language other than 14,573 100% English Count of Languages 96

Source: OPS District English Language Learner/Refugee Report, 2012-13

Spanish:

OPS data confirms that Spanish speakers make up the largest percentage of LEP individuals in the area. The “District English Language Learner/Refugee Report, 2012-13” shows that 80.5% of the ESL students in the district speak Spanish which is consistent with the 2008-2012

Metro Transit – Title VI Plan 2013

American Community Survey findings that show that Spanish speakers constitute 73.1% of LEP individuals in Metro’s service area.

Other Asian Languages:

OPS data in the “District English Language Learner/Refugee Report, 2012-13” shows enrollment from students speaking Turkish, Mongolian, Telegu, Tamil, Kannada, Malayalam, Dzongkha, Burmese, Karen, and Kachin, all of which are classified in the Census Data as “Other Asian Languages”. Of these, the most commonly used language within OPS is Karen with 840 students who speak Karen at home. Data is not readily available on how many of these Karen speakers also speak English. Additionally, OPS reports students classified as refugees from Bhutan and Myanmar (Burma).

To date, Metro has not received any requests for translation to Karen. Furthermore, it is noteworthy that the Karen languages are comprised of at least eighteen (18) languages including Sgaw and Pwo that are mutually unintelligible. Many other Karen languages do not have a written form.

Metro will continue to monitor Asian languages and especially Karen for increased usage in the Omaha urbanized area, but to date has not identified any written language classified as “Other Asian Languages” that exceeds 1,000 persons.

African Languages:

OPS data in the “District English Language Learner/Refugee Report, 2012-13” shows enrollment from students speaking Amharic, Dinka, Nuer, Nilo-sharan, Swahili, Somali, Igbo, Burun, and Yoruba, all of which are classified in the Census data as “African Languages”. Of these, the most commonly used languages within the OPS district are Nuer and Somali, neither of which had greater than 375 students enrolled in the district. Additionally, OPS reports refuge students

Metro Transit – Title VI Plan 2013 from Burundi, Congo, Ethiopia, Kenya, Rwanda, Somalia, Sudan, and the United Republic of Tanzania.

Applying the distribution of languages classified as African languages from the OPS data to the 1,335 individuals who speak other African languages and speak English less than very well identified in Metro’s service area from the 2008-2012 American Community Survey data, there are no African languages in the Omaha urbanized area that exceed 1,000 persons who speak English less than very well.

Vietnamese:

OPS data in the “District English Language Learner/Refugee Report, 2012-13” shows that 111 students in the Omaha Public School District speak Vietnamese at home.

Table 5: Vietnamese Speakers

Vietnamese, Speak English Less than Very Well Speak Vietnamese Census Data (Metro Service area) At Home, OPS Data 845 111 Source: 2008-2012 American Community Survey, U.S. Census and OPS District English Language Learner/Refugee Report, 2012-13

Task 1, Step 4A: Identify community organizations.

Community organizations and social service agencies serving large numbers of LEP individuals were identified and include, but are not limited to:  Catholic Social Services  Lutheran Refugee Services  Southern Sudan Community Association  South Omaha Business Association  South Omaha Neighborhood Alliance  Department of Health and Human Services, Refugee Coordinator  Vietnamese Alliance Church of Omaha  Latino Center of the Midlands  Omaha Together One Community 39

Metro Transit – Title VI Plan 2013

 Omaha Refugee Task Force  One World Health Center  International Center of the Heartland  Somali Bantu Association of Nebraska

Task 1, Step 4B: Contact relevant community organizations.

Organizations and agencies to be contacted were prioritized based on their apparent level of involvement with LEP individuals. Staff members at representative community organizations were contacted via phone or an in-person interview.

Task 1, Step 4C: Obtain information.

Client Population Characteristics Organizations working with Spanish speaking individuals indicated that there is a variance in English proficiency among their clients. Additionally, there are varied literacy levels with some Spanish speaking individuals unable to read or write in Spanish. Catholic Charities indicated that they encountered a high written literacy among their Spanish speaking clientele while the Latino Center for the Midlands reported a lower literacy rate among their clients. Catholic Charities also indicated that less than 50% of the population they serve is able to speak English.

Organizations working with refugee populations indicated that very few refugees speak English and that the majority are illiterate in their written native languages. Of the 200 Sudanese dialects the most common are Arabic, Nuer, Dinka, and Luo.

Travel Needs Many of the organizations indicated that their clientele does not have enough money for bus fare and requires more information about the destinations served and timetables. Refugee LEP populations face additional challenges in needing travel training in order to learn how to utilize the bus. The Southern Sudanese Community Association and Lutheran Family Services provide this training to their clients. A major issue for refugee LEP populations is the service availability. The majority of refugees are employed in hospitals and production plants on either the second

Metro Transit – Title VI Plan 2013 or third shift. The second shift generally ends around 10 or 11pm which is the beginning of the third shift and outside of Metro’s service hours. Additionally, Metro service does not always extend to the production plants that employ their clients. The Southern Sudanese Community Association tries to place clients in the same neighborhoods in order to facilitate carpooling opportunities. Many of the contacted organizations suggested communicating with their clients through them with schedules, flyers, posters and other sources of information.

Task 2: Determine the frequency with which LEP persons come into contact with the program

Task 2, Step 1: Review the relevant programs, activities, and services you provide

Metro assessed the frequency with which LEP persons come in contact with Metro’s programs, activities and services. Frequencies of contact with LEP individuals for the avenues have been identified on an order of magnitude scale as frequently (daily), often (weekly), occasionally (monthly), and rarely (less than monthly). Avenue of Contact Frequency Drivers Occasionally Customer Service Phone Line Occasionally MOBY Paratransit Reservationists Occasionally On-Street Signage Frequently Website Occasionally Interior fare cards Frequently Receptionist Rarely MOBY Certification Rarely Print media Occasionally Transit Fairs Occasionally

Task 2, Step 2: Review information obtained from community organizations

As discussed in Task 1, Step 4, staff of community organizations and social service agencies reported that limited numbers of their clients use transit. However, in general, respondents did not have detailed knowledge of which routes are most heavily used, or the frequency with which transit services are used. Spanish speaking LEP individuals are the most likely to use

Metro Transit – Title VI Plan 2013

Metro service as community organizations serving refugees indicated that a few of their clients use transit but that many carpool and are employed in third shift work that is outside of Metro’s service hours.

Task 2, Step 3: Consult directly with LEP persons

Metro monitors the frequency with which LEP persons come in contact with the program through calls to customer service, passengers on the bus, attendance at public meetings, and walk-in individuals to the administrative facility. Metro interacts with Spanish speaking individuals and provides verbal and written translation services in Spanish. To date, Metro has not received a request for translation to Vietnamese, Nuer, Somali or Karen.

On Metro’s 2012 on-board survey weekday responses from Spanish respondents indicated:

Trip Purpose:

Number of Responses Work 56 Medical 10 School 2 College 2 Personal 7 Shopping 7 Other 4

Metro Transit – Title VI Plan 2013

Frequency:

Number of Responses 6 or 7 days per week 21 5 days per week 22 3 or 4 days per week 4 1 or 2 days per week 2 1 or 2 days per month 2 Less than once per 1 month First Time 0

How long riding Metro:

Number of Responses Less than 6 14 months 6 to 12 months 8 1 to 2 years 9 3 to 5 years 11 More than 5 years 13

If bus service was not available, how trip would be completed:

Number of Responses Drive 2 Bicycle 6 Taxi 6 Walk/Wheelchair/ 12 Other Device Ride with Someone 16 Else Would not Make Trip 11

Metro Transit – Title VI Plan 2013

Fare Payment:

Number of Responses Cash 46 10 Ride Card 5 30 Day Pass 2 University Pass 3 One Ride with Transfer 1 Card

Task 3: The nature and importance of the program, activity or service provided by the program to people’s lives

Task 3, Step 1: Identify your agency’s most critical services

Public transportation provides a vital service allowing passengers to access jobs, medical facilities, shopping, and other necessary programs. Although public transportation does not traditionally provide life-saving or emergency type access to medical services (such as an ambulance), Metro considers its services to be extremely important and believes, as such, that it is important to facilitate usage by all including those who speak English less than very well.

Critical services are defined by the DOT guidance as programs or activities that would have serious consequences for individuals if language barriers prevent a person from benefiting from the activity. Serious consequences could include the inability of an LEP individual to effectively utilize public transportation to obtain health care, education, or access to employment. Critical services provided by Metro include:

 Route and Schedule Information  Fare media information  System rules, particularly transfer rules  Information on how to ride the system  Safety and security announcements  Communication related to transit planning and service changes  Information on ADA Paratransit services  Non-discrimination (Title VI) policy

Metro Transit – Title VI Plan 2013

Task 3, Step 2: Review input from community organizations and LEP persons

Input suggests that route, schedule, MOBY (Paratransit) certification, and fare information is the most vital information needed by LEP individuals. Additionally, refugee individuals, in particular, desire information on how to ride the system.

Task 4: The resources available to the recipient for LEP outreach as well as the costs associated with that outreach

Task 4, Step 1: Inventory language assistance measures currently being provided, along with associated costs

Metro has approximately 13 staff members who speak Spanish. Metro provides written translation of vital documents including schedules in Spanish, offers customer service on the phone in Spanish, and provides Spanish translation at public meetings and hearings. Additional accommodations and language translation services at public meetings are available with advanced request. Metro provides translation of its website through Google Translate to a number of languages including, but not limited to, Spanish, Vietnamese, Tamil, Telegu, Kannada, and Swahili.

Additionally, Metro strives to present information in a format that is easily understandable by LEP individuals. These measures include simple formatting and verbiage for schedules and other sources of passenger information and the use of graphics whenever possible. All Metro bus stops feature the international bus symbol for ease of identification.

Metro front line staff is equipped with the U.S. Census language identification, I speak, card in order to identify additional language needs and telephone translation services to assist in translation as needed.

Task 4, Step 2: Determine what, if any, additional services are needed

Although Metro has not received requests for this service, Metro has identified a service for providing verbal customer service translation over the phone through three-way translation

Metro Transit – Title VI Plan 2013 service calls. Metro is also identifying partnerships with community organizations to provide additional information about its service through these community organization conduits to LEP individuals.

Task 4, Step 3: Analyze your budget

Metro translates documents to Spanish and provides verbal Spanish translation in house with staff and will continue to do so. Metro’s resources for additional translation services are extremely limited with only $5,000 budgeted in the 2013 budget for marketing and promotion including translation and printing.

Costs of Additional Services:

- Written translation costs through a professional translator for languages other than Spanish cost approximately $0.10 per word or $27 per page. - Live verbal translation over the phone is approximately $1.95-$5 per minute, depending on frequency of use and language

Task 4, Step 4: Consider cost-effective practices for providing language services

Cost-effective practices for providing language services that Metro has pursued or may pursue include:

 Partnering with community organizations to assist with translation or interpretation  Partnering with community organizations to assist with distribution of printed information to LEP individuals, or to provide educational or outreach opportunities to LEP individuals.  Live verbal translation service for customer service calls in languages other than English and Spanish.  Utilizing U.S. Census I Speak language identification cards for front line personnel  Providing Spanish translation at public meeting through in-house personnel  Translation of all vital documents to Spanish  Continuing to offer Google Translate on website

Metro Transit – Title VI Plan 2013

Results of Four Factor Analysis:

The Four Factor Analysis showed that approximately 6.4% of the population in Metro’s service area speaks English less than very well. Spanish is the most commonly used language other than English and is the only other language which exceeds 1,000 persons likely to be encountered or affected by Metro’s service. The Safe Harbor Provision stipulates that, if a recipient provides written translation of vital documents for each eligible LEP language group that constitutes five percent (5%) or 1,000 persons, whichever is less, of the total population of persons eligible to be served or likely to be affected or encountered, then such action will be considered strong evidence of compliance with the recipient’s written translation obligations. Continued translation and distribution of written vital documents in Spanish in order to satisfy this provision and ensure Metro’s services are accessible. Other languages that do not meet or exceed 1,000 persons in the service area include Vietnamese, Karan, Somali, and Nuer. Given the costs and limited resources available it is not prudent for Metro to invest in written translation to these languages. However, investing in three-way calling translation services and enhanced partnerships with community organizations in order to reach these individuals may be warranted.

Based on the outcome of the Four Factor Analysis, Metro’s Language Assistance plan includes a description of language assistance services provided; notice to LEP persons; a description of staff training; and the procedure for monitoring, evaluating and updating the Language Assistance Plan in order to ensure meaningful access for LEP individuals to Metro’s services.

Language Assistance Services Provided

As noted in the four-factor analysis, Metro provides:

 Translation of written vital documents in Spanish including but not limited to schedules, Title VI forms and notices, MOBY applications, and interior bus car cards regarding fares and passenger rules;  Verbal translation to Spanish for passenger calls;  Verbal translation to Spanish at public meetings and hearings;  Translation of website through Google translate;

Metro Transit – Title VI Plan 2013

 Simplified schedules, bus stop signs and other resources that utilize graphics when feasible;  Opportunity for advanced requests for other language services (including sign language) at public meetings;  Opportunity to accept comments, questions through a number of means including verbal, written, and electronic comments. The public comment period for proposed changes is extended as long as feasible in order to allow meaningful access for LEP persons. An extended comment period allows LEP individuals to seek clarification and/or assistance from Metro and other resources;  Availability of U.S. Census, I Speak, Language Identification Cards by front line staff; and  Availability of live language translation services through a phone service.

Additional services to be investigated for possible inclusion by Metro are:

 Enhanced partnerships with community organizations

Providing Notice to LEP Persons Regarding the Availability of Language Assistance

Metro publishes schedules; car cards regarding fares, Title VI, and passenger rules in the buses; MOBY applications; and other vital documents in English and Spanish.

Staff uses the U.S. Census, I Speak, Language Identification cards to identify other requested languages and can connect to telephone translation services for language requests that cannot be handled internally by staff. Furthermore, Metro will continue to develop relationships with community organizations in order to notify LEP persons about Metro’s services and the availability of language assistance.

Notices for all public hearings are published and disseminated through intermediary groups. Metro provides Spanish translation at public meetings and publishes the ability for others to request additional services such as translation to other languages with advance notice to Metro. Additionally, Metro accepts public comments through a number of avenues including verbal, written, and electronic means. A public comment period is established for all public hearings so that LEP individuals are given a meaningful opportunity to comment. A notice to the public regarding the availability of language assistance services is published in both English and Spanish and posted on the buses. Additionally, Metro’s Title VI Policy Statement which is

Metro Transit – Title VI Plan 2013 posted inside all Metro buses and on the website provides information on how to request information in additional languages. Intermediary partner organizations are also made aware of the availability of language assistance services provided by Metro.

Training

Metro will train front line staff, when they are hired, on how to help individuals who need language assistance. Training with front line staff will occur at least annually thereafter.

 A summary of responsibilities under the DOT LEP Guidance,  A summary of the Language Assistance Plan,  A description of the type of language assistance offered by Metro and instructions for accessing these services (including the I Speak Cards and telephone translation services), and  Strategies for working effectively with Limited English Proficient individuals and Spanish- speaking LEP individuals in particular.

Front line staff includes:

 Receptionist  Bus operators  Customer Service Staff  Transit Service Representatives  Paratransit Operators  Paratransit Eligibility Evaluators

In developing the training, Metro may make use of the training resources identified in the DOT LEP Guidance.

Monitoring, Updating, and Evaluating the Language Assistance Plan

At a minimum, the Language Assistance Plan will be evaluated and updated every three years to coincide with submittal of Metro’s Title VI Program to the Federal Transit Administration. Evaluating and updating the LAP will include review of updated census and American Community Survey data, discussions with Metro employees, collaboration with resource agencies who interact with LEP individuals, outreach, and review of survey data.

Metro Transit – Title VI Plan 2013

In the interim, monitoring activities may identify changes that should be made to the Language Assistance Plan. Monitoring activities will include evaluation of the following information:

 Needs identified by front line staff during employee training activities related to Limited English Proficiency or in the course of day-to-day operations of the system;  Needs identified by community partners or LEP individuals during outreach activities or other engagement with Metro staff; and  New data related to LEP populations in the service area.

If evaluation of new information received during monitoring of the plan leads to substantive changes in language assistance policies or practices, the Language Assistance Plan will be updated accordingly.

Metro Transit – Title VI Plan 2013

Minority Representation on Board of Directors and Technical Advisory Committee

Background

Recipients that have transit-related, non-elected planning boards, advisory councils or committees, or similar bodies, the membership of which is selected by the recipient, must provide a table depicting the membership of those committees broken down by race, and a description of efforts made to encourage the participation of minorities on such committees.

Metro Transit – Board of Directors

Metro is a political subdivision of the State of Nebraska having no affiliation with the City of Omaha except for the appointment of the Board of Directors (Board). The five-member Board is appointed by the Mayor of the City of Omaha with concurrence by the Omaha City Council and Douglas County Board of Commissioners. Board members serve a five-year term with member appointments staggered with no more than one annual appointment. Interested persons must request in writing to the Mayor their interest and qualifications for appointment to the Metro Board.

While Metro has no influence on board member selection, we urge the mayor, council members, and county commissioners to appoint members representing the minority and disabled community. In addition, we urge interested persons to apply for a Board appointment.

Metro Transit – Technical Advisory Committee (TAC)

TAC members are appointed by the Mayors of Omaha, Bellevue, Papillion, Ralston and LaVista, NE, Council Bluffs, IA and the members of the Omaha City Council and Metro Board.

Metro Transit – Title VI Plan 2013

Individually each has one appointment and while it’s not mandatory for an appointee to travel exclusively on Metro, it is preferable. TAC averages 13 to 15 members out of the maximum of 17.

TAC, established in 1978, has met continuously on the second Wednesday of the month. TAC is charged with review of all proposed service changes, fare structure adjustments, passenger comments, complaints, suggestions, compliments, and attends and assists at public hearings and community forums. Additionally, TAC is the first step in addressing Title VI complaints and has final approval / disapproval of ADA complementary paratransit certification appeals.

Again, Metro has no influence on TAC member appointments, but does urge the Mayors, Council and Board members to consider appointing representatives from the minority and disabled community. In addition, we urge interested persons, social service agencies, community and faith based organizations and education centers, etc., to contact their representatives charged with TAC appointments to request a TAC appointment.

Body Caucasian African American

Board 80% 20%

TAC* 77% 23%

______

* TAC Committee membership is 27% disabled.

Metro Transit – Title VI Plan 2013

Providing Assistance to and Monitoring Sub-Recipients

Background

In accordance with 49 CFR 21.9(b), and to ensure that sub-recipients are complying with the DOT Title VI regulations, primary recipients must monitor their sub-recipients for compliance with the regulations. Importantly, if a sub-recipient is not in compliance with Title VI requirements, then the primary recipient is also not in compliance.

Monitoring

Metro did not have any sub-recipients in the review period. However, in the event of obtaining sub-recipients, in order to ensure Metro is in compliance with Title VI requirements, regarding the monitoring of sub-recipients, Metro would undertake the following activities:

 Document its process for ensuring that all sub-recipients are complying with the general reporting requirements of FTA Circular C 4702.1B, as well as other requirements that apply to the sub-recipient based on the type of entity and the number of fixed route vehicles it operates in peak service if a transit provider.

 Collect Title VI Programs from sub-recipients and review programs for compliance. Collection and storage of sub-recipient Title VI Programs may be electronic at the option of Metro.

 At the request of FTA, in response to a complaint of discrimination, or as otherwise deemed necessary by Metro, Metro shall request that sub-recipients who provide transportation services verify that their level and quality of FTA C 4702.1B Chap. III- 11 service is provided on an equitable basis.

When a sub-recipient is also a direct recipient of FTA funds, that is, applies for funds directly from FTA in addition to receiving funds from Metro, the sub-recipient reports directly to FTA

Metro Transit – Title VI Plan 2013 and Metro is not responsible for monitoring compliance of that sub-recipient. The supplemental agreement signed by both entities in their roles as designated recipient and direct recipient relieves Metro of this oversight responsibility.

Metro Transit – Title VI Plan 2013

Facility Equity Analysis

Background

The recipient shall complete a Title VI equity analysis during the planning stage with regard to 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 siting of facilities. The Title VI equity analysis must compare the equity impacts of various siting alternatives, and the analysis must occur before the selection of the preferred site.

Facility Construction Equity Analysis for the Period 2010 through 2012

Metro Transit is working under the current Title VI Plan approved by Federal Transit Administration on April 6, 2009. During this period, no new facilities were constructed that were subject to a facility construction equity analysis.

During this period, Metro initiated a major renovation of the North Omaha Transit Center (NOTC). Although not a new facility, Metro analyzed the location of the existing transit center and conducted outreach to nearby residents to ensure the renovation would not result in disparate impact on the basis of race, color, or national origin. The renovation project did not involve the acquisition of land or the displacement of persons from their residences or businesses.

North Omaha Transit Center Renovation

Background

The North Omaha Transit Center (NOTC) is located at 4308 N. 30th Street in Omaha, Nebraska and was originally dedicated on July 16, 1997. The current transit center serves as the primary connection point between 11 Metro routes with a weekday average of 5,452 passengers. 39.2% of all transit revenue miles in Omaha connect with the North Omaha Transit Center. The

Metro Transit – Title VI Plan 2013 existing facility is a 2 block linear design extending between North 30th Street and 31st Avenue and facilitates off-street transfers to and from Metro services. The facility consists of concrete bus lanes, a center island passenger platform, benches, bus stop signage and waiting shelters. The existing passenger waiting shelters include a permanent heated structure and bus stop shelters placed throughout the platform.

After 15 years of wear and tear, the concrete in the bus lanes and passenger platform is failing and needs to be replaced. Additionally, Metro intends to improve the functionality of the transit center design in order to make it more pedestrian friendly.

Planning/Location

The North Omaha Transit Center is ideally situated within a primarily minority area and serves 11 Metro routes including Routes: 3, 5, 8, 16, 18, 24, 25, 26, 30, 34, and 35. The transit center is currently situated on a large parcel of land over 500 feet in length. The Northeast Precinct Station of the Omaha Police Department, located on the adjacent parcel to the north, provides additional safety and security to the area.

The ideal placement and size of the current transit center makes it prudent for Metro to invest in the renovation of this facility in order to continue to serve Metro passengers.

Proposed Improvements During Renovation

Safety and convenience for the passengers waiting on the platform was the critical design concern for Metro. The proposed improvements include improved pedestrian and ADA access, more spacious passenger waiting area, and expanded green space and landscaping.

While existing passenger waiting shelters provide necessary amenities and shelter from inclement weather, the narrow linear design of the transit center impedes pedestrian access in and around the shelters, creating numerous locations that are not comfortably navigated by passengers using a wheelchair or other ADA mobility assistance device. The proposed redesign

Metro Transit – Title VI Plan 2013 replaces the failing concrete and adds an overhead canopy across the entire platform to protect waiting passengers without impeding ADA and pedestrian access.

The southwest extension of the renovated transit center within the same parcel of land is intended to allow a greater platform surface area that includes a larger waiting area and greatly expands the green space and landscaping. Additionally, the platform is enlarged to follow current ADA regulations regarding spacing requirements between benches, structural columns and ingress/egress into buses.

Current and Future Planned Uses

The renovated NOTC will maintain the same functionality and use as the existing facility.

The primary current and planned use of the NOTC is to accommodate the safe alighting, boarding, and transfer of passengers between Metro routes. Both the current and planned designs accommodate 14 bus bays along the passenger waiting platform to provide for the ease of transferring. Similarly, both the existing and future transit centers offer heated passenger waiting areas. The improved transit center also features increased passenger amenities such as an emergency call box, additional seating options, and a drinking water fountain.

The NOTC also is a common driver break and relief area. As such, the existing driver restroom will remain in the planned renovation. Additionally, the current site configuration does not allow for the parking of Metro staff vehicles. These vehicles are currently parked on the grass on the southwest end of the transit center. The proposed renovation design includes staff vehicle parking facilities for this purpose. However, neither the current nor proposed NOTC will have offices or regular staffing of the facility.

Additionally, both the existing and future transit centers have an electrical/IT storage equipment area. In the existing facility, a ceiling mounted rack system in the passenger waiting shelter currently houses electrical and mechanical equipment. The proposed new waiting area

Metro Transit – Title VI Plan 2013 includes a separate electrical room that can be accessed at ground level instead of going through the ceiling as before.

Community Input

A public open house was held on Wednesday, August 22, 2012 at the Northeast Precinct Station of the Omaha Police Department. The open house was advertised in the Omaha Star newspaper, the Metro website and Rider Alerts distributed on buses. During the public open house, the proposed redesign of the renovated transit center was displayed and the public was invited to comment. Spanish translation was available. Public comments were also accepted via mail, fax, and the Metro website. Letters were mailed to nearby property owners and current residents near the transit center informing them of the proposed design and construction. These neighborhood notices also invited comments, provided pertinent details on the scope of the project and provided contact information for Metro’s project manager. One public comment regarding the aesthetics of the design and the placement of the passenger waiting shelter was received.

Other Considerations

The proposed redesign of the NOTC exists completely within the same parcel of land as the existing NOTC and does not require the acquisition of additional land. The redesigned transit center will not encroach into the city streets or right-of-way. The entrances and exits to the transit center in the new design do not require a street reconfiguration.

Future Construction Projects

Future construction projects for which Metro has been awarded 5309 and 5307 funding include the development of transit centers in Downtown and near the Crossroads development at 72nd Street and Dodge Street. Equity Analyses will be conducted for each of these facilities during the planning stages to ensure that the sites are selected without regard to race, color, or national origin and to determine any adverse effects.

Metro Transit – Title VI Plan 2013

Service Equity Analysis

Background

Recipients shall evaluate the impacts of proposed service and fare changes on minority and low-income populations.

Service Equity Analysis For the Period 2010 through 2012

Metro Transit is working under the current Title VI Plan approved by Federal Transit Administration in 2009. Our submission included our Board of Directors Resolution Number 287, dated July 29, 1993. In part the resolution states, “ Whereas, Section 9 (e) (3) (H) of the Federal Transit Administration Act of 1964, requires a recipient, as a condition of receiving funds under Section 9, certify that it “has a locally developed process to solicit and consider public comment prior to raising fares or implementing a major reduction in transit service.” The resolution goes on to say, “1. Prior to the implementation of any proposed service reduction of ten percent to twenty percent of total system revenue miles, the opportunity for a public hearing shall be granted by the BOARD in accordance with the procedures hereinafter stated.” (A copy of this Resolution follows this analysis.)

There was no Service Equity Analysis triggered in this review period under the current approved plan. Metro understands the importance placed on equity of service through Title VI and has revised the definition of a major service change in the proposed 2013 Title VI Program. The amount which will trigger a Title VI analysis will be:

 12% of the revenue miles of the system  25% of the revenue miles of a route  The addition and/or elimination of a route

In determining if Metro met the current threshold of a reduction in service of 10 percent to twenty percent of the total system revenue miles an analysis was completed at the beginning of

Metro Transit – Title VI Plan 2013 each service change. Metro, by negotiated union agreement has a minimum of three picks per year. It is during these picks that mileage or service may change. Metro looked at the previous pick in each cycle and compared the total system miles for a day type (Weekday, Schoolday, Saturday, and Sunday). In no instance did the percent of change approach 10 percent of the total system miles.

Even though Metro was not required, by our Plan, to initiate a Service Equity Analysis, Metro performed the following activities when planning service changes under the current adopted Title VI Program:

 Historical analysis of ridership and productivity  Analysis of demographic profile of riders  Review of available alternative transportation including within and beyond the Metro system  Rider Alerts to the affected passengers  Driver surveys to elicit the rider type (commuter, student, elderly, etc.)  Contact with schools in the affected areas  Information placed on Metro’s website describing the changes  Comment cards on the buses and a comment area on the website  Contact with social service agencies in the affected areas  Alternate trip planning for customers in the affected areas  Postings at Metro Transit Centers

Metro Transit – Title VI Plan 2013

Below is the percent change in system revenue mileage for each of the service changes in the review cycle. Percent of Mileage Change

Weekday Schoolday Saturday Sunday

4/25/2010 -1.18% -1.22% 3.86% -2.68% 6/24/2010 0.08% 0.06% -0.71% 0.19% 12/12/2010 0.42% 0.43% -0.10% 6.17% 4/24/2011 3.97% 4.14% -0.65% -1.72% 8/9/2011 -0.18% -0.18% 0.54% 0.67% 12/11/2011 0.00% 0.00% -0.01% 0.05% 4/15/2012 0.05% 0.06% -0.30% -0.43% 7/31/2012 0.00% 0.21% -0.04% -0.06% 12/16/2012 0.00% 0.00% 0.00% 0.00%

Metro Transit – Title VI Plan 2013

Fare Equity Analysis

Metro Transit’s last fare increase was January 2001. After a decade of stable fares, increasing expenses, cost savings measures, maintaining system revenue miles and flat or reduced revenues, Metro is faced with budgetary constraints necessitating a fare increase.

For the past several years, expense savings measures allowed continuance of the current fare structure. It seemed logical not to increase fares as we saw increases in passenger traffic, serve very transit dependent populations and consciously want to continue attracting new passengers to the system.

Examples of measures taken to maintain the current fare structure are: 1) identification and implementation of creative solutions to obtain local match for capital investments by forging partnerships to help offset those costs; 2) negotiating agreements with employers to subsidized circulator weekday rush hour services; 3) active pursuit of congressional discretionary (commonly called “earmarks”) funding for such purchases as the upgraded Fare Collection and new onboard Video and Audio Surveillance Systems; 4) ARRA funds for fleet replacement, the “repowering” of circa 2000 buses and other “shovel ready” projects; 5) continuous monitoring of the transit system, reallocating unproductive revenue miles to areas with projected increased travel demand; and in 6) Calendar Year 2011: a) froze administrative salaries; b) initiated hourly and salaried participants health insurance contributions and c) increased salaried pension participants contributions to 6% from 5.3%.

As effective as the cost-saving measures have been, the projected Calendar Year 2012 budget reveals an adjustment to our fares is prudent. We can no longer offset the ever increasing fuel price, regular inflation and flat and in some cases decreasing operating dollars. Impacts to the revenue stream are: 1) Nebraska’s statutorily annual 3% maximum restriction to our dedicated taxing authority, 2) stagnant federal funding; 3) the ceasing of congressional discretionary grants;

Metro Transit – Title VI Plan 2013

4) reduced interest income and 5) reduction in State of Nebraska transit funding. The aforementioned are demonstrated in Figure 1.

Figure 1

2009 2010 Percent 2011 Percent REVENUES BUDGET BUDGET Change BUDGET Change FARES 3,894,165 3,352,014 -16.17% 3,560,394 5.85% TAX LEVY 12,228,364 12,656,357 3.38% 13,099,330 3.38% FEDERAL 7,149,249 7,018,782 -1.86% 7,386,569 4.98% STATE 1,020,000 850,000 -20.00% 755,110 -12.57% CONTRACT SERVICES 937,860 841,779 -11.41% 788,000 -6.82% INTEREST 250,000 179,613 -39.19% 50,000 -259.23% OTHER 252,800 215,572 -17.27% 211,200 -2.07% TOTAL 25,732,438 25,114,117 -2.46% 25,850,603 2.85%

A Fare Structure Adjustment Equity Analysis (ANALYSIS) was conducted to evaluate increased revenues by fare categories and to ensure equitable distribution between protected populations including Limited English individuals and non-protected populations.

The Analysis included a 1) Review of fare payment by fare media type; 2) Peer Fare Structures Survey; 3) Consumer Price Index CY 2001 – mid-year 2011 percent changes to our current fare categories; 4) Fare Elasticity Model estimating fare category revenue increases and lost ridership resulting from fare adjustments; 5) Transfer Abuse Survey and 6) Express Service Fare Media Payment Review.

In the first 9 months of Calendar Years 2009 and 2010, Metro’s farebox collections are close to an even split at 50% prepaid fare card (CARD) and cash and illustrated in Figure 2. While a preference would be to reduce the cash payment by at least 20%, 75% of our Cards (1 Ride w/ Transfer) are purchased by the State of Nebraska, Douglas County General Assistance and social service agencies for distribution to their clients. With Omaha ranked 11th in the nation for person living below poverty, the reduction of cash fares at this time is not anticipated.

Metro Transit – Title VI Plan 2013

Figure 2

January - September

Purchased Card Type 2010 2011 Percentage Percentage Quantity Quantity

1 Ride Adult w/Trans 212,409 76% 189,501 75%

2 Ride Adult w/Trans 0 0% 3,165 1%

10 Ride Adult w/Trans 39,379 14% 29,518 12%

10 Ride Adult 8,253 3% 9,366 4%

10 Ride Express 7,526 3% 6,944 3%

10 Ride Student 3,817 1% 4,591 2%

10 Ride Elderly/Handicap 3,958 1% 4,171 2%

30 Reg Pass - Full Fare 3,613 1% 3,847 2%

30 Half-Fare Pass 1,683 1% 2,085 1%

TOTAL 280,638 100.00% 253,188 100.00%

Cash Value Purchased Cards 2010 Percentage 2011 Percentage

1 Ride Adult w/Trans $276,132 21% $246,351 21%

2 Ride Adult w/Trans $0 0% $8,229 1%

10 Ride Adult w/Trans $511,927 40% $383,734 33%

10 Ride Adult $103,163 8% $117,075 10%

10 Ride Express $112,890 9% $104,160 9%

10 Ride Student $38,170 3% $45,910 4%

10 Ride Elderly/Handicap $23,748 2% $25,026 2%

30 Rag Pass - Full Fare $180,650 14% $192,350 16%

30 Half-Fare Pass $42,075 3% $52,125 4%

TOTAL $1,288,754 100% $1,174,960 100%

Metro Transit – Title VI Plan 2013

Fare Payment January - September

2010 Dollars Percentage

Total Cards $1,288,754 53%

Total Cash Fares $1,124,002 47%

Total $2,412,756 100.00%

2011 Dollars Percentage

Total Cards $1,174,960 50%

Total Cash Fares $1,162,725 50%

Total $2,337,685 100.00%

Metro Transit – Title VI Plan 2013

The Fare Elasticity Model in Figure 3 estimates an “across the board” Fare Structure Adjustment would generate total additional CY 2012 revenues of $697,122 and a loss of 519,116 passenger trips. NOTE: the Fare Elasticity Model assumes a .43% decrease in ridership for every 1% increase in fares.

Figure 3

2010 2010 Current Increased % Revenue Elasticity Adjusted Loss of Adjusted Revenue Percentage Fare Category Ridership Revenue Fares Fares Increase Factor Ridership Ridership Revenue Increase Increase Adult 1,116,573 $1,395,716 $1.25 $1.60 28.00% (0.1120) 991,517 (125,056) $1,586,426.92 $190,710.67 13.66%

Adult w/Trans 745,297 $968,886 $1.30 $1.85 42.31% (0.1692) 619,163 (126,134) $1,145,451.43 $176,565.33 18.22%

Transfers 853,820 $42,691 $0.05 $0.25 400.00% (0.2500) 640,365 (213,455) $160,091.25 $117,400.25 275.00%

Express 71,194 $106,791 $1.50 $2.00 33.33% (0.1330) 61,725 (9,469) $123,450.40 $16,659.40 15.60%

Student 82,163 $82,163 $1.00 $1.25 25.00% (0.1000) 73,947 (8,216) $92,433.38 $10,270.38 12.50%

Half-fare 132,985 $79,791 $0.60 $0.80 33.33% (0.1330) 115,298 (17,687) $92,238.40 $12,447.40 15.60%

Child 15,473 $7,737 $0.50 $0.75 50.00% (0.2000) 12,378 (3,095) $9,283.80 $1,547.30 20.00%

MOBY 79,961 $159,922 $2.00 $3.20 60.00% 0.0000 79,961 0 $255,875.20 $95,953.20 60.00%

30 Day Pass 5,024 $251,200 $50.00 $57.50 15.00% (0.0600) 4,723 (301) $271,547.20 $20,347.20 8.10%

30 Half-Fare 2,289 $57,225 $25.00 $28.75 15.00% (0.0600) 2,152 (137) $61,860.23 $4,635.23 8.10%

*MCC/MAV Ride 259,415 $254,227 $0.98 $1.25 27.55% (0.0600) 243,850 (15,565) $304,812.63 $50,585.93 19.90% Total 3,364,194 $3,406,349 $84 $99 729.53% ($1) 2,845,078 (519,116) $4,103,470.82 $697,122.27 20.47%

* MCC / MAV Ridership is calculated by using the last 12 months rides and the average fare. The new average fare will increase the same percentage as the Adult Fare - 28%, there is not an Elasticity Factor since rides will not decrease.

Additionally, the Consumer Price Index (CPI) indicates our base fare should have been increased to $1.60 four years ago. Adjustment of our current fare categories to the annual CPI percentage increases would result in our fares being the highest as illustrated in Figure 4.

However, the aforementioned options, an “across the board” fare increase and CPI projection, conflict with our efforts to maintain equitable fare structure for both our current and potential passengers.

Metro Transit – Title VI Plan 2013

Figure 4

Percent Change Consumer Price Index from Previous Period Proposed Metro Fares All Urban Intracity All Urban Year Intracity ADULT EXPRESS Items1 Transportation2 Goods1 Transportation2 2001 177.1 180.1 $1.25 4 $1.50 5 2002 179.9 184.1 1.6% 2.2% $1.28 $1.53 2003 184.0 197.4 2.2% 7.2% $1.37 $1.64 2004 188.9 208.9 2.6% 5.8% $1.45 $1.74 2005 195.3 218.5 3.3% 4.6% $1.52 $1.82 2006 201.6 225.9 3.1% 3.4% $1.57 $1.88 2007 207.3 230.6 2.8% 2.1% $1.60 $1.92 2008 215.3 239.8 3.7% 4.0% $1.66 $2.00 2009 214.5 251.1 -0.4% 4.7% $1.74 $2.09 2010 218.1 261.0 1.6% 4.0% $1.81 $2.17 2011 3 225.7 266.3 3.4% 2.0% Notes: Source: Table 1A. Consumer Price Index for All Urban Consumers: US City Average, by 1 - Expenditure Category and Commodity and Service Group (2001 through 2010), Bureau of Labor Statistics, US Department of Labor. Source: Table 3A. Consumer Price Index for All Urban Consumers: US City Average, Detailed 2 - Expenditure Categories (2001 through 2010), Bureau of Labor Statistics, US Department of Labor. Source: Table 1. Consumer Price Index for All Urban Consumers: US City Average, by Expenditure Category and Commodity and Service Group (June 2011), Bureau of Labor Statistics, US Department of Labor. 3 - Table 2. Consumer Price Index for All Urban Consumers: Seasonally Adjustes US City Average, by Expenditure category, Commodiaty and Service Group (June 2011), Bureau of Labor Statistics, US Department of Labor. http://www.fintrend.com/inflation/Consumer_Price_Index/HistoricalCPI.aspx 4 - Base Metro January 2001 Adult Fare. 5 - Base Metro January 2001 Express Fare.

The next step in the Analysis was review of current transfer pricing and the proposed 400% increase (5¢ versus 25¢) in comparison to: 1) Peer Survey pricing for linked trips (fare plus transfer), 2) recorded 2010 total used transfers compared to our reported 2010 National Transit Data Base Unlinked Passenger Trips and 3) Operators Transfer Abuse Survey.

Metro Transit – Title VI Plan 2013

The Peer Fare Survey revealed there is no industry standard for transfers. See Figure 5. The pricing, timing and / or number of buses is decided on a local level. Industry options are numerous with the following encompassing the majority: a) free with a specific time / number of buses, whichever comes first; b) discontinued and passengers pay for each trip and c) increased transfer pricing.

Metro Transit – Title VI Plan 2013

Figure 5

Metro Transit – Title VI Plan 2013

Our current 5¢ transfer and proposed 25¢ transfer plus the $1.25 base fare are individually the lowest linked trip pricing of the Peer Fare Survey. NOTE: Transfer pricing haven’t increased since January 2008 as illustrated in Figure 6.

Figure 6

Our 2010 total used transfers are 22.8% of reported 2010 National Transit Data Base Unlinked Passenger Trips (857,703 versus 3,746,554). See Figures 7 and 8

Metro Transit – Title VI Plan 2013

Figure 7

NTD Ridership Activity Summary Report for 2010 Report Year

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total

DR Unlinked Passenger Tirps 7665 8262 9594 9420 8896 9107 8791 9550 10055 10289 9583 9885 111094 Unlinked Avg Weekday Trips Vehicle Revenue Hours 3983 3910 4549 4701 4365 4440 4182 4350 4465 4503 4441 4609 52498 Vehicle Revenue Miles 56716 59142 69387 70566 65586 66841 60942 64820 66912 67748 65138 67063 780861 VOMS 47 47 51 51 51 51 41 45 54 54 54 54 50 Regular ServiceDays 20 20 23 22 20 22 22 22 21 21 21 23 257

MB Unlinked Passenger Tirps 277323 285939 337216 332217 295300 316384 302012 320519 331587 342624 311705 293728 3746554 Unlinked Avg Weekday Trips Vehicle Revenue Hours 23930 23355 26417 25332 24092 26958 25518 25332 24571 25362 24606 25972 301445 Vehicle Revenue Miles 32508 317786 359496 344925 325548 355768 345365 344925 332495 342550 332885 352682 4079935 VOMS 99 99 99 99 99 99 99 99 99 99 99 99 99 Regular ServiceDays 20 20 23 22 20 22 22 22 21 21 21 23 257

Metro Transit – Title VI Plan 2013

Figure 8

Metro Transfer Usage Year 2010 Route Transfers Transfers Issued Issued Used 1 3,299 2,540 2 93,670 74,614 3 45,210 37,253 4 37,781 28,960 5 45,066 42,876 7 56,826 48,274 8 39,894 37,730 9 17,953 14,724 10 1,674 1,085 11 40,753 35,025 13 62,177 50,363 14 45,303 41,392 15 48,801 39,695 16 10,054 8,601 17 5,669 5,987 18 108,607 86,198 22 9,051 9,274 24 59,386 49,410 25 6,514 5,853 26 21,410 21,433 30 83,138 69,055 32 20,177 17,760 34 1,371 1,085 35 53,734 44,915 40 7,201 5,875 41 13,046 11,121 42 6,974 5,862 43 9,681 8,504 44 4,347 5,919 45 3,494 3,117 48 1,901 1,739 55 47,375 38,338 92 1,427 549 93 1,042 253 94 485 88 95 2,226 1,436 96 577 195 97 1,279 168 98 952 437 Total 1,019,525 857,703 72

Metro Transit – Title VI Plan 2013

The Operators Transfer Abuse Survey was conducted as lost fares attributed to transfer abuse have become an increasing problem. The bus operators report our passengers have identified both blatant and, on occasion, creative ways to travel round-trip on our system while only depositing a one-way fare plus the cost of a transfer. Our survey showed that the riders would purchase a transfer, attempt to sell it, especially at transfer centers, to waiting passengers at a cost far below the $1.25 base fare. This is substantiated by the 16% difference between the 2010 number of transfers issued versus those used (857,703 versus 1,019,525) illustrated by the arrows in Figure 8.

Proposed Fare Increase/Adjustment

Staff revisited the proposed “across the board” fare category increases and recommends at this time a “modest” adjustment projected to keep pace with inflation and budget challenges associated with a weak economy. If market conditions change dramatically, a more broad based fare increase could be implemented at a later date. This approach provides the opportunity to gauge the impact on lost passenger trips and provides the flexibility to adjust additional fare categories in the future.

Transfers:

Recommend increasing the transfers from 5¢ to 25¢. The recommendation is to maintain the current transfer policy and add one mitigating option. The current policy includes 1) Weekdays: one-direction travel using the transfer 3 times within a 90 minute timeframe, 2) Weekends: one- direction travel using the transfer up to 3 times within 2 hours and 3) Mitigation Option: eliminate paying for a transfer on interlined routes. NOTE: The farebox prints on the backside of a transfer, eligible timeframe, originating bus and route numbers. 4) Effective the first of this month, passengers can only transfer at posted transfer points. This was implemented to reduce transfer abuse and improve “dwell” times. (The time needed for passengers to board, deposit a fare and/ or alight.) Reduced dwell times improve on-time performance.

Metro Transit – Title VI Plan 2013

30 Consecutive Day Unlimited Ride Cards:

Recommend increasing the 30 Day Consecutive Unlimited Pass 8.10% to $55 from $50. And continue to offer the ½ Fare 30 Day Consecutive Unlimited Pass at an 8.10% increase from $25 to $27.50. Research revealed Metro’s pricing for both the full and ½ fare Cards were below the average of the Peer Transit Agencies surveyed. See Figure 5

MOBY Complementary Paratransit Fare:

MOBY’s fare is less than double the regular fixed route fare permitted by ADA complementary paratransit regulations. With the current MOBY fare of $2.00 per trip, our MOBY passengers have had the benefit of a 20% discount for a decade. MOBY’s fare when compared to surveyed transit agencies is the only one not aligned with ADA Complementary Paratransit regulations permitting a paratransit fare to be double the base fare charged for regular service. The one- way fare subsidy for a MOBY trip is $16.19. Adjusting MOBY’s fare by 50¢ per trip to $2.50 is in compliance with ADA Complementary Paratransit regulations. Compliance with the ADA is equitable and there are no projected lost passenger trips.

Event Fare:

Research revealed numerous transit agencies have a published event fare. The fare is designed for published transit services such as the College World Series Express Park and Ride.

Proposed Transfer Fee Increase:

In order to determine the impact of the proposed fare changes, Metro evaluated the 2010 farebox reports. These reports show that transfer redemption accounted for 22.4% of fare payments across the system. Transfer redemption on Express Routes is much lower ranging from 0.8% to 11.2% by route. Express passengers on Metro service tend to be non-minority with higher incomes. However, the cumulative effect of the proposed transfer fee and 30 consecutive day pass, as noted below, will provide an equitable distribution of the burden of the fare increase between local and express passengers.

Metro Transit – Title VI Plan 2013

For local fixed route services, the transfer utilization by route ranges from 16% to 35.1%. The mean percentage utilization of transfers among local fixed routes is 24.4% with a standard deviation of 4.9%. Therefore, transfer utilization on 22 of the 32 local fixed routes, or 68.75% of the routes, is within one standard deviation of the mean. The ten routes outside of one standard deviation include both routes that primarily serve minority and low income areas and non-minority areas. The findings are noted below in Figure 9.

Figure 9

% of Non- Minority Route Transfers Notes minority Mileage Redeemed Mileage Routes with transfer redemption rates lower than one standard deviation below the mean 54.84% of revenue miles operate in 48 16.0% 240.09 197.72 a minority census tract 100% of revenue miles operate in a 9 17.5% 2175.48 0 minority census tract 100% of revenue miles operate in a 7 19.3% 3344.9 0 minority census tract 44.11% of miles operate in a 4 19.4% 1395.14 1767.96 minority census tract Total: 7,155.61 1,965.68 Routes with transfer redemption rates higher than one standard deviation above the mean 100% of revenue miles operate in a 25 30.2% 675.1 0 minority census tract 0% of revenue miles operate in a 44 30.6% 0 776.27 minority census tract 100% of revenue miles operate in a 24 30.7% 1800.96 0 minority census tract 0% of revenue miles operate in a 22 31.7% 0 1043.48 minority census tract 71.76% of revenue miles operate in 16 32.9% 1188.36 467.75 a minority census tract 53.92% of revenue miles operate in 34 35.1% 113.11 96.68 a minority census tract Total: 3,664.42 2,384.18

Metro Transit – Title VI Plan 2013

The four routes with transfer redemption rates lower than the average are in predominantly minority census tracts (78.4%). 60.5% of the mileage of the six routes with transfer redemption rates above average is located in minority census tracts.

A minority census tract is a census tract as defined by the 2000 Census data in which the percentage of minority residents exceeds the average percentage of minority residents throughout the service area. For purposes of this analysis, Metro utilized the definition of minority tracts in the most recent approved Title VI plan. The census tracts in Metro's service area were divided into quartiles by percentage of minority population. The average percentage of minority residents by census tract in Metro's service area is 11.3%. Any census tract with a percentage of minority population exceeding 11.3% of the entire population of the census tract was counted as a minority tract for the purposes of this analysis.

Proposed 30 Day Consecutive Pass Increase:

The 30 Day pass is traditionally preferred by high-income, non-minority, demographics as exemplified by Metro’s findings of express bus passengers using the card to ride for a reduced fare. NOTE: Transit industry research finds that low income and minority passengers more frequently pay cash or favor fare cards with lower sales value.

Conclusion:

A modest increase in fares is necessary in order to maintain services. The proposed increases to transfer fees, MOBY (Paratransit) fees, and the 30 day pass will have a less harmful impact on ridership than an ‘across the board’ increase as shown by the fare elasticity model. Additionally, the proposed increases are well within the range of fares of peer agencies. The analysis of the proposed increase in the transfer fee shows that 68.75% of local fixed routes, regardless of ethnicity or income level of the served demographic, have similar utilization of transfers. Additionally, the remaining 31.25% of routes serve both minority and non-minority areas. The 30 Day Consecutive Pass, based on observation, farebox data, and industry trends is not believed to have a disproportionate impact on minority or low income riders. No disparate

Metro Transit – Title VI Plan 2013 impacts on minority populations or disproportionate burdens on low-income populations were identified in this fare increase proposal.

Staff requests authority to conduct public hearings to solicit comments on the proposed fare increase. The proposed implementation date is Sunday, January 1, 2012 pending Board action at the November meeting.

The proposed modest fare adjustment is in Figure 10 below.

Figure 10

% Fare Type Current Proposed Change Transfer $0.05 $0.25 400.00% 30 Day Consecutive Unlimited Ride Card - Full Fare $50.00 $55.00 8.10% 30 Day Consecutive Unlimited Ride Card - ½ Fare $25.00 $27.50 8.10% MOBY Fare $2.00 $2.50 20.00% New: Event Fare ------$3.00 ------

Public Engagement

At the October Board Meeting, the Board of Directors authorized conducting three (3) Public Hearings (HEARINGS) to present the proposed Fare Adjustments and gather input. All meetings were held at public ADA accessible locations along transit routes and scheduled at different times of the day to provide the fullest opportunity for public engagement. Persons with special communication or needs for other accommodations such as sign language interpreters, translation for non-English speaking, readers, large print or for additional information were encouraged to contact Metro at least two working days prior to a meeting so appropriate arrangements could be made.

Public Hearing Schedule

Tuesday, November 8: OIC, 2724 North 24 Street 6:15 PM

Wednesday, November 9: MCC, South Omaha Library, 2808 Q Street, 6:15 PM

Thursday, November 10: Peter Kiewit Conference Center, 1313 Farnam, Rm 218, 11:30 AM 77

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Description of the Public Engagement Process

Notice of the Public Hearings (NOTICE) was published in the Omaha World Herald and Omaha Star, at Transit Centers and Metro’s administrative lobby where the public can purchase fare cards and receive trip planning assistance. Website and interior bus cards include the Notice and additional pertinent information. The same information was published as Rider Alerts in both English and Spanish and distributed on the fleet. Notice of the Hearings were disseminated to the Hispanic community with the assistance of the Greater Omaha Chamber of Commerce’s South Omaha Development Project staff and Metro partners such as Omaha by Design, Activate Omaha, Metropolitan Planning Agency, Metro Community College, Downtown Omaha, Inc., Omaha Veteran Hospital, the University of Nebraska of Omaha, social service agencies and employers. Our partners were asked to disseminate the Notice to their individual memberships, clients, employees, etc. It’s estimated the Notice was emailed to over 500 interested persons, companies, other agencies, etc.

Throughout the Hearing process and comment phase, Thursday, October 27, 2011 – Sunday, November 13, 2011, the proposed fare adjustments were posted online or available by calling Metro Customer Service or the TDD line.

Attendance at the Hearings was not required to comment. Persons unable to attend a meeting or having thoughts after attending a meeting could submit comments in writing, by fax, text message, or electronically. Comments had to be post marked / received no later than midnight Sunday, November 13, 2011.

The Hearings began with a power point presentation followed by discussion. Handouts, English, Spanish and large print format, included the power point presentation, proposed fare adjustments, question / comments forms and the opportunity to submit comments through midnight Sunday, November 13, 2011 via Metro mailing address, fax and email. A Spanish interpreter attended the meetings. There were no requests for special accommodations such as a sign language interpreter. No media attended the meetings or aired stories.

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Collectively, 32 persons attended the Hearings with 29 testifying and 40 written comments submitted. There were 20 in favor, 8 against and 12 general on such things as our service level, suggestions for routing, hours of service, etc.

The Board of Directors at their October 27, 2011 meeting authorized conducting public hearings regarding the proposed fare adjustment.

The Board of Directors at their November 17, 2011 meeting authorized the fare adjustments effective Sunday, January 1, 2012.

Board of Director’s Minutes October 27, 2011 are included in the following pages.

80 81 82 83 84 85 86 Metro Transit – Title VI Plan 2013

Board of Directors Minutes, November 17, 2011 are included in the following pages.

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Public Engagement for Major Service Change Policy

Background

As a federally funded and regulated transit provider, through the Federal Transit Administration (FTA), Metro has a responsibility to adhere to the objectives of Title VI of the Civil Rights Act of 1964 as well as the policies set forth in the Executive Order on Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations (1994).

Title VI

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).

Environmental Justice (EJ)

Although no formal report is required for the Executive Order on Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, FTA requires transit providers to incorporate EJ and non-discrimination principles into transportation planning and decision making processes as well as environmental review for specific projects. The two primary classes considered are minorities and low-income populations.

Metro Transit – Title VI Plan 2013

Solicitation of Public Comments

In response to recent changes made by the FTA on Title VI Requirements and Guidelines for FTA Recipients, Metro sought public comment on the following proposed policies regarding major service changes, all fare changes and their corresponding impacts and / or burdens on Metro service populations:

 Title VI Major Service Change Policy  Title VI Disparate Impact Policy  Environmental Justice Disproportionate Burden Policy  Fare Equity Analysis Policy

Description of the Public Engagement Process

First Draft of Policies

In compliance with the revised requirements and to ensure decisions do not result in discrimination based on race, ethnicity or national origin, Metro conducted five public meetings (July 15, 2013 through July 18, 2013) to present the proposed policies and gather input. All meetings were held at public ADA accessible locations along transit routes and scheduled at different times of the day to provide the fullest opportunity for public engagement. Persons with special communication or needs for other accommodations such as sign language interpreters, translation for non-English speaking, readers, large print or for additional information were encouraged to contact Metro at least two working days prior to a meeting so appropriate arrangements could be made.

Notice of the Public Hearings was published in the Omaha World Herald and Omaha Star, at Transit Centers and Metros administrative lobby where the public can purchase fare cards and receive trip planning assistance. Website and interior bus cards include the Notice and additional pertinent information. Text messaging and an online town hall meeting blog were

Metro Transit – Title VI Plan 2013 available throughout the comment period. Over 6,000 Rider Alerts with the same information, printed in English and Spanish, were distributed to our passengers by bus and MOBY drivers. In addition, the Notice was disseminated to the Latino community with the assistance of the Greater Omaha Chamber of Commerce’s South Omaha Development Project staff and Metro partners such as Omaha by Design, Activate Omaha, Metropolitan Planning Agency, Metro Community College, Downtown Omaha, Inc., the University of Nebraska of Omaha, Omaha Veteran Hospital, social service agencies and employers. Our partners were asked to share the Notice with their individual memberships, clients, employees, etc. It’s estimated the Notice was forwarded to 500 individuals.

Throughout the public notice and initial comment phase, July 10 – August 11, 2013, the proposed policies were posted online or available by calling Metro Customer Service or the TDD line.

Attendance at the public meetings was not required to comment. Persons unable to attend a meeting or having thoughts after attending a meeting could submit comments in writing, by fax, text message, or electronically. Comments had to be post marked / received no later than midnight Sunday, August 11, 2013.

The meetings began with a power point presentation followed by discussion. Handouts included the power point presentation, draft major service change, disparate impact and disproportionate burden policies, question / comments forms and the opportunity to submit comments through midnight Sunday, August 11, 2013 via Metro mailing address, fax and email. All were provided in English, Spanish and large print format. A Spanish interpreter attended the meetings. There were no requests for special accommodations such as a sign language interpreter. No media attended the meetings or aired stories.

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Public Meeting Summary - July 2013

A total of 10 persons attended the meetings. While the attendance was minimal discussions were lively and informative. We received 6 comments: 4 on the form provided, a two text messages and two from the online town hall meeting.

There was one comment in favor of the proposed policies and one suggesting the Major Service Change quantitative threshold should be by route and not total system revenue miles.

The remaining four comments were general in nature with none stating whether they were in favor or not of the draft proposed policies adjustments, but had suggested system and customer service improvements, e.g., longer hours, more routes and route frequencies; and that a bus operator was not wearing a seat belt.

The initial proposed policy defined the threshold for a “major service change” as 15% of revenue system miles and addition or elimination of a route. At the July Board meeting, the Board discussed the viability of adding a by route quantitative threshold for the major service change policy as had been suggested by a meeting participant. Based on feedback from the public and Board, staff revised the proposed Major Service Change, Disparate Impact, and Disproportionate Burden Policies.

Revised Draft Policies

A second set of public meetings were held on Thursday, August 15, 2013 at 10:45 AM and 5:45 PM at Metro to present the revised Major Service Change, Disparate Impact, and Disproportionate Burden Policies. The facility is well served by transit and easily accessible.

Staff duplicated all the Public Notice activities, special accommodation contact information, document availability and comment process outlined for the July meetings. The revised polices

Metro Transit – Title VI Plan 2013 were posted on Metro’s website and on the online townhall. The comment period was extended to Sunday, August 18th.

The presentation materials and handouts were updated to reflect the revised policies which were proposed as follows:

 The addition and / or elimination of a bus route;  A twelve (12) percent or more addition or reduction in the system revenue miles;  A twenty-five percent or more addition or reduction of revenue miles on any individual route, whether by frequency, span of service or route realignment beyond a three- quarter mile buffer of the terminus and either side of an existing alignment.  Disparate Impact and Disproportion Burden quantitative threshold at twenty five (25) percent or greater.

Public Meeting Summary - August 2013

A total of 16 people attended the two meetings, evenly split with no duplicates at either meeting. The presentation and discussions were spirited. Three written comments were received. One very much in support of the revised policies and the remaining two regarding a MOBY (Paratransit) client with a destination outside the service area. The MOBY comments have been forwarded to transportation for review and follow-up.

Implementation and Adoption of Proposed Policies

Upon completion of the public meetings and public comment phase, Metro reviewed its Proposed Title VI and Environmental Justice Policies as needed. The documents have been forwarded to the Board’s Title VI subcommittee and the full Board for review and analysis.

Metro staff will present the Proposed Title VI Plan and associated elements to the Board of Directors with discussion lead by their subcommittee. Adoption is tentatively scheduled for Wednesday, September 11, 2013 for awareness, approval, and adoption.

Metro Transit – Title VI Plan 2013

Title VI Policies

Background

Metro proposes to establish these Major Service Change, Fare Equity, Disproportionate Burden, and Disparate Impact Policies in compliance with applicable federal requirements under Title VI of the Civil Rights Act of 1964, including 49 CFR Section 21 and FTA Circular 4702.1B, "Title VI Requirements and Guidelines for Federal Transit Administration Recipients" which became effective October 1, 2012. This Circular requires any FTA funding recipient that operates 50 or more fixed route vehicles in peak service and serving a population of 200,000 or greater to evaluate all fare changes and any major service change at the planning and programming stages to determine whether those changes have a Disparate Impact on the minority population or Disproportionate Burden on low-income population.

Major Service Change Policy

The purpose of the Major Service Change Policy is to define thresholds for determining major service changes and whether potential changes to existing transit services will have adverse effects: a) disparate impact based on race, color, or national origin, or whether potential service changes will have a b) disproportionate burden on low-income populations.

Major Service Change

The following is considered a major service change (unless otherwise noted under Exemptions), and will be evaluated in accordance with the regulatory requirements set forth in FTA Circular 4702.1B.

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The following thresholds for analysis are not set so high so as to never require an analysis; rather, are established to yield a meaningful result in light of Metro’s service characteristics and shall be defined as any significant change in transit service in effect for twelve or more months that meets at least one of the following:

1. The addition and / or elimination of a bus route.

2. A twelve percent or more addition or reduction in the system revenue miles.

3. A twenty-five percent or more addition or reduction of revenue miles on any individual route, whether by frequency, span of service or route realignment beyond a three- quarter mile buffer of the terminus and either side of an existing alignment.

All major service changes will be subject to an equity analysis which includes an analysis of adverse effects on protected service populations. Metro recognizes that additions to service may also result in disparate impacts and disproportionate burdens, especially if the additions come at the expense of reductions in service on other routes. Metro shall consider the degree of adverse effects and analyze those effects when planning major service changes and / or any fare change.

Exempt Service Changes with no Adverse Effect Review

1. Any service change that does not meet the conditions of a major service change as defined above.

2. Seasonal service changes.

3. Headway adjustments up to 7 minutes during the peak hour periods, and 15 minutes during non-peak hour periods.

4. Changes to a service on a route with fewer than 10 total trips in a typical service day are not considered “major” unless service on that route is eliminated completely on any such day.

5. Reduction in revenue miles on one transit route that is offset by an increase in revenue miles on the overlapping section of an alternative transit route (an

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overlapping section is where two or more bus routes share the same alignment, stops, etc. for a short distance).

6. Changing a route number, name or other designation.

7. Any temporary service addition, change or discontinuance of a demonstration route with less than 12 months of operation.

8. The introduction or discontinuation of short or limited-term service (e.g., promotional, seasonal or emergency service, or service activities), as long as the service will be/has been operated for no more than 12 months.

9. Changes to bus service levels on routes which occur because of seasonal ridership changes and event activities served by dedicated temporary bus routes or increased service frequencies.

10. Changes on special service routes such as sporting events, special events or service contracted with other cities, agencies, employers, etc.

11. Route changes/detours caused, but not limited to, road construction/maintenance closures, emergencies, major construction, inadequate fuel supplies, safety concerns.

12. Actions of other service providers or public agencies providing/administering transit services that are not the responsibility of Metro.

13. Service addition, change or discontinuance of transit service contracts operated by Metro, but not within Metro’s taxing service area.

14. Forces of nature such as tornados, snow emergencies, or other natural, or human-caused catastrophic disasters that may force the suspension of transit service for public safety or technical reasons.

15. Failures of auxiliary transportation infrastructure such as vehicular bridges, highway bridge overpasses, tunnels, or elevated highways that force the suspension of transit service.

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Equity Analysis Data Sources

Category Action Sub Action Evaluation Method

Survey, farebox reports, Fare Adjustment N/A Censusand Data/ or of affected fare category

Reduction N/A Surveys, farebox reports, Service Span and / or Census data of affected route(s) Expansion N/A

Service Reduction N/A Surveys, farebox reports, and / or Census data of Headway Expansion N/A affected route(s) Surveys, farebox reports, Reduction N/A and / or Census data Route Length Surveys, farebox reports, Expansion N/A and / or Census data Surveys, farebox reports, Reduced Alignment N/A and / or Census data Surveys, farebox reports, Expanded Alignment N/A and / or Census data Route Alignment Surveys, farebox reports, Eliminated Segment(s) and / or Census data Modified Alignment Segment(s) to New Surveys, farebox reports, Areas and / or Census data Surveys, farebox reports, New Route New Route N/A and / or Census data

Definitions:

1. Adverse Effect - defined as a geographical or temporal reduction in service which includes but is not limited to: span of service changes, frequency changes, route segment elimination, re-routing and route elimination.

2. Disparate Impact - A facially neutral policy or practice that has a disproportionately excluding or adverse effect on the minority riders or population of the service area.

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3. Disproportionate Impact - A facially neutral policy or practice that has a disproportionately excluding or adverse effect on the low-income riders or population of the service area.

4. Express Transit Service - Metro designated express routes.

5. Local Transit Service – Metro fixed-route bus routes not designated as express routes.

6. For purposes of this policy, “low-income population” is defined as any readily identifiable group of households who live in geographic proximity and whose median household income is at or below of the Department of Health and Human Services Poverty Guidelines.

7. Minority Populations & Areas - Minority populations include those persons who self- identity as being one or more of the following ethnic groups: American Indian and Alaska Native, Asian, Black or African American, Hispanic or Latino, Native Hawaiian and Other Pacific Islander, as defined in the FTA Title VI Circular. "Minority Areas" are residential land use areas within Census tracts where the percentage of minority persons is higher than the Metro service area average.

8. Revenue Mile - For technical purposes, one revenue mile represents a bus being on the road for one mile. Three revenue miles represents one bus being on the road for three miles or three buses being on the road for one mile each. By using revenue miles instead of revenue dollars, Metro can control for currency inflation and can better prepare for and evaluate major service changes.

9. Route-Level - Refers to the geographic level of analysis by which the performance of a transit route is measured for equity.

10. Route-Service Area - A three-quarter mile buffer on both sides and terminus of a transit route's alignment.

11. Service Level - Refers to the span of service (hours of operation), days of operation, trips, and headways (service frequencies) for a transit route or the regional transit system.

12. Service Area - According to 49 CFR 604.3, geographic service area means "the entire area in which a recipient is authorized to provide public transportation service under appropriate local, state, and federal law."

13. Service Span - The span of hours over which service is operated (e.g., 6 a.m. to 10 p.m.). The service span may vary by weekday, Saturday, or Sunday.

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14. System-wide - Refers to the geographic level of analysis by which the performance of the entire transit system is measured for equity.

15. Transit Center - A transit facility that serves as the connection point for three or more bus routes.

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Fare Equity Analysis Policy

Metro’s Fare Equity Analysis Policy in compliance with applicable federal requirements under Title VI of the Civil Rights Act of 1964, including 49 CFR Section 21, the Environmental Justice requirements under Executive Order 12898 and FTA Circular 4702.1B.

Except for those limited and unique conditions noted below, the FTA requires that recipients of FTA funding prepare and submit fare equity analyses for all proposed fare changes, regardless of whether the proposed change is an increase or decrease. As with the service equity analyses required under Title VI and Federal Environmental Justice requirements, FTA requires Metro to evaluate the effects of fare changes on minority populations and low-income populations. Metro’s Fare Equity Analysis Policy is a stand-alone provision, separate from Metro’s Major Service Change Policy. Metro’s Fare Equity Analysis Policy operates in tandem with all other Metro policies for changing the fare structure, fare media, or fare price.

For purposes of this policy, “minority population” is defined as: Any readily identifiable group of minority persons (persons identified by race, color, or national origin) who live in geographic proximity.

For purposes of this policy, “low-income population” is defined as: Any readily identifiable group of households who live in geographic proximity and whose median household income is at or below of the Department of Health and Human Services Poverty Guidelines.

This policy incorporates by reference the definitions of “Disparate Impact” and “Disproportionate Burden” from Metro’s Title VI Disparate Impact Policy and Disproportionate Burden Policy, respectively.

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This policy incorporates by reference the percentage thresholds for “Disparate Impact” and “Disproportionate Burden” from Metro’s Title VI Disparate Impact Policy and Metro’s Disproportionate Burden Policy, respectively.

For proposed changes that would increase or decrease the fares on the entire system, on certain transit modes, or by fare payment type or fare media, Metro shall analyze ridership surveys, census demographic data, farebox reports, and other sources of information as available to determine whether minority and/or low-income riders are disproportionately more likely to use the mode of service, payment type, or payment media that would be subject to the fare change.

Metro shall then— a. Determine the number and percent of users of each fare media being changed.

b. Review fares before and after the change.

c. Compare the percentage differences for each particular fare media between minority users and overall users.

d. Compare the percentage differences for each particular fare media between low- income users and overall users.

Metro will analyze proposed fare changes to see if the proposed change would result in a disparate impact to minority populations or a disproportionate burden on low-income populations. If a disparate impact or disproportionate burden is identified, Metro must attempt to modify the proposed changes to avoid, minimize, or mitigate potential disparate impacts and/or disproportionate burdens. Metro shall then reanalyze the proposed changes to determine whether the modifications actually removed, minimized or mitigated the disparate impacts of the changes.

Where disparate impacts and/or disproportionate burdens are identified, Metro shall provide a meaningful opportunity for public comment on any proposed mitigation measures, including any less discriminatory alternatives that may be available.

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If Metro chooses not to alter the proposed fare changes despite a disparate impact on minority ridership or disproportionate burden on low-income riders, or if Metro finds, even after the revisions, those minority or low-income riders will continue to bear a disproportionate share of the proposed fare change, Metro may implement the fare change only if:

a. Metro has a substantial justification for the proposed change, and b. Metro can show that there are no alternatives that would have a less disparate impact on minority riders but would still accomplish Metro’s legitimate program goals.

Exceptions: Metro will not require a fare equity analysis for the following conditions: a. Emergencies, or other instances in which Metro may declare that all passengers ride free. b. Temporary fare reductions that are mitigating measures for other actions. c. Promotional fare reductions lasting less than six months in duration.

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Disproportionate Burden Policy

Metro’s Disproportionate Burden Policy, in compliance with applicable federal Environmental Justice requirements under Executive Order 12898 and FTA Circulars 4703.1 and 4702.1B requiring that recipients of FTA funding prepare and submit service and / or fare equity analyses.

The Disproportionate Burden Policy establishes a threshold for determining whether proposed service or fare changes have a disproportionate effect on low-income populations relative to non-low-income populations.

The threshold is the difference between the burdens borne by, and benefits experienced by, low-income populations compared to non-low income populations. Exceeding the threshold means either that a service or fare change negatively impacts low-income populations more than non-low-income populations, or that the change benefits non-low-income populations more than low-income populations.

If the threshold is exceeded, Metro must avoid, minimize or mitigate impacts where practicable.

For purposes of this policy, “low-income population” is defined as any readily identifiable group of households who live in geographic proximity and whose median household income is at or below of the Department of Health and Human Services Poverty Guidelines.

Metro establishes the threshold for a “disproportionate burden” as follows: Should the burden of any fare or major service changes require a low-income population to bear adverse effects twenty-five percent or greater of the cumulative burden compared to the effects borne by the non-low-income population that impact will be considered a disproportionate burden.

Disproportionate Burden will be reviewed on the affected changes on a cumulative basis.

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Should a proposed fare or major service change result in a disproportionate burden, Metro will consider modifying the proposed change to avoid, minimize, or mitigate the disproportionate burden of the change. If Metro finds a potential disproportionate burden and then modifies the proposed changes to avoid, minimize, or mitigate potential disproportionate burdens, Metro will reanalyze the proposed changes to determine whether the modifications actually removed the potential disproportionate burden of the changes. If Metro chooses not to alter the proposed changes, Metro may implement the service change if a.) There is substantial legitimate justification for the change and b.) The agency can show that there are no alternatives that would have less impact on the low-income population and would still accomplish the agencies legitimate program goals.

In accordance with FTA guidance, Metro will not alter this Disproportionate Burden Policy until its next Title VI Program Submission, though Metro maintains the freedom to select the most appropriate and informative dataset for use in low-income population service equity analyses. Metro shall, however, use the same comparison population data in low-income population service equity analyses as it uses for minority population service equity analyses. For example, if Metro uses ridership surveys to determine the comparison population in minority population service equity analyses, Metro will also use ridership surveys to determine the comparison population for low-income service equity analyses.

Metro engaged the public in the decision-making process prior to adopting this Policy, and will do so when altering, or amending this Disproportionate Burden Policy, if needed at the next submission.

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Disparate Impact Policy

Metro has established a Disparate Impact Policy in compliance with applicable federal requirements under Title VI of the Civil Rights Act of 1964, including 49 CFR Section 21 and FTA Circular 4702.1B requiring that recipients of FTA funding prepare and submit service equity analyses for proposed major service or fare changes.

The Disparate Impact Policy establishes a threshold for determining whether proposed service or fare changes disproportionately affect minority populations relative to non-minority populations on the basis of race, ethnicity or national origin.

The threshold is the difference between the burdens borne by, and benefits experienced by, minority populations compared to non-minority populations. Exceeding the threshold means either that a service or fare change negatively impacts minority populations more than non- minority populations or that the change benefits non-minority populations more than minority populations.

A “disparate impact” refers to a facially neutral policy or practice that disproportionately affects members of a group identified by race, color, or national origin, where Metro’s policy or practice lacks a substantial legitimate justification and where there exists one or more alternatives that would serve the same legitimate objectives but with less disproportionate effect on the basis of race, color, or national origin.

Metro defines the threshold for a “disparate impact” as follows: Should the impact of any major service change require a minority population to bear adverse effects twenty-five percent or greater of a cumulative impact compared to those adverse effects borne by the non-minority population, that impact will be deemed a disparate impact unless, there is substantial legitimate justification for the change, and no other alternatives exist that would serve the

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Metro Transit – Title VI Plan 2013 same legitimate objectives but with less disproportionate effects on the basis of race, color or national origin.

Disparate impacts will be reviewed on the affected changes on a cumulative basis.

Should a proposed major service change or any fare change result in a disparate impact, Metro will consider modifying the proposed change to avoid, minimize, or mitigate the disparate impact of the change. If Metro finds potential disparate impacts and then modifies the proposed changes to avoid, minimize, or mitigate potential disparate impacts, Metro will reanalyze the proposed changes to determine whether the modifications actually removed the potential disparate impacts of the changes.

In accordance with FTA guidance, Metro will not alter this Disparate Impact Policy until its next Title VI Program Submission, though Metro maintains the freedom to select the most appropriate and informative dataset for use in minority population service and fare equity analyses. Metro shall, however, use the same comparison population data in low-income population equity analyses as it uses for minority population equity analyses. For example, if Metro uses ridership surveys to determine the comparison population in minority population equity analyses, Metro will also use ridership surveys to determine the comparison population for low-income equity analyses.

Metro engaged the public in the decision-making process prior to adopting this Policy, and will do so when altering, or amending this Disparate Impact Policy, needed at the next submission.

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Service Standards and Policies

Overview

In order to ensure continued progress towards Metro’s objectives and guiding principles implementation of service will require close and systematic monitoring of service performance and delivery. Service standards define a policy level set of evaluation metrics which serve as a management tool to assess the efficiency, effectiveness, and quality of service delivered. Monitoring productivity and financial effectiveness supports Metro’s objective of building long- term financial sustainability and a market-based network. Service standards define benchmarks to inform decision-making on existing and future services.

It is the policy of Metro to provide quality service to all customers regardless of race, color, national origin or income. This document establishes service standards and related policies for Metro's fixed route transit service. In addition to serving as a guide for staff and stakeholders, this document satisfies several requirements with Title VI of the Civil Rights Act of 1964, Executive Order 12898, and related civil rights laws which help assure that Metro's services are provided in a non-discriminatory manner.

The updated Service Standards document defines proposed service tiers for Metro, establishes service performance standards, recommends a methodology for applying service standards, and identifies strategies for future service investments.

This document is broken into four main sections:

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Service Service Products and Design Tiers Standards

Service Service Performance Evaluation Standards Process

Service Products and Tiers

The establishment of the recommended service tiers allow for the classification of Metro service products by network role and market function. Organization of transit service into tiers creates a consistent and balanced approach to service performance monitoring. Figure 1 and Table 1 illustrate recommended service products and tiers.

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BRT/Rapid Corridors Frequent Local

Supporting Local Network Connectors Community Circulators

Commute Express

Service Products & Tiers & ServiceProducts Reverse Commute

Figure 1: Service Products and Tiers Overview

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Service Frequency Description Network Role Key Markets Type Target High frequency, high capacity, and high quality Spontaneous All-day, service that uses transit priority measures to use, transit- all-week Arterial BRT speed travel times. Stop spacing is typically oriented community 10 minutes Rapid Bus greater than local bus with enhanced service corridor, fast and sub-

characteristics intended to emulate the passenger travel and regional experience of arterial rail transit. short waits travel Conventional bus service, operating on a All-day, timetable following a pre-set route with identified Structural Corridors all-week Key stops that typically operate as part of a wider network community Corridor network of integrated routes. May include corridor, fast 15 minutes and sub- Local Bus enhanced service characteristics such as signal sub-regional regional priority, bus lanes or other amenities where service travel appropriate. All-day

Fixed route transit using various size vehicles Network weekday Supporting serving a specific community area with completion community 30 minutes Local Bus connections to the regional and/or sub regional and service and sub- transit network. coverage regional travel Targeted Community Fixed route or flexible route transit using various network travel in less 60 minutes Community size vehicles serving a specific community area connection, transit- or Demand Network Connections Circulators with connections to the regional and/or sub local conducive Based regional transit network. circulation areas Peak hour express bus service with limited stops Freeway or connecting surrounding communities with Peak period Commute key corridor Tailored to downtown and other major regional destinations. regional Express based Demand

Typically accessed via park-and-ride at the travel commute residential end. Peak hour express bus service with limited stops

Express Freeway or Reverse connecting major core area hubs (often Reverse key corridor Tailored to Commute downtown) with employment in surrounding commute based Demand Express communities, serving reverse direction travel commute commuters.

Table 1: Detailed Service Types and Tiers

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Service Design Standards

The dynamic nature of development in Omaha results in changing travel markets and patterns in Metro’s service area. In order for Metro to continuously improve the attractiveness of transit service that it provides to Omaha area residents and visitors, it is imperative that service standards be adopted in order to constantly monitor the quality of service provided as well as determine where new services may be appropriate or what services need to be refined or discontinued. Given budget and equipment constraints it is imperative that Metro has specific standards and guidelines in place to ensure the highest possible quality of service is provided and delivered efficiently and effectively. Figure 2 provides an overview of the service design standards.

Route Design

Service Availability

Stop Spacing and Placement

Connectivity

Service Frequency

Span of Service

Passenger Amenities

Vehicle Assignment ServiceStandards Design New Service Warrants

Figure 2: Service Design Standard

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Route Design

The alignment of each route is a key factor in its ability to successfully serve customers’ mobility needs. Route design refers to route directness, connections to key origins and destinations, and how the route interfaces with other transit tiers and services that comprise the overall network.

 Metro routes should be designed to serve origins and destinations via direct pathways, minimizing out-of-direction movements. This provides a faster trip to attract more customers and fare revenue, while minimizing the cost to provide service.  With the exception of community routes, bus routes should serve major mixed use corridors throughout the service area, avoiding smaller neighborhood streets.  Metro routes should be designed in a hybrid grid and radial crosstown structure, with higher-frequency routes serving major corridors and connecting on-street rather than deviating to serve transfer hubs in the urban core.

Service Availability

The Service Availability standard generally defines how transit service should be provided in the different mobility markets of the service area. This includes defining the maximum allowable walking distance to transit services and how far apart stops should be placed given the type of service that is being proposed or provided currently.

 Transit routes in the urban core should be ideally no closer than one half mile to balance good access with service cost effectiveness. This provides customers with ¼ mile walk access (roughly five minutes) to more frequent service than is possible with closer spaced routes. Placing routes closer should only occur where regular ½ mile spacing is not feasible and/or where market densities support productive service more closely spaced.  Outside of the urban core network route spacing should follow the demand corridors where densities meet minimum requirements for productive service. Areas with fewer than 2,000 residents or jobs per square mile (3.1 per acre) within the Metro service area do not have the necessary density to support productive transit service, and should only

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receive service if a major trip generator activity or unique corridor development is present.

Stop Spacing and Placement

Stop spacing and placement is an important part of the customer experience and balances convenient access with short waits and fast service. Stops spaced further apart allow for higher bus speeds (minimizing travel time for passengers on the bus and potentially reducing operating costs), but require customers to walk further to access service. Stop spacing standards differ by service type, with Rapid stops spaced further apart than Local or community service stops.

The urban core of Omaha is conducive to walking, which should be taken into account in stop spacing decisions. Where grid-based, walkable streets with sidewalks are present, bus stops can be spaced further apart without negatively impacting customer access.

 Rapid bus routes on corridors also served by Local routes should have stops spaced a minimum of ½ mile apart extending up to one mile, and should be placed at major destinations, intersections, and transfer points.  For Local and Community services, stop spacing between 800 and 1,320 feet is desirable. Community services can sustain the most closely-spaced stops (since trip distances are usually short) while Local stops on major arterial streets risk introducing unnecessary delay if stops are placed closer than 1,000 feet. Existing stops with continuously low utilization shall be subject to review for consolidation or removal to increase service speed and reliability.  Express services will use park-and-ride access with additional Rapid-type stopping patterns at the origin end with a Rapid or Local spacing pattern at the destination end. Far-side stop placement for new and relocated bus stops is recommended wherever possible. Far-side stop placement improves bus speed with and without transit signal priority, and improves pedestrian and bicycle safety (crossing the street behind instead of in front of the bus). Stops should be made in the travel lane to maximize speed and safety (pulling in and out

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Metro Transit – Title VI Plan 2013 of traffic increases safety issues) including use of bus bulbs where parallel parking is present. At posted travel lane speeds over 45 miles per hour curb cuts with a reentry lane are recommended.

Connectivity To fully realize success Metro needs customers to “use the network,” rather than just individual routes. This is especially critical for growing transit ridership for non-commute travel, which has much more dispersed patterns and is used less regularly. For customers to “use the network” transfers need to be easy, convenient, and reliable. This means connecting with short waits at major hubs, such as North Omaha Transit Center, or on-street at major intersections. While transfers can usually be timed at major hubs, street transfer waits cannot and must rely on service frequency to minimize wait times. As a result, routes in the urban core network should focus on street transfers for fast network travel, which means that frequent service is necessary to support convenient transfer waits (see frequency standards in the following section). Outside of the urban core network, transfers should focus on hubs where well timed connections between routes can be made in most cases.

Designing the service and network to enable convenient transfers allows Metro to minimize service duplication, since every route does not need to provide a one-seat ride to the customer’s final destination. Within a limited-resource environment, minimizing duplication allows for a more effective use of resources. As a result, new services should not only be evaluated as isolated routes, but also for their role in the overall transit network. Where the demand does not support regular all-day transit, special “first mile/last mile” connections should be considered.

Lastly, the connection experience for the customer is also affected by the waiting facility on the street corner or at the transit hub. Upgraded passenger facilities should be a priority at major on-street transfer locations and hubs, supporting Metro’s brand. Facility attributes should include enhanced shelters, seating, real-time trip departure/other customer information,

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Service Frequency/Vehicle Headway Service frequency defines how long customers must wait for bus service with waits occurring multiple times for customers who transfer to complete journeys. High frequencies result in short customer wait times, but increase costs by requiring more buses and operators. Thus, establishing frequent service requires balancing route and network productivity against cost.

Consumer research shows that the “sweet spot” where frequency provides the maximum value is in the 10-15 minute headway range, resulting in average waits of 5-7½ minutes. Research shows that at 15 minute service levels a significant number of patrons begin to arrive at the stop randomly, rather than timing their arrival around the transit trip. At 10 minute service levels the majority of customers attracted to arrive randomly is higher. The opportunity to just randomly show is the key attribute that attracts the largest market segment of potential riders.

As a result, Metro frequency warrants are:

 BRT/Rapid routes should be both fast and frequent, operating a desired frequency of 15 minutes or better throughout a majority of the day (evenings and possible weekends may require less frequent service), with 10 minutes or better being highly desirable for this style of service. Rapid services should operate more frequently than Local service on the same corridor, to allow maximum customer convenience and greater service effectiveness on the faster service option (carrying passengers at a lower cost per mile).  Local routes should operate at 30 minutes or better throughout the day and week. Local routes on major corridors (especially those without Rapid options) warrant much more frequent service, with 15 minutes or better being desirable.  Community routes should operate every 60 minutes or better to ensure that service remains accessible to passengers who rely on it.  Express and Commuter route frequency should be tailored to demand volumes but should operate 15 minutes or better during peak demand periods to foster spontaneous use.

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All frequency warrants are subject to cost effectiveness and should be adjusted based on productivity and passenger loading capacity needs as defined in the section on Service Performance.

Table 2 illustrates the frequency warrants by transit service tier:

BRT/Rapid Frequent Local Local Community Express

Peak Tailored to 15 mins 15 mins 30 mins 60 mins Demand

Off-Peak Tailored to 15 mins 30 mins 30 mins 60 mins Demand

Evening Tailored to 30 mins 30 mins 60 mins 60 mins Demand

Saturday Tailored to 15 mins 30 mins 30 mins 60 mins Demand

Sunday Tailored to 15 mins 30 mins 30 mins 60 mins Demand

Table 2: Frequency Requirements by Transit Service Tier Span of Service

The span of service defines the start and finish of service each day for both specific routes and the network. A longer span of service allows a route to capture more riders throughout the day for a wider variety of trip purposes, but also increases overall costs.

Span of service standards are more important to differentiate by the type of market/corridor served than the category of service, as local routes serving major regional corridors may have very different span needs than secondary arterials. As well, it is important that the route spans be coordinated to provide appropriate networks to meet time-of-day market needs.

 Metro urban core network service should operate from approximately 4:15am until 11:00pm on weekdays, 6:00am to 10:00pm on Saturdays, and 7:00am to 7:00pm on

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Sundays. Earlier or later service may be required on certain corridors based on markets and patronage.  Community services should be tailored to local demand patterns, but typically should operate from 6:00am to 7:00pm on weekdays.  Express service spans (i.e., trip times) should be tailored to demand patterns.

Passenger Amenities

Metro should provide riders with safe, accessible, and comfortable wait areas. However like many other transit agencies and jurisdictions, resources for providing and improving passenger facilities are limited requiring them to prioritize what and where improvements will be made. The following passenger amenities should be provided as funding permits:

 Transit Centers: Should include a passenger waiting area, a shelter area, passenger seating, trash receptacles, and route maps/schedules for routes traveling through the Transit Center, and digital information such as real-time transit information signage will be placed at transit centers.  Bus Shelters: Should be placed where there is an expected boarding of 200 or more passengers per day. Bus shelters may include lighted advertising panels and bench type seating.  Bus Benches: Should be placed where deemed appropriate by the public and the city. Currently, bus benches are contracted by local jurisdictions with an outside vendor.  Bus Stops: Information at each bus stop should include a Metro's logo, the international bus stop graphic, Metro’s website, phone number to Metro Customer Service, and the TDD number for Metro Customer Service.

Vehicle Assignment

Prior to each operator signup, revenue vehicles are assigned to routes/blocks based on several factors including required vehicle passenger capacity, community or street operating restrictions, operating performance requirements, and special equipment needs. Each service timetable is designed to meet ridership demand through the balancing of frequency or trips using different vehicles with specific capacities assigned to special blocks. Special operating restrictions including tight turns or community vehicle size limitations will also be respected.

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Higher performing vehicle types may be assigned to blocks with more schedule adherence problems. As well, certain blocks may be designated to have buses with special equipment, e.g. branded or wrapped vehicles or signal prioritization equipment. After the special vehicle block needs have been addressed, the remaining vehicles are rotated through random assignment to any route/block on which the vehicle can travel. New Service Warrants

As development patterns and population/employment/school centers continue to evolve, Metro should analyze the need for new services using a set of consistent criteria to ensure that new market opportunities are comprehensively and equitably assessed. New services or improvements to existing services should be evaluated with respect to design standards and consistency with adopted policy principles. Service investment decisions can provide incentives for community support of transit in policy, funding, zoning, and site design.

Planning and implementing new transit service requires an examination of certain characteristics of the proposed service area. The densities and demographic characteristics of a given service area are important determinants of transit success. To determine whether an area warrants new transit service, Metro should analyze the following characteristics of a proposed service:

 Population and Employment Density: A minimum level of density (2,000 residents or jobs per square mile) needs to be present in a given area to support regular bus service. Generally higher density areas are more conducive to effective bus service than low density areas due to greater demand and potential ridership. Above this threshold, the density of the proposed new service area should be compared to the densities of existing Metro areas to identify the most appropriate service type and network structure. Metro can deviate from the minimum density thresholds where there is specific evidence of short term plan implementation of corridor intensification that will result in exceeding the minimum threshold by 50% or more.  Transit Dependent Populations: Certain demographic groups are more inclined to use transit than others such as seniors, the disabled, students, low-income individuals, and households without automobiles. In assessing an area’s demand for transit service it is

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important to examine the presence and intensity of these demographics groups and whether any unmet needs are present.  Key Destinations: Connecting residents with key destinations such as employment centers, hospitals, schools, shopping, and entertainment is a key factor in designing transit service.  Network Integration: Any new service should avoid duplicating existing service (see Service Spacing guidelines), and should link into the existing transit network in a logical manner to ensure that connections to other routes and services provide attractive linked journeys.  Pedestrian Access: Adequate sidewalks should be in place in order to ensure safe access to service.  Safety Considerations: Safety factors include the avoidance of potentially hazardous turns and the availability of traffic signals and stop-sign protection.  Travel Patterns: Consider customer and non-user travel patterns. Customer travel patterns can be collected through interviews and on-board surveys. Data for non-users can be obtained from the region travel demand model.  Routing and Scheduling: Factors such as headways, running times, number of vehicles, and unnecessary deviations and turns should be considered.  Special Funding: Services outside of Metro’s service area should be fully funded through public-private partnerships and/or inter-local agreements.  Projected Performance: In order to ensure ongoing Metro financial sustainability through continued maintenance or improvement of Metro service productivity, new routes should be projected to perform at levels at or exceeding system average based on the metrics outlined in the Service Performance section. New services depend on long term budget availability and can only be initiated when funding allows, either through resource reallocation, additional fare revenue, or new sustained outside funding. Testing of new service with special limited term funding (e.g., JARC) should be undertaken as long as post-trial period funding is identified to sustain the service following a successful trial period.

Introduction of all new services should be subject to a trial period of 12 months to meet minimum performance standards within the appropriate service category. If the new service

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Metro Transit – Title VI Plan 2013 does not meet minimum performance standards within six months, the route should be evaluated for adjustments with a second evaluation at 12 months. If the route continues to fall below minimum performance standards after 12 months, the ’trial” service should automatically “sunset” (be discontinued) unless approved for an extension of the trial period.

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Service Performance Standards

Service performance standards are necessary to ensure that all services are fulfilling their roles in the transit network and contributing to the overall financial sustainability of Metro. Performance should be measured regularly in order to identify changes in performance over time, and to allow prompt changes to be enacted if necessary. Performance standards help ensure that Metro services are useful to customers as well as cost-effective for the agency.

Key Performance Metrics

Service performance standards may be measured using a number of industry best practice key performance indicators (KPIs). These fall into three distinct groups, the first two groups focused on efficiency and effectiveness, the third on service quality (see Figure 3):

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Passengers per Revenue Hour Efficiency & Effectiveness Passengers per One-Way Trip

Farebox Recovery Ratio Cost Effectiveness Subsidy per Passenger Boarding

On-Time Performance (service predictability) Service Quality Load Standards (service availability & comfort) Service Performance Standard ServicePerformance

Figure 3: Service Performance Standards

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Minimum Service Effectiveness Measures

Passengers per Revenue Hour (PPH) This KPI measures service effectiveness or productivity based on ridership (unlinked passenger trips) generated for each hour of service operated.

Current Metro route-level performance for these metric ranges from approximately 10 passengers per revenue hour to 30 passengers per revenue hour on weekdays, and from approximately 6 to over 25 passengers per revenue hour on weekends.

Table 3 shows the following recommended minimum thresholds required to justify service. There are different minimum expectations for each service category and day of the week. Express services should not be evaluated on a passenger’s per hour basis, as there is less passenger turnover leading to lower boardings overall but longer trip distances. Express service is evaluated on passengers per one-way trip basis.

Minimum Passenger Boardings per Revenue Hour

Category Weekday Weekend

Rapid 30 25

Key Corridor Local 20 15

Supporting Local 15 10

Community 15 10

Table 3: Passenger Boardings per Revenue Hour Threshold

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Passengers per One-Way Trip This indicator measures the average boardings per one-way trip. It is useful in evaluating express or “point-to-point” services where passengers board at the start of the trip and alight at the end of the trip, with little to no activity in between. Passengers per one-way trip provides a way to gauge how full the bus is during its journey. A typical Metro vehicle has 40 seats, and effective service should generate enough passengers to fill a majority of those seats.

Minimum Passenger Boardings Per One-Way Trip

Category Weekday

Peak Express 30

Table 4: Passenger Boardings per One-Way Trip Threshold Relative Service Effectiveness Measures and Corrective Action Guidelines

Along with minimum performance standards, routes should be evaluated in comparison with each other for service efficiency and effectiveness. Metro should derive the system wide average for each metric and determine how each route performs compared with the system average. For example, if the system wide average is 20 passengers per revenue hour, and one route generates 15 passengers per revenue hour, that route performs at 75% of system average.

Based on percentage of system average, the routes should be evaluated within the following categories:

 Low-performing service: 50% of system average and below  Average-performance service: Between 51% and 149% of system average  High-performing service: 150% of system average or better

The sections below include action plans for routes falling into these categories. Routes in the low and high categories may warrant more intensive actions, while routes towards the middle

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Metro Transit – Title VI Plan 2013 are adequately fulfilling their roles in the network and are unlikely to need major attention between major system-wide studies.

Low-Performing Service (50 percent or lower of system average)

Routes which rank within this category should be reviewed to determine their potential for improvement. Remedial actions include any and all of the following:

 Segment Level Analysis: A segment level analysis of a low-performing service may highlight a specific portion of the route that significantly reduces the overall performance, causing it to perform below the standard for its service class. If a low- performing segment is identified, it can be modified to attempt to raise productivity for the route as a whole. If the results of a segment level analysis turn out to be inconclusive, however, modifications to the entire route should be considered.

 Operational Analysis: Often the difference between meeting and failing minimum performance standards is an inefficient or ineffective schedule that requires unnecessary vehicle resources. Realigning service to cover only critical segments or eliminating unnecessary delay (e.g. deviations) are ways to reduce travel time and save resources.

 Targeted Marketing: Marketing tactics can help to raise the public awareness of a route in need of remedial action. Poor ridership may be occasionally a result of a lack of public knowledge of a route, and investing in marketing can reverse this trend. This can be the case for concentrated market groups like employment centers, shopping districts, schools, hospitals, agencies, and other major destinations.

 Rider Outreach: Onboard surveys and rider interviews are methods for gaining valuable information on how a route can be improved. These methods can reveal information about popular destinations that a route may bypass, or other attributes of a service that may be holding back ridership growth.

 Change in Service Levels: Adjusting the available service along a low-performing route – by any combination of frequency, span, or service day changes that reduces operating resources and costs – to better match the transit product to its market, and subsequently increase productivity.

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 Discontinuation: Discontinuation is the final option for a low-performing route that does not meet minimum performance standards, and can be applied to a route segment or the route as a whole. If none of the aforementioned remedial actions are successful in raising productivity above the minimum standard for its service class, discontinuation may be necessary to ensure effective use of resources and maintain overall system financial sustainability. Remedial actions to discontinue service should assess the effects on disadvantaged or vulnerable riders (Title VI/EJ populations) and allow time for these riders to make other mobility arrangements.

 Delayed action: Remedial actions involving service level changes and discontinuation can be delayed only in circumstances where demonstrable changes are expected from external factors in the short term that are likely to result in significant improvement in service performance. Such changes may include such factors as new market densification (short term planning and construction), delayed availability of replacement service, or short term corridor circumstances (e.g., road construction) that have artificially decreased demand.

Average-Performing Service (51 to 149 percent of system average) Routes in this category are adequately fulfilling their roles in the transit network, and no remedial action is required. These routes should be monitored on an ongoing basis to determine whether their performance improves, decreases, or remains steady. While no particular action is necessary, ranking in this category does not preclude service adjustments at the discretion of Metro.

 Actions: Routes in this category perform well as a whole; however, their average performance may point to routes which perform equally throughout their length or those which may contain segments of very high and also low performance. Routes in this category should undergo a trip-by-trip or segment-level analysis periodically to determine whether they are average overall, or include trips or segments which fall into the more extreme categories. Segments which would be considered low or very high performers should be subject to the actions detailed in those sections.

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High-Performing Service (150 percent or higher of system average) Routes ranking in this category suggest the need for greater investment, as high performance may signal the presence of significant latent demand. Actions for high-performing routes include:

 Increase service levels: Increasing frequency can help make service more attractive to a wider pool of potential customers, including those that currently drive. High frequencies provide dependable service with minimal waits, encouraging passengers to arrive randomly without consulting a schedule. Increasing service levels by adjusting the service’s frequency, span, or days of week served should be monitored to ensure that high performance is maintained above the 100 percent level as service is added.

 Upgrade transit operating environment: Providing additional customer and operational amenities can provide an improved customer experience. Adding operating improvements such as signal priority, bus bulbs, or bus lanes can improve performance by making service faster and more reliable. Providing additional amenities at route stops such as bus shelters, benches, and real-time bus information can also heighten the perception of higher-quality service.

 Introduce additional service types (Rapid): High-performing corridors may warrant the upgraded service quality of Rapid bus service with or without Local underlays. Very high-performing corridors should be analyzed for the need to introduce new Rapid service.

This category of routes constitutes the top-performing tier of the entire Metro system and essentially the system’s critical service spines that support the overall network. It is very important to maintain a high-quality level of service as well as to continue further investment. It is important to monitor these routes and make investments in key areas that are aimed at further improving overall service.

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Service Quality Measures

Passenger Loads Passenger loads refers to how many people are on the bus at any given moment compared to its capacity both seated and standing. High passenger loads results in overcrowded conditions, which may require additional service to address the issue1.

Service quality issues with crowding are dependent on the amount of time that customers must stand on the bus. If crowding is a relatively brief phenomenon, it does not justify the expense of adding additional service. Table 5 illustrates the proposed maximum load standards by

Category Maximum Load Standard Rapid 125% of seated capacity for two or more miles Local (Key Corridor, 125% of seated capacity for two or more miles Supporting) Community 125% of seated capacity (short duration routes) Express 125% of seated capacity for two or more miles service category.

Table 5: Maximum Load Standard by Service Vehicle Type

Short term fluctuations in ridership associated with fuel cost increases and special- events do not apply to these load standard criteria.

1 Metro considers a route to be overcrowded if 25 percent or more of one-way vehicle trips on a given route exceed the maximum load standard. 132

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On-Time Performance An on-time performance standard defines a minimum threshold of Metro daily trips by route and for the system that operate on-time. On-time performance reflects both the quality and reliability of service, which can affect whether or not people choose to use transit or continue to use transit.

Metro currently defines “on time” as zero to 3 minutes late at each timepoint, a standard unnecessarily tight compared with the industry best practice standard of one minute early to 5 minutes late at each timepoint. The industry standard represents a better balance of quality and efficiency for the customer.

In addition, Metro should adopt a minimum goal of 85% on-time performance system wide, also an industry standard that balances performance and cost. This standard results in a customer experience that is most often very good while recognizing that there are operating issues beyond Metro’s control on some days.

Data Needed for Service Performance Monitoring The performance measures discussed above require the regular collection and updating of the following data sources:

 Ridership: Total number of boardings and on-board load by route and day of the week should be collected regularly. Manual collection of ridership and operating data is expensive and time consuming; which means it is not undertaken frequently. Metro should consider investing in Automatic Passenger Counter (APC) systems which cost- effectively collect ridership and operating data daily and allow for trends over time to be examined.  Resources: The number of vehicles and revenue hours per route by day of the week should be collected from Metro scheduling information.  On-Time Performance: Departure times at each timepoint (and arrival at final timepoint) should be collected regularly. This data is provided by both Automatic Vehicle Location (AVL) and Automatic Passenger Counter (APC) systems.

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Service Evaluation Process

The service evaluation process is conducted in order to ensure the continued performance of individual services, as well as the overall network. This evaluation is intended to improve service design and productivity within categories, which is important to ensure that Metro offers a consistent system that is easy for customers to use and easy for Metro to promote, manage, and administer. Figure 4 illustrates the service evaluation process.

Monthly

Data Analysis Quarterly

Annually Public Input & Review

Title VI & Environmental Justice Service Evaluation Process ServiceEvaluation

Figure 4: Service Evaluation Process

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Service Evaluation Timeline

Monthly & Quarterly Route Performance Analysis In preparation for each service change, at least three times per year, service performance measures should be reviewed according to the metrics and standards outlined above. The service performance report should provide information to allow for immediate actions that can be made with the next operator sign-up to modify service (frequency or alignment changes). Monthly metrics of efficiency and effectiveness KPIs including Passengers per Revenue Hour and Passengers per One-Way trip, will be provided as a part of the regular reporting, but commentary and potential actions will be provided prior to each service change.

Triennial System Analysis Metro will conduct system-level performance analysis of individual routes and route segments at least once every three years. Cost effectiveness and Service quality KPIs will be reported at least once every 3 years as part of the system-level performance review. This report should also analyze market trends affecting route performance including service and fare changes, seasonal differences, operational issues, employment trends, and gas prices. Title VI implications, as well as the route network implications relative to ADA service provisions, should be considered with recommendations for route modifications as necessary to achieve or maintain the performance measures adopted by Metro.

The annual system analysis should identify routes not meeting performance measures for alignment modifications, scheduling adjustments, and/or additional marketing. New service(s) may also be proposed along with proposals for elimination of non- productive service. The results of this analysis should provide the basis for development of the following years’ service plan for the annual budget. The timing of analysis should be done accordingly.

Also as part of the annual system analysis, new performance measures may be proposed and existing measures modified or removed.

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Title VI Analysis

At least once every three years, in conjunction with the Title VI submission, Metro will monitor service standards and policies to compare the services provided in minority areas to non- minority areas. As provided for in the regulation and next section, a minority route is a transit route in which at least one-third of the revenue miles are located in a Census block where the percentage of the minority population exceeds the percentage of the minority population in Metro’s service area as whole which will be used in this analysis. The service standards and polices, as defined in this section, to be monitored are:

 Service Standards: o Vehicle Load o Vehicle Headway o On-Time Performance o Service Accessibility  Service Policies: o Vehicle Assignment o Distribution of Transit Amenities

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Demographic and Service Profile Maps and Charts

Background

Transit service providers that operate 50 or more fixed route vehicles in peak service and are located in urbanized areas (UZA) of 200,000 or more people, or that otherwise meet the threshold defined in Chapter IV, are required to prepare demographic and service profile maps and charts to determine whether and to what extent transit service is available to minority populations within the recipient’s service area. Transit providers shall include charts and tables summarizing data in their Title VI Programs.

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Metro Service Area Statistics

Total Population 476,674

Total Non-Hispanic White 329,950

Total Percent Minority 30.78%

Total Census Blocks (with population) 7,780

Total Block Average % Minority 29.67%

Total Minority Blocks (exceeds Block Average) 2,885

Statistic from within 1/4 mile of any bus route

Total Pop Total Pop 329,511 NHisp_Tot Non Hispanic total 278,143 84.4% NH_WH Non-Hispanic White 207,330 62.9% NH_BL NH Black 51,598 15.7% NH_AI Nh American Indian 2,134 0.6% NH_AS NH Asian 8,107 2.5% NH_PI NH Pacific Islander 269 0.1% NH_Other NH Other 748 0.2% NH_2More NH Two or More Races 7,957 2.4%

Hisp_Tot Hispanic Total 51,368 15.6% H_WH Hispanic White 19,301 5.9% H_BL H Black 803 0.2% H_AI 1,079 0.3% N_AS 98 0.0% N_PI 70 0.0% H_Other 26,803 8.1% H_2More 3,214 1.0%

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Demographics Demographics Demographics Demographics Demographics within 1/4 mile within 1/4 mile within 1/4 mile within 1/4 mile within 1/4 mile

Minority_Length_M Percent_Length_ Total_Blocks_With_P Total_Minority_ Route_Percent_ Avg_Block_PercentMi LineName LengthMI i Minority op Blocks Minority_Population Sum_Total_Pop nority ROUTE 2 16.53 2.84 17.17% 299 107 29.96% 19,633 26.80% ROUTE 3 25.43 10.95 43.07% 769 587 57.26% 44,316 57.95% ROUTE 4 22.22 5.70 25.68% 606 219 32.41% 39,144 26.74% ROUTE 5 68.71 16.92 24.62% 1428 743 40.60% 92,668 41.41% ROUTE 7 14.36 9.34 65.04% 456 377 62.63% 30,231 58.78% ROUTE 8 40.61 18.91 46.58% 1164 684 45.83% 64,921 45.68% ROUTE 9 10.02 3.62 36.11% 266 160 48.29% 17,603 42.67% ROUTE 11 36.02 6.47 17.96% 678 266 35.18% 48,268 29.02% ROUTE 13 46.57 12.94 27.79% 867 491 44.01% 57,510 39.14% ROUTE 14 38.86 11.97 30.79% 914 497 42.19% 56,206 42.85% ROUTE 15 50.62 6.19 12.22% 746 266 32.08% 54,080 26.89% ROUTE 16 21.93 4.55 20.77% 347 235 60.59% 13,401 59.32% ROUTE 18 27.26 11.72 42.99% 746 511 52.54% 38,412 56.74% ROUTE 22 11.69 1.25 10.69% 108 19 20.61% 11,563 16.79% ROUTE 24 18.35 9.37 51.05% 488 429 61.71% 26,159 69.33% ROUTE 25 12.04 8.00 66.38% 429 405 73.83% 19,354 76.40% ROUTE 26 14.08 9.28 65.92% 460 434 70.89% 21,946 74.28% ROUTE 30 17.27 6.91 39.98% 430 313 56.39% 18,364 59.25% ROUTE 32 21.18 4.97 23.46% 406 180 40.35% 32,442 33.89% ROUTE 34 52.98 10.55 19.91% 744 474 48.71% 43,958 49.13% ROUTE 35 15.07 6.79 45.07% 443 388 66.79% 21,017 73.45% BLUE 20.01 1.53 7.65% 379 58 15.59% 20,280 14.94% YELLOW 25.96 1.34 5.16% 447 96 19.00% 20,344 18.38% ROUTE 55 55.47 6.65 12.00% 789 289 33.48% 58,070 27.40% ROUTE 92 30.66 3.18 10.37% 358 120 27.43% 24,284 25.54% ROUTE 93 33.26 2.70 8.11% 483 201 36.73% 36,341 31.03% ROUTE 94 33.13 1.77 5.35% 380 147 33.02% 31,121 29.43% ROUTE 95 46.68 8.62 18.48% 743 417 47.04% 45,880 39.84% ROUTE 96 34.82 2.48 7.11% 421 165 34.35% 35,848 30.04% ROUTE 97 32.48 1.75 5.39% 369 145 34.28% 28,957 29.74%

ROUTE 152 98 24.10 7.22 29.95% 526 179 29.26% 39,916 25.26% ROUTE 200 2.32 0.17 7.31% 30 8 26.02% 2,383 25.09%

Routes highlighted in yellow are considered minority routes for the purposes of the monitoring program in that one-third or more of the route miles travel through a Census block that is a minority census block. Metro Transit – Title VI Plan 2013

Demographic Ridership and Travel Patterns

Metro conducted an on-board transit passenger survey in October 2012 that gathered information about passengers and their one-way transit trips across the entire Metro network of local and express bus routes. Metro collected 4,391 surveys during the weekdays and 2,110 weekend surveys. The surveys were available in both English Spanish and were offered to all passengers on selected trips distributed across the system as a self-administered survey. Surveyors assisted passengers with the completion of the survey as requested.

# of Surveys English Spanish Weekday 4,391 4,319 72 Weekend 2,110 2,072 38 Total 6,501 6,391 110

Self-Reported Demographic Breakdown of Riders Black/African White, Hispanic Asian American Other Multiple Total American Non- Indian selections Responses Hispanic Weekday 1,678 1,531 207 96 108 89 164 3,873 Weekend 668 682 95 34 41 35 44 1,599 Total 2,346 2,213 302 130 149 124 208 5,472

Demographic data is available by route, trip purpose, and other salient characteristics and will be used in service and fare equity analyses as appropriate.

Demographic Breakdown by Fare Payment Type The following chart shows the demographic breakdown by fare payment method for all weekday and weekend surveyed passengers and will be used in any fare equity analysis.

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Cash Fare Black/African White, Hispanic Asian American Other American Non- Indian Hispanic Weekday 48.2% 36.1% 6.8% 1.4% 4.7% 2.7% Weekend 42.3% 44.6% 6.2% 2.5% 2.6% 1.9%

10 Ride Card Black/African White, Hispanic Asian American Other American Non- Indian Hispanic Weekday 43.2% 40.1% 4.3% 4.3% 5.4% 2.7% Weekend 52.9% 36.3% 4.0% 0.7% 2.9% 3.2%

30 Day Pass Black/African White, Hispanic Asian American Other American Non- Indian Hispanic Weekday 38.7% 47.1% 4.6% 3.0% 3.7% 3.0% Weekend 36.4% 55.5% 3.0% 0.0% 3.4% 1.7%

University Pass Black/African White, Hispanic Asian American Other American Non- Indian Hispanic Weekday 43.4% 36.5% 9.1% 4.2% 3.1% 3.6% Weekend 61.5% 25.0% 4.2% 7.3% 0.0% 2.1%

One Ride Card with Transfer Black/African White, Hispanic Asian American Other American Non- Indian Hispanic Weekday 50.0% 30.0% 7.6% 0.8% 7.3% 4.3% Weekend 60.0% 26.7% 10.0% 0.0% 3.3% 0.0%

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Travel Patterns: The origin and destination data from the October 2012 on-board survey was then used to identify travel patterns and linked trips for all passengers on Metro’s system as illustrated in the following map.

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Monitoring Program

Background

FTA requires transit providers that operate 50 or more fixed route vehicles in peak service and are located in urbanized areas (UZAs) of 200,000 or more people, to monitor their service standards and policies to compare the service provided in minority areas to non-minority areas. As provided for in the regulation, a minority route is a transit route in which at least one-third of the revenue miles are located in a Census block, Census block group, or traffic analysis zone where the percentage of minority population exceeds the percentage of minority population in the service area. For the purposes of monitoring past performance, Metro relied on the classification of routes as either minority or non-minority as defined in the most recent approved Title VI plan.

The monitoring of service standards and policies compares the level of service provided to predominantly minority areas with the level of service provided to predominantly non-minority areas to ensure the end result of policies and decision-making is equitable. These service standards and policies are evaluated for each mode. Metro does not operate rail or other modes of service. The following analyses are for all fixed route bus service operated by Metro. The evaluated service standards and policies are:

 Service Standards: o Vehicle Load o Vehicle Headway o On-Time Performance o Service Accessibility  Service Policies: o Vehicle Assignment o Distribution of Transit Amenities

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Service Standards:

Vehicle Load Analysis

Metro conducted a Vehicle Load Analysis of its system in 2012. According to Metro’s current Service Standards and Policies, the Vehicle Load Factor should not exceed 100% for express routes, 110% for local routes during off-peak hours, and 125% for local routes during peak periods.

Methodology

A random sample of 208 one-way trips (the same used for National Transit Data Base “NTD” sampling) was selected and peak loads were recorded for each trip. A “Load Factor” was then calculated based on the peak load as a percentage of the vehicle’s seated capacity.

Assessment

Of the 208 trips sampled, only one trip on express route 92 experienced a load factor beyond Metro’s Service Standards (109.4%). As route 92 is a non-minority route, this load factor did not represent a disparate impact. Figure 1 shows average load factors for both minority (24.8%) and non-minority (23.2%) routes, neither of which represent issues of vehicle capacity. Individual route samples that experienced a vehicle load above the system average are highlighted in blue.

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Figure 1 . Vehicle Load Analysis 2012

Trips Load Route Sampled Factor Non-Minority Routes 93 1 5.6% 32 10 12.7% 1 3 15.7% 22 5 16.2% 98 2 17.1% 11 10 19.9% 15 13 23.7% 41 1 31.3% 43 3 39.3% 55 5 45.6% 97 2 57.0% 92 2 61.7% Non-Minority Total 57 24.8% Minority Routes 48 1 5.3% 200 10 8.1% 25 6 12.3% 26 5 12.6% 8 10 14.3% 9 3 14.8% 16 3 15.3% 5 6 20.7% 3 10 23.4% 4 9 24.8% 96 1 25.0% 24 12 25.2% 18 15 25.7% 35 6 25.8% 7 16 28.2% 13 7 28.5% 30 10 29.2% 2 14 30.4% 14 7 33.4% Minority Total 151 23.2%

SYSTEM TOTAL 208 23.7%

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Vehicle Headway Analysis

Metro conducted an analysis of its system to evaluate the frequency of service for minority and non- minority routes. Figure 2 below shows the number of routes operating and the average headway in minutes for minority and non-minority routes by time of day for weekday, Saturday, and Sunday service.

Methodology

A review of all schedules and frequencies as of 2012 was conducted by weekday peak hour, weekday mid-day, weekday night, Saturday day, Saturday night, Sunday day and Sunday night.

Assessment

Overall, Metro operates more service on minority routes throughout the week, and at higher frequencies than non-minority routes.

Figure 2 . Vehicle Headway Analysis 2012

Weekday Saturday Sunday Minority Routes Peak Hour Mid-Day Night Day Night Day Night Routes Operating 22 15 12 14 12 13 0 Average Headway (Min.) 33 49 83 69 86 73

Non-Minority Weekday Saturday Sunday Routes Peak Hour Mid-Day Night Day Night Day Night Routes Operating 12 7 3 6 2 3 0 Average Headway (Min.) 39 56 80 88 90 90

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On-Time Performance Analysis

Metro conducted an On-Time Performance Analysis of its system in 2012. According to Metro’s current Service Standards and Policies, a bus was considered to be on time if it arrived at a published time point zero minutes early and no more than three minutes late. Many factors affect bus on-time performance. Some of the factors are within Metro’s control, such as mechanical or driver problems. Other factors such as traffic, weather, or unplanned detours dues to construction, accidents and similar disturbances are outside Metro’s control. Methodology

A random sample of 208 one-way trips ( NTD sampling) was selected and reviewed using archived video surveillance. For each trip, one time point was selected in sequence for comparison with the published schedule. (For the first sampled trip, the first time point was reviewed, for the second sampled trip, the second time point was selected, etc.) Each trip was then classified as either “On Time” or “Not on Time” based on the reviewed time point. Assessment

Figure 3 shows that 80.8% of total sampled trips were considered on time. Non-minority routes reflected an on-time percentage of 84.2, while 79.5% of minority routes were found to be on time. Individual route samples that experienced greater delay than the system average are highlighted in red. These findings suggest that on-going monitoring of on-time performance to assess potential disparate impacts is warranted. Metro will continue training efforts to help bus operators and dispatchers minimize delay, especially on minority routes. Metro also plans to purchase Automatic Vehicle Locating equipment for the bus fleet to better monitor on-time performance on all routes.

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Figure 3 . On-Time Performance Analysis 2012

Trips Percent Route Sampled On Time

Non-Minority Routes 41 1 100.0% 93 1 100.0% 97 2 100.0% 15 13 92.3% 11 10 90.0% 32 10 90.0% 22 5 80.0% 55 5 80.0% 1 3 66.7% 43 3 66.7% 92 2 50.0% 98 2 50.0% Non-Minority Total 57 84.2%

Minority Routes 2 14 100.0% 13 7 100.0% 16 3 100.0% 48 1 100.0% 96 1 100.0% 200 10 100.0% 30 10 90.0% 5 6 83.3% 24 12 83.3% 25 6 83.3% 18 15 80.0% 4 9 77.8% 14 7 71.4% 8 10 70.0% 35 6 66.7% 7 16 62.5% 3 10 60.0% 26 5 60.0% 9 3 33.3% Minority Total 151 79.5%

SYSTEM TOTAL 208 80.8%

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Service Availability Analysis

Metro conducted an analysis of the availability of service within the service area. Methodology

Metro used 2010 Census block data to calculate the percentage of individuals residing within ¼ mile of a transit route as of May 2013 for both the system as well as the percentage of minorities within ¼ mile by route. Assessment

Figure 4 below shows the percentages of minority and non-minority residents served in the Metro service area. The percentage of minority residents within ¼ mile walk of a route was 83.3%. The percentage of all residents in the service area within a ¼ mile of a route was 69.1%. Figure 5 shows the average block percentage of minority residents within ¼ mile of each route. Overall, the percentage of minorities in the service area within ¼ mile of a route is higher than the percentage of the entire population within the service area that is within ¼ mile from a route.

Figure 4: Service Availability Analysis of System

Residents Within ¼ Mile More than ¼ Mile

Minority 83.3% 16.7%

Non-Minority 62.8% 37.2%

System 69.1% 30.9%

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Figure 5: Service Availability Analysis by Route

Demographics within ¼ Mile Route Average Block Percent Minority

2 26.80% 3 57.95% 4 26.74% 5 41.41% 7 58.78% 8 45.68% 9 42.67% 11 29.02% 13 39.14% 14 42.85% 15 26.89% 16 59.32% 18 56.74% 22 16.79% 24 69.33% 25 76.40% 26 74.28% 30 59.25% 32 33.89% 34 49.13% 35 73.45% Blue 14.94% Yellow 18.38% 48 45.47% 55 27.40% 92 25.54% 93 31.03% 94 29.43% 95 39.84% 96 30.04% 97 29.74% 98 25.26% 200 25.09%

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Service Policies

Vehicle Assignment Analysis

Metro conducted a Vehicle Assignment Analysis of its system in 2012. According to Metro’s current Service Standards and Policies, older, high floor vehicles* shall be distributed equally across all bus routes.

Methodology

A random sample of 208 one-way trips ( NTD sampling) was selected and vehicle age was recorded for each trip. Additionally, each vehicle was classified as either “low floor” or “high floor”.

Assessment

Figure 6 shows that 76.4% of total sampled trips were operated by low floor vehicles, with an average age of 5.6 years. Non-minority routes had a low floor percentage of 80.7, and vehicles on these routes had an average age of 5.1 years. However, 74.8% of minority routes had low floor vehicles, with an average age of 5.8 years. Individual route samples with an older average fleet age or lower percentage of low floor vehicles compared to the system averages are highlighted in red. These findings suggest that additional monitoring of vehicle assignment to assess potential disparate impacts is warranted. Metro will continue to examine the placement of vehicles to ensure that all vehicles are rotated equitably throughout the system. Metro also will continue efforts to replace aging high floor vehicles as funding permits.

* Metro’s fleet is 100% ADA accessible. All high floor vehicles are lift equipped.

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Figure 6 . Vehicle Assignment Analysis 2012

Trips Average Percent ROUTE Sampled Age Low Floor

Non-Minority Routes 22 5 5.6 100.0% 41 1 2.0 100.0% 43 3 8.3 100.0% 55 5 4.0 100.0% 93 1 12.0 100.0% 15 13 4.2 92.3% 11 10 4.2 90.0% 32 10 4.2 70.0% 92 2 8.5 50.0% 97 2 7.5 50.0% 98 2 13.0 50.0% 1 3 3.0 0.0% Non-Minority Total 57 5.1 80.7%

Minority Routes 35 6 3.7 100.0% 48 1 12.0 100.0% 9 3 5.0 100.0% 7 16 3.9 93.8% 24 12 5.3 91.7% 30 10 5.4 90.0% 4 9 7.6 88.9% 18 15 6.3 86.7% 2 14 5.1 85.7% 3 10 6.2 80.0% 26 5 2.0 80.0% 16 3 5.7 66.7% 13 7 10.0 57.1% 14 7 3.9 57.1% 5 6 6.5 50.0% 8 10 6.0 40.0% 200 10 7.9 40.0% 25 6 8.2 33.3% 96 1 3.0 0.0% Minority Total 151 5.8 74.8%

SYSTEM TOTAL 208 5.6 76.4%

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Distribution of Transit Amenities Analysis

Metro conducted an analysis of the distribution of transit amenities throughout the system in 2012 to ensure equitable distribution. According to Metro’s current Service Standards and Policies, bus shelters shall be installed where there is an expected boarding of 200 or more passengers per day, funding permitting. Bus benches are placed where deemed appropriate by the public and are contracted by local jurisdictions with an outside vendor and beyond the control of Metro. Signs at all bus stops include a Metro logo, the international bus stop graphic, and Metro’s website and phone numbers (voice and TDD). At stops with transfer opportunities, route numbers are posted. Metro does not have elevated transit centers or bus shelters and does not have escalators/elevators.

Methodology

Metro classified all existing bus stop shelters and transit centers as located in either a minority or non- minority area.

Assessment

Figure 7 shows that Metro has 72 bus shelters installed along its bus routes with 49 or 68.06% serving minority routes.

Metro has five Transit Centers where numerous routes converge providing multi-directional transfer opportunities. As shown in Figure 8, four of the five Transit Centers (80 percent) are located in areas defined as minority / low income communities.

 Figure 7 On the Next Page: Bus Shelter Distribution Analysis 2012

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Address Direction Zip Code Address Direction Zip Code 15 & Farnam WB 68102 73rd & Military MB 68114

16 & Farnam SE 68102 72nd & Mercy Road SE 68124

Farnam at 16 NE 68102 72 & Lawndale SW 68134

Farnam at 16 NW 68102 50th & Dodge NW 68132

35 & Farnam WB 68131 Saddle Creek & Dodge EB 68046

20 & Farnam SE 68102 62 & Dodge WB 68132

24 & Farnam NW 68102 62 & Dodge EB 68132

16 & Harney SE 68102 66th & Dodge MB 68132

16 & Douglas SW 68102 76th & Dodge NE 68114

16 at Douglas NE 68102 Perimeter of Westroads NB 68114

17 & Douglas SW 68102 Perimeter of Westroads NB 68114

19 & Douglas NB 68102 90 & Blondo NW 68114

44 - 42 on Douglas south of Douglas 68131 93 & Maple SE 68134

44 - 42 on Douglas south of Douglas 68131 100 & Maple EB 68134

44 - 42 on Douglas south of Douglas 68131 84 & Center SW 68124

44 - 42 on Douglas south of Douglas 68131 120 & Center SW 68144

35 & Leavenworth EB 68105 122 & Center NE 68144

41 & Leavenworth EB 68105 129 & Center SE 68144

4101 Woolworth Ave Pull out 68105 132 & Center SW 68144

Park Ave & Woolworth NB 68105 139 & Center SE 68144

24 & St. Mary's WB 68102 6303 "Q" Street EB 68117

16 & Pine NB 68108 96 & "Q" SW 68127

21 & Ames WB 68110 110 & "I" NE 68137

37 & Lake EB 68111

23 & Cuming WB 68102

40 & Cuming SB 68131 EB – Eastbound

52 & N.W. Radial WB 68104 WB – Westbound

60 & N.W. Radial NW 68104 SB – Southbound

N.W.Radial & Nicholas SE 68132 NB - Northbound

Park Ave & Dodge NE 68131 NW – Northwest corner

34 & Dodge EB 68121 NE- Northeast corner

42 & Ames SW 68104 SE – Southeast corner

54 & Military WB 68104 SW – Southwest corner

42 & Center MB 68105 MB - Midblock

Florence & Spencer NW 68110

30 & Fort SB 68111

30th & Ellison SB 68111

30 & Webster SE 68131

3O & Binney NW 68111

30 & Clay NB 68112

30 & California SB 68131

24 & Vinton MB 68108

24 & "L" NW 68107

33 & L SB 68107

33 & L NB 68107

42 & Pierce SE 68105

42 & William NE 68105

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Figure 8: Transit Center Distribution Analysis 2012

Transit Center Location

Minority Areas

Benson Park Transit Center 4405 N. 72nd Street

North Omaha Transit Center 4308 N. 30th Street

Downtown Transit Center 16th Street between Douglas and Harney Streets

Metro College Transit Center 2808 Q Street

Total: 4 Transit Centers in areas classified as minority

Non-Minority Areas

Westroads Transit Center 1099 N 102nd Street

Total: 1 Transit Center in areas classified as non-minority

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Title VI Program: Board Awareness, Review and Adoption

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Minutes from the June 27, 2013 Board of Directors Meeting including a presentation and discussion of Title VI are included in the following pages.

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Minutes from the July 25, 2013 Board of Directors Meeting including a presentation and discussion of Title VI are included in the following pages.

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Minutes from the August 22, 2013 Board of Directors Meeting approving the Monitoring of Service Standards and Policies are included in the following pages.

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Minutes from the September 11, 2013 Board of Directors Meeting approving the Title VI Plan are included in the following pages.

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