**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**CENTRAL PUGET SOUND REGIONAL TRANSIT AUTHORITY**

**(Sound Transit)**

**SEATTLE, WA**

**Final Report**

**February 2005**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**MILLIGAN & CO., LLC**

[Table of Contents]{.underline}

I. GENERAL INFORMATION [1](#__RefHeading___Toc51057800)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc51057801)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc51057802)

IV\. BACKGROUND INFORMATION [5](#__RefHeading___Toc51057803)

V. SCOPE AND METHODOLOGY [10](#__RefHeading___Toc51057804)

VI\. FINDINGS AND RECOMMENDATIONS [18](#__RefHeading___Toc51057805)

1\. List of Active Complaints and Lawsuits
[18](#__RefHeading___Toc51057806)

2\. Pending Applications for Financial Assistance
[19](#__RefHeading___Toc51057807)

3\. Summary of Civil Rights Compliance Reviews
[19](#__RefHeading___Toc51057808)

4\. FTA Civil Rights Assurance [20](#__RefHeading___Toc51057809)

5\. DOT Title VI Assurance [21](#__RefHeading___Toc51057810)

6\. Fixed-Facility (Environmental Justice) Impact Analysis
[21](#__RefHeading___Toc51057811)

7\. Demographic and Service Profile Maps, Overlays and Charts
[24](#__RefHeading___Toc51057812)

8\. Service Standards and Policies [25](#__RefHeading___Toc51057813)

9\. Assessment of Compliance by Grantees [28](#refheading___toc51057814)

10\. Other Areas of Title VI Considerations
[30](#__RefHeading___Toc51057815)

11\. Internal Monitoring Procedures 29

12\. Title VI Complaints [37](#__RefHeading___Toc51057817)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[40](#__RefHeading___Toc51057818)

VIII\.
ATTENDEES\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....42

I.  []{#__RefHeading___Toc51057800 .anchor}GENERAL INFORMATION

Grant Recipient: Central Puget Sound Regional Transit Authority

City/State: Seattle, WA

Grantee No: 5656

Executive Official: Ms. Joni Earl

> Director
>
> Central Puget Sound Regional Transit Authority\
> 401 South Jackson Street\
> Seattle, WA 98104

Report Prepared By: MILLIGAN & CO., LLC

105-107 N. 22^nd^ Street, 2^nd^ Floor,

Mulberry Atrium North

Philadelphia, PA 19103

Site Visit Dates: August 17-19, 2004

Compliance Review

Team Members: Denise Bailey

> Lead Reviewer Milligan & Co., LLC

James Buckley

> Reviewer

Milligan & Co., LLC

Diane King

> Reviewer

Milligan & Co., LLC

Judith Bizjak

> Reviewer

Milligan & Co., LLC

II. []{#__RefHeading___Toc51057801 .anchor}JURISDICTION AND AUTHORITIES

The Federal Transit Administration (FTA) Office of Civil Rights is
authorized by the Secretary of Transportation to conduct civil rights
compliance reviews. Reviews are undertaken to ensure compliance of
applicants, recipients, and subrecipients with Title VI of the Civil
Rights Act of 1964, as amended (42 U.S.C. 2000d); Section 12 of the
Master Agreement, Federal Transit Administration M.A. (10), October 1,
2003; and 49 U.S.C. 5332, "Non-Discrimination."

The Central Puget Sound Regional Transit Authority (Sound Transit) is a
recipient of FTA funding assistance and is therefore subject to the
Title VI compliance conditions associated with the use of these funds
pursuant to FTA Circular 4702.1, "Title VI Program Guidelines for
Federal Transit Administration Recipients," dated May 26, 1988. The
program guidelines of FTA Circular 4702.1 define the components that
must be addressed and incorporated in Sound Transit's Title VI Program
and were the basis for the selection of compliance elements that were
reviewed.

[]{#__RefHeading___Toc51057802 .anchor}**III. [PURPOSE AND
OBJECTIVES]{.underline}**

**Purpose**

The Federal Transit Administration (FTA) Office of Civil Rights
periodically conducts discretionary reviews of grant recipients and
subrecipients to determine whether they are honoring their commitments,
as represented by certification, to comply with the requirements of 49
U.S.C. 5332. In keeping with its regulations and guidelines, FTA
determined that a Compliance Review of the Central Puget Sound Transit
Authority (Sound Transit) Title VI Program was necessary.

The Office of Civil Rights authorized Milligan & Co., LLC to conduct the
Title VI Compliance Review of Sound Transit. The primary purpose of this
Compliance Review was to determine the extent to which Sound Transit has
met its General Reporting and Program-Specific requirements, in
accordance with FTA Circular 4702.1, "Title VI Program Guidelines for
Federal Transit Administration Recipients," as represented to FTA. The
Compliance Review had a further purpose to provide technical assistance
and to make recommendations regarding corrective actions, as deemed
necessary and appropriate. The Compliance Review was not an
investigation to determine the merit of any specific discrimination
complaints filed against Sound Transit.

#### 

#### Objectives

The objectives of FTA's Title VI Program, as set forth in FTA Circular
4702.1 are:

-   To ensure that FTA-assisted benefits and related services are made
    available and are equitably distributed without regard to race,
    color, or national origin;

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-   To ensure that the level and quality of FTA-assisted transit
    services are sufficient to provide equal access and mobility for any
    person without regard to race, color, or national origin;

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-   To ensure that opportunities to participate in the transit planning
    and decision-making process are provided to persons without regard
    to race, color, or national origin;

-   To ensure that decisions on the location of transit services and
    facilities are made without regard to race, color, or national
    origin; and

-   To ensure that corrective and remedial action is taken by all
    applicants and recipients of FTA assistance to prevent
    discriminatory treatment of any beneficiary based on race, color, or
    national origin.

    []{#__RefHeading___Toc51057803 .anchor}IV. BACKGROUND INFORMATION

The Central Puget Sound Regional Transit Authority (Sound Transit),
incorporated in September 1993, is a regional public agency with the
mission to develop and deliver a regional public transportation system
to the urban areas in King, Pierce, and Snohomish counties. In November
1996, voters in the three counties approved local taxes to fund *Sound
Move*, a regional transit system plan that incorporates regional express
bus service (Regional Express) commuter rail (Sounder), and light rail
(Link). The plan incorporates over 100 miles of high occupancy vehicle
(HOV) expressway lanes, 82 miles of commuter rail service, and 21 miles
of light rail service.

The plan identifies projects for five sub areas: Pierce County,
Snohomish County, North King County, South King County, and East King
County. It also contains several commitments to the region: distribute
projects equitably by using tax revenues collected in a sub area on
projects in that sub area, implement projects in all sub areas
simultaneously, coordinate service with local transit services,
integrate fares with the other transit service providers, obtain voter
approval for additional system expansion, provide service outside the
existing district only through contracts or district expansion, and hold
planning and operations accountable to the public.

Following the successful passage of the tax measure, Sound Transit
became a fast growing organization with activity in the three lines of
business: Regional Express bus service, Sounder commuter rail service,
and Link light rail service. Sound Transit has initiated service in all
three lines of business.

Regional Express bus service began on nine routes and has expanded to
the current 19 routes. Buses serve major travel corridors; are
accessible; operate day seven days a week in both directions; operate at
relatively high speeds by using high occupancy vehicle (HOV) lanes;
connect two or more major urban centers; cross city or county
boundaries; provide connections to commuter rail, light rail, ferries
and other bus service; and make limited stops. In addition to creation
of a regional bus fleet, Regional Express encompasses more than \$800
million in transportation improvement projects, including new and
improved transit centers, park-and-ride lots, and high occupancy vehicle
(HOV) access lanes and ramps. The current fleet, which is operated under
contract by King County Metro, Pierce Transit, and Community Transit
(Snohomish County), numbers 195 buses. Plans call for expanding the
fleet to 228 buses by 2005.

Sounder (commuter rail) began in September 2000 with service from Tacoma
to Seattle with two a.m. peak and two p.m. peak trains. Sounder
currently provides three a.m. peak and three p.m. peak trains between
Tacoma and Seattle and one a.m. peak and one p.m. peak train between
Everett and Seattle. Full build-out, scheduled for year-end 2007, calls
for nine a.m. peak and nine p.m. peak trains between Lakewood and
Seattle and four a.m. peak and four p.m. peak trains between Everett and
Seattle.

Sounder has a fleet of 11 locomotives, 18 cab cars, and 40 coaches. As
not all the equipment is needed for the current level of service, Sound
Transit leases two locomotives, four cab cars, and 14 coaches to
Virginia Rail Express in Manassas, Virginia; one locomotive, four cab
cars, and eight coaches to MetroLink in Los Angeles, California; and one
locomotive to West Coast Express in Vancouver, British Columbia, Canada.
Sound Transit will call back the equipment as needed for service
expansion. The full build-out will require the whole fleet.

The 1.6-mile Tacoma Link service, which runs between downtown Tacoma and
Tacoma Dome Station, opened August 23, 2003. Sound Transit operates and
maintains Tacoma Link.

On October 24, 2003, FTA signed a full-funding grant agreement for the
Central Link light rail line, which will run from Convention Place in
downtown Seattle to South 154^th^ Street in Tukwila. The 14-mile line
will have 11 stations. Construction began November 8, 2003 and the
Central Link will be completed and operating by 2009. Plans call for
expanding the line to South 200^th^ and north to Northgate as part of
*Sound Move*. Sound Transit intends to contract with King County
Department of Transportation, Transit Division (King County Metro) to
operate and maintain Central Link.

Sound Transit uses a zone fare system for both Regional Express and
Sounder. Fares on Regional Express are \$1.25, \$2.00, and \$2.50 for
adults and \$0.50, \$1.00, and \$1.25 for elderly persons, persons with
disabilities, and Medicare cardholders. (Route 550, operated by King
County Metro, follows King County Metro's fare structure.) Fares on
Sounder are \$2.00, \$3.00, and \$4.00 for adults and \$1.00, \$1.50,
and \$2.00 for elderly persons, persons with disabilities, and Medicare
cardholders. Sound Transit offers one-month, three-month, and 12-month
passes for both Regional Express and Sounder through the regional
transit operators Puget Pass program. Rides on Tacoma Link are free. The
main administrative offices are located at the former Union Station at
the south end of downtown Seattle.

FTA-funded projects completed within the past three years include:

-   **Regional Express**: Lynnwood Transit Center, Bellevue Transit
    Center, Overlake Transit Center, and purchase of diesel and
    compressed natural gas (CNG) buses.

-   **Sounder**: Kent Station, Auburn Station, Everett Station, and
    negotiations with Burlington Northern Santa Fe (BNSF) railroad for
    the Lakewood and Everett alignments.

-   **Link**: Full Funding Grant Agreement from FTA for the Central Link
    light rail line.

FTA-funded projects that are underway include:

-   **Regional Express**: Federal Way Transit Hub, Totem Lake In-Line
    Station, Kirkland Transit Hub, Mercer Island Transit Center,
    park-and-ride, and two-ways operations, hybrid bus procurement, and
    Smart Card regional fare coordination.

-   **Sounder**: Lakewood/SR 512 Station, South Tacoma Station, Edmonds
    Station, Mukilteo Station, Tacoma and Lakewood and Everett to
    Seattle alignments, and safety and security equipment purchases.

-   **Link**: construction of Central Link.

**Racial Breakdown of Sound Transit Service Area**

######### 2000 Census

+-------------------------------------------------+--------------------+
| **Racial/ Ethnic Group**                        | #### Sound Tr      |
|                                                 | ansit Service Area |
|                                                 |                    |
|                                                 | #### Total/        |
|                                                 |                    |
|                                                 | #### Percent       |
+-------------------------------------------------+--------------------+
| #### White                                      | #### 2,037,720     |
|                                                 |                    |
|                                                 | *76.28%*           |
+-------------------------------------------------+--------------------+
| #### Black                                      | #### 150,656       |
|                                                 |                    |
|                                                 | *5.64%*            |
+-------------------------------------------------+--------------------+
| #### Native American                            | #### 28,476        |
|                                                 |                    |
|                                                 | *1.07%*            |
+-------------------------------------------------+--------------------+
| #### Asian                                      | 254,120            |
|                                                 |                    |
| ####                                            | *9.51%*            |
+-------------------------------------------------+--------------------+
| #### Pacific Islander                           | 16,026             |
|                                                 |                    |
|                                                 | *0.60%*            |
+-------------------------------------------------+--------------------+
| #### Other                                      | 67,006             |
|                                                 |                    |
|                                                 | *2.51%*            |
+-------------------------------------------------+--------------------+
| #### Two or more Races                          | 117,299            |
|                                                 |                    |
|                                                 | *4.39%*            |
+-------------------------------------------------+--------------------+
| #### Total Population                           | **2,671,303**      |
+-------------------------------------------------+--------------------+
| #### *Total Minorities*                         | **633,583**        |
|                                                 |                    |
|                                                 | **23.72%**         |
+-------------------------------------------------+--------------------+

[]{#__RefHeading___Toc51057804 .anchor}V. SCOPE AND METHODOLOGY

#### Scope

The Title VI Compliance Review of Sound Transit examined the following
requirements as specified in FTA Circular 4702.1:

1.  [General Reporting Requirements]{.underline} - all applicants,
    recipients and subrecipients shall maintain and submit the
    following:

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a.  list of active Title VI lawsuits or complaints;

b.  description of pending applications for financial assistance;

c.  summary of recent civil rights compliance review activities;

d.  signed FTA Civil Rights Assurance;

e.  signed standard DOT Title VI Assurance; and

f.  fixed-facility impact assessment analysis, if applicable, for
    construction projects.

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2.  [Program-Specific Requirements]{.underline} - all applicants,
    recipients and subrecipients that provide public mass transit
    service in areas with populations over 200,000 shall also submit the
    following:

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a.  demographic and service profile maps, overlays and charts;

b.  service standards and policies;

c.  assessment of compliance by grantees; and

d.  information on other areas of Title VI considerations.

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3.  [Monitoring Procedures for Transit Providers]{.underline} -- all
    applicants, recipients and subrecipients that provide public transit
    service are required to develop and implement procedures to monitor
    their level and quality of transit service to determine compliance
    with Title VI.

4.  [Complaint Process for Title VI]{.underline} -- all applicants,
    recipients, and subrecipients shall have a procedure in place for
    the filing of Title VI discrimination complaints. The procedure
    shall be made available to participants, beneficiaries, and other
    interested parties.

#### Methodology

[Data Collection]{.underline}

Initial discussions were conducted with the Region VI Civil Rights
Officer to review specific Title VI issues and concerns regarding Sound
Transit. A detailed letter was also sent to Sound Transit advising the
agency of the site visit and indicating information that would be needed
and issues that would be discussed.

In the letter, Sound Transit was requested to provide the following
background information:

-   Sound Transit's most recent Title VI Update that was submitted to
    FTA

-   Description of Sound Transit's service area, including general
    population and other demographic information using Census 2000 data

-   Current description of Sound Transit's fixed route services,
    including system maps, public timetables, transit service brochures,
    etc.

-   Any studies or surveys conducted by Sound Transit, its consultants
    or other interested parties (colleges or universities, community
    groups, etc.) regarding ridership, service levels and amenities,
    passenger satisfaction, passenger demographics or fare issues during
    the past three years.

-   Budget documents showing actual capital and operating expenditures
    by department for the past three years.

In the letter, Sound Transit was requested to provide an update of the
following General Reporting Requirements (Chapter III, Section 2 of FTA
Circular 4702.1) since its August 2001 Title VI submittal to FTA.

-   A list of any active lawsuits and complaints

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-   Pending grant applications

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-   Other civil rights compliance reviews during the last three years

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-   Fixed facility impact analysis and, if needed, a program or other
    measures to mitigate any identified adverse impact on the minority
    community

Sound Transit was also requested to provide the following information
and updates on the Program-Specific Requirements in accordance with
Chapter III, Section 3 of FTA Circular 4702.1, since its 2001 Title VI
submittal to FTA.

-   Base map showing census tracts from 2000 census or traffic analysis
    zones (TAZs), identification of major streets and highways, fixed
    transit facilities, and major activity centers or trip generators

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-   Map overlays which show areas with significant minority populations
    based on 2000 census tract data or TAZ, and which show transit
    services (e.g., bus routes, transit centers, garages, etc.)

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-   A population/racial distribution chart which shows the number and
    percentage of each minority group population in each 2000 census
    tract or TAZ

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-   Service standards adopted by Sound Transit for use in measuring the
    level of service provided to minority and non-minority communities.
    This should include standards for vehicle load, vehicle assignment,
    vehicle headway, distribution of transit amenities, and transit
    access

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-   Information collected by Sound Transit for each bus route to monitor
    service for compliance with established service standards, e.g.,
    vehicle load factor analyses, vehicle assignment sheets, vehicle
    headways, and amenities, such as those provided at bus stops.

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-   Results of any analysis performed to compare the level and quality
    of services in minority and non-minority areas

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-   Ridership by route

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-   Passenger boardings by bus stop

-   Maximum load points by route

-   Fleet inventory for buses, by garage or shop, that indicates vehicle
    type, vehicle number, age and key amenities, e.g. air conditioning,
    wheelchair lifts/ramps, soft seating, etc.

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-   Inventory of bus stops which indicates their location and any
    amenities

-   Inventory of rail transit stations that indicates: location in a
    minority or non-minority area (ranked from highest concentration of
    minorities to the least concentration of minorities); date of the
    station opening; list of amenities; any design features that impact
    maintenance and security;

-   Sound Transit criteria for ranking stations to determine allocation
    of personnel and resources (e.g. weekday boardings, number of bus
    trips, etc)

-   Capital expenditures *by rail station*

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-   Listing of service changes in the past three years, including
    increases/decreases in headways, additions/deletions
    extensions/contractions of routes.

In addition, Sound Transit was requested to provide the following other
Program- Specific Requirements in accordance with Chapter III, Section
4, Chapter IV, Section II and Chapter VII, Section 2 of FTA Circular
4702.1:

-   Information about possible service changes over the next three years
    and a description of the effect of these changes on minority
    communities and minority transit users, including additions or
    deletions of routes/lines, extensions or reductions of routes/lines,
    increases or decreases in days and hours of service, changes to
    headway or fares, and additions or deletions of amenities

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-   Description of the methods used to inform minority communities of
    planned service changes

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-   A racial breakdown of all non-elected boards, advisory councils, and
    committees and a description of efforts to encourage minorities to
    participate on these boards, councils and committees

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-   A description of efforts to make communications and information
    available in non-English formats for those minority groups which
    need this assistance and which constitute a significant number or
    portion of the total population

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-   Description of Sound Transit's internal monitoring procedure to
    ensure that its level and quality of service is in compliance with
    Title VI, along with copies of Sound Transit's "level of service"
    and "quality of service" evaluations, including recommendations for
    addressing disparities, if any are identified

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-   Description of the existing Title VI or service complaint process
    and copies of materials available to the public that describe the
    process for filing complaints.

[Site Visit]{.underline}

The site visit to Sound Transit took place August 17-19, 2004. The exit
conference was held August 19, 2004. The individuals participating in
the review are listed in Section VIII of this report. At the entrance
conference, the purpose of the Title VI Compliance Review and the review
process were discussed. A detailed schedule for conducting the on-site
visit was discussed. The focus of the site visit then turned to the
status of the information requested in the letter notifying Sound
Transit of the Compliance Review. Arrangements were also made for a tour
of Sound Transit facilities and interviews with Sound Transit's staff
and community representatives.

During the site visit, the review team conducted tours of the Tacoma
Dome Station, (located in a minority community, serving the Tacoma Link
light rail, Regional Express buses and the Sounder commuter rail),
Federal Way Transit Center (located in a minority community, serving
Regional Express service); Auburn Station (located in a non-minority
community, serving Sounder commuter rail and Regional Express buses);
the Kent Park and Ride lot (located in a non-minority community, serving
Regional Express service and Sounder commuter rail); and King County
Metro's South Base garage. Additionally, the review team rode the Tacoma
Link light rail and Regional Express bus routes 565 (minority route) and
522 (non-minority route). It is important to note that the labels of
non-minority and minority routes for the tours were approximated with
Sound Transit staff, as the determination of minority routes had to be
determined by Sound Transit based on the previous day's review of this
area. Distribution of amenities, vehicles assigned, and ridership and
operating characteristics of these routes and transit centers were
observed by the review team.

Interviews were conducted with Sound Transit's staff to provide
information on the extent to which Title VI requirements are
incorporated in the planning and implementation of service by Sound
Transit. The interviews also focused on staff efforts to make
communications and information available to persons with limited English
proficiency.

[]{.mark}

Interviews were also conducted with representatives of community
organizations to gain insight on how the minority community is
represented and participates in Sound Transit's planning process. Those
interviewed included representatives from the Pacific Northwest Chapter
of the National Black Chamber of Commerce, the Vietnamese American
Economic Development Association, and the International District Forum.

At the exit conference FTA representatives, Sound Transit staff, and the
review team discussed the results of the site visit and the next steps,
which included the submittal of additional data and documentation needed
to meet FTA requirements for Title VI.

[]{#__RefHeading___Toc51057805 .anchor}VI. FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on Sound Transit's compliance
with both the General Reporting Requirements and the Program-Specific
Requirements. This section describes the requirements and findings at
the time of the Compliance Review site visit.

1.  []{#__RefHeading___Toc51057806 .anchor}List of Active Complaints and
    Lawsuits

**Requirement:** All applicants, recipients and subrecipients shall
maintain and submit a list of any active lawsuits or complaints naming
the applicant that alleges discrimination on the basis of race, color,
or national origin with respect to service or other transit benefits.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for a List of Active
Complaints and Lawsuits. Information on the following complaints were
reviewed:

-   Sound Transit's 2001 Title VI submission noted one that a portion of
    one complaint, Save our Valley vs. Sound Transit, was still active.
    The suit against Sound Transit alleged that the street-level
    alignment of the proposed Central Link light rail through Rainer
    Valley would cause disproportionate adverse impacts to minority
    residents. The District Court found in favor of Sound Transit. At
    the site visit, Sound Transit presented documentation that on July
    10, 2003, the case was closed, as the Ninth Circuit US Court of
    Appeals upheld the District Court's finding.

-   On March 25, 2004 a complaint was filed by a DBE subcontracting firm
    alleging discrimination on the basis of disability. The complaint
    was filed with the Washington State Department of Transportation who
    referred it to Sound Transit, as the projects the complaint was
    based on were Sound Transit projects. At the time of the Title VI
    Review site visit, Sound Transit provided documentation
    demonstrating that it was currently investigating the complaint.

2.  []{#__RefHeading___Toc51057807 .anchor}Pending Applications for
    Financial Assistance

**Requirement:** All applicants, recipients and subrecipients shall
maintain and submit a description of all pending applications for
financial assistance, and all financial assistance currently provided by
other Federal agencies.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for Pending Applications
for Financial Assistance. Prior to the site visit, Sound Transit
provided information on its pending and active FTA grants. At time of
the site visit, the agency had 19 pending grants totaling \$105,143,495.
The grants were primarily for construction, vehicles, and right-of-way.

3.  []{#__RefHeading___Toc51057808 .anchor}Summary of Civil Rights
    Compliance Reviews

**Requirement:** All applicants, recipients and subrecipients shall
maintain and submit a summary of all civil rights compliance review
activities conducted in the last three years.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for Summary of Civil
Rights Compliance Reviews. FTA conducted its Triennial Review of Sound
Transit in July 2004, however, the Title VI area was not reviewed in
light of this pending review.

Sound Transit's 2001 Title VI submission discusses that beginning in the
first quarter 2002, Sound Transit would perform an annual internal Title
VI review in March-April of each year. At the time of the site visit,
these internal reviews had not commenced.

4.  []{#__RefHeading___Toc51057809 .anchor}FTA Civil Rights Assurance

**Requirement:** All applicants, recipients and subrecipients shall
maintain and submit a signed FTA Civil Rights Assurance that all of the
records and other information required have been or will be compiled, as
appropriate.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for FTA Civil Rights
Assurance. Sound Transit provided a copy of its most recent FTA Civil
Rights Assurance signed August 31, 2001 by the current Director, Joni
Earl. An updated assurance is to be included with its next Title VI
submission this year.

5.  []{#__RefHeading___Toc51057810 .anchor}DOT Title VI Assurance

**Requirement:** All applicants, recipients and subrecipients shall
maintain and submit a signed standard DOT Title VI Assurance. This is a
\"One-Time Submission.\"

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for DOT Title VI
Assurance. Sound Transit provided a copy of its most recent DOT Title VI
Assurance signed August 31, 2001 by the current Director, Joni Earl. It
is anticipated that an updated assurance will be included with its next
Title VI submission this year.

6.  []{#__RefHeading___Toc51057811 .anchor}Fixed-Facility Impact
    Analysis

**Requirement:** For construction projects, all applicants, recipients
and subrecipients shall conduct a fixed-facility impact analysis (FFIA)
to assess the effects on minority communities. This information can be
included in the environmental assessment or environmental impact
statement.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for Fixed Facility Impact
Analysis. The review team examined documentation on two of Sound
Transit's major construction efforts, the construction of the Sounder
Commuter Rail and the Central Link Light Rail. Sound Transit's 2001
Title VI submission noted the environmental documents where information
on the required elements of FFIAs for its Sounder Commuter Rail
construction projects was contained. For this project, Sound Transit
included an analysis of Environmental Justice requirements as part of
its Final EIS. The agency used census data to identify minority and
low-income populations, and determined that the proposed action would
not involve any significant adverse impacts on populations protected by
the Environmental Justice Executive Order, with the exception of tribal
populations. Impacts on fisheries and marine resources affecting tribal
populations were identified and mitigation measures proposed.

For the Central Link Light Rail, Sound Transit has an appendix entitled
"Environmental Justice Technical Report" in its Final Environmental
Impact Statement (EIS). In this appendix and in the Draft Supplemental
EIS for the Tukwila Freeway Route, Sound Transit discussed temporary and
permanent effects of the construction on minority and low-income
communities, and described a program it developed consistent with
Federal and state laws to address the concerns of those being relocated.

[]{.mark}

The required FFIA elements of the projects were reviewed as follows:

  ---------------------- ----------------------- ------------------------
  **4702.1 FFIA          **Central Link Light    **Sounder Commuter
  Element**              Rail**                  Rail**

  Discussion of          Discusses potential     Discusses potential
  potential impacts on   impacts during and      impacts during and after
  minority communities   after construction,     construction to minority
  and minority-owned     specifically to         populations.
  businesses during and  minority communities or 
  after construction     businesses.             

  Discussion of all      Discussion of potential Discussion of during and
  potential negative     negative impacts during after potential negative
  environmental impact,  and after construction. impacts. No significant
  such as noise, air, or Negatives noted during  impacts were anticipated
  water pollution        construction include    on environmental
                         noise, and air and      elements or resources,
                         water quality           with the exception of
                         degradations.           fisheries and marine
                                                 resources.

  Detailed list of       No detailed list was    No detailed list was
  minority-owned         provided; rather, the   provided; rather, used
  businesses and         EIS noted that due to   census data for the
  households that will   confidentiality of      Sound Transit taxing
  be affected by the     records regarding       district to document the
  construction project   minority status of      demographic
                         businesses and          characteristics of the
                         households, census      station areas in the
                         demographics were used  EIS.
                         to estimate the         
                         residences and          
                         businesses that would   
                         likely be affected      
                         temporarily or          
                         permanently by the      
                         project.                

  Description of other   Evaluated, concluded    Evaluated, concluded
  significant changes or that construction       that there would be no
  impacts on the         impacts and residential disproportionately high
  minority community,    and non-residential     and adverse impacts on
  such as increased      displacements would     human health and the
  traffic, reductions in have a statistically    environment.
  the amount of          greater impact on       
  available parking,     minority and low-income 
  etc.                   populations; however,   
                         the impacts would not   
                         be disproportionately   
                         high and adverse on     
                         these groups.           

  Description of         States that Sound       Identified measures to
  measures to mitigate   Transit would           mitigate potential
  any identified adverse substantially mitigate  impacts on businesses
  social, economic, or   temporary construction  and on fisheries and
  environmental effect   impacts, and            marine resources, and
  of the proposed        displacements would be  non-residential
  construction project.  mitigated through       displacements would be
                         relocation assistance.  mitigated through
                                                 relocation assistance.
  ---------------------- ----------------------- ------------------------

This review shows that much of the fixed-facility impact analysis was
conducted in the EIS process, and where impacts are identified,
mitigation measures are defined. In the environmental impact statements
for the above projects, an analysis of racial and economic make-up of
the project area was included in the "Environmental Justice" section.

7.  []{#__RefHeading___Toc51057812 .anchor}Demographic and Service
    Profile Maps, Overlays and Charts

**Requirement:** Information must be kept on the minority population
eligible to receive federally funded services. Transit providers meeting
the threshold must prepare demographic and service profile maps,
overlays, and charts. These maps must be updated and submitted after
each Federal census or as soon as the census data becomes available, or
within three years when there are significant changes in the transit
system.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for Demographic and
Service Profile Maps, Overlays and Charts. Sound Transit provided
several maps that depicted the minority makeup of census tracts (using
2000 census data) in their service area. In its Title VI submittal and
information provided at the site visit, Sound Transit provided
integrated maps and overlays that met with the Title VI Requirements, as
follows:

-   **Base Maps and Overlays --** For its service area, Sound Transit
    provided a legible scaled base map that identified each census tract
    by number. It also included separate maps that identified bus
    routes, major streets and highways, major trip generators, and
    maintenance and garage facilities. Each of these maps included a
    color-coded integrated overlay that denoted minority and
    non-minority census tracts.

-   **Population/Racial Distribution Charts --** For its service area,
    Sound Transit provided population distribution charts that follow
    the format suggested in FTA Circular 4702.1.

8.  []{#__RefHeading___Toc51057813 .anchor}Service Standards and
    Policies

**Requirement:** Information on the system-wide service policies and
standards used by the transit provider that relates to service
considerations covered by Title VI must reflect current practices. The
five transit service indicators FTA considers significant to monitor a
public transit system's compliance with Title VI are:

(1) Vehicle Load or Load Factor

(2) Vehicle Assignment

(3) Vehicle Headway

(4) Distribution of Transit Amenities

(5) Transit Access

**Finding:** During this Title VI Compliance Review of Sound Transit,
deficiencies were found with FTA requirements for Service Standards.
Sound Transit has a manual entitled "*1999 Service Standards and
Performance Measures*" that details various standards for its bus
system. In addition to those required by FTA, they include standards
such as dependability (missed trips, on time performance, etc.). Sound
Transit's current light rail system in Tacoma consists of one 1.6-mile
rail line. Sound Transit's Sounder Commuter rail service consists of one
approximately 80-mile line with nine stations. Only distribution of
transit amenities and transit access were reviewed for the light rail
and commuter rail services during this review. The analysis of
information provided and observed showed that formal standards need to
be established for the following areas: Distribution of Transit
Amenities for bus, commuter rail, and light rail, and Transit Access for
bus, commuter rail and light rail.

+-----------------+-------------------------+--------------------------+
| **FTA Service   | **Sound Transit         | #### Comments            |
| Standard**      | Policy**                |                          |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | **Bus** -- In Regional  | > Sound Transit provided |
| Load** - A      | Express's *1999 Service | > a sample of its "Ride  |
| ratio of the    | Standards and           | > Load Summaries" that   |
| number of       | Performance Measures*,  | > details ridership      |
| passengers on a | maximum average load    | > statistics for each    |
| vehicle to the  | factor is 100%.         | > route, that includes   |
| number of seats |                         | > percent of bus seats   |
|                 |                         | > occupied.              |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | **Bus -** Vehicles are  | This practice was        |
| Assignment      | assigned to King County | confirmed at the bus     |
| -**The process  | Metro, Pierce Transit   | depot visit conducted    |
| by which        | and Community Transit's | during the site review.  |
| vehicles are    | garages, as they are    | Additionally, at the     |
| assigned to     | the contracted          | site visit, a review of  |
| routes          | operating agencies for  | the age of fleet at each |
| throughout the  | bus service. Within a   | garage showed that the   |
| system due to   | particular garage,      | average age of Sound     |
| variations      | Sound Transit factors   | Transit's fleet is       |
| among vehicles  | that influence bus      | approximately 5 years,   |
| (age, size,     | assignment to routes    | with the exception of 20 |
| amenities,      | include type of fuel    | buses at the East        |
| etc.).          | used, and whether the   | Maintenance Base which   |
|                 | buses operate in the    | are leased from King     |
|                 | downtown Seattle        | County Metro. These      |
|                 | tunnel.                 | buses are due for        |
|                 |                         | replacement with new     |
|                 |                         | buses in later this      |
|                 |                         | year.                    |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | **Bus** -- In Regional  | > Sample of current      |
| Headway** -     | Express' *1999 Service  | > headways conformed to  |
|                 | Standards and           | > standards.             |
| The time        | Performance Measures*,  |                          |
| interval        | maximum headways are 30 |                          |
| between two     | minutes during peak     |                          |
| vehicles        | hours and 60 during     |                          |
| traveling in    | base hours.             |                          |
| the same        |                         |                          |
| direction on    | ####                    |                          |
| the same route  |                         |                          |
+-----------------+-------------------------+--------------------------+
| **Distribution  | **Bus -** In Regional   | > Sound Transit provided |
| of Transit      | Express' *1999 Service  | > an inventory of        |
| Amenities** -   | Standards and           | > amenities at its bus   |
|                 | Performance Measures*,  | > stops. The review team |
| Criteria for    | the following are       | > verified this          |
| installation of | listed as passenger     | > information during its |
| items of        | amenities for all bus   | > field visits.          |
| comfort and     | stops:                  | >                        |
| convenience     |                         | > Sound Transit provided |
| available to    | -   Bus shelters or     | > an inventory of        |
| the general     |     other means of      | > amenities at each      |
| public          |     weather protection  | > station that was       |
|                 |     for passengers.     | > confirmed by the       |
|                 |                         | > review team during its |
|                 | -   Schedule            | > field visits at        |
|                 |     information should  | > selected stations.     |
|                 |     be made available   |                          |
|                 |     to passengers at    | Sound Transit provided   |
|                 |     each stop.          | an inventory of          |
|                 |                         | amenities at each        |
|                 | -   ADA accessibility   | station that was         |
|                 |                         | confirmed by the review  |
|                 | **Commuter Rail -**     | team during its field    |
|                 | While the nine          | visits at selected       |
|                 | operating stations      | stations.                |
|                 | (which include 2        |                          |
|                 | interim stations) each  |                          |
|                 | include ADA accessible  |                          |
|                 | Ticket Vending          |                          |
|                 | Machines, shelters, and |                          |
|                 | mini-high platforms, no |                          |
|                 | specific written        |                          |
|                 | standard or policy was  |                          |
|                 | provided. In its 2001   |                          |
|                 | Title VI submission,    |                          |
|                 | Sound Transit noted     |                          |
|                 | that amenities at each  |                          |
|                 | station were determined |                          |
|                 | under a sub-area equity |                          |
|                 | agreement. Each taxing  |                          |
|                 | entity determined what  |                          |
|                 | percentage of funds     |                          |
|                 | would be applied to     |                          |
|                 | capital improvements    |                          |
|                 | and what percentage     |                          |
|                 | towards operations.     |                          |
|                 |                         |                          |
|                 | **Light Rail** -- While |                          |
|                 | the Tacoma Link light   |                          |
|                 | rail amenities at its   |                          |
|                 | five stations include   |                          |
|                 | shelters, benches,      |                          |
|                 | lights, art, trash      |                          |
|                 | receptacles, ashtrays   |                          |
|                 | and handicapped access  |                          |
|                 | ramps, no specific      |                          |
|                 | written standard or     |                          |
|                 | policy was provided.    |                          |
|                 |                         |                          |
|                 | .                       |                          |
+-----------------+-------------------------+--------------------------+
| **Transit       | > **Bus** -- Regional   | > []{.mark}              |
| Access** - The  | > Express' *1999        |                          |
| distance a      | > Service Standards and |                          |
| person must     | > Performance Measures* |                          |
| travel to gain  | > describe that the     |                          |
| access to       | > service is to         |                          |
| transit service | > complement local      |                          |
|                 | > transit service.      |                          |
| []{.mark}       | > Also, under the Bus   |                          |
|                 | > Stop Spacing it       |                          |
|                 | > describes items to    |                          |
|                 | > consider when placing |                          |
|                 | > a bus stop, such as   |                          |
|                 | > (except for downtown  |                          |
|                 | > Seattle other major   |                          |
|                 | > areas), passenger     |                          |
|                 | > stops should be at    |                          |
|                 | > transit centers,      |                          |
|                 | > park-and-ride lots,   |                          |
|                 | > and other locations   |                          |
|                 | > where there is        |                          |
|                 | > significant passenger |                          |
|                 | > activity. It further  |                          |
|                 | > describes that the    |                          |
|                 | > selection of stops    |                          |
|                 | > should also take into |                          |
|                 | > account the           |                          |
|                 | > availability of other |                          |
|                 | > local transit routes, |                          |
|                 | > the presence of major |                          |
|                 | > trip generators and   |                          |
|                 | > the availability of   |                          |
|                 | > transit-only or HOV   |                          |
|                 | > lanes. However, it    |                          |
|                 | > does not define a     |                          |
|                 | > standard for the      |                          |
|                 | > distance a person     |                          |
|                 | > should travel to gain |                          |
|                 | > access to the system. |                          |
|                 | >                       |                          |
|                 | > []{.mark}             |                          |
|                 | >                       |                          |
|                 | > **Sounder Commuter    |                          |
|                 | > Rail:**               |                          |
|                 |                         |                          |
|                 | No standard or policy   |                          |
|                 | provided.               |                          |
|                 |                         |                          |
|                 | > **Link Light Rail**:  |                          |
|                 |                         |                          |
|                 | No standard or policy   |                          |
|                 | provided.               |                          |
+-----------------+-------------------------+--------------------------+

**Corrective Actions and Schedule:** Within 90 days, Sound Transit must
submit to the FTA Region X Civil Rights Officer service standards that
have been established in the following areas:

-   Distribution of Transit Amenities

-   Transit Access

9.  []{#refheading___toc51057814 .anchor}Assessment of Compliance by
    Grantees

**Requirement:** The recipient is required to develop procedures and
guidelines for monitoring compliance with Title VI. This includes
evaluating system-wide changes and improvements at the planning and
programming stages to determine whether the overall benefits and costs
of such changes are distributed equally. Additionally, compliance
assessments must be conducted to determine whether the transit service
provided to minority communities and minority users is consistent with
the objectives of FTA's Title VI program.

**Finding:** During this Title VI Compliance Review of Sound Transit, an
advisory comment was made with respect to FTA requirements for
assessment of compliance with Title VI. Other than service changes to
individual routes, no system-wide service changes have occurred within
the past three years.

[]{.mark}

In November 1996, voters in the three counties approved local taxes to
fund *Sound Move*, a regional transit system plan that incorporates
regional express bus service (Regional Express) commuter rail (Sounder),
and light rail (Link). The plan incorporates over 100 miles of high
occupancy vehicle (HOV) expressway lanes, 82 miles of commuter rail
service, and 21 miles of light rail service.

The plan identifies projects for five sub areas: Pierce County,
Snohomish County, North King County, South King County, and East King
County. It also contains several commitments to the region: distribute
projects equitably by using tax revenues collected in a sub area on
projects in that sub area, implement projects in all sub areas
simultaneously, coordinate service with local transit services,
integrate fares with the other transit service providers, obtain voter
approval for additional system expansion, provide service outside the
existing district only through contracts or district expansion, and hold
planning and operations accountable to the public.

For long range transit planning, Sound Transit coordinates with the
outreach efforts of the area's Metropolitan Planning Organization (MPO),
Puget Sound Regional Council. On its Transportation Improvement Program
website, the MPO states that it "fully complies with Title VI of the
Civil Rights Act related statutes and regulations in all programs and
activities." []{.mark}Sound Transit works with their staff in developing
short and long-range transportation plans. Sound Transit provided a copy
of the TIP and the public outreach used by the MPO.

**Advisory Comment:** As Sound Transit prepares for the next voter
measure for approval and funding for anticipated system expansion, it
should ensure that an assessment be conducted to determine whether the
overall benefits and costs of such changes and improvements are
distributed equally.

10. []{#__RefHeading___Toc51057815 .anchor}Other Areas of Title VI
    Considerations

Title VI considerations extend to four other components: (1) Changes in
Service Features; (2) Information Dissemination; (3) Minority
Representations on Decision-making Bodies; and (4) Multilingual
Facilities.

[]{.mark}

**[Changes in Service Features]{.underline}**

**Requirement:** Recipients must provide a description of proposed
service changes to be made over a three-year period and a statement of
the effect of these changes on the minority communities and minority
transit users.

**Finding:** During this Title VI Compliance Review of Sound Transit,
deficiencies were found with FTA requirements for Changes in Service
Features. Sound Transit provided information on the service changes for
the past three years. These changes were primarily expansion, deletion,
and modification of bus routes. In its Title VI submission of 2001,
Sound Transit notes that each line of business is required to notify the
Title VI Manager of a proposed major change in service standards and
policies so that the impact on minority communities can be assessed.
However, Sound Transit could not provide examples of this assessment on
any of the service changes that occurred during the past three years.
Additionally, in Sound Transit's *1999 Service Standards and Performance
Measures*, the service adjustment process is discussed. In particular,
it notes an Annual Services and Operations Plan and a Comprehensive
Operational Analysis (every five years), but does not include an
analysis for compliance with Title VI as a part of that process.

**Corrective Action and Schedule:** Within 90 days, Sound Transit must
provide the Region X Civil Rights Officer documentation that it has
implemented its plan to assess service changes on minority transit users
and communities.

[]{.mark}

######## Information Dissemination

**Requirement:** Recipients must provide a description of the methods
used to inform the minority communities of service changes relating to
transit service and improvements.

> **Finding:** During this Title VI Compliance Review of Sound Transit,
> no deficiencies were found with FTA requirements for Information
> Dissemination. Documentation was provided to demonstrate that Sound
> Transit communicates with minority groups on changes related to
> transit service and improvements. Minority communities are provided
> with information regarding service changes both as part of Sound
> Transit's general information dissemination efforts, and where a
> service change impacts a minority community, as part of a targeted
> informational effort. Dissemination methods include, posted rider
> alerts, postings on Sound Transit's website, public hearings when
> necessary, and community meetings. If public hearings are necessary,
> they are held at facilities that are transit-accessible. Sound
> Transit's efforts include advertisements in local minority-focused
> publications.
>
> At the site visit, representatives from Sound Transit presented their
> media plan, which details cost and timing for external media buys for
> radio, postings, print, and sponsorships. Within each section, is a
> "diversity" line item that details communications targeted to minority
> customers.
>
> Additionally, a representative from Sound Transit detailed the
> extensive multi-lingual efforts being used for the construction of the
> Central Link light rail project. This includes construction and
> project updates in 12 languages and the use of appropriate-language
> interpreters for community meetings.

######## Minority Representation on Decision-Making Bodies

**Requirement:** Recipients must provide a racial breakdown of
transit-related non-elected boards, advisory councils or committees,
which are an integral part of the transit agency's planning process and
a description of the efforts made to encourage minorities to participate
on such boards, councils, or committees.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with respect to FTA requirements for Minority
Representation on Decision-Making Bodies.

Sound Transit is governed by an 18 member Board. In accordance with
Sound Transit's organizational structure, its board consists of 17 local
elected officials and the Secretary of the Washington State Department
of Transportation. According to the latest board revision, minorities
represent 17 percent (3 of 18) of the Sound Transit board members.

In addition to the Board, Sound Transit also has a 15 member Citizen's
Oversight Panel (COP). The current COP is comprised of seven men, six
women and two recent vacancies. Additional race and ethnic information
is not gathered for these members. The Goals of the Mission adopted by
Sound Transit in 2001 state "The COP will seek to represent the
geographic, demographic, and interest perspectives of the Sound Transit
district." Additionally, Sound Transit described that when conducting
outreach during the recruitment process, emphasis is placed in
communications on seeking persons from diverse backgrounds. In addition,
specific language states "Persons of color and women are encouraged to
apply."

######## Multilingual Facilities

**Requirement:** Recipients must provide a description of the extent to
which bilingual persons and/or materials are or will be used to assist
non-English speaking persons desiring use of the transit system.

**Finding:** During this Title VI Compliance Review of Sound Transit, no
deficiencies were found with FTA requirements for Multilingual
Facilities.

During the site visit, evidence of various multilingual communications
including schedules, signage, and public notices were provided and
viewed during facility visits. Sound Transit works with the appropriate
language representatives on its translations to ensure that not only the
wording, but also the meaning and subtle issues of dialect, are correct
so that the documents can be easily understood. Sound Transit's
Corporate Communications office provides an interpretation conference
call capability for anyone calling the front desk seeking information.
Customer service staff, or anyone in the agency, can establish a
conference call with a non-English speaking member of the public and an
interpreter. Corporate Communications also provides non-English
information on almost all of the agency's corporate publications. Sound
Transit will translate entire publications on an as-needed basis. Sound
Transit noted in its Title VI submission that all Sounder commuter rail
ticket vending machines, when in final configuration, will provide
written/audio information in multiple languages.

The Central Link light rail office provides information to neighborhoods
impacted by construction of that project. The non-English languages used
are determined by the 2000 census information for each neighborhood.
Additionally, a field community office was opened in the impacted area
of the Rainier Valley to provide information in multiple languages on
the upcoming rail system and construction. At the time of the site
visit, upcoming meetings were planned in nine languages at the community
office. Additionally, the review team was provided information about
outreach meetings that have been held with minority groups for input on
the business mitigation plan for the construction phases. To provide
more information on the project, Sound Transit also participated in
several ethnic festivals, including the Hispanic Seafair and Pista Sa
Nayon Festival.

During the site visit, information was shared with Sound Transit on the
Department of Transportation Guidance to DOT recipients regarding
Limited English Proficient requirements.

11. Internal Monitoring Procedures

**Requirement:** Recipients must develop and implement procedures to
monitor the level and quality of service provided to the minority
community, against overall system averages. At a minimum, recipients
must monitor transit service and related benefits to determine whether
the transit service provided to minority communities and minority users
is consistent with Title VI objectives.

**Findings:** During this Title VI Compliance Review of Sound Transit,
deficiencies were found with FTA requirements for Internal Monitoring
Procedures. At the time of the site visit, Sound Transit had not fully
implemented the required "level of service" and "quality of service"
monitoring procedures.

For its 2001 Title VI submission, Sound Transit had developed detailed
monitoring procedures that it had intended to implement during the first
quarter of 2002. However, at the time of the site review, these
procedures had not been fully implemented. Highlights of those
procedures include an annual review of each line of businesses'
(Sounder, Regional Express, Link Light Rail) performance with respect to
Title VI compliance standards.

Sound Transit provided several types of analysis and data collection
that it conducts for measuring route performance against established
standards. In 2001, it conducted on on-board survey of transit
passengers that analyzed trip characteristics (boarding locations,
alighting locations, zones crossed), transfer rates, fare payment
methods, average fare per boarding and satisfaction. Additionally, Sound
Transit compiles a quarterly *Ridership Report* that reports on
systemwide ridership and ridership by mode (commuter rail, bus, light
rail). As noted in the previous section on Service Standards and
Policies, Sound Transit does keep an inventory of amenities located at
its transit stations and stops. Using these methods, Sound Transit
collects information that can be used to monitor performance of the
transit system in accordance with FTA Circular 4702.1.

The reviewers discussed the method in the circular that specifies
selecting a sample size of at least 10 percent of all census tracts in
the service area and assessing the performance of minority areas against
established standards. It was further discussed that to complete this
required monitoring, Sound Transit needed to identify its minority and
non-minority transit routes as defined in FTA Circular 4702.1.

For quality of service monitoring, FTA Circular 4702.1 requires the
selection of an appropriate sample size of minority and non-minority
census tracts, and a survey of riders to determine travel patterns,
travel time, and fare for the three most-traveled destinations.

While Sound Transit is collecting much of the data that can serve as
inputs to internal monitoring, an analysis of the minority and
non-minority routes and tracts was not performed.

**Corrective Action and Schedule:** Within 90 days, Sound Transit must
submit to the Region X Civil Rights Officer documentation on procedures
it has developed for level and quality of service monitoring along with
a schedule for completing this monitoring and analysis.

12. []{#__RefHeading___Toc51057817 .anchor}Title VI Complaints

**Requirement:** All applicants, recipients, and subrecipients shall
have a procedure in place for the filing of Title VI discrimination
complaints. The procedure shall be made available to participants,
beneficiaries, and other interested parties.

**Finding:** During this Title VI Compliance Review of Sound Transit,
deficiencies were found with FTA requirements for Title VI Complaints.
Sound Transit's Customer Service and Information Center handle Service
complaints. Representatives from this department provided information on
the intake and processing of service complaints. This included
instructions to employees on how to categorize complaints. While there
was no specific category for Title VI or Civil Rights complaints, a
description was provided on how these complaints are categorized
(facilities, fares, service-related) and then forwarded to the Diversity
Program Manager's office for resolution. Service complaints are recorded
and tracked in a database system developed by Sound Transit. Copies of
reports from this system were provided to the review team. Sound Transit
staff also noted that the operators of their service are the staff of
other regional transit agencies, but that they still track their own
complaints. It was further noted that the transit providers in the
region are developing a combined complaint system for all agencies. All
complaints will be entered and tracked in this system, while each agency
will still be able glean their individual system's complaints from the
data.

No evidence was provided to demonstrate how the public is made aware of
their right to file a Title VI complaint or the procedure for doing so.
While there are contact numbers and an email address on the back of the
Transit Guide, no specific mention is made of a customer's right to file
a civil rights complaint. Additionally, no posters were found during the
site visit that included information on Sound Transit's Title VI program
or the procedures for filing a complaint. For the Central Link
construction project, project update information does note, "Sound
Transit's toll-free construction hotline is available to respond to your
comments, complaints, or concerns 24 hours a day..." Sound Transit
representatives noted that the Transit Guide would be re-published in
the near future and that it would include such a notice, along with a
language block.

**[Corrective Actions and Schedule]{.underline}:** Within 90 days, Sound
Transit must submit to the FTA Region X Civil Rights Officer
documentation that the complaint procedure has been made available to
the public.

[]{#__RefHeading___Toc51057818 .anchor}VII. SUMMARY OF FINDINGS AND
CORRECTIVE ACTIONS

+--------------+------+---------------------+-----------+------+-----+
| **Title VI   | **   | Description of      | **C       | **   | **D |
| Requirements | Site | Deficiencies        | orrective | Resp | ate |
| For Transit  | Re   |                     | Ac        | onse | Cl  |
| Providers**  | view |                     | tion(s)** | D    | ose |
|              | F    |                     |           | ays/ | d** |
|              | indi |                     |           | Da   |     |
|              | ng** |                     |           | te** |     |
+==============+======+=====================+===========+======+=====+
| 1\. List of  | ND   |                     |           |      |     |
| Active       |      |                     |           |      |     |
| Complaints   |      |                     |           |      |     |
| and Lawsuits |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 2\. List of  | ND   |                     |           |      |     |
| Pending      |      |                     |           |      |     |
| Grant        |      |                     |           |      |     |
| Applications |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 3\. Summary  | ND   |                     |           |      |     |
| of           |      |                     |           |      |     |
| Compliance   |      |                     |           |      |     |
| Reviews      |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 4\. Signed   | ND   |                     |           |      |     |
| Civil Rights |      |                     |           |      |     |
| Assurance    |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 5 Signed DOT | ND   |                     |           |      |     |
| Title VI     |      |                     |           |      |     |
| Assurance    |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 6\.          | ND   |                     |           |      |     |
| Fi           |      |                     |           |      |     |
| xed-Facility |      |                     |           |      |     |
| Impact       |      |                     |           |      |     |
| Analysis     |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 7\.          | ND   |                     |           |      |     |
| Demographic  |      |                     |           |      |     |
| and Service  |      |                     |           |      |     |
| Maps,        |      |                     |           |      |     |
| Overlays and |      |                     |           |      |     |
| Charts       |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 8\. Service  | D    | > Following         |           |      |     |
| Standards    |      | > standards not     |           |      |     |
| and Policies |      | > formally defined: |           |      |     |
|              |      |                     |           |      |     |
|              |      | -   Distribution of |           |      |     |
|              |      |     Transit         |           |      |     |
|              |      |     Amenities       |           |      |     |
|              |      |                     |           |      |     |
|              |      | -   Transit Access  |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 9\.          | AC   | > In preparation of |           |      |     |
| Assessment   |      | > its next voter    |           |      |     |
| of           |      | > referendum,       |           |      |     |
| Compliance   |      | > ensure that       |           |      |     |
| by Grantee   |      | > compliance with   |           |      |     |
|              |      | > Title VI is       |           |      |     |
|              |      | > analyzed.         |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 10\. Other   | D    | Service changes are | Provide   | 90   |     |
| Areas of     |      | not analyzed for    | the       |      |     |
| Title VI     | ND   | impacts on minority | Region X  |      |     |
| Co           |      | communities or      | Civil     |      |     |
| nsiderations | ND   | riders              | Rights    |      |     |
|              |      |                     | Officer   |      |     |
| Changes in   | ND   |                     | docu      |      |     |
| Service      |      |                     | mentation |      |     |
| Features     |      |                     | that      |      |     |
|              |      |                     | plans to  |      |     |
| Information  |      |                     | assess    |      |     |
| D            |      |                     | service   |      |     |
| issemination |      |                     | changes   |      |     |
|              |      |                     | on        |      |     |
| Minority     |      |                     | minority  |      |     |
| Re           |      |                     | transit   |      |     |
| presentation |      |                     | users and |      |     |
| on           |      |                     | co        |      |     |
| Dec          |      |                     | mmunities |      |     |
| ision-making |      |                     | has been  |      |     |
| Bodied       |      |                     | imp       |      |     |
|              |      |                     | lemented. |      |     |
| M            |      |                     |           |      |     |
| ulti-lingual |      |                     | []{.mark} |      |     |
| Facilities   |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 11\.         | D    | > Sound Transit did | Submit to | 90   |     |
| Monitoring   |      | > not provide       | the FTA   |      |     |
| Procedures   |      | > documentation of  | Region X  |      |     |
|              |      | > completion of     | Civil     |      |     |
|              |      | > level and quality | Rights    |      |     |
|              |      | > of service        | Officer   |      |     |
|              |      | > monitoring.       | docu      |      |     |
|              |      |                     | mentation |      |     |
|              |      |                     | that it   |      |     |
|              |      |                     | has       |      |     |
|              |      |                     | im        |      |     |
|              |      |                     | plemented |      |     |
|              |      |                     | p         |      |     |
|              |      |                     | rocedures |      |     |
|              |      |                     | for level |      |     |
|              |      |                     | and       |      |     |
|              |      |                     | quality   |      |     |
|              |      |                     | of        |      |     |
|              |      |                     | service   |      |     |
|              |      |                     | mo        |      |     |
|              |      |                     | nitoring. |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 12\. Title   | D    | Complaint           | Submit to | 90   |     |
| VI           |      | procedures not made | the FTA   |      |     |
| Complaints   |      | available to the    | Region X  |      |     |
|              |      | public              | Civil     |      |     |
|              |      |                     | Rights    |      |     |
|              |      |                     | Officer   |      |     |
|              |      |                     | docu      |      |     |
|              |      |                     | mentation |      |     |
|              |      |                     | that the  |      |     |
|              |      |                     | complaint |      |     |
|              |      |                     | procedure |      |     |
|              |      |                     | has been  |      |     |
|              |      |                     | made      |      |     |
|              |      |                     | available |      |     |
|              |      |                     | to the    |      |     |
|              |      |                     | public.   |      |     |
+--------------+------+---------------------+-----------+------+-----+

Findings at the time of the site visit: ND = No Deficiencies; D =
Deficiency; NA = Not Applicable; NR = Not Reviewed; AC = Advisory
Comment

**VIII.** **[ATTENDEES]{.underline}**

+-------------+-----------------------+----------+--------------------+
| **NAME**    | *                     | *        | **E-MAIL**         |
|             | *ORGANIZATION/TITLE** | *PHONE** |                    |
+-------------+-----------------------+----------+--------------------+
| Richard.    | FTA Region X          | 206-     | <Richard.kroc      |
| Krochalis   | Administrator         | 220-7954 | halis@fta.dot.gov> |
+-------------+-----------------------+----------+--------------------+
| Herman      | FTA/Region X Civil    | 206-     | <herman.p          |
| Payton      | Rights Officer        | 220-4462 | ayton@fta.dot.gov> |
+-------------+-----------------------+----------+--------------------+
| David       | FTA/Equal Opportunity | 202-     | <david.schn        |
| Schneider   | Specialist            | 493-0175 | eider@fta.dot.gov> |
|             |                       |          |                    |
| Via         |                       |          |                    |
| tel         |                       |          |                    |
| econference |                       |          |                    |
+-------------+-----------------------+----------+--------------------+
| Alec        | Sound                 | 206-     | <Stephensa         |
| Stephens    | Transit/Diversity     | 398-5160 | @soundtransit.org> |
|             | Program Manager       |          |                    |
+-------------+-----------------------+----------+--------------------+
| Susan       | Sound Transit/Capital | 206-     | <Petersons         |
| Peterson    | Projects              | 398-5160 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Vernon      | Sound Transit/Deputy  | 206-     | <stonerv           |
| Stoner      | CEO                   | 398-5451 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Ellen       | Sound                 | 206-     | <gustafsone        |
| Gustafson   | Transit/Contracts     | 398-5094 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| JoAnn       | Sound Transit/DPO     | 206-     | <koplitzj          |
| Koplitz     |                       | 689-4914 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Ron Lewis   | Sound Transit/Link    | 206-     | <lewisr            |
|             |                       | 689-4905 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Tim Healy   | Sound                 | 206-     | <healyt            |
|             | Transit/Marketing     | 398-5062 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Monica      | Sound Transit/Grants  | 206-     | <overbym           |
| Overby      |                       | 689-4979 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Mike        | Sound                 | 206-     | <bergmanm          |
| Bergman     | T                     | 398-5358 | @soundtransit.org> |
|             | ransit/Transportation |          |                    |
|             | Services              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Martin      | Sound                 | 206-     | <youngm            |
| Young       | T                     | 398-5115 | @soundtransit.org> |
|             | ransit/Transportation |          |                    |
|             | Services              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Fred Chun   | Sound                 | 206-     | <chunf             |
|             | T                     | 398-5044 | @soundtransit.org> |
|             | ransit/Transportation |          |                    |
|             | Services              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Kathy       | Sound Transit/Program | 206-     | <albertk           |
| Albert      | Manager Community     | 398-5456 | @soundtransit.org> |
|             | Outreach              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Nick        | Sound Transit/Program | 206-     | <marquardtn        |
| Marquardt   | Manager Customer      | 689-4903 | @soundtransit.org> |
|             | Service               |          |                    |
+-------------+-----------------------+----------+--------------------+
| Cheryl      | Sound Transit/Program | 206-     | <hustonc           |
| Huston      | Manager               | 398-5330 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Gerald      | Sound Transit         | 253-     | <jacklg            |
| Jackl       |                       | 383-0151 | @soundtransit.org> |
+-------------+-----------------------+----------+--------------------+
| Bruce Porad | King County           | 206-     | <Bruce.            |
|             | Metro/Base Super.     | 684-2279 | porad@metrokc.gov> |
+-------------+-----------------------+----------+--------------------+
| Charles     | Pacific Northwest     | 253-     | <PacRimD@msn.com>  |
| Horne       | Chapter National      | 473-0515 |                    |
|             | Black Chamber of      |          |                    |
|             | Commerce/President    |          |                    |
+-------------+-----------------------+----------+--------------------+
| John Eddie  | Pacific Northwest     | 253-     | <PacRimD@msn.com>  |
| Jones       | Chapter National      | 473-0515 |                    |
|             | Black Chamber of      |          |                    |
|             | Commerce              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Tom Im      | International         | 206-     | <tomi              |
|             | District              | 624-1802 | m@interimicda.org> |
|             | Forum/Community       |          |                    |
|             | Planner               |          |                    |
+-------------+-----------------------+----------+--------------------+
| Thao Tran   | Vietnamese American   | 206-     | <thao@vaeda.ogr>   |
|             | Economic Development  | 568-7771 |                    |
|             | Association/Executive |          |                    |
|             | Director              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Denise      | Milligan & Company,   | 215-     | <dbaile            |
| Bailey      | LLC/Principal         | 496-9100 | y@milligancpa.com> |
|             |                       | X 127    |                    |
+-------------+-----------------------+----------+--------------------+
| Jim Buckley | Milligan & Company,   | 410-     | <jbuckle           |
|             | LLC/Reviewer          | 732-4626 | y@milligancpa.com> |
+-------------+-----------------------+----------+--------------------+
| Judy Bizjak | Milligan & Company,   | 202-     | <jbizja            |
|             | LLC/Reviewer          | 223-5550 | k@milligancpa.com> |
+-------------+-----------------------+----------+--------------------+
| Diane King  | Milligan & Company,   | 215-     | <dkin              |
|             | LLC/Reviewer          | 496-9100 | g@milligancpa.com> |
|             |                       | X 135    |                    |
+-------------+-----------------------+----------+--------------------+