## **TITLE VI COMPLIANCE ASSESSMENT**

#### **OF THE**

### **BROWNSVILLE URBAN SYSTEM**

**(BUS)**

**BROWNSVILLE, TEXAS**

[Final Report]{.underline}

August, 2005

##### Prepared For

U.S. DEPARTMENT OF TRANSPORTATION

FEDERAL TRANSIT ADMINISTRATION

OFFICE OF CIVIL RIGHTS

## 

## 

## **Prepared By**

## MILLIGAN & Company, LLC

###### Table of Contents

####### GENERAL INFORMATION......................................................3

I.  JURISDICTION AND
    AUTHORITIES.........................................4

II. PURPOSE AND
    OBJECTIVES.................................................5

III. BACKGROUND
     INFORMATION.................................\...\...\...\...\....6

IV. SCOPE AND
    METHODOLOGY................................................8

V.  FINDINGS AND RECOMMENDATIONS................................... 11

VI. SUMMARY OF FINDINGS AND RECOMMENDATIONS...............17

VII. ATTENDEES........................................................................18

**I.** **[GENERAL INFORMATION]{.underline}**

Grant Recipient: Brownsville Urban System

700 Jose Colunga Jr. Street

Brownsville, Texas 78521

City/State: Brownsville, Texas

Grantee No: 1591

Executive Official: Norma H. Zamora, Director

Brownsville Urban System

700 Jose Colunga Jr. Street

Brownsville, Texas 78521

Report Prepared By: MILLIGAN & Company, LLC

Mulberry Atrium North

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

Philadelphia, PA 19103

Site Visit Dates: February 4, 2003 to February 6,2003

Compliance Review

Team Members: Sandra Swiacki

Lead Reviewer

Milligan & Company, LLC

Anne Marie Byrnes

Reviewer

Milligan & Company, LLC

Isidro Cardenas

Reviewer

JDG Associates

**II. [JURISDICTION AND AUTHORITIES]{.underline}**

The Federal Transit Administration (FTA) Office of Civil Rights is
authorized by the Secretary of the U.S. Department 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 22 of the Master Agreement, Federal Transit Administration C.A.
(3), October 1, 1996: and 49 U.S.C. 5332, "Non-Discrimination."

The Brownsville Urban System (BUS) 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 4704.1, "Title VI Program Guidelines for Grant Recipients,"
dated July 26, 1988; Part II, Section 117(a) of the FTA Agreement; and
FTA Circular 4702.1, "Title VI Program Guidelines for Federal Transit
Administration Recipients," dated May 26, 1988.

On August 11, 2000, Executive Order 13166, Improving Access to Services
for Persons with Limited English Proficiency (LEP), was signed into law.
On the same day, the U.S. Department of Justice issued policy guidance
for recipients of Federal financial assistance to ensure that their
programs and activities normally provided in English are accessible to
LEP persons and do not discriminate on the basis of national origin in
violation of Title VI. On January 22, 2001, the U.S. Department of
Transportation (DOT) issued guidance on Title VI's prohibition against
national origin discrimination as it affects LEP persons. The DOT LEP
Guidance defines the components that should be addressed by BUS and were
the basis for the selection of elements that were reviewed in this
document.

**III. [PURPOSE AND OBJECTIVES]{.underline}**

**Purpose**

The Federal Transit Administration (FTA) Office of Civil Rights
contracted with Milligan & Company, LLC to develop guidance for
conducting Title VI Assessments in four areas -- Multilingual
Communications, Fare Increases, Service Changes and Equitable Allocation
of Resources. To evaluate the procedures in the newly developed
guidance, the Office of Civil Rights authorized Milligan & Company, LLC
to conduct pilot reviews in each of the four areas.

The Brownsville Urban System (BUS) was selected by the FTA's Office of
Civil Rights for the pilot assessment for Multilingual Communications.
The purpose of the assessment was to determine the extent to which BUS
has met its Title VI Program requirements as specified in the U. S.
Department of Transportation (DOT) Limited English Proficiency (LEP)
Guidance and to solicit their input on the guidance.

**Objectives**

The objectives of FTA's Title VI Program, as set forth in FTA Circular
4702.1, "Title VI Program Guidelines for Federal Transit Administration
Recipients," 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;

-   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;

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

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

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

**IV. [BACKGROUND INFORMATION]{.underline}**

The Brownsville Urban System (BUS) is a department of the city of
Brownsville, TX and is responsible for providing public transit to the
citizens of Brownsville. BUS is governed by the Brownsville City
Commission, which is comprised of the Mayor and six City Commissioners.
BUS has been providing public transportation since 1978. It has
approximately 69 employees and operates two main types of service --
fixed route and paratransit.

There are 12 fixed-route bus routes in the city of Brownsville. All
routes originate at the Downtown Terminal located at Market Square.
Operating hours are Monday through Saturday from 5:50 AM to 8:26 PM. The
regular fare is \$1.00 with no transfers.

Paratransit service is available for elderly and disabled patrons and
others who are not able to use the regular fixed-route bus service. The
service is curb-to-curb and provided with ramp- or lift-equipped vans
and buses. Patrons must fill out an application to determine whether
they qualify. Service is offered from 6 AM to 7 PM, Monday through
Saturday. Reservations must be made at least 24 hours in advance and the
fare is currently \$1.50. All fixed route buses are also equipped with
lifts and are totally accessible.

The city of Brownsville has a population of approximately 140,000.
According to the 2000 Census, 91 percent of Brownsville residents are of
Hispanic descent. As Brownsville is a border community, Mexican
Nationals comprise 41 percent of the system's ridership. General
demographic characteristics for the city of Brownsville, obtained from
the 2000 census, are summarized below.

##### [City of Brownsville, TX]{.smallcaps}

  ------------------------------ ---------------- -----------------------
  **Race/Ethnicity**             **Number**       **Percent %**

  White                          10,234           7

  Black                          575              \<1

  Asian/Pacific Islander         798              \<1

  American Indian/Alaskan Native 580              \<1

  Hispanic**\***                 127,535          91

  **Total Population**           139,722          100
  ------------------------------ ---------------- -----------------------

**\***Includes 103,297 Mexicans, 215 Puerto Ricans, 159 Cubans, and
23,864 Other Hispanic/Latino

**[City of Brownsville, TX]{.smallcaps}**

  ----------------------------------------------- ------------ -----------
  **Language Spoken at Home**                     **Number**   **Percent
                                                               %**

  Total Population 5 years and over               126,114      100

  English only                                    16,111       13

  Language other than English                     110,003      87

  Speak English less than "very well"             52,970       42

  Spanish                                         109,153      87

  Speak English less than "very well"             52,711       42

  Other Indo-European languages                   391          \<1

  Speak English less than "very well"             86           \<1

  Asian and Pacific Island languages              367          \<1

  Speak English less than "very well"             125          \<1
  ----------------------------------------------- ------------ -----------

## **Results of BUS Customer Survey**

BUS conducts an annual customer survey as a method of monitoring quality
of service. Results of recently conducted surveys were reviewed during
the site review. The survey is conducted in English and in Spanish. It
was noted that the Spanish version of the survey had a higher response
rate than the English version.

**V. [SCOPE AND METHODOLOGY]{.underline}**

######## Scope

The Title VI Compliance Assessment of the Brownsville Urban System (BUS)
for Multilingual Communications focused on the following areas, as
specified in the U. S. Department of Transportation (DOT) Guidance to
Recipients on Special Language Services to Limited English Proficient
(LEP) Beneficiaries:

> 1\. [Ensuring Meaningful Access to LEP Persons]{.underline} -- The key
> to providing meaningful access to LEP persons is to ensure that
> recipients and LEP beneficiaries can communicate effectively and act
> appropriately based on the communication. DOT recipients should take
> reasonable steps to ensure that LEP persons are given adequate
> information, are able to understand that information, and are able to
> participate effectively in recipient programs or activities, where
> appropriate.
>
> 2\. [Compliance and Enforcement - Assurance Forms.]{.underline} When
> organizations receive DOT financial assistance, they accept the
> obligation to implement DOT's Title VI regulations. These assurances
> include provision of services to national origin minority persons who
> are limited in English proficiency.
>
> 3\. [Framework for Language Assistance]{.underline} -- DOT has
> determined that effective language assistance programs usually address
> the following elements: Needs Assessment, Written Language Assistance
> Plan, Staff Training, Provision of Special Language Assistance and
> Monitoring.
>
> 4\. [Ways of Providing Language Services]{.underline} -- Once the
> recipient has determined that language services are needed, there are
> three main ways of providing services: oral interpretations, written
> translations, and alternative, non-verbal methods.
>
> 5\. [Application of this Guidance for DOT Recipients]{.underline} --
> Guidance in this chapter covers the following areas: Grievance or
> Complaint Procedures, LEP Community Outreach and Education,
> Transportation Planning, Numerical Thresholds, Emergency Services,
> Charging for Special Language Services, and Surveys.

######## Methodology

At the beginning of the pilot review, a telephone interview was
conducted with the Regional Civil Rights Officer about specific Title VI
issues and concerns regarding BUS. Following the interview, a detailed
letter was sent to Norma Zamora, Director of BUS, advising her of the
site visit, its purpose, issues to be discussed, and information that
would be needed for the pilot review. In the letter, BUS was asked to
provide the following background information:

-   Any analysis conducted that identifies communities where languages
    other than English are the predominate languages.

-   Listing of media used to make service information available to the
    public, such as: newspapers, system maps, brochures, postings, radio
    and television.

-   Listings and samples of information provided in languages other than
    English. This includes description of the extent to which bilingual
    persons and/or materials are used to assist non-English speaking
    persons.

-   Contact information for community groups that represent non-English
    speaking communities.

In a follow-up telephone conversation with the Director of BUS, the
review team also requested a copy of their Title VI Program. BUS
provided their Title VI Program approved by the FTA on July 28, 1999 and
their most recent submission dated January 15, 2003.

The site visit at BUS was conducted on February 4 to February 6, 2003.
The individuals participating in the review are listed in Section VIII
of this report. At the entrance conference, the purpose of the pilot
review, the proposed schedule for conducting the review and the review
process were discussed. The agenda included interviews with appropriate
staff representatives to verify methods and types of communication used
to convey service and planning information in languages other than
English. Some interviews were conducted in Spanish to ascertain the
skill level and availability of multilingual personnel on staff.

Interviews were also conducted with community representatives to
determine the efforts taken by the grantee to communicate with and
provide service information to customers with limited English
proficiency, the adequacy of the communications provided, and the areas
needing improvement. Lastly, the site review included a tour of the
Market Square Terminal, the main station terminal in the city of
Brownsville, and a ride on the Bus Route #7 to Billy Mitchell Boulevard.
Observations were made during the inspection to verify the existence of
safety instructions, and in-station and on-board information in
languages other than English.

During the site visit, the following documents were requested and
provided to the review team:

-   Samples of communications not previously submitted with the request
    for information, including newspaper articles and notices of route
    changes and public hearings

-   Public Participation Policy dated January 2, 1996

-   The BUS Newsletter

-   Brownsville MPO Newsletters

-   BUS Passenger Survey Results Dated March 2001

-   The Paratansit Owner's Manual

-   BUS Request for Certification of ADA Paratransit Eligibility

-   Employment Application.

At the exit conference, the review team and BUS management discussed the
results of the pilot review, recommendations and suggestions, and the
next steps.

**VI. [FINDINGS AND RECOMMENDATIONS]{.underline}**

The Title VI Compliance Assessment for Multilingual Communications
focused on the Brownsville Urban System's (BUS') compliance with the
Title VI Program requirements as specified in the U. S. Department of
Transportation (DOT) Limited English Proficiency (LEP) Guidance. This
section describes the areas examined, results of the review, and
recommendations.

**1. [Needs Assessment]{.underline}**

> The recipient should conduct an overall assessment of the language
> needs of the population and communities served by the recipient to
> determine whether multilingual needs exist in their service area.
>
> **Results of Review:** The community served by BUS is predominantly of
> Hispanic origin. As such, the need to provide communications in
> Spanish is a generally accepted business practice and is fully
> integrated into their daily operations. Although the other communities
> in their service area are relatively small in comparison, no
> assessment has been conducted to determine if multilingual needs exist
> in those communities.
>
> **Recommendations:** Per the DOT LEP Guidance, it is recommended that
> BUS conduct a thorough assessment of the population it serves to
> determine whether there is a need for language assistance beyond the
> Hispanic community. Suggested ways to determine language needs include
> identifying the non-English languages used in communities affected by
> BUS, estimating how many people speak each language, where they live,
> and how well they are currently accessing services being used by those
> who are fully English proficient. Data from local organizations,
> community groups, the census, and the Geographic Information System
> (GIS) maintained by the Brownsville Metropolitan Planning Organization
> are excellent sources to identify communities with potential special
> language needs.

**2. [Assessment of Linguistically Isolated Populations]{.underline}**

> The DOT LEP Guidance specifically encourages recipients to identify
> linguistically isolated populations or job sites in which LEP persons
> represent a significant proportion of the workforce. Linguistically
> isolated is defined in the census as the percentage of the persons in
> households in which no one over the age of 14 speaks English well, and
> is used as a direct measure of those persons with a severe language
> barrier.
>
> **Results of Review**: BUS has not identified linguistically isolated
> populations or jobsites in which LEP persons represent a significant
> proportion of the workforce.
>
> **Recommendations:** As suggested in the DOT LEP Guidance**,** BUS is
> encouraged to determine whether any of these populations exist when
> conducting the overall assessment of their service area.

**3. [Identification of Barriers]{.underline}**

> After identifying LEP communities, recipients should determine if any
> barriers exist in any of their methods of communication.
>
> **Results of Review:** No specific barriers to communication with the
> Hispanic community have been identified by BUS. The need to provide
> communications in Spanish is a generally accepted practice at BUS in
> order to effectively communicate with the Hispanic community. Although
> not related to language, BUS recognizes that a large portion of their
> ridership, particularly those from Mexico, are not literate and
> obstacles may exist if written translation is the only method utilized
> to communicate information.
>
> **Recommendations:** If other populations are identified with language
> needs after conducting the above recommended assessment, BUS is
> encouraged to determine if any barriers exist in any of their methods
> of communication with these communities.

**4. [Availability of Multilingual Communications]{.underline}**

> The recipient should take reasonable steps to ensure that LEP persons
> are given adequate information, are able to understand that
> information, and are able to participate effectively in recipient
> programs and activities.
>
> **Results of Review:** BUS demonstrated that it has taken reasonable
> steps to provide meaningful opportunities for the Hispanic community
> to access transit information. Evidence of these efforts included
> bilingual notices regarding public hearings, service changes, and
> capital projects. General information on fares, service hours, routes,
> schedules, and procedures for using the transit system were contained
> in a bilingual BUS Rider Guide. The paratransit manual and
> certification application, the passenger survey, and customer comment
> cards were also available in Spanish. During the facility tour, the
> existence of bilingual signage, maps, schedules and passenger
> announcements was also confirmed by the review team.
>
> However, it was noted during the review that several items were found
> only in English. These included the hours of operation posted at the
> Market Square Terminal, the city's employment application, the BUS
> Newsletter which is distributed to the community, and the agency's
> website. Additionally, at the exit conference, it was pointed out that
> some information on the route schedules and system maps was not fully
> translated into Spanish. These included the symbol legend and verbiage
> such as depart and arrive terminal, days of the week, and some notes
> and comments. A full translation would ensure a better understanding
> of the route and schedule information by limited English proficient
> individuals.
>
> **Recommendations:** BUS should translate the hours of operation and
> remaining information on the route schedules and system maps into
> Spanish. BUS should also consider the other items listed above and,
> based on the resources available, translate those that would provide
> the most benefit to non-English proficient individuals in their
> service area.

**5. [Written Language Assistance Plan]{.underline}**

> The recipient should develop and implement written language assistance
> plans that will ensure meaningful opportunities for LEP persons to
> access their programs and activities and fully participate in them.
>
> **Results of Review:** BUS has not developed or implemented a written
> language assistance plan as suggested in the DOT LEP Guidance.
> However, due to the nature of their service area, several of the
> suggested items in the guidance have been routinely integrated into
> their normal course of business. These included a mix of oral and
> written language assistance, an inventory of translated materials,
> staff training and program monitoring. However, as previously
> mentioned, one critical item not addressed was the needs assessment.
>
> **Recommendations:** BUS should consider developing a written language
> assistance plan as recommended in the LEP Guidance to document the
> results of their needs assessment and all other efforts that have been
> taken to provide meaningful opportunities for LEP persons to date.

**6. [Staff Training]{.underline}**

> The recipient should ensure that staff understand the language
> assistance plan and are capable of carrying it out.
>
> **Results of Review:** BUS requires that all employees who deal with
> the public on a routine basis be bilingual. Bus operators participate
> in an orientation program that includes 120 hours of training. This
> ensures that operators can provide information to the public in both
> English and Spanish. Cultural sensitivity to the language needs of
> their customers is also regularly reinforced through memorandums and
> meetings with employees. BUS indicated that their challenge in this
> area, to the contrary, has been to encourage operators to communicate
> more with the public in English. This issue was also voiced during the
> interviews by one of the community representatives.

**7. [Special Language Assistance]{.underline}**

> A vital part of an effective compliance program includes having
> effective methods for notifying LEP persons regarding their right to
> language assistance and the availability of such assistance free of
> charge.
>
> **Results of Review:** Since BUS personnel are predominantly
> bilingual**,** the Hispanic community appear to be aware that language
> assistance is available through their regular and daily interaction
> with staff. When commuters ask questions in Spanish, staff
> automatically respond in Spanish. At public hearings, the audience is
> queried as to whether the meeting should be conducted first in Spanish
> or English. Staff respond according to the preference of the audience.
> Telephone lines with a Spanish-speaking option are also available.
> Based on the above factors, having formal methods at BUS to notify the
> public of their right to language assistance is not an issue nor does
> it appear to be necessary.

**8. [Monitoring]{.underline}**

> Recipients should conduct regular oversight of their language
> assistance programs to ensure that LEP persons can meaningfully access
> their programs and activities.
>
> **Results of the Review**: BUS primarily uses feedback from the
> community to monitor its language assistance program. Information
> obtained from complaints and telephone calls is evaluated to determine
> how well the agency is meeting the language needs of the public. BUS
> takes corrective action to improve the effectiveness of their
> communication depending on the number and type of complaints received.
>
> **Recommendations:** BUS should consider using the passenger survey as
> an additional tool to monitor and evaluate the effectiveness of their
> language assistance program. Wider distribution of the survey, for
> example, to various community centers may also provide BUS with more
> direct feedback to better gauge their progress and areas needing
> improvement.

**9. [Types of Language Services]{.underline}**

> Once the recipient has determined that language services are needed,
> there are three main ways of providing those services -- oral
> interpretation, written translation and alternative, non-verbal
> methods.
>
> **Results of Review:** Language services provided by BUS primarily
> involve oral and written translation. Bilingual personnel on staff are
> responsible for providing these services to the public. Evidence of
> written translations included various notices, applications,
> schedules, signage, passenger surveys and several informational
> brochures and pamphlets. The translated materials and the language
> skills of the staff were also evaluated by the bilingual specialist on
> the review team. Both were determined to be adequate.
>
> **Recommendations:** BUS should consider utilizing more alternative,
> non-verbal methods of communication in the future, such as pictures,
> symbols, illustrations, graphics and diagrams. This may help to
> address some of the challenges in providing language services that BUS
> voiced during the review. These included the education and literacy
> level of their customers, the expense of using outside contractors for
> translation, and the regional differences in dialects.

**10.** **[Grievance or Complaint Procedures]{.underline}**

> The recipient should maintain a written and publicly known grievance
> or complaint procedure that is available to members of the public so
> that LEP persons can bring alleged problems with lack of services to
> the recipient's attention for resolution.
>
> **Results of Review:** Complaints are generally initiated through the
> secretary at the main office. A complaint form is available for the
> public to provide information regarding an alleged problem. Incoming
> complaints are recorded and forwarded to a transit supervisor in the
> Customer Service area for investigation. The administrative staff
> responds directly to the complaining party, usually in a face-to-face
> meeting. Telephone numbers to contact BUS are listed in the passenger
> guide and on system maps and route schedules.
>
> **Recommendations:** Per the DOT LEP Guidance, it is suggested that
> BUS formalize their complaint procedure in a written document.

**11. [LEP Community Outreach and Education]{.underline}**

> The DOT LEP Guidance suggests that the recipient establish a formal
> link with minority, community-based organizations.
>
> **Results of Review:** Interviews with community representatives
> confirmed that BUS is responsive and sensitive to the needs of the
> community it serves. It was apparent during the review that BUS has
> initiated and developed effective working relationships with community
> organizations. Two such examples are the partnerships that were formed
> with Cameron Works, Inc. and Ozanam Center, Inc. Through their
> combined efforts, transportation was made more accessible and
> affordable to low-income persons and welfare recipients. BUS also
> recently invited the directors of these organizations to participate
> on their Transit Advisory Committee, which demonstrates their efforts
> to further develop and sustain ongoing relationships with the
> community.

**12. [FTA Circular 4702.1 Requirements]{.underline}**

> The following requirements of FTA Circular 4702.1 were discussed
> during this review:

-   **Chapter III, Section 4 (d). Multilingual Facilities**. For
    agencies serving areas over 200,000, 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.

> **Results of the Review**: This area not specifically reviewed, as BUS
> serves an area of under 200,000. However, the information gathered in
> previous sections of this report demonstrates BUS' accomplishments in
> this area.

-   **Chapter IV, Section 2 (c) (2). Quality of Service Methodology**.
    Conduct a survey of transit riders in the identified areas to
    determine travel patterns and opinions on the transit service
    provided.

> **Results of the Review**: As discussed in other sections of this
> report,
>
> BUS conducts an annual customer survey as a method of monitoring
> quality of service. Results of recently conducted surveys were
> reviewed during the site review. The survey is conducted in English
> and in Spanish. It was noted that the Spanish version of the survey
> had a higher response rate than the English version.

-   **Chapter VIII, Section 2 (c). Multilingual Requirements**. Where a
    significant number or portion of the population eligible to be
    served needs service or information in a language other than English
    to participate in UMTA-assisted programs, the recipient shall take
    every reasonable step to provide information in appropriate
    languages.

> **Results of Review**: As discussed in other sections of this report,
> BUS demonstrates that this is accomplished using various methods of
> information dissemination, both written and oral.

**VII. [SUMMARY OF RESULTS AND RECOMMENDATIONS]{.underline}**

+-----------------------+-----------------------+-----------------------+
| **Areas Examined**    | **Results of Review** | **Recommendations**   |
+-----------------------+-----------------------+-----------------------+
| **1. Needs            | Overall assessment    | Identify other        |
| Assessment**          | not conducted.        | language needs in the |
|                       |                       | community.            |
+-----------------------+-----------------------+-----------------------+
| **2. Assessment of    | Not conducted.        | Identify              |
| Linguistically        |                       | linguistically        |
| Isolated              |                       | isolated populations  |
| Populations**         |                       | during overall needs  |
|                       |                       | assessment.           |
+-----------------------+-----------------------+-----------------------+
| **3. Identification   | Not conducted.        | Identify              |
| of Barriers**         |                       | communication         |
|                       |                       | barriers during       |
|                       |                       | overall needs         |
|                       |                       | assessment.           |
+-----------------------+-----------------------+-----------------------+
| **4. Availability of  | Reasonable efforts to | Translate the hours   |
| Multilingual          | provide multilingual  | of operation and      |
| Communications**      | communications.       | remaining information |
|                       |                       | on the route          |
|                       |                       | schedules and system  |
|                       |                       | maps into Spanish.    |
+-----------------------+-----------------------+-----------------------+
| **5. Written Language | Language Assistance   | Draft written         |
| Assistance Plan**     | Plan not in writing.  | Language Assistance   |
|                       |                       | Plan.                 |
+-----------------------+-----------------------+-----------------------+
| **6. Staff Training** | Staff aware of and    |                       |
|                       | understand language   |                       |
|                       | assistance plan.      |                       |
+-----------------------+-----------------------+-----------------------+
| **7. Special Language | Adequate and          |                       |
| Assistance**          | effective methods for |                       |
|                       | notification of       |                       |
|                       | language assistance   |                       |
+-----------------------+-----------------------+-----------------------+
| **8. Monitoring**     | Regular oversight     | Use passenger survey  |
|                       | provided.             | for additional        |
|                       |                       | feedback.             |
+-----------------------+-----------------------+-----------------------+
| **9. Types of         | Adequate mix of oral  | Consider the use of   |
| Language Services**   | interpretation and    | alternative,          |
|                       | written translations. | non-verbal methods of |
|                       |                       | communication.        |
+-----------------------+-----------------------+-----------------------+
| **10. Grievance or    | Adequate complaint    | Put complaint         |
| Complaint             | procedure in place.   | procedure in writing. |
| Procedures**          |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **11. LEP Community   | Adequate community    |                       |
| Outreach and          | outreach.             |                       |
| Education**           |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **12. Circular        | -   N/A BUS service   |                       |
| 4702.1**              |     area under        |                       |
|                       |     200,000           |                       |
| -   **Chapter III,    |                       |                       |
|     Section 4 (d).**  | -   Adequate survey   |                       |
|                       |     instruments       |                       |
| -   **Chapter IV,     |     utilized          |                       |
|     Section 2 (c)     |                       |                       |
|     (2).**            | -   Adequate          |                       |
|                       |     information       |                       |
| -   **Chapter VIII,   |     dissemination     |                       |
|     Section 2 (c).**  |                       |                       |
+-----------------------+-----------------------+-----------------------+

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

+----------------+---------------------+------------+-----------------+
| **NAME**       | **T                 | **PHONE**  | **EMAIL**       |
|                | ITLE/ORGANIZATION** |            |                 |
+----------------+---------------------+------------+-----------------+
| William Jones  | Regional Civil      | \(817\)    | [               |
|                | Rights Officer/     | 978-0558   | Bill.jones@fta. |
|                |                     |            | dot.gov]{.mark} |
|                | Federal Transit     |            |                 |
|                | Administration      |            |                 |
+----------------+---------------------+------------+-----------------+
| Norma H.       | D                   | \(956\)    | <               |
| Zamora         | irector/Brownsville | 541- 4881  | nzamora@cob.us> |
|                | Urban System (BUS)  |            |                 |
+----------------+---------------------+------------+-----------------+
| Elida Garza    | Assistant           | \(956\)    | <elida@cob.us>  |
|                | Director/BUS        | 541- 4881  |                 |
+----------------+---------------------+------------+-----------------+
| Tom Logan      | Transit Planner/BUS | \(956\)    | <tomlog@cob.us> |
|                |                     | 541- 5281  |                 |
+----------------+---------------------+------------+-----------------+
| Jose Sosa      | Transit             | \(956\)    |                 |
|                | Supervisor/BUS      | 548- 6050  |                 |
+----------------+---------------------+------------+-----------------+
| Jose Luis      | Transit             | \(956\)    |                 |
| Espericueta    | Supervisor/BUS      | 541- 8381  |                 |
+----------------+---------------------+------------+-----------------+
| Demetria       | Public              | \(512\)    | <dfairley@d     |
| Fairley        | Transportation      | 416- 2808  | ot.state.tx.us> |
|                | Programs            |            |                 |
|                | Administrator/Texas |            |                 |
|                | Department of       |            |                 |
|                | Transportation      |            |                 |
|                | (TXDOT)             |            |                 |
+----------------+---------------------+------------+-----------------+
| Gracie Cantu   | Public              | \(956\)    | <gcantu@d       |
|                | Transportation      | 702-6237   | ot.state.tx.us> |
|                | Coordinator/TXDOT   |            |                 |
+----------------+---------------------+------------+-----------------+
| Bill Young     | Public Information  | \(956\)    | <bill@cob.us>   |
|                | Officer/City of     | 548-0604   |                 |
|                | Brownsville         |            |                 |
+----------------+---------------------+------------+-----------------+
| Louis Tatum    | Finance             | \(956\)    | <tatum@ies.net> |
|                | Manager/Cameron     | 548-6768   |                 |
|                | Works Inc.          |            |                 |
+----------------+---------------------+------------+-----------------+
| Rey Guevara    | Director of         | \(956\)    | <rguevara       |
|                | Communication/      | 548-6767   | @camwksinc.org> |
|                | Cameron Works Inc.  |            |                 |
+----------------+---------------------+------------+-----------------+
| Mark D. Maddy  | Chairperson/Transit | \(956\)    | <Mda            |
|                | Advisory Committee  | 546-5226   | vid956@aol.com> |
+----------------+---------------------+------------+-----------------+
| Sister Fatima  | Social              | \(956\)    |                 |
| Santiago       | Worker/Ozanan       | 831-6331   |                 |
|                | Center, Inc.        |            |                 |
+----------------+---------------------+------------+-----------------+
| Alejandro      | Executive           | \(956\)    | [www.g          |
| Fuentes        | Director/Ozanan     | 831-6331   | arta.net/ozanam |
|                | Center, Inc.        |            | ](http://www.ga |
|                |                     |            | rta.net/ozanam) |
+----------------+---------------------+------------+-----------------+
| Sandra Swiacki | Lead                | \(215\)    | <Sswi           |
|                | Reviewer/Milligan & | 496-9100   | acki48@aol.com> |
|                | Company, LLC        |            |                 |
+----------------+---------------------+------------+-----------------+
| Anne Marie     | Reviewer/Milligan & | \(215\)    | <abyrnes@m      |
| Byrnes         | Company, LLC        | 496-9100,  | illigancpa.com> |
|                |                     | x151       |                 |
+----------------+---------------------+------------+-----------------+
| ######### I    | Reviewer/JDG        | (21        |                 |
| sidro Cardenas | Associates          | 0)410-8728 |                 |
+----------------+---------------------+------------+-----------------+