**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**City of Phoenix**

**(City)**

**Phoenix, Arizona**

**Final Report**

**July 2005**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORTATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**THE DMP GROUP**

**Subcontractor to**

**MILLIGAN & CO., LLC**

[Table of Contents]{.underline}

I. GENERAL INFORMATION [1](#__RefHeading___Toc96402320)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc96402321)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc96402322)

IV\. BACKGROUND INFORMATION [5](#__RefHeading___Toc96402323)

V. SCOPE AND METHODOLOGY [15](#__RefHeading___Toc96402324)

VI\. FINDINGS AND RECOMMENDATIONS [22](#__RefHeading___Toc96402325)

1\. List of Active Complaints and Lawsuits
[22](#__RefHeading___Toc96402326)

2\. Pending Applications for Financial Assistance
[23](#__RefHeading___Toc96402327)

3\. Summary of Civil Rights Compliance Reviews
[24](#__RefHeading___Toc96402328)

4\. FTA Civil Rights Assurance [24](#__RefHeading___Toc96402329)

5\. DOT Title VI Assurance [25](#__RefHeading___Toc96402330)

6\. Fixed-Facility (Environmental Justice) Impact Analysis
[25](#__RefHeading___Toc96402331)

7\. Demographic and Service Profile Maps, Overlays and Charts
[27](#__RefHeading___Toc96402332)

8\. Service Standards and Policies [28](#__RefHeading___Toc96402333)

9\. Assessment of Compliance by Grantees
[31](#__RefHeading___Toc96402334)

10\. Other Areas of Title VI Considerations
[32](#__RefHeading___Toc96402335)

11\. Internal Monitoring Procedures [38](#__RefHeading___Toc96402336)

12\. Title VI Complaints [40](#__RefHeading___Toc96402337)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[42](#__RefHeading___Toc96402338)

VIII\. ATTENDEES [44](#__RefHeading___Toc96402339)

I.  []{#__RefHeading___Toc96402320 .anchor}GENERAL INFORMATION

Grant Recipient: City of Phoenix

City/State: Phoenix, AZ

Grantee No: 1683

Executive Official: Ms. Debbie Cotton

> Acting Director
>
> Public Transit Department
>
> City of Phoenix
>
> 302 North 1^st^ Avenue, Suite 900
>
> Phoenix, AZ 85003

Report Prepared By: MILLIGAN & CO., LLC

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

Mulberry Atrium North

Philadelphia, PA 19103

THE DMP GROUP

2423 Killdeer Street

New Orleans, LA 70122

Site Visit Dates: December 13 -- 15, 2004

Compliance Review

Team Members: John Potts Dana Lucas

Lead Reviewer Reviewer

The DMP Group The DMP Group

Donald Lucas Maxine Marshall

Reviewer Reviewer

The DMP Group The DMP Group

> Bridgett Gagné

Reviewer

The DMP Group

II. []{#__RefHeading___Toc96402321 .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. (11), October 1,
2004; and 49 U.S.C. 5332, "Non-Discrimination."

The City of Phoenix, Arizona (City) 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 the City's Title VI Program and were the basis for the
selection of compliance elements that were reviewed.

III. []{#__RefHeading___Toc96402322 .anchor}PURPOSE AND OBJECTIVES

**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 City of Phoenix's (City)
Title VI Program was necessary.

The Office of Civil Rights authorized Milligan & Co., LLC and its
subcontractor, the DMP Group, to conduct the Title VI Compliance Review
of the City. The primary purpose of this Compliance Review was to
determine the extent to which the City 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 the City.

####  

**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;

```{=html}
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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;

```{=html}
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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

```{=html}
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```
-   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.

IV. []{#__RefHeading___Toc96402323 .anchor}BACKGROUND INFORMATION

[Description of Transit Service in the Phoenix Metropolitan
Area]{.underline}

The City of Phoenix Public Transit Department is responsible for
overseeing the City's transit program and also serves as the designated
recipient for federal funding of the region under FTA Programs 5307 and
5309. In this regional role, the City of Phoenix Public Transit
Department is responsible for ensuring compliance with federal funding
requirements for itself and the subrecipients to which it passes federal
funds.

The City operates fixed route and complementary paratransit service
within the City of Phoenix (through contracted service) and has eleven
subrecipients that provide service in areas outside of the city limits.
Those subrecipients are: Regional Public Transportation Authority
(RPTA), Maricopa County, and the cities of Tempe, Mesa, Glendale,
Surprise, Peoria, Chandler, Avondale, Goodyear, and Scottsdale. Each
subrecipient signs an Intergovernmental Agreement with the City of
Phoenix for the receipt of FTA funds.

For the most part, the City of Phoenix and its subrecipients provide
transit service by contract with private operators. The exceptions are
Dial-A-Ride service provided directly by the cities of Glendale, Peoria,
and Surprise, and the Sun Cities Area Transit.

In 1993, "Valley Metro" was chosen as the identity for the regional
transit system. The Valley Metro name and graphic design were chosen to
give buses and vans of the City of Phoenix and its subrecipients a more
recognizable identity and to help unify the public transit systems
within the region. Additionally, the fares are consistent for fixed
route service for all Valley Metro service. The base fare is \$1.25 and
the discounted base fare (offered to children, senior citizens, persons
with disabilities, and Medicare cardholders) is \$0.60. There is also a
premium fare of \$1.75 charged for express and bus rapid transit (BRT)
bus service, locally known as RAPID.

On March 14, 2000, Phoenix voters passed Proposition 2000. The
Proposition levied a 0.4% sales tax to fund expanded bus service, light
rail transit, RAPID, and expanded dial-a-ride within the City. RAPID
became operational in July 2003. The light rail system will be
operational in late 2008 and operated by a subrecipient, Valley Metro
Rail, Inc. (VMR), a non-profit corporate agency comprised of
representatives of the rail participating cities of Phoenix, Mesa, Tempe
and Glendale. VMR is in final design and under final review for a FTA
Full Funding Grant Agreement (FFGA). The rail line will be approximately
13 miles within the Phoenix city limits and will extend to the cities of
Tempe and Mesa to complete a 20.3-mile starter system.

[]{.mark}

In addition to projects completed by its subrecipients, the City
completed the following FTA-funded projects during the past three years:

-   Bus Stop Improvement Program

-   Bus Stop Retrofit Program

-   40^th^ Street/Pecos Park-and-Ride

-   Bell Road/SR51 Park-and-Ride

-   Ed Pastor Transit Center

-   Deer Valley Park-and-Ride Expansion/Upgrades

-   Desert Sky Transit Center Upgrades

-   North and South Bus Divisions Improvements

[]{.mark}

In the next three to five years, the City expects to complete the
following transit projects:

-   HASTUS Scheduling system

-   Vehicle Management System

-   Construction of a new (West) Operations Facility

-   Continued improvements to North and South bus divisions

-   Electronic Fare Collection system

-   Fuel Management System

-   Transit Center Refurbishments

Currently, fixed route transit service in metropolitan Phoenix is
operated by three independent transit agencies under the Valley Metro
identity: City of Phoenix, RPTA, and City of Tempe. Each agency has its
own service area, service levels, and funding sources. Federal funds are
disbursed to the City of Phoenix, the designated recipient of federal
funds. The City of Phoenix distributes these funds to the various
transit agencies as described below.

[City of Phoenix]{.underline}

The fixed route transit system in Phoenix is owned and funded by the
City of Phoenix. A private company, ATC-Phoenix, provides the majority
of service. In addition, Laidlaw Transportation Services, MV
Transportation, and Arnett Transportation also provide transit services
under contract to the City of Phoenix. The service area encompasses all
of Phoenix and parts of the adjacent cities of Glendale, Scottsdale, and
Tempe, with some routes extending into further adjacent cities. The
other cities maintain intergovernmental funding agreements with the City
of Phoenix for the service provided within their individual borders.

The Public Transit Department oversees and monitors the contracts with
the private bus companies providing transit services to its citizens.
The Public Transit Department reports to the City Manager and the
Phoenix City Council.

Transit service for the City of Phoenix is funded through farebox
revenues, general fund revenues, dedicated sales tax revenues, state
local transit assistance funds (LTAF) and federal funds. Each of the
private contractors provides its own management, operations, and
maintenance staff. The City of Phoenix owns all of the buses used in the
provision of transit service. The City also oversees five maintenance
and operations facilities that are used to provide transit services. Two
of these facilities are owned by the City of Phoenix. Two are leased by
the City through contractors, and one facility is owned by a contractor.

[Regional Public Transportation Authority (RPTA)]{.underline}

RPTA provides regionally oriented transit service in the Phoenix area.
The majority of RPTA's fixed route service is in the form of express or
park-n-ride routes; however some local service is also provided. RPTA
funds its transit service via farebox revenues, an annual allocation of
the dedicated regional mobility tax (passed in a local referendum in
1985), state LTAF funds, and federal funds. In some cases, other transit
agencies operate RPTA-owned vehicles.

RPTA currently manages its fixed route vehicles from a leased facility
in southeast Phoenix that is operated by ATC-RPTA. In April 2005, MV
Transportation will operate all fixed route service managed by RPTA.
RPTA's paratransit vehicles are managed from a separate leased facility
in the City of Gilbert operated by Atlantic Paratransit. In January
2005, MV Transportation will operate all paratransit serviced managed by
RPTA.

RPTA is governed by a 13-member board of directors comprised of the
mayors of all the member jurisdictions in RPTA. An Executive Director,
appointed by the board, is assisted by a staff of 58 that oversees the
operations contracts for fixed route service and sub-regional
dial-a-ride programs. RPTA also conducts regional planning studies,
provides regional marketing and customer services, and operates the
regional transportation demand management program.

The City of Mesa recently finished construction on a new transit
operating and maintenance facility that will serve its growing fleet.
This new facility combined all of the services necessary to support a
transit fleet, including fueling, dispatch, maintenance, and cleaning.
In August 2004, RPTA assumed the transit contracts and services within
the City of Mesa and will eventually purchase the maintenance facility
from the City of Mesa.

[City of Tempe]{.underline}

The City of Tempe provides fixed route transit service for more than 40
square miles through a contract with ATC-Tempe. The City owns the 107
buses and ATC-Tempe operates and maintains them. Funding is derived from
farebox revenues, general fund revenues, a dedicated local sales tax
within the Tempe city limits, state LTAF funds, and federal funds. The
City of Tempe Transportation Division oversees the contract for service,
reporting to the Public Works Manager, City Manager, and Tempe City
Council.

[Regional Overview]{.underline}

The metropolitan population in Maricopa County is expected to increase
by more than 76% in the next 30 years. With the current countywide
half-cent sales tax dedicated to transportation expiring in 2005, the
County's government and business leaders developed a plan for the next
20 years of transportation improvements. The plan has \$16 billion of
projects programmed over the 20-year period. More than half of the
plan's funding will come from a half-cent sales tax for transportation
that was approved by voters in November 2004. Funding for freeways,
streets, and transit will be kept separate and projects will be audited
every five years to evaluate performance. Major changes will require
public review.

The region's service levels have traditionally been limited by a lack of
a reliable source of revenues. While capital expenses have been funded
through a partnership with the FTA, operating funds region-wide remain
scarce. The cities of Phoenix, Tempe, Glendale, and Mesa have secured
local funding via local sales taxes. The cities of Scottsdale, Chandler,
and Gilbert are each undertaking planning studies that could ultimately
lead to the adoption of expanded transit plans and local funding
referenda to implement those plans. It is anticipated that the regional
bus fleet will grow from the current level of 741 vehicles to nearly
1,200 by 2020. Plans are in process to add additional facilities
throughout the Valley.

[Fixed Route Service Summary]{.underline}

Publicly funded fixed route transit service is provided in 18
communities in Maricopa County. The cities of Avondale, Chandler,
Gilbert, Glendale, Mesa, Phoenix, Scottsdale, Tempe, Tolleson, and the
RPTA provide funding for these services.

Sixty (60) local routes, fifteen (15) express, and four (4) RAPID routes
are operated throughout the region each weekday. Transit service is
operated weekdays for approximately 19 hours from 4 a.m. to 1:40 a.m. On
Saturdays, service hours are from 5 a.m. to 10 p.m., again with
variations by route. The service on Sunday generally operates from 6
a.m. to 9 p.m. and is primarily concentrated in Phoenix, Glendale, and
Tempe, with limited service into the communities of Chandler, Mesa and
Scottsdale.

The regional distribution of vehicles is detailed below:

  ------------------------ ------------------------ ---------- --------------
  **Operating Agency**     **Model**                **Year**   **Quantity**

  **GLENDALE**             Freightliner             2003       2

                           El Dorado (Ford)         2003       2

                           El Dorado (MST)          2001       1

                           Supreme (Ford)           2000       1

                           Aerotech (Ford)          1995       1

                           Supreme (Ford)           1993       1

                           Supreme (Ford)           1992       1

  **PHOENIX**              New Flyer                2004       20

                           NABI                     2003       56

                           Supreme                  2002       1

                           El Dorado/National       2001       9

                           Supreme                  2001       6

                           NABI                     2001       96

                           NABI                     1999       35

                           NABI                     1998       156

                           New Flyer                1996       28

                           New Flyer                1994       30

                           TMC                      1990       37

                           TMC                      1989       10

                           TMC                      1988       16

  **RPTA**                 El Dorado/National       2002       3

                           El Dorado/National       2001       9

                           NABI                     1999       16

                           El Dorado/National       1999       7

                           NABI                     1998       7

                           New Flyer                1994       37

  **MESA**                 NABI                     2001       20

                           El Dorado MST            2000       6

                           El Dorado/National       1994       13

  **TEMPE**                Supreme (Ford)           2003       9

                           NABI                     2002       4

                           El Dorado/National       2000       9

                           NABI                     1999       15

                           El Dorado/National       1999       18

                           NABI                     1998       23

                           El Dorado/National       1998       20

                           NABI                     1998       9

  **SCOTTSDALE**           Freightliner Trolley     2003       **7**

                           **GRAND TOTAL**                     **741**
  ------------------------ ------------------------ ---------- --------------

The following table shows the racial/ethic breakdown of the City service
area in Maricopa County, which includes the City of Phoenix and its
eleven subrecipients:

**Racial/ Ethnic Breakdown of the City of Phoenix and the**

**City Service Area**

######### 2000 Census

<table style="width:100%;">
<colgroup>
<col style="width: 14%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 7%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 9%" />
</colgroup>
<tbody>
<tr class="odd">
<td><strong>Racial/ Ethnic Group</strong></td>
<td><strong>City of Chandler Total/</strong> Percent</td>
<td><strong>City of Glendale Total/</strong> Percent</td>
<td><strong>City of Mesa Total/</strong> Percent</td>
<td><strong>City of Peoria Total/</strong> Percent</td>
<td><strong>City of Phoenix Total/</strong> Percent</td>
<td><strong>City of Scottsdale Total/</strong> Percent</td>
<td><strong>City of Tempe Total/</strong> Percent</td>
<td><strong>Cities of Avondale, Goodyear, Surprise Total/</strong>
Percent</td>
<td><p><strong>Transit</strong></p>
<p><strong>Service Area Total</strong>/</p>
<p>Percent</p></td>
<td><strong>Maricopa County Total/</strong> Percent</td>
</tr>
<tr class="even">
<td rowspan="2">White</td>
<td><strong>136,296</strong></td>
<td><strong>165,293</strong></td>
<td><strong>323,655</strong></td>
<td><strong>92,050</strong></td>
<td><strong>938,853</strong></td>
<td><strong>186,883</strong></td>
<td><strong>122,952</strong></td>
<td><strong>64,000</strong></td>
<td><strong>2,029,982</strong></td>
<td><strong>2,376,359</strong></td>
</tr>
<tr class="odd">
<td>77%</td>
<td>76%</td>
<td>82%</td>
<td>85%</td>
<td>71%</td>
<td>92%</td>
<td>78%</td>
<td>75%</td>
<td>76%</td>
<td>77%</td>
</tr>
<tr class="even">
<td rowspan="2">Black</td>
<td><strong>6,151</strong></td>
<td><strong>10,270</strong></td>
<td><strong>9,977</strong></td>
<td><strong>3,012</strong></td>
<td><strong>67,416</strong></td>
<td><strong>2,501</strong></td>
<td><strong>5,801</strong></td>
<td><strong>3,655</strong></td>
<td><strong>108,783</strong></td>
<td><strong>114,551</strong></td>
</tr>
<tr class="odd">
<td>3%</td>
<td>5%</td>
<td>3%</td>
<td>3%</td>
<td>5%</td>
<td>1%</td>
<td>4%</td>
<td>4%</td>
<td>4%</td>
<td>4%</td>
</tr>
<tr class="even">
<td rowspan="2">American Indian and Alaska Native</td>
<td><strong>2,121</strong></td>
<td><strong>3,181</strong></td>
<td><strong>6,572</strong></td>
<td><strong>734</strong></td>
<td><strong>26,696</strong></td>
<td><strong>1,240</strong></td>
<td><strong>3,186</strong></td>
<td><strong>793</strong></td>
<td><strong>44,523</strong></td>
<td><strong>56,706</strong></td>
</tr>
<tr class="odd">
<td>1%</td>
<td>1%</td>
<td>2%</td>
<td>1%</td>
<td>2%</td>
<td>1%</td>
<td>2%</td>
<td>1%</td>
<td>2%</td>
<td>2%</td>
</tr>
<tr class="even">
<td rowspan="2">Asian, Native Hawaiian or Pacific Islander</td>
<td><strong>7,453</strong></td>
<td><strong>6,003</strong></td>
<td><strong>5,917</strong></td>
<td><strong>2,077</strong></td>
<td><strong>26,449</strong></td>
<td><strong>3,964</strong></td>
<td><strong>7,531</strong></td>
<td><strong>1,330</strong></td>
<td><strong>60,724</strong></td>
<td><strong>66,445</strong></td>
</tr>
<tr class="odd">
<td>4%</td>
<td>3%</td>
<td>1%</td>
<td>2%</td>
<td>2%</td>
<td>2%</td>
<td>5%</td>
<td>2%</td>
<td>2%</td>
<td>2%</td>
</tr>
<tr class="even">
<td rowspan="2">Hawaiian/Pacific Islander</td>
<td><strong>251</strong></td>
<td><strong>293</strong></td>
<td><strong>932</strong></td>
<td><strong>120</strong></td>
<td><strong>1,766</strong></td>
<td><strong>167</strong></td>
<td><strong>455</strong></td>
<td><strong>84</strong></td>
<td><strong>4,068</strong></td>
<td><strong>4,406</strong></td>
</tr>
<tr class="odd">
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0%</td>
<td>0.1%</td>
</tr>
<tr class="even">
<td rowspan="2">Some Other Race</td>
<td><strong>18,993</strong></td>
<td><strong>26,188</strong></td>
<td><strong>38,271</strong></td>
<td><strong>7,686</strong></td>
<td><strong>216,589</strong></td>
<td><strong>4,603</strong></td>
<td><strong>13,464</strong></td>
<td><strong>13,210</strong></td>
<td><strong>339,004</strong></td>
<td><strong>364,213</strong></td>
</tr>
<tr class="odd">
<td>11%</td>
<td>12%</td>
<td>10%</td>
<td>7%</td>
<td>16%</td>
<td>2%</td>
<td>8%</td>
<td>15%</td>
<td>13%</td>
<td>12%</td>
</tr>
<tr class="even">
<td rowspan="2">Two or more Races</td>
<td><strong>5,316</strong></td>
<td><strong>7,584</strong></td>
<td><strong>11,051</strong></td>
<td><strong>2,685</strong></td>
<td><strong>43,276</strong></td>
<td><strong>3,347</strong></td>
<td><strong>5,236</strong></td>
<td><strong>2,570</strong></td>
<td><strong>81,065</strong></td>
<td><strong>89,469</strong></td>
</tr>
<tr class="odd">
<td>3%</td>
<td>3%</td>
<td>3%</td>
<td>2%</td>
<td>3%</td>
<td>2%</td>
<td>3%</td>
<td>3%</td>
<td>3%</td>
<td>3%</td>
</tr>
<tr class="even">
<td><strong>Total Population</strong></td>
<td><strong>176,581</strong></td>
<td><strong>218,812</strong></td>
<td><strong>396,375</strong></td>
<td><strong>108,364</strong></td>
<td><strong>1,321,045</strong></td>
<td><strong>202,705</strong></td>
<td><strong>158,625</strong></td>
<td><strong>85,642</strong></td>
<td><strong>2,668,149</strong></td>
<td><strong>3,072,149</strong></td>
</tr>
<tr class="odd">
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td rowspan="2">Hispanic Origin*</td>
<td><strong>37,059</strong></td>
<td><strong>54,343</strong></td>
<td><strong>78,281</strong></td>
<td><strong>16,699</strong></td>
<td><strong>449,972</strong></td>
<td><strong>14,111</strong></td>
<td><strong>28,473</strong></td>
<td><strong>27,706</strong></td>
<td><strong>706,644</strong></td>
<td><strong>763,341</strong></td>
</tr>
<tr class="odd">
<td>21%</td>
<td>25%</td>
<td>20%</td>
<td>15%</td>
<td>34%</td>
<td>7%</td>
<td>18%</td>
<td>32%</td>
<td>26%</td>
<td>25%</td>
</tr>
</tbody>
</table>

\* Per the 2000 Census, people of Hispanic origin can be, and in most
cases are, counted in two or more race categories.

Based on the 2000 Census, the population of Maricopa County is
3,072,149. The total minority population of Maricopa County is 34%. The
population of the public transit service area is 2,668,149. The largest
minority group is the Hispanic population. As shown in the Table,
Hispanics represent 26% of the transit service area population. Blacks
represent 4% of the transit service area population.

The total aggregate population of the cities of Avondale, Goodyear and
Surprise is 85,642. These are smaller service areas with the following
percentages of Hispanics and Blacks:

  ------------------------------- -------------------- ------------------
                                  Hispanic             Black

  Avondale                        46%                  5%

  Goodyear                        21%                  5%

  Surprise                        23%                  3%

  City Service Area               26%                  4%

  Maricopa County                 25%                  4%
  ------------------------------- -------------------- ------------------

V.  []{#__RefHeading___Toc96402324 .anchor}SCOPE AND METHODOLOGY

#### Scope

The Title VI Compliance Review of the City 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.  A list of active Title VI lawsuits or complaints;

b.  A description of pending applications for financial assistance;

c.  A summary of recent civil rights compliance review activities;

d.  A signed FTA Civil Rights Assurance;

e.  A signed standard DOT Title VI Assurance; and

f.  A 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;

d.  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 interviews were conducted with Headquarter Civil Rights staff
and the Region IX Civil Rights Officer to discuss specific Title VI
issues and concerns regarding the City. Following the interviews, a
detailed letter was sent to the City advising it of the site visit and
indicating additional information that would be needed and issues that
would be discussed.

In the letter, the City was requested to provide the following
Background Information:

**1. Background Information**

-   The City's most recent Title VI Update that was to be submitted to
    FTA in November 2004.

-   Description of the Phoenix urbanized service area, including general
    population and other demographic information using Census 2000 data.

-   Current description of fixed route bus service for the City and its
    subrecipients, including system maps, public timetables, transit
    service brochures, etc.

-   Any studies or surveys conducted by the City, its subrecipients,
    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.

-   Financial statements showing actual capital and operating
    expenditures for the Public Transit Department and its
    subrecipients, including the BRT project and Valley Metro Rail (VMR)
    for the past three years.

-   Fixed facility analyses, including those conducted for BRT and VMR,
    and, if needed, a program or other measures to mitigate any
    identified adverse impact on the minority community.

-   Capital and Operating Budget projections for the next three to five
    years for the Public Transit Department and its subrecipients,
    including BRT and VMR.

    2.  **Copies of Title VI Program Specific Requirements** (Chapter
        III, Section 3 of FTA Circular 4702.1)

        -   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

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

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

        -   Service Standards adopted by the City and its subrecipients
            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

        -   Information collected by the City and its subrecipients for
            each bus route to assess service for compliance with
            established service standards, e.g., vehicle load factor
            analyses, vehicle assignment sheets, vehicle headways, and
            amenities, such those provided at bus stops, transfer
            centers, etc.

        -   Ridership by route

        -   Passenger boardings by bus stop

        -   Maximum load points by route

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

        -   Inventory of transit amenities, such as transit centers, bus
            stop shelters and benches which indicates their location and
            any amenities such as benches, lights, and telephones

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

**3. Other Program Specific Requirements** (Chapter III, Section 3 (4)
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

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

-   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

-   A description of the efforts to assess and address the ability of
    persons with Limited English Proficiency (LEP) to use transit
    services. Copies of schedules and other public information provided
    in languages other than English.

-   Description of the City's internal monitoring procedures to insure
    that its level and quality of service is in compliance with Title
    VI, along with copies of the City's "level of service" and "quality
    of service" evaluations, including recommendations for addressing
    disparities, if any are identified.

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

[Site Visit]{.underline}

The site visit to Phoenix occurred December 13-15, 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. After the entrance
conference, the site visit focused on the status of the information
requested in the letter notifying the City of the Compliance Review.
Arrangements were also made for a tour of the City's facilities and bus
routes, observation of vehicle assignments to sample minority and
non-minority routes, review of actual headways and ridership on sample
minority and non-minority routes, as well as interviews with the City's
staff and community representatives.

Several of the City's bus garages, maintenance facilities and transit
centers were toured, including the Sunnyslope Transit Center, Paradise
Valley Mall Transit Center, Ed Pastor Transit Center, Tempe Transit
Mall, ATC/RPTA Facility and MV Transportation Facility. In addition,
several bus routes were toured, including Routes 13, 44, 61, 72, 104,
and 136. On the third day of the site visit, the review team also
examined the assignment and condition of vehicles from two bus garages
-- the ATC/Phoenix Facility and MV Transportation Facility.

Interviews were conducted with City staff and community representatives
to provide information on the extent to which the City incorporates
Title VI requirements in the planning and implementation of service. The
interviews also focused on City efforts to make communications and
information available in non-English formats for minority groups, as
required. In addition, the interviews with community representatives
focused on perceptions of the level and quality of bus service and
amenities in minority communities and the availability of information on
proposed changes in service.

Representatives interviewed from Black and Hispanic community groups
indicated that the level and quality of service has improved over the
past several years. The most notable concern is the level and quality of
amenities throughout the system, particularly in the minority
communities. The minority representatives indicated that it seemed that
fewer shelters were in the minority community versus the non-minority
community. Some representatives were also concerned about passenger
safety, particularly as it related to bus "cut outs" in the street. They
noted that bus lanes were available in the non-minority community
whereby buses could pull out of the main lanes of traffic, however, in
minority communities, buses used traffic lanes for passenger boardings.

Community representatives felt the City does a great job of distributing
public timetables, routes, notices and other written information in
Spanish. Members of the Hispanic community also want to see the City
improve its efforts to educate the community on how to access the
system, with training being conducted in a Spanish format.

[]{.mark}

VI. []{#__RefHeading___Toc96402325 .anchor}FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on the City\'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.

Initially, the City did not meet the Title VI requirements for Service
Standards and Policies, Assessment of Compliance by Grantee, and
Minority Representation on Boards. In the City's draft Title VI Update
Report dated December 2004, the City provided documentation that it had
developed two of the five required service standards and collected
relevant data with respect to the written standards, as required by the
Circular. At the time of the site visit, the City did not have
quantifiable written standards for vehicle assignment, transit
amenities, and transit access nor had the City conducted assessments in
accordance with Circular requirements. These two areas were corrected
subsequent to the site visit.

#### 

1.  []{#__RefHeading___Toc96402326 .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 who alleges discrimination on the basis or race, color, or
national origin with respect to service or other transit benefits.

**Finding:** During this Title VI Compliance Review of the City, no
deficiencies were found with FTA requirements for List of Active
Complaints and Lawsuits. In its most recent draft Title VI Update Report
dated December 2004 and at the site visit, the City reported that it did
not have any active Title VI complaints or lawsuits.

2.  []{#__RefHeading___Toc96402327 .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 the City, no
deficiencies were found with FTA requirements for Pending Applications
for Financial Assistance. In information provided in its draft Title VI
Update Report dated December 2004 and at the site visit, the City did
report on its pending applications for financial assistance by other
Federal agencies, in conformance with FTA Circular 4702.1. In its most
recent report and at the time of the site visit, the City had two FTA
pending applications for financial assistance and one amendment. The
City had no pending applications for financial assistance for public
transit by any other federal agency.

3.  []{#__RefHeading___Toc96402328 .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 the City, no
deficiencies were found with FTA requirements for Summary of Civil
Rights Compliance Reviews. There have been no civil rights compliance
reviews conducted by other local, State, or Federal agencies in the last
three years. The most recent FTA Triennial Review conducted in December
2003 examined Civil Rights requirements and no deficiencies were
identified with the FTA requirements for Title VI.

4.  []{#__RefHeading___Toc96402329 .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 the City, no
deficiencies were found with FTA requirements for FTA Civil Rights
Assurance. During the site visit, the City provided a document titled
"Nondiscrimination Assurance," written to satisfy both the annual FTA
Civil Rights Assurance and the one-time DOT Title VI Assurance
requirements. The document assures that facilities and services will be
operated in accordance with all applicable requirements of FTA Circular
4702.1, 49 U.S.C. 5332 and 49 CFR part 21. The Nondiscrimination
Assurance was dated December 9, 2004 and signed by Debbie Cotton, Acting
Public Transit Director and Alan Max, Public Transit Department General
Counsel.

5.  []{#__RefHeading___Toc96402330 .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 the City, no
deficiencies were found with FTA requirements for DOT Title VI
Assurance. During the site visit, the City provided a document titled
"Nondiscrimination Assurance," written to satisfy both the annual FTA
Civil Rights Assurance and the one-time DOT Title VI Assurance
requirements. The document assures that facilities and services will be
operated in accordance with all applicable requirements of FTA Circular
4702.1, 49 U.S.C. 5332 and 49 CFR part 21. The Nondiscrimination
Assurance was dated December 9, 2004 and signed by Debbie Cotton, Acting
Public Transit Director and Alan Max, Public Transit Department General
Counsel.

6.  []{#__RefHeading___Toc96402331 .anchor}Fixed-Facility Impact
    Analysis

**Requirement:** For construction projects, all applicants, recipients
and subrecipients shall conduct a fixed-facility impact analysis 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 the City, no
deficiencies were found with FTA requirements for Fixed-Facility/
Environmental Justice Impact Analysis. According to the City's draft
Title VI Update Report dated December 2004, the City had seven projects
in various phases of development -- one constructed project and six
other projects with completed Title VI documentation. The results are as
follows:

  --------------------------------- -------------------------------------
  **PROJECT**                       **MINORITY IMPACT**

  40^th^ Street/Pecos Park-n-Ride   *Constructed.* No identifiable
  (Phoenix),                        minority population in the area.

  East Valley Operating Facility    No specific impact to the minority
                                    owned businesses or residents within
                                    the area.

  West Operating/Regional Heavy     No specific impact to minority owned
  Maintenance Facility              businesses or residents within the
                                    area.

  Replacement Parking for the       No disproportionate impact on
  Downtown Tempe Transit Building   minority or low-income persons will
                                    occur.

  Downtown Gilbert Park-n-Ride      Will not have a disproportionate
                                    impact on the minority group.

  Mesa Park-n-Ride                  Will not have any disproportionately
                                    high or adverse effects on minority
                                    and low-income populations.

  Central Phoenix/East Valley Light There were concerns on the part of
  Rail Project                      the minority and low-income
                                    individuals and business owners,
                                    however, mitigating actions were
                                    taken by VMR and the City of Phoenix.
  --------------------------------- -------------------------------------

In addition, there were five projects underway that require a
fixed-facility/environmental justice assessment and these projects will
be included in future Title VI report submittals.

7.  []{#__RefHeading___Toc96402332 .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.

**Findings:** During this Title VI Compliance Review of the City, no
deficiencies were found with FTA requirements for Demographic and
Service Profile Maps, Overlays and Charts. During the site visit, the
City provided Base Maps and Overlays as required by the Circular. The
Base Maps identified each census tract by number, major streets and
highways, the transit facilities and identified the major activity
centers and transit trip generators. The following list of maps by title
was submitted at the time of the site visit:

-   *Phoenix Metropolitan Area Base Map* -- showed Census Tracts,
    Transit Facilities, and Activity Centers.

-   *Peak Bus Frequency Map* -- showed Local/Circular Bus Route
    Frequency including Express, Limited and RAPID Bus Routes.

-   *Park-and-Ride Location Map*

-   *Minority Population Percentage Overlay* -- showed percentage
    concentrations of minorities throughout the service area for
    placement on the Phoenix Metropolitan Area Base Map.

-   *Total Minority Population Overlay --* showed 2000 Census data of
    concentrations of minorities throughout the service area for
    placement on the Phoenix Metropolitan Area Base Map

8.  []{#__RefHeading___Toc96402333 .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) Distribution of Transit Amenities

(4) Vehicle Headway

(5) Transit Access

**Findings:** At the site visit, deficiencies were found with FTA Title
VI Program requirements for Service Standards and Policies. In the
City's draft Title VI Update Report dated December 2004 and at the time
of the site visit, the City had quantifiable service standards for
vehicle load and vehicle headway. In the Title VI Update Report, the
City did not have quantifiable service standards for vehicle assignment,
transit amenities and transit access. At the site visit, the City did
provide standards for some amenities (e.g. bus shelters and bus
benches), but they did not appear to have been incorporated into the
Title VI program. Subsequent to the site visit, the City provided
Service Standards and Policies for vehicle assignment, transit
amenities, and transit access that were sufficient to correct the
deficiencies noted during the site visit. The City's service standards
required for Title VI are summarized in the following table:

+---------------------+------------------------------------------------+
| **FTA Service       | **City Policy**                                |
| Standard**          |                                                |
+=====================+================================================+
| **Vehicle Load** -  | Fixed route service has a vehicle load of 125  |
| A ratio of the      | percent for peak local routes and 100 percent  |
| number of           | for non-peak local and express routes.         |
| passengers on a     |                                                |
| vehicle to the      |                                                |
| number of seats     |                                                |
+---------------------+------------------------------------------------+
| **Vehicle Headway** | Maximum peak headway is 20 minutes (except on  |
| -                   | low ridership routes); and maximum off-peak    |
|                     | headway is 60 minutes.                         |
| The time interval   |                                                |
| between two         |                                                |
| vehicles traveling  |  -------------- --------------- -------------- |
| in the same         |   ***Service     ***Headway***                 |
| direction on the    |   Type***                                      |
| same route          |                                                |
|                     |                  Peak            Off-peak      |
|                     |                                                |
|                     |   Local          ≤ 15 min.       ≤ 30 min.     |
|                     |                                                |
|                     |   Express        ≤ 15 min.       N/A           |
|                     |                                                |
|                     |   Saturday\*     ≤ 30 min.                     |
|                     |                                                |
|                     |   Sunday/Night   ≤ 60 min.                     |
|                     |   Holiday \*                                   |
|                     |                                                |
|                     |  -------------- --------------- -------------- |
|                     |                                                |
|                     | \* No Express Routes                           |
|                     | Saturday/Sunday/Holiday/Night                  |
+---------------------+------------------------------------------------+
| **Transit           | **Bus Stops:** should be placed no more than   |
| Access** - The      | one quarter mile apart.                        |
| distance a person   |                                                |
| must travel to gain |                                                |
| access to transit   |                                                |
| service             |                                                |
+---------------------+------------------------------------------------+

+---------------------+------------------------------------------------+
|                     | -   Vehicle Age                                |
|                     |                                                |
|                     |     -   One to six years -- 5 points           |
|                     |                                                |
|                     |     -   Seven to twelve years -- 3 points      |
|                     |                                                |
|                     |     -   Over twelve years -- 1 point           |
|                     |                                                |
|                     | -   Low Floor vs. High Floor                   |
|                     |                                                |
|                     |     -   Low Floor -- 5 points                  |
|                     |                                                |
|                     |     -   High Floor -- 1 point                  |
+---------------------+------------------------------------------------+
| **Distribution of   | > **Bus Benches & Shelters**                   |
| Transit Amenities** | >                                              |
| -                   | > Service Standard Elements:                   |
|                     |                                                |
| Criteria for        | -   Boardings                                  |
| installation of     |                                                |
| items of comfort    | -   Activity Center Location                   |
| and convenience     |                                                |
| available to the    | -   Availability of Shade                      |
| general public      |                                                |
|                     | -   Length of waiting time                     |
|                     |                                                |
|                     | > Service Standard Point Values:               |
|                     |                                                |
|                     | -   Boardings: 25 or more -- 10 points         |
|                     |                                                |
|                     | -   Activity Center: Bus stops located within  |
|                     |     one quarter mile of Activity Center -- 4   |
|                     |     points                                     |
|                     |                                                |
|                     | -   Bus stops with no natural or man-made      |
|                     |     shade -- 4 points                          |
|                     |                                                |
|                     | -   Frequency: in excess of 15 minutes at peak |
|                     |     -- 4 points                                |
|                     |                                                |
|                     | -   Bus stop warrants                          |
|                     |                                                |
|                     |     -   4 to 9 points -- bench                 |
|                     |                                                |
|                     |     -   10 points or more -- shelter           |
|                     |                                                |
|                     | **Transit Centers:** placements based on       |
|                     | regional average employment and population     |
|                     | density within a TAZ. Then an analysis of the  |
|                     | following three criteria:                      |
|                     |                                                |
|                     | 1.  More than 400 boardings per day at the bus |
|                     |     stops within TAZ                           |
|                     |                                                |
|                     | 2.  TAZ is located within one-quarter mile of  |
|                     |     an Activity Center.                        |
|                     |                                                |
|                     | 3.  Census data confirms that private          |
|                     |     automobile ownership within TAZ is less    |
|                     |     than the regional average                  |
|                     |                                                |
|                     | **Park-and-Rides:** based on population        |
|                     | density per square mile by TAZ that is equal   |
|                     | to or greater than the regional average.       |
|                     | Analyze if the TAZ area is located near a      |
|                     | major freeway and at least eight miles from    |
|                     | one of the top ten employment density areas in |
|                     | the region.                                    |
+---------------------+------------------------------------------------+

[]{#__RefHeading___Toc96402334 .anchor}

9.  Assessment of Compliance by Grantees

**Requirement:** To develop procedures and guidelines for monitoring
compliance with Title VI. At a minimum, periodic 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.

**Findings:** During this Title VI Compliance Review of the City, no
deficiencies were found with FTA requirements for Internal Monitoring
Procedures. The City provided documentation to show that it had
developed and implemented procedures to assess service provided to the
minority community in conformance with the Circular. Using 2000 Census
data, the level and quality of transit service was measured in every
minority and non-minority census tract in the service area. The service
analysis results are as follows:

+---------------------------------------+--------------+--------------+
| Service                               | Service Area | Service Area |
|                                       | Minority     | Non-Minority |
| Indicators                            |              |              |
|                                       | Census       | Census       |
|                                       | Tracts       | Tracts       |
+---------------------------------------+--------------+--------------+
| Average number of available routes    | 4.5          | 3.0          |
+---------------------------------------+--------------+--------------+
| Peak frequency-local only (minutes)   | 26           | 28           |
+---------------------------------------+--------------+--------------+
| Off-peak frequency-local only         | 33           | 33           |
| (minutes)                             |              |              |
+---------------------------------------+--------------+--------------+
| Number of daily trips                 | 63           | 65           |
+---------------------------------------+--------------+--------------+
| Average percent of on-time trips      | 90%          | 90%          |
+---------------------------------------+--------------+--------------+
| Average age of Vehicles (years)       | 5.7          | 6.7          |
+---------------------------------------+--------------+--------------+

\*Minority Census Tract has minimum minority population of 34% (total
percent minorities in Maricopa County)

Overall, the analysis demonstrates that citizens in minority census
tracts received an equitable level of transit service compared to
non-minority citizens.

10. []{#__RefHeading___Toc96402335 .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

**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 the City, no
deficiencies were found with FTA requirements for Changes in Service
Features. In its draft Title VI Update Report dated December 2004, the
City provided documentation that it did identify and consider the
impacts on minorities prior to making decisions on fare increases and
service changes. Twice a year, the City of Phoenix, along with other
Valley Metro members, coordinate the implementation of regional and
local transit service changes. Those service changes are reviewed to
determine compliance with the FTA's Title VI Program Guidelines.
According to the City's 2004 draft Title VI Update Report, the
determination of compliance is based upon an analysis of the impact of
the service changes to minority and non-minority census tracts.

Since the passage of Proposition 2000 (a 0.4% sales tax levied to fund
transit services), there have been dramatic improvements in fixed route
service. Transit service was increased to midnight on most weekday
routes and to 10 PM on most weekend routes. Weekday and weekend
frequency was increased on over 30 routes region-wide.

######## 

######## 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 the City, no
> deficiencies were found with FTA requirements for Information
> Dissemination. In its draft Title VI Update Report and at the site
> visit, the City provided documentation that it makes efforts to inform
> the minority communities of transit service changes or improvements.
> The City uses the following methods to inform minority communities:

-   Public Hearings

-   Open houses

-   Focus Groups

-   Public Meeting Notices: published in minority newspapers such as
    *LaVoz, The Arizona Informant,* and *The Asian Times*

-   Internet

-   Government Access Station

-   Mass Email Distributions

-   The Bus Book

######## 

######## 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 the City,
deficiencies were found with FTA requirements for Minority
Representation on Decision-Making Bodies. As previously described, the
minority population in the service area is approximately 34%. The City
and its subrecipients have 11 policy-making and/or advisory bodies
related to public transit. None of the members of these bodies are
directly elected by the voters, but several of the bodies are made up of
elected officials and/or specific appointed staff members. Several of
the policy/advisory bodies serve the Maricopa Association of Governments
(MAG), the local metropolitan planning organization. The following table
shows the racial breakdown of all non-elected boards, commissions, and
committees:

  -------------------------- ---------- -------------- ------------------------
  Committee/Board Name       Minority   Non-Minority   Comments

  Citizens Transit           20%        80%            Appointed by the Phoenix
  Commission (15)                                      Mayor and City Council

  RPTA Board of Directors    8%         92%            Elected Officials
                                                       representing member
                                                       jurisdictions

                                                       

  Valley Metro/RPTA Transit  12%        88%            
  Management Committee                                 

  MAG Regional Council       13%        87%            Elected Officials
  Membership                                           

  MAG Management Committee   16%        84%            

  MAG Transportation Review  14%        86%            
  Committee                                            

  MAG Transportation Policy  8%         91%            
  Committee                                            

  Tempe Transportation       0%         100%           Appointed members
  Committee                                            

  Glendale Transportation    36%        64%            Appointed members
  Commission                                           

  Scottsdale Transportation  14%        86%            Appointed members
  Commission                                           

  Chandler Transportation    28%        72%            Appointed members
  Commission                                           
  -------------------------- ---------- -------------- ------------------------

As shown, eight of the eleven policy-making and advisory bodies are not
reflective of the minority population of the areas served. Only the
Glendale, Scottsdale and the Chandler Transportation Commissions have
membership on decision-making bodies that is reflective of or exceeds
the minority population of their respective areas. The City and its
subrecipients did not provide information on the efforts made to
encourage minorities to participate on its boards, committees, or
commissions.

**Corrective Action and Schedule**: Within 90 days, the City must submit
to the FTA Region IX Civil Rights Officer a description of the efforts
made by the City and its subrecipients to encourage minorities to
participate on its boards, committees, or commissions.

######## 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 the City, no
deficiencies were found with FTA requirements for Multilingual
Facilities. The City's largest minority group is its Hispanic
population. The City's Bus Book is a comprehensive book of information
about the City's transit service throughout the system. It provides
information in both English and Spanish. The transit customer
information phone system provides information in both English and
Spanish. Other commonly used communications are the City's printed
passenger notice and passenger pamphlets that are placed in transit
centers and on buses that are assigned routes in the impacted areas.
Examples of passenger notices include:

-   Express Changes: New Schedules, More Trips for Routes 531, 532, 533
    -- Effective Monday, Oct. 4, 2004 (on bright blue paper)

-   Route Changes: Route Change on Express Route 581 -- Effective
    Monday, Sept. 24, 2004 (on bright yellow paper)

-   Route and Schedule Change -- Route 62 Hardy Route and Schedule
    Change Effective Nov. 1, 2004 (on purple paper)

Examples of passenger pamphlets include:

-   *The Phoenix Transit Plan: Getting You There* -- Includes
    information about the history of The Phoenix Transit Plan, what the
    City has accomplished and what is in process (Spanish & English
    versions)

-   *Park and Ride --* Detailed information about using the Park and
    Ride

-   *Valley Metro:* A Regional Partnership -- Includes information about
    "who" Valley Metro is; facts about Valley Metro, Valley Metro
    Transit Services and Frequently Asked Questions (Spanish & English
    versions)

Whenever possible, information on transit services is disseminated via
the Internet, the government access station, and via email on a listserv
(which is a list of email addresses). In addition, communication with
existing and potential transit users is achieved in a variety of ways,
including public hearings, open houses and focus groups. The City's
Marketing Department is constantly seeking and creating relationships
with members of the non-English speaking communities in an effort to
improve communication regarding transit service with non-English
speaking communities.

11. []{#__RefHeading___Toc96402336 .anchor}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.

**Finding:** During this Title VI Compliance Review of the City,
deficiencies were found with FTA requirements for Assessment of
Compliance by Grantees. In its draft Title VI Update Report and during
the site visit, the City provided documentation of its monitoring of
compliance with Title VI requirements. At the site visit, it was
determined that the City was not conducting periodic assessments for
three of the five standards, namely vehicle assignment, transit
amenities and transit access.

During the site visit, the review team performed on-site observations of
vehicle loads, vehicle headways, vehicle assignment, transit access and
transit amenities throughout the service area. No disparities with
respect to vehicle loads, vehicle headways, and vehicle assignment were
apparent from the on site assessment. There appeared to be some
disparities with transit amenities (i.e., bus benches) in the minority
versus non-minority areas based on the observation of the review team.

Subsequent to the site visit, the City provided documentation that it
had performed assessments of vehicle assignment, transit amenities, and
transit access. For vehicle assignment, the City analyzed data from
August 2004 utilizing its point system as described in the Service
Standards and Policies section of this report (Section 8). According to
the resultant data, minority routes achieved a higher average point
value than non-minority routes in all categories except type of seat. In
its explanation, the City addressed the perceived disparity citing two
factors. First, the City of Tempe acquired 102 buses with full cloth
seats for its routes, which are predominantly non-minority routes. The
City of Tempe independently operates its own fixed route system. The 102
buses represent 12% of the total regional fixed route fleet. Second,
Laidlaw Transit, a City of Phoenix contractor, has 53 New Flyer diesel
buses with full cloth seats, serving a significant number of
non-minority routes. Since the Laidlaw facility does not have LNG or CNG
capability, the flexibility to exchange these buses with other
contractors serving minority routes is severely limited.

According to the City's analysis, of the bus stop amenities located in
minority versus non-minority census tracts, amenities do not appear to
be disproportionately distributed throughout the service area. According
to the resultant data, the percentage of bus stops with no amenities and
bus stops with shelters are comparable to for minority and non-minority
routes. In addition, there is a higher percentage of benches located in
minority routes (43%) versus non-minority routes (35%). The City's
analysis confirms that bus stops amenities are distributed in an
equitable manner.

The City's analysis of transit access showed that approximately 33% of
bus stop spacing gaps on minority routes fail to meet the one quarter
mile standard as compared to 39% on non-minority routes. Overall,
transit access in minority areas meets the standard at a higher rate
than it does in non-minority areas.

Subsequent to the site visit the City provided sufficient documentation
to comply with the assessment requirements of the Title VI Circular. No
adverse disparities were noted. There are no outstanding deficiencies in
this area.

12. []{#__RefHeading___Toc96402337 .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 the City, no
deficiencies were found with FTA requirements for Title VI Complaints.
The City provided documentation that it had conducted training to
operations and customer service staff specifically related to
recognizing and reporting Title VI complaints. The City has shown that
it has a complaint process. Subsequent to the site visit, the City
provided documentation that was printed in its January 2005 Bus Book to
include specific information on filing Title VI complaints. The Customer
Rights section of the Bus Book tells customers (in English and Spanish):

-   How to file a complaint

> *Customers wishing to file a complaint -- including discrimination due
> to disability, race, color or national origin -- may call Customer
> Relations at (602) 253-5000, option 2, or TTY (602) 261-8208.*

-   How complaints are processed

> *In accordance with federal standards (28CFR Part 35 and FTA Circular
> 4705.1); all regional transit providers are trained in the correct
> processing, investigation and documentation of passenger complaints
> involving discrimination based on disability, race, color or national
> origin. The Office of the Civil Rights Manager in the Public Transit
> Department monitors the complaint process as well as completed
> reports.*
>
> *All complaints received by customer Relations are documented and
> assigned to the appropriate transit staff for investigation. After the
> complaint is processed, a response is sent to the customer filing the
> complaint and appropriate corrective action is taken.*

VII. []{#__RefHeading___Toc96402338 .anchor}SUMMARY OF FINDINGS AND
     CORRECTIVE ACTIONS

+--------------+------+-----------+-------------------+--------+------+
| **Title VI   | **   | **De      | **Corrective      | **Re   | **   |
| Requirements | Site | scription | Action(s)**       | sponse | Date |
| For Transit  | Re   | of        |                   | Days/  | Clos |
| Providers**  | view | Defic     |                   | Date** | ed** |
|              | F    | iencies** |                   |        |      |
|              | indi |           |                   |        |      |
|              | ng** |           |                   |        |      |
+==============+======+===========+===================+========+======+
| 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   | ND   |           |                   |        |      |
| DOT Title VI |      |           |                   |        |      |
| Assurance    |      |           |                   |        |      |
+--------------+------+-----------+-------------------+--------+------+
| 6\.          | ND   |           |                   |        |      |
| Fi           |      |           |                   |        |      |
| xed-Facility |      |           |                   |        |      |
| Impact       |      |           |                   |        |      |
| Analysis     |      |           |                   |        |      |
+--------------+------+-----------+-------------------+--------+------+
| 7\.          | ND   |           |                   |        |      |
| Demographic  |      |           |                   |        |      |
| and Service  |      |           |                   |        |      |
| Maps,        |      |           |                   |        |      |
| Overlays and |      |           |                   |        |      |
| Charts       |      |           |                   |        |      |
+--------------+------+-----------+-------------------+--------+------+
| 8\. Service  | D    | > Service | > The City must   | 90     | 2/1/ |
| Standards    |      | >         | > submit to the   | Days   | 2005 |
| and Policies |      | Standards | > FTA Region IX   |        |      |
|              |      | > Not     | > Civil Rights    |        |      |
|              |      | >         | > Officer         |        |      |
|              |      |  Adequate | > quantifiable    |        |      |
|              |      |           | > service         |        |      |
|              |      |           | > standards for   |        |      |
|              |      |           | > vehicle         |        |      |
|              |      |           | > assignment,     |        |      |
|              |      |           | > transit         |        |      |
|              |      |           | > amenities, and  |        |      |
|              |      |           | > transit access  |        |      |
|              |      |           | > in accordance   |        |      |
|              |      |           | > with the        |        |      |
|              |      |           | > requirements of |        |      |
|              |      |           | > the FTA         |        |      |
|              |      |           | > Circular        |        |      |
|              |      |           | > 4702.1.         |        |      |
+--------------+------+-----------+-------------------+--------+------+
| 9\.          | ND   |           |                   |        |      |
| Assessment   |      |           |                   |        |      |
| of           |      |           |                   |        |      |
| Compliance   |      |           |                   |        |      |
| by Grantee   |      |           |                   |        |      |
+--------------+------+-----------+-------------------+--------+------+
| 10\. Other   | ND   | I         | The City must     | ####   |      |
| Areas of     |      | nadequate | submit to the FTA | #####  |      |
| Title VI     | ND   | Docu      | Region IX Civil   |        |      |
| Co           |      | mentation | Rights Officer a  | ####   |      |
| nsiderations | ##   | of        | description of    | #####  |      |
|              | #### | En        | the efforts made  |        |      |
| Changes in   | ###  | couraging | by the City and   | ####   |      |
| Service      |      | Minority  | its subrecipients | #####  |      |
| Features     | ###  | Repre     | to encourage      |        |      |
|              | #### | sentation | minorities to     | ####   |      |
| Information  | ## D | on        | participate on    | #####  |      |
| D            |      | Decisi    | its boards,       |        |      |
| issemination | #### | on-Making | councils, and     | ####   |      |
|              | #### | Bodies    | committees, as    | #####  |      |
| Minority     | # ND |           | required by FTA   |        |      |
| Re           |      |           | Circular 4702.1   | ####   |      |
| presentation |      |           |                   | #####  |      |
| on           |      |           |                   |        |      |
| Dec          |      |           |                   | ####   |      |
| ision-making |      |           |                   | #####  |      |
| Bodied       |      |           |                   |        |      |
|              |      |           |                   | ####   |      |
| M            |      |           |                   | #####  |      |
| ulti-lingual |      |           |                   |        |      |
| Facilities   |      |           |                   | ####   |      |
|              |      |           |                   | #####  |      |
|              |      |           |                   |        |      |
|              |      |           |                   | ####   |      |
|              |      |           |                   | #####  |      |
|              |      |           |                   |        |      |
|              |      |           |                   | ####   |      |
|              |      |           |                   | #####  |      |
|              |      |           |                   |        |      |
|              |      |           |                   | ####   |      |
|              |      |           |                   | #####  |      |
|              |      |           |                   |        |      |
|              |      |           |                   | #####  |      |
|              |      |           |                   | #### 9 |      |
|              |      |           |                   | 0 Days |      |
+--------------+------+-----------+-------------------+--------+------+
| 11\.         | D    | > I       | > The City must   | 90     | 2/1/ |
| Monitoring   |      | nadequate | > submit          | Days   | 2005 |
| Procedures   |      | > M       | > documentation   |        |      |
|              |      | onitoring | > to the FTA      |        |      |
|              |      | >         | > Region IX Civil |        |      |
|              |      | Conducted | > Rights Officer  |        |      |
|              |      |           | > that it has     |        |      |
|              |      |           | > conducted       |        |      |
|              |      |           | > monitoring in   |        |      |
|              |      |           | > accordance with |        |      |
|              |      |           | > FTA Circular    |        |      |
|              |      |           | > 4702.1.         |        |      |
+--------------+------+-----------+-------------------+--------+------+
| 12\. Title   | ND   |           |                   | ####   |      |
| VI           |      |           |                   | #####  |      |
| Complaints   |      |           |                   |        |      |
+--------------+------+-----------+-------------------+--------+------+

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

VIII. []{#__RefHeading___Toc96402339 .anchor}ATTENDEES

+-----------+----------------------+----------+-----------------------+
| **NAME**  | **TITLE/**           | **       | **E-MAIL**            |
|           |                      | PHONE/** |                       |
|           | **ORGANIZATION**     |          |                       |
|           |                      | **FAX**  |                       |
+===========+======================+==========+=======================+
| John      | Lead Reviewer/       | 504-     | <john.p               |
| Potts     |                      | 283-7661 | otts@thedmpgroup.com> |
|           | The DMP Group (DMP)  |          |                       |
|           |                      | 504-     |                       |
|           |                      | 283-0791 |                       |
+-----------+----------------------+----------+-----------------------+
| Donald    | Reviewer/            | 202-     | [                     |
| Lucas     |                      | 726-2630 | donald.lucas@thedmpgr |
|           | DMP                  |          | oup.com](mailto:royal |
|           |                      | 202-     | eiii@thedmpgroup.com) |
|           |                      | 726-1830 |                       |
+-----------+----------------------+----------+-----------------------+
| Bridgett  | Associate/           | 202-     | <bridgett.g           |
| Gagné     |                      | 726-2630 | agne@thedmpgroup.com> |
|           | DMP                  |          |                       |
|           |                      | 202-     |                       |
|           |                      | 726-1830 |                       |
+-----------+----------------------+----------+-----------------------+
| Maxine    | Reviewer/            | 504      | <Maxine.mars          |
| Marshall  |                      | 282-7949 | hall@thedmpgroup.com> |
|           | DMP                  |          |                       |
|           |                      | 504      |                       |
|           |                      | 283-0791 |                       |
+-----------+----------------------+----------+-----------------------+
| Dana P.   | Reviewer/            | 202-     | [dana.lucas@thedmpgr  |
| Lucas     |                      | 726-2630 | oup.com](mailto:royal |
|           | DMP                  |          | eiii@thedmpgroup.com) |
|           |                      | 202-     |                       |
|           |                      | 726-1830 |                       |
+-----------+----------------------+----------+-----------------------+
| Russ      | Compliance/          | 602      | <rste                 |
| Stevens   |                      | 534-4274 | vens@vm.maricopa.gov> |
|           | City of Phoenix      |          |                       |
|           | (City)               | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Jo Lynn   | Financial Management | 602      | <jke                  |
| Kegley    | Specialist/ City     | 534-9199 | gley@vm.maricopa.gov> |
|           |                      |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Paula     | Civil Rights         | 602      | <paula                |
| Barocas   | Coordinator/ City    | 534-6284 | .barocas@phoenix.gov> |
|           |                      |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| John      | Civil Rights         | 602      | <john.c               |
| Cleveland | Manager/             | 261-8392 | leveland@phoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Al        | Deputy Director of   | 602      | <al.vi                |
| V         | Contract             | 261-8997 | llaveroe@phoenix.gov> |
| illaverde | Compliance/City      |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Louis     | Transit OPS          | 602      | <louis.m              |
| Matamoros | Supervisor/          | 261-8957 | atamoros@phoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Debbie    | Acting Public        | 602      | <debbi                |
| Cotton    | Transit              | 534-6765 | e.cotton@phoenix.gov> |
|           | Director/City        |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Alan Max  | Transit Dept General | 602      | <                     |
|           | Counsel/             | 534-9132 | alan.max@phoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Scott     | Manager of Customer  | 602      | <swi                  |
| Wisner    | Service & Marketing/ | 495-5518 | sner@valleymetro.org> |
|           | Valley Metro         |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Susan     | Management Assist    | 602      | <susan.ro             |
| R         | II/                  | 534-6292 | bustelli@phoenix.gov> |
| obustelli |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Mark      | Principal Planner/   | 602      | <mark.me              |
| Me        |                      | 262-7240 | lnchenko@phoenix.gov> |
| lnychenko | City                 |          |                       |
|           |                      | 602      |                       |
|           |                      | 534-0879 |                       |
+-----------+----------------------+----------+-----------------------+
| Scott     | Senior Transit       | 602      | <scot                 |
| Miller    | Planner/             | 495-5734 | t.millner@hoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-7007 |                       |
+-----------+----------------------+----------+-----------------------+
| Becky     | ADA Quality          | 602      | <bjoh                 |
| Johnson   | Assurance            | 534-1869 | nson@valleymetro.org> |
|           | Specialist/Valley    |          |                       |
|           | Metro                |          |                       |
+-----------+----------------------+----------+-----------------------+
| Steven    | Deputy Director      | 602      | <Ste                  |
| Brown     | Operations &         | 261-8932 | ve.brown@phoenix.gov> |
|           | Planning/ City       |          |                       |
|           |                      | 602      |                       |
|           |                      | 261-8838 |                       |
+-----------+----------------------+----------+-----------------------+
| Mike      | Acting Deputy        | 602      | <mike                 |
| Nevarez   | Director Regional    | 262-7303 | .nevarez@phoenix.gov> |
|           | Information          |          |                       |
|           | Technology           | 602      |                       |
|           | Services/City        | 261-8838 |                       |
+-----------+----------------------+----------+-----------------------+
| Jennifer  | Supervisor Graphics  | 602      | <jw                   |
| Watts     | C                    | 534-7391 | atts@valleymetro.org> |
|           | ommunications/Valley |          |                       |
|           | Metro                | 602      |                       |
|           |                      | 261-8756 |                       |
+-----------+----------------------+----------+-----------------------+
| Kini      | Facilities Engineer/ | 602      | <kini                 |
| Knudson   |                      | 262-7254 | .knudson@phoenix.gov> |
|           | City                 |          |                       |
|           |                      | 602      |                       |
|           |                      | 534-0879 |                       |
+-----------+----------------------+----------+-----------------------+
| Dale      | Transit Planning     | 602      | <da                   |
| Hardy     | Manager/             | 262-1611 | le.hardy@phoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-7007 |                       |
+-----------+----------------------+----------+-----------------------+
| Marie     | Public Information   | 602      | <marie                |
| Chapple   | Officer/             | 261-8254 | .chapple@phoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Angie     | Management Assistant | 602      | <angi                 |
| Harvey    | III/                 | 262-1823 | e.harvey@phoenix.gov> |
|           |                      |          |                       |
|           | City                 | 602      |                       |
|           |                      | 495-2002 |                       |
+-----------+----------------------+----------+-----------------------+
| Anne      | Operations &         | 602      | <amaccra              |
| M         | Planning Planner     | 495-0352 | cken@valleymetro.org> |
| acCracken | III/Valley Metro     |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-0411 |                       |
+-----------+----------------------+----------+-----------------------+
| Bryan     | Deputy Director/     | 602      | <bjungw               |
| Jungwirth |                      | 534-1803 | irth@valleymetro.org> |
|           | Valley Metro         |          |                       |
|           |                      | 602      |                       |
|           |                      | 495-0411 |                       |
+-----------+----------------------+----------+-----------------------+
| Jim       | Deputy Executive     | 602      | <jdi                  |
| Dickey    | Director             | 495-0585 | ckey@valleymetro.org> |
|           |                      |          |                       |
|           | Valley Metro/RPTA    | 602      |                       |
|           |                      | 495-0411 |                       |
+-----------+----------------------+----------+-----------------------+
| Dan Matta | Transit Systems      | 602      | <dm                   |
|           | Supervisor/          | 534-6888 | atta@vm.maricopa.gov> |
|           |                      |          |                       |
|           | ATC Phoenix          |          |                       |
+-----------+----------------------+----------+-----------------------+