**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**Detroit Department of Transportation**

**(DDOT)**

**Detroit, Michigan**

**Final Report**

**October 2005**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**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___Toc95819634)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc95819635)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc95819636)

IV\. BACKGROUND INFORMATION [5](#__RefHeading___Toc95819637)

V. SCOPE AND METHODOLOGY [9](#__RefHeading___Toc95819638)

VI\. FINDINGS AND RECOMMENDATIONS [17](#__RefHeading___Toc95819639)

1\. List of Active Complaints and Lawsuits
[17](#__RefHeading___Toc95819640)

2\. Pending Applications for Financial Assistance
[18](#__RefHeading___Toc95819641)

3\. Summary of Civil Rights Compliance Reviews
[18](#__RefHeading___Toc95819642)

4\. FTA Civil Rights Assurance [19](#__RefHeading___Toc95819643)

5\. DOT Title VI Assurance [20](#__RefHeading___Toc95819644)

6\. Fixed-Facility (Environmental Justice) Impact Analysis
[20](#__RefHeading___Toc95819645)

7\. Demographic and Service Profile Maps, Overlays and Charts
[22](#__RefHeading___Toc95819646)

8\. Service Standards and Policies [24](#__RefHeading___Toc95819647)

9\. Assessment of Compliance by Grantees
[27](#__RefHeading___Toc95819648)

10\. Other Areas of Title VI Considerations
[29](#__RefHeading___Toc95819649)

11\. Internal Monitoring Procedures [34](#__RefHeading___Toc95819650)

12\. Title VI Complaints [35](#__RefHeading___Toc95819651)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[37](#__RefHeading___Toc95819652)

VIII\. ATTENDEES [41](#__RefHeading___Toc95819653)

I.  []{#__RefHeading___Toc95819634 .anchor}GENERAL INFORMATION

Grant Recipient: Detroit Department of Transportation

City/State: Detroit, MI

Grantee No: 2107

Executive Official: Mr. Norman L. White

> Director
>
> Detroit Department of Transportation
>
> 1301 E. Warren
>
> Detroit, MI 48207

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: November 15 -- 17, 2004

Compliance Review

Team Members: John Potts Bridgett Gagné

Lead Reviewer Reviewer

The DMP Group The DMP Group

Donald Lucas

Reviewer

The DMP Group

II. []{#__RefHeading___Toc95819635 .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 Detroit Department of Transportation (DDOT) 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 DDOT's Title VI Program and were the basis for the
selection of compliance elements that were reviewed.

III. []{#__RefHeading___Toc95819636 .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 Detroit Department of
Transportation's (DDOT) 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 DDOT. The primary purpose of this Compliance Review was to determine
the extent to which DDOT 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 DDOT.

#### Objectives

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

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

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

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

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

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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___Toc95819637 .anchor}BACKGROUND INFORMATION

The Detroit Department of Transportation (DDOT) is a City of Detroit
owned and operated public transportation system. The Director of DDOT
reports to the Mayor. DDOT operates all fixed route bus service
in-house. It contracts with ATC/VANCOM for MetroLift complementary
paratransit service. DDOT was formed in 1921 and began operating public
transportation service in the early 1920's through the Department of
Street Railways. Between 1937 and 1956, DDOT made the transition from
operating streetcar service to bus service.

DDOT provides public transportation service to the Cities of Detroit,
Highland Park, and Hamtramck, and to contiguous portions of other
municipalities (Wayne, Oakland, and Macomb counties). The City of
Detroit has a land area of 136 square miles and a population of 951,270
(2000 US Census). Detroit is the center of an Urbanized Area that has a
population of 3,903,377 and a land area of 1,261 square miles.

DDOT operates a network of 52 fixed routes. Fixed route service is
provided 24 hours a day, everyday on several routes. On routes that do
not operate all day, weekday service ranges from 4:06 a.m. on Route 36
until 1:40 a.m. on Route 9. On Saturday, fixed route service operates
from 3:57 a.m. on Route 54 until 1:30 a.m. on Routes 29, 36, and 54,
and, on Sunday, from 4:38 a.m. on Route 38 until 1:39 a.m. on Route 49.

The basic adult fare for service within the City limits is \$1.50. A
reduced fare of 75¢ is offered to Medicare cardholders and students at
all times. Transfers are 25¢ for adults and students and 10¢ for
Medicare cardholders. Senior citizens and persons with disabilities ride
free at all times.

DDOT operates a fleet of 512 buses for fixed route service. The current
peak requirement is 418 vehicles. ATC/Vancom owns and operates 51 vans
for the MetroLift paratransit service. DDOT operates from three bus
garages (Coolidge, Gilbert and Shoemaker), with the central shops and
administrative offices at 1301 East Warren Street.

Over the past three years, DDOT has purchased new buses, installed new
telephone and computer systems, and started planning for the downtown
transit center and an automated vehicle locator system. Currently, DDOT
is implementing the Trapeze system for used by the Scheduling and
Customer Service offices and updating its security system. In the next
three years, DDOT plans to purchase 214 replacement buses and complete
construction of the Downtown Transit Center.

The following table shows the racial/ethic breakdown of the DDOT service
area, which includes the City of Detroit:

[]{.mark}

[]{.mark}

**Racial/ Ethnic Breakdown of Detroit and the DDOT Service Area**

######### 2000 Census

+--------------+-------+--------+----------+-------+-------+-------+
| **Racial/    | ###   | #      | #### C   | #     | #     | ####  |
| Ethnic       | # Cit | ### Ci | ity of H | ### M | ### O |  DDOT |
| Group**      | y of  | ty of  | amtramck | acomb | aklan |       |
|              |       |        |          |       | d Cou | ##    |
|              | ##    | #### H | ###      | **Cou | nty T | ## Se |
|              | ## De | ighlan | # Total/ | nty** | otal/ | rvice |
|              | troit | d Park |          |       |       |  Area |
|              |       |        | ####     | **Tot | ##    |       |
|              | #     | ##     |  Percent | al/** | ## Pe | #     |
|              | ### T | ##  To |          |       | rcent | ### T |
|              | otal/ | tal/ P |          | *     |       | otal/ |
|              |       | ercent |          | *Perc | \*    |       |
|              | ###   |        |          | ent** |       | ##    |
|              | # Per | ####   |          |       |       | ## Pe |
|              | cent  |        |          | **^   |       | rcent |
|              |       |        |          | \*^** |       |       |
+--------------+-------+--------+----------+-------+-------+-------+
| #### White   | *     | *      | **       | **34, | **54, | *     |
|              | *116, | *688** | 14,007** | 411** | 284** | *219, |
|              | 599** |        |          |       |       | 989** |
|              |       | 4%     | 61%      | 90%   | 65%   |       |
|              | 12%   |        |          |       |       | 20%   |
+--------------+-------+--------+----------+-------+-------+-------+
| #### Black   | #     | **15   | *        | **2,  | **27, | *     |
|              | ### 7 | ,648** | *3,473** | 552** | 568** | *825, |
|              | 75,77 |        |          |       |       | 013** |
|              | 2 82% | 93%    | 15%      | 7%    | 33%   |       |
|              |       |        |          |       |       | 74%   |
+--------------+-------+--------+----------+-------+-------+-------+
| ##           | **3,  | **45** | **98**   | **    | **    | **3,  |
| ## American  | 140** |        |          | 222** | 304** | 809** |
| Indian and A |       | \<1%   | \<1%     |       |       |       |
| laska Native | \<1%  |        |          | \<1%  | \<1%  | \<1%  |
+--------------+-------+--------+----------+-------+-------+-------+
| #### Asian   | **9,  | **41** | *        | **    | **1,  | **14, |
|              | 268** |        | *2,382** | 957** | 477** | 125** |
|              |       | \<1%   |          |       |       |       |
|              | 1%    |        | 10%      | 3%    | 2%    | 1%    |
+--------------+-------+--------+----------+-------+-------+-------+
| #            | **    | **3**  | **23**   | **0** | **0** | **    |
| ### Native H | 251** |        |          |       |       | 277** |
| awaiian/Paci |       | \<1%   | \<1%     | 0%    | 0%    |       |
| fic Islander | \<1%  |        |          |       |       | \<1%  |
+--------------+-------+--------+----------+-------+-------+-------+
| #### Som     | **24, | **42** | **262**  | **0** | **0** | **24, |
| e Other Race | 199** |        |          |       |       | 503** |
|              |       | \<1%   | 1%       | 0%    | 0%    |       |
|              | 3%    |        |          |       |       | 2%    |
+--------------+-------+--------+----------+-------+-------+-------+
| #### Two o   | **22, | *      | *        | **0** | **0** | **25, |
| r More Races | 041** | *279** | *2,731** |       |       | 051** |
|              |       |        |          | 0%    | 0%    |       |
|              | 2%    | 2%     | 12%      |       |       | 2%    |
+--------------+-------+--------+----------+-------+-------+-------+
| #### Tota    | *     | **16   | **       | **38, | **83, | **1   |
| l Population | *951, | ,746** | 22,976** | 142** | 633** | ,112, |
|              | 270** |        |          |       |       | 767** |
+--------------+-------+--------+----------+-------+-------+-------+

+--------------+-------+--------+----------+-------+-------+--------+
| #### Hispani | #     | **95** | **300**  | **    | **1,  | **49   |
| c Origin\*\* | ### 4 |        |          | 696** | 288** | ,546** |
|              | 7,167 | 1%     | 1%       |       |       |        |
|              |       |        |          | 2%    | 2%    | 4%     |
|              | 5%    |        |          |       |       |        |
+--------------+-------+--------+----------+-------+-------+--------+

\* DDOT only services portions of Macomb and Oakland counties. These
figures represent Census tract data for those areas of Macomb and
Oakland counties in which DDOT service is provided.

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

In the City of Detroit, there is a higher concentration of minorities,
particularly with Blacks (82 percent) and Hispanics (5 percent), when
compared to the City of Hamtramck and areas of Macomb and Oakland
counties served by DDOT. While the City of Highland Park does have a
Black population percentage that exceeds that of the City of Detroit,
Hispanics represent one percent of the City of Highland Park. There is a
higher concentration of minorities, particularly Blacks (33 percent), in
the areas of Oakland County served by DDOT when compared to the areas of
Macomb County served by DDOT.

The DDOT service area also includes a significant concentration of Arab
Americans. Within this community exist two distinct groups: Chaldeans
and Muslims. The 2000 US Census assigns people of Arab descent to the
white population count making it difficult to determine exactly how many
Arab Americans live in the DDOT service area. However, the 2000 US
Census did reveal that in the Detroit Metropolitan Area there were
92,328 people that reported primary Arab ancestry. This figure is
significant as it represents a substantial portion (42%) of the whites
in the DDOT service area.

V.  []{#__RefHeading___Toc95819638 .anchor}SCOPE AND METHODOLOGY

#### Scope

The Title VI Compliance Review of DDOT 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 discussionss were conducted with the Headquarters Civil Rights
staff and the Region V Civil Rights Officer to discuss specific Title VI
issues and concerns regarding DDOT. Following this discussion, a
detailed letter was sent to DDOT advising it of the site visit and
indicating additional information that would be needed and issues that
would be discussed.

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

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

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

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

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

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

-   DDOT By-laws

DDOT was also requested to provide Updates of Title VI General Reporting
requirements (Chapter III, Section 2 of FTA Circular 4702.1) since its
most recent Title VI submittal:

-   A list of any active lawsuits and complaints

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-   Pending grant applications

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-   Other civil rights compliance reviews during the last three years

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

DDOT was also requested to provide Updates of Title VI Program-Specific
Requirements (Chapter III, Section 3 of FTA Circular 4702.1) since its
Title VI submittal.

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

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

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

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

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

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-   Ridership by route

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-   Passenger boardings by bus stop

-   Maximum load points by route

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-   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.

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

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

> Additionally, DDOT was requested to provide the following Other
> Program- Specific Requirements in accordance with Chapter III, Section
> 3.a(4); Chapter IV, Section 2.c; Chapter VII; and Chapter VIII,
> Section 2 of FTA Circular 4702.1:

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

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

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

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

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

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

> [Site Visit]{.underline}

The site visit to DDOT occurred November 15-17, 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 DDOT of the Compliance Review.
Arrangements were also made for a tour of DDOT's facilities and bus
routes, observation of vehicle assignments to routes, review of actual
headways and ridership on sample minority and non-minority routes, and
interviews with DDOT's staff and community representatives.

The Gilbert and Coolidge bus garages were toured. Several bus routes
were toured, including Routes 11, 25, 34, and 49. On the third day of
the site visit, the review team also examined the assignment and
condition of vehicles at the Gilbert bus garage.

Interviews were conducted with DDOT staff and community representatives
to provide information on the extent to which DDOT incorporates Title VI
requirements in the planning and implementation of service. The
interviews also focused on DDOT 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.

There was a general consensus among Black, Hispanic, and Arab American
community representatives regarding DDOT service. Community
representatives did not express concern over level and quality of
service disparities within DDOT. Many acknowledged that there were few
non-minority routes in the DDOT service area and, therefore, few, if
any, discriminatory practices. However, all of the community
representatives interviewed did indicate that the level and quality of
service, system-wide, needed significant improvement. Notable areas of
needed improvement include:

-   Frequency of service

-   On-time performance and general reliability

-   Transit access

-   Vehicle cleanliness

-   Operator customer service and sensitivity training

-   Safety

-   Better representation on non-elected boards and advisory committees

-   Transit amenities -- particularly shelter placement

-   Better bus stop signage -- stops are not clearly marked

-   Outreach -- particularly regarding system changes

Nearly all of those interviewed emphasized their frustration with long
wait times at bus stops and the overall unreliability of the fixed route
system. One community representative and DDOT rider indicated that the
public timetables published by DDOT are unreliable and vehicles seldom
run according to schedule.

Members of the Hispanic community noted needs for improvement in DDOT's
production and distribution of bilingual (Spanish) material. In
addition, they would like more consultation when DDOT makes service and
operational decisions that may affect the Hispanic community.

VI. []{#__RefHeading___Toc95819639 .anchor}FINDINGS AND RECOMMENDATIONS

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

#### 

1.  []{#__RefHeading___Toc95819640 .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 DDOT, no
deficiencies were found with FTA requirements for List of Active
Complaints and Lawsuits. In its most recent Title VI submittal, made in
2003, DDOT reported that it had three active complaints, however, none
of the complaints listed were based on race, color, or national origin
with respect to service or other transit benefits. All were filed under
Title VII of the Civil Rights Act of 1964. Two of the three complaints
listed were filed with the Equal Employment Opportunity Commission
(EEOC), one for alleged ADA discrimination, and one for sexual
harassment. The third complaint was filed with the Detroit Police
Department for sexual harassment.

During the site visit, DDOT provided another list of complaints and/or
lawsuits filed between 2001 and 2004. This list contained sixteen
complaints and/or lawsuits, of which three were based on race and not
included in DDOT's 2003 Title VI Submittal. Two of the three complaints
were active and one was dismissed. All three complaints were filed with
the EEOC under Title VII of the Civil Rights Act of 1964 and were not
based on race, color, or national origin with respect to service or
other transit benefits.

2.  []{#__RefHeading___Toc95819641 .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 DDOT, no
deficiencies were found with FTA requirements for Pending Applications
for Financial Assistance. In its most recent submittal, and at the time
of the site visit, DDOT did not have any pending applications for
Federal funds from any agency other than FTA. In its most recent Title
VI submittal, made in 2003, DDOT reported that it did not have any
FTA-funded grants pending. DDOT did report on, and submit documentation
for, three pending applications for FTA-funded grants filed since their
2003 Title VI submittal: MI-90-X434-01, MI-70-X003, and MI-03-0204-01.

3.  []{#__RefHeading___Toc95819642 .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 DDOT, no
deficiencies were found with FTA requirements for Summary of Civil
Rights Compliance Reviews. In September 2002, the FTA Office of Civil
Rights provided to DDOT a report titled *Assessment of ADA Complementary
Paratransit Service Capacity Constraints*. The purpose of the assessment
was to assist DDOT and FTA in assessing whether capacity constraints
exist in ADA Complementary Paratransit services. This Review identified
several deficiencies that are being addressed outside of the scope of
this Title VI Compliance Review. The most recent FTA Triennial Review
conducted in June 2003 examined Civil Rights requirements and no
deficiencies were identified with the FTA requirements for Title VI.

4.  []{#__RefHeading___Toc95819643 .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 DDOT, no
deficiencies were found with FTA requirements for FTA Civil Rights
Assurance. The FTA Civil Rights Assurance is incorporated in the Annual
Certifications and Assurances submitted annually to FTA through the
Transportation Electronic Award and Management (TEAM) system. DDOT's
most recent Annual Certifications and Assurances were pinned on October
26, 2004. At the site visit, DDOT also provided a FTA Civil Rights
Assurance signed on November 17, 2004 by Norman L. White, Director.

5.  []{#__RefHeading___Toc95819644 .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 DDOT, no
deficiencies were found with FTA requirements for DOT Title VI
Assurance. At the site visit, DDOT provided its "one-time" DOT Title VI
Assurance signed on November 17, 2004 by Norman L. White, Director.

6.  []{#__RefHeading___Toc95819645 .anchor}Fixed-Facility Impact
    Analysis

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

**Finding:** During this Title VI Compliance Review of DDOT,
deficiencies were found with FTA requirements for Fixed-Facility/
Environmental Justice Impact Analysis. DDOT is currently building a new
Downtown Transit Center (DTC) in the Central Business District (CBD).
The DTC is envisioned as a "state of the art" transportation center
offering mobility in the CBD as rail, bus, pedestrian, and bicycle users
are to be integrated into a seamless system. Its goal is to attract more
users to public transportation, improve air quality, reduce traffic, and
replace bus terminal facilities at Cadillac Square and Capital Park.
Completion of the DTC is scheduled for January 2006.

During the planning stage of the DTC, DDOT conducted an Environmental
Impact Study. At the site visit, DDOT submitted the results of the
analysis in a report titled *Phase I Environmental Site Assessment*. The
FTA requirement for a fixed-facility impact analysis was not included in
the report. DDOT should have conducted and submitted a fixed-facility
impact analysis on the DTC or included the fixed facility impact
analysis in its environmental impact study. In addition, DDOT has FTA
grants to make major improvements to its three bus garages, Coolidge,
Gilbert, and Shoemaker. DDOT did not conduct fixed-facility impact
analyses on the bus garages.

At the site visit, discussion took place regarding fixed-facility impact
analyses, environmental impact studies, categorical exclusions, and how
they relate to one another. DDOT was advised that it must conduct fixed
facility analyses for construction projects or include information that
responds to the fixed facility impact analysis requirements in its
Environmental Impact Statement, Environmental Assessment or application
for a doucumented categorical exclusion.

Subsequent to the compliance review, DDOT submitted a fixed facility
impact analysis for the Downtown Transit Center.

**Corrective Actions and Schedules:** Within 90 days, DDOT must submit
to the FTA Region V Civil Rights Officer fixed-facility impact analyses
for the Coolidge, Gilbert, and Shoemaker bus garages.

7.  []{#__RefHeading___Toc95819646 .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 DDOT,
deficiencies were found with FTA requirements for Demographic and
Service Profile Maps, Overlays and Charts. In general, the Maps and
Overlays provided during the site visit suggested that DDOT was capable
of producing system information in the form of maps as required by the
Title VI Circular. However, DDOT did not provide all of the Maps and
Overlays required by the Circular, e.g., Demographic Maps showing the
percentage of Blacks by census tract and the percentage of Hispanics by
census tract. In addition, DDOT could significantly improve the
usefulness of its maps by standardizing map size, decreasing the number
of data elements per map, minimizing and/or eliminating the use of
overlays, using distinguishable color-coding, and using proper labeling
and version control. With these improvements, the Base Maps and Overlays
would be effective tools for assessing service provision as required by
the Title VI Circular.

DDOT provided the following Service Profile Maps and Overlays:

-   *Detroit Department of Transportation System Map* -- Map showing
    system routes, bus stops, bus shelters, major streets, and city
    boundaries.

-   *Detroit Department of Transportation 1999-2002 Title Six Base Map*
    -- Map showing service area by census tract.

-   *2000 Census Tracts Largest Minority Percentage* -- Map showing
    service area by census tract and highlighted areas occupied by the
    three largest minority population groups.

-   *2000 Census Tracts Largest Minority Percentage* -- Map showing
    service area by census tract and highlighted areas occupied by the
    three largest minority population groups (Blacks, Hispanics, and
    Asians).

-   *Detroit Department of Transportation 1999*-*2002 Title Six Minority
    Population Percentage* -- Map showing total minority population
    percentage by census tract.

-   *Detroit Department of Transportation 1999 -- 2002 Title Six
    Generators* -- Overlay showing DDOT service area trip generators.

-   *Detroit Department of Transportation 1999 -- 2002 Title Six Service
    Routes* -- Overlay showing routes by service time (24 hour, AM & PM
    Peak, AM & PM Peak-Base, AM & PM Peak-Base-Night).

Each map and overlay provided by DDOT contained one or several of the
following characteristics:

-   Map was difficult to read and understand due to size and/or too much
    data being plotted.

-   Map was not dated, making it difficult to track and document changes
    in the transit system.

-   Map included dates that might suggest that the data, particularly
    census tract data, might not be current, i.e., "...1999 -- 2002."
    When plotting census tract data, this data set, as labeled, could
    include the 1990 and 2000 Census data.

-   Overlays did not effectively complement base maps, making the
    presentation difficult to understand, due to a combination of
    factors, including: indistinguishable color schemes, map/overlay
    size (overlays too small), and too many data elements included on
    Base Map and/or Overlay.

> Subsequent to the compliance review, DDOT submitted revised versions
> of its maps and overlays. No further corrective action is required in
> response to this finding.

[]{.mark}

8.  []{#__RefHeading___Toc95819647 .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:** During this Title VI Compliance Review of DDOT,
deficiencies were found with FTA requirements for Service Standards and
Policies. In its most recent Title VI Program submittal to the FTA, DDOT
indicated that there were no changes to the service standards during the
2000 to 2002 reporting period, but DDOT did not list its service
standards. In documentation provided during the site visit, DDOT
provided quantifiable service standards for three of the required
standards: Vehicle Load, Distribution of Transit Amenities, and Vehicle
Headway. DDOT provided incomplete service standards for Transit Access.
It does have a standard for bus route spacing standards based on
population density categories. DDOT did not provide quantifiable service
standards for Vehicle Assignment.

DDOT's service standards for Title VI are summarized in the following
tables:

[]{.mark}

+-----------------+----------------------------------------------------+
| **FTA Service   | **DDOT Policy**                                    |
| Standard**      |                                                    |
+=================+====================================================+
| **Vehicle       |   --                                               |
| Load** - A      | ----------- --------------------- ---------------- |
| ratio of the    |                                                    |
| number of       | ***Route      ***Peak***            ***Off-Peak*** |
| passengers on a |   Type***                                          |
| vehicle to the  |                                                    |
| number of seats |   Local         125%                  100%         |
|                 |                                                    |
|                 |   Limited       125%                  100%         |
|                 |   --                                               |
|                 | ----------- --------------------- ---------------- |
+-----------------+----------------------------------------------------+
| **Distribution  | > DDOT has the following policy for amenities:     |
| of Transit      | >                                                  |
| Amenities** -   | > *Benches*: Bus stops that have a minimum of 25   |
|                 | > boardings per day will have a bench. Other       |
| Criteria for    | > criteria, such as the presence of "sensitive"    |
| installation of | > facilities, such as hospitals, senior activity   |
| items of        | > centers, schools, social service agencies, and   |
| comfort and     | > medical facilities, may be considered if the     |
| convenience     | > minimum boarding requirement is only partially   |
| available to    | > met.                                             |
| the general     | >                                                  |
| public          | > In addition, a bus bench must be located in a    |
|                 | > safe location and may not be located where an    |
|                 | > existing bench is located unless additional      |
|                 | > seating is required.                             |
|                 | >                                                  |
|                 | > *Shelters:* Bus stops that have a minimum of 50  |
|                 | > boardings per day will have a shelter. Other     |
|                 | > criteria, such as the presence of "sensitive"    |
|                 | > facilities as described above, may be considered |
|                 | > if the minimum boarding requirement is only      |
|                 | > partially met.                                   |
|                 |                                                    |
|                 | In addition, the shelter must be able to be safely |
|                 | sited and the location and site plan must receive  |
|                 | the approval of the participating municipality and |
|                 | the other governing authorities, as required.      |
+-----------------+----------------------------------------------------+
| **Vehicle       | Maximum peak headway is 30 minutes; and maximum    |
| Headway** -     | off-peak headway is 60 minutes.                    |
|                 |                                                    |
| The time        | <table>                                            |
| interval        | <colgroup>                                         |
| between two     | <col style="width: 22%" />                         |
| vehicles        | <col style="width: 11%" />                         |
| traveling in    | <col style="width: 11%" />                         |
| the same        | <col style="width: 15%" />                         |
| direction on    | <col style="width: 18%" />                         |
| the same route  | <col style="width: 9%" />                          |
|                 | <col style="width: 10%" />                         |
|                 | </colgroup>                                        |
|                 | <tbody>                                            |
|                 | <tr class="odd">                                   |
|                 | <td><em><strong>Route Type</strong></em></td>      |
|                 | <td><p><em><strong>Peak</strong></em></p>          |
|                 | <p>Max</p></td>                                    |
|                 | <td><p><em><strong>Base</strong></em></p>          |
|                 | <p>Max</p></td>                                    |
|                 | <td><p><em><strong>Midday</strong></em></p>        |
|                 | <p>Max</p></td>                                    |
|                 | <td><p><em><strong>Evening/</strong></em></p>      |
|                 | <p><em><strong>Night</strong></em></p>             |
|                 | <p>Max</p></td>                                    |
|                 | <td><p><em><strong>Sat</strong></em></p>           |
|                 | <p>Max</p></td>                                    |
|                 | <td><p><em><strong>Sun</strong></em></p>           |
|                 | <p>Max</p></td>                                    |
|                 | </tr>                                              |
|                 | <tr class="even">                                  |
|                 | <td>Local</td>                                     |
|                 | <td>30</td>                                        |
|                 | <td>60</td>                                        |
|                 | <td>60</td>                                        |
|                 | <td>60</td>                                        |
|                 | <td>60</td>                                        |
|                 | <td>60</td>                                        |
|                 | </tr>                                              |
|                 | <tr class="odd">                                   |
|                 | <td>Limited</td>                                   |
|                 | <td>30</td>                                        |
|                 | <td>---</td>                                       |
|                 | <td>60</td>                                        |
|                 | <td>60</td>                                        |
|                 | <td>---</td>                                       |
|                 | <td>---</td>                                       |
|                 | </tr>                                              |
|                 | </tbody>                                           |
|                 | </table>                                           |
+-----------------+----------------------------------------------------+

+-----------------+----------------------------------------------------+
| **Transit       | **DDOT has Route spacing** requirements based on   |
| Access -**      | **population density** which is broken down into   |
|                 | four categories: Very High, High, Moderate, and    |
| The distance a  | Low **(**not defined**).** The following are       |
| person must     | DDOT's coverage-based goals for the radial routes: |
| travel to gain  |                                                    |
| access to       |   ----------------------- -----------------------  |
| transit service |   ***Population           ***Bus Route Spacing***  |
|                 |   Density***                                       |
|                 |                                                    |
|                 |   Very High               ½ mile                   |
|                 |                                                    |
|                 |   High                    ½mile                    |
|                 |                                                    |
|                 |   Moderate                1 mile                   |
|                 |                                                    |
|                 |   Low                     As needed (specific      |
|                 |                           trip generators or       |
|                 |                           attractors)              |
|                 |   ----------------------- -----------------------  |
+-----------------+----------------------------------------------------+

Subsequent to the compliance review, DDOT submitted revised service
standards. No further corrective action is required in response to this
finding.

9.  []{#__RefHeading___Toc95819648 .anchor}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.

**Finding:** During this Title VI Compliance Review of DDOT,
deficiencies were found with FTA requirements for Assessment of
Compliance by Grantees. DDOT did not submit procedures and guidelines
for assessing compliance with Title VI, nor did DDOT demonstrate that it
actively assesses transit service as it relates to Title VI.

DDOT submitted the following three reports to show how it performed
assessments of its transit system:

-   *Comprehensive Operations Analysis*, May 2000

-   *DDOT Comprehensive Operations Analysis -- Run-time Analysis
    Preliminary Report*, February 2002

-   *Assessment of ADA Complementary Paratransit Service Capacity
    Constraints*, September 2002

However, none of the reports listed could be considered an assessment of
transit service as required by FTA Circular 4702.1. In its most recent
Title VI Submittal, DDOT included the report titled, *Comprehensive
Operations Analysis*, published in May 2000*.* This report contained the
results of an effort to assess DDOT operations with the intent to
improve system reliability and efficiency. DDOT also provided the
results of six additional studies, including Run-Time Analysis, Route
Rationalization, Telephone Survey, Title VI Ridership Survey, Focus
Groups, and Community Input. None of the six studies were specifically
conducted to assess compliance with established DDOT service standards
in relationship to service provided by minority and non-minority routes.
The Title VI Ridership Survey revealed riders' opinions of DDOT's
performance, but could not be considered an internal assessment as
required by FTA Circular 4702.1 because it did not identify the
respondents by race and determine if the disparities existed.

Subsequent to the compliance review, DDOT submitted an assessment of
compliance as well as a process to conduct assessments on a periodic
basis. No additional corrective action is required in response to this
finding.

10. []{#__RefHeading___Toc95819649 .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 DDOT, no
deficiencies were found with FTA requirements for Changes in Service
Features. In its 2003 Title VI submittal, DDOT did identify and consider
the impacts on the minority communities and minority transit users prior
to making decisions on fare increases and service changes.

######## 

######## 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 DDOT, no
> deficiencies were found with FTA requirements for Information
> Dissemination. DDOT makes efforts to inform the minority communities
> of transit service changes or improvements. DDOT uses the following
> methods to inform minority communities:

-   Rider Alerts -- distributed by bus operators and available at
    libraries, Neighborhood City Halls and locations where DDOT passes
    are purchased, including DDOT properties.

-   Radio

-   Service Change Brochures

-   Brochures describing a specific service or program

-   DDOT Website

-   Scheduled community meetings

-   Newspaper Print Ads

-   Public Hearings

> At the site visit, DDOT provided examples of Rider Alerts used to
> inform riders of service changes and system improvements. One example
> was a Rider Alert poster informing the public of new route schedules
> for Route 2, effective April 24, 2004. The poster provided a customer
> service number for riders to call if they had questions about the
> service changes. Another example was a similar Rider Alert poster
> alerting the public to construction taking place at the Downtown
> Transit Center. DDOT provided additional examples of Public Hearing
> Notices, Legal Notices, and newspaper ads used to inform the community
> of upcoming service changes.

######## 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 DDOT, no
deficiencies were found, but an advisory comment is included with
respect to FTA requirements for Minority Representation on
Decision-Making Bodies. DDOT has two primary advisory committees:
Advisory Commission and Local Advisory Council. The Advisory Commission
has five members that advise DDOT on its policies. The Mayor appoints
all commissioners. There are four Black commissioners and one White
commissioner.

DDOT also has a Local Advisory Council (LAC). The LAC is made up of
consumers and interested persons or agencies who represent the elderly
and persons with disabilities within DDOT\'s service area. The LAC
advises DDOT on service issues pertaining to public transit services for
the elderly and persons with disabilities. At the site visit, DDOT
reported that the LAC is comprised of 47 Blacks, 17 Whites, 2 Hispanics,
and 35 members whose race is unknown.

Input from community leaders included comments that there are not enough
Hispanic and Arab American representation on non-elected boards and
committees at DDOT.

**Advisory Comment:** FTA encourages DDOT to identify and encourage
qualified members of the Hispanic and Arab American community to serve
on its non-elected boards and committees.

######## 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 DDOT,
deficiencies were found with FTA requirements for Multilingual
Facilities. DDOT's second largest minority group is its Hispanic
population. DDOT did produce one example of a 1998 route information
handout for Route 3 that had been converted to Spanish. However, at the
time of the site visit, DDOT did not have adequate materials to assist
Hispanics or any other non-English speaking persons. DDOT staff
indicated that the City of Detroit provided centralized telephone
support for all non-English speaking persons on behalf of all City
agencies. DDOT also indicated that in September 2004, the Detroit City
Council awarded a contract to an outside company to develop materials to
assist non-English speaking persons who wish to use the transit system.
At the time of the site visit, DDOT staff did not know when the
materials would be available.

Subsequent to the site visit, DDOT submitted documentation that it has
taken action to provide language assistance to the Spanish and
Arabic-speaking communities in its service area. Among other actions,
DDOT has contacted community leaders in the Hispanic and Arab
communities to identify best methods for reaching the target audiences,
developed flyers in English, Spanish and Arabic announcing the
availability of multi-language materials, scheduled customer information
meetings in targeted communities with interpreters to provide
translation services, and is producing all schedules in multi-language
formats. No further corrective action is required in response to this
finding.

**Advisory Comment:** In addition to taking the above steps, FTA
encourages DDOT to provide access to its service for people with limited
English proficiency consistent with the Department of Transportation
Guidance to Recipients on Special Language Services to Limited English
Proficient Beneficiaries. This guidance provides the following framework
for ensuring meaningful access to limited English proficient persons:

1\. Needs Assessment

A recipient should conduct a thorough assessment of the language needs

of the population and communities affected by the recipient.

2\. [Written Language Assistance Plan]{.underline}\
Recipients should develop and implement written language assistance
plans that will ensure meaningful opportunities for LEP persons to
access their programs and activities and effectively participate in\
them.\
3. [Staff Training]{.underline}\
Recipients should ensure that staff understand the recipient\'s language
assistance policy and are capable of carrying it out.

4\. [Provision of Special Language Assistance]{.underline}\
Recipients must actually provide necessary services to LEP persons.\
5. [Monitoring\
]{.underline}Recipients should conduct regular oversight of their
language assistance programs to ensure that LEP persons can meaningfully
access their programs and activities.

A more detailed description of this framework for providing language
assistance is contained in the DOT LEP Guidance previously provided to
DDOT and available on the Title VI page of FTA's website.

11. []{#__RefHeading___Toc95819650 .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.

**Findings:** During this Title VI Compliance Review of DDOT,
deficiencies were found with FTA requirements for Internal Monitoring
Procedures. At the time of the site visit, DDOT had not implemented the
required "level of service" and "quality of service" monitoring
procedures. DDOT indicated that their current "level of service" and
"quality of service" monitoring procedures specifically included
assessment of schedule adherence, daily coach pullouts, and missed
trips. DDOT provided documentation of transit route analyses used to
evaluate transit services, including route rationalization, run-time
analysis, and ADA capacity constraints. Collectively, these procedures
are used by DDOT to monitor the efficiency and effectiveness of transit
service.

In addition, in its most recent Title VI Submittal, DDOT submitted
information indicating that it did perform general quality of service
monitoring. As mentioned in Section 9, "Assessment of Compliance by
Grantees," DDOT's *Comprehensive Operations Analysis May 2000* included
results from four studies designed to collect feedback from the DDOT
user-community. The four studies were, Telephone Survey, Title VI
Ridership Survey, Focus Groups, and Community Input. The Title VI
Ridership Survey contained rider feedback on number of shelters, travel
time, convenience of bus service, driver courtesy, cleanliness of buses,
personal safety, and DDOT information dissemination. DDOT conducted the
same Title VI Ridership Survey in 1993. Two characteristics, number of
shelters and the time between buses, rated poorly in 1993 and rated even
worse in 2000. In response, DDOT acknowledged in the 2000 report that
the problems in these areas continue and should be examined during
future operations and service planning. At the time of the site visit,
DDOT did not produce plans to address these problems, or explain what
was being done to improve service in these areas.

While these efforts demonstrate general monitoring of its transit
service, these are not the monitoring methodologies required by the
Title VI Circular to monitor the level and quality of its transit
service.

**Corrective Actions and Schedules:** Within 90 days, DDOT must submit
to the FTA Region V Civil Rights Officer documentation of procedures to
implement an internal monitoring process. Further, DDOT must provide
documentation that it has initiated the internal monitoring process and
has a schedule of dates for periodic monitoring of its bus services and
transit amenities for the next three years.

12. []{#__RefHeading___Toc95819651 .anchor}Title VI Complaints

**Finding:** During this Title VI Compliance Review of DDOT,
deficiencies were found with FTA requirements for Title VI Complaints.
At the site visit, DDOT provided a series of process flow charts that
diagram how various service complaints are categorized and handled.

Complaints can be filed via telephone, in person during normal working
hours, or by submitting customer comment cards. The process flow charts
describe the process for receiving, documenting and handling complaints
from DDOT's customers. The process flow charts describe a multi-step
process of receiving and logging the complaint into a database and
sending the complaint to the appropriate DDOT department or person. The
complaint process does not designate a Title VI Officer responsible for
investigating and resolving Title VI complaints.

DDOT did not address the Circular requirement that:

> "Each recipient shall make available to participants, beneficiaries
> and other interested parties, information regarding the recipient's
> Title VI Program. At a minimum, this shall include the display of
> posters which briefly explain the procedures for filing a compliant.
> Recipients shall also include disseminating information on complaint
> procedures and the rights of beneficiaries in handbooks, pamphlets,
> and other materials ordinarily distributed to the public by the
> recipient." (Circular 4702.1. Chapter 8 Part 2(b)).

At the site visit, DDOT indicated that there were no outstanding Title
VI complaints against it.

**Corrective Actions and Schedules**: Within 90 days, DDOT must submit
to the FTA Region V Civil Rights Officer a complaint process that
conforms fully to the requirements found in FTA Circular 4702.1.

VII. []{#__RefHeading___Toc95819652 .anchor}SUMMARY OF FINDINGS AND
     CORRECTIVE ACTIONS

+--------------+------+-----------+-------------------+-------+------+
| **Title VI   | **   | **De      | **Corrective      | **Res | **   |
| Requirements | Site | scription | Action(s)**       | ponse | Date |
| For Transit  | Re   | of        |                   | D     | Clos |
| Providers**  | view | Defic     |                   | ays/D | ed** |
|              | F    | iencies** |                   | ate** |      |
|              | 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\.          | D    | No        | DDOT must submit  | 90    |      |
| Fi           |      | Fixed     | to the FTA Region | Days  |      |
| xed-Facility |      | -Facility | V Civil Rights    |       |      |
| Impact       |      | Impact    | Officer           |       |      |
| Analysis     |      | Analysis  | fixed-facility    |       |      |
|              |      | for the   | impact analyses   |       |      |
|              |      | DTC and   | for Coolidge,     |       |      |
|              |      | the three | Gilbert, and      |       |      |
|              |      | bus       | Shoemaker bus     |       |      |
|              |      | garages   | garages.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 7\.          | D    | > Base    | In response to    |       |      |
| Demographic  |      | > maps    | the draft report, |       |      |
| and Service  |      | > and     | DDOT submitted to |       |      |
| Maps,        |      | >         | the FTA Region V  |       |      |
| Overlays and |      |  overlays | Civil Rights      |       |      |
| Charts       |      | > were    | Officer revised   |       |      |
|              |      | > in      | Demographic and   |       |      |
|              |      | complete. | Service Profile   |       |      |
|              |      |           | Maps and Overlays |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 8\. Service  | D    | > Service | > In response to  | []{.  |      |
| Standards    |      | >         | > the draft       | mark} |      |
| and Policies |      | Standards | > report DDOT     |       |      |
|              |      | > Not     | > submitted to    |       |      |
|              |      | >         | > quantifiable    |       |      |
|              |      |  Adequate | > service         |       |      |
|              |      |           | > standards for   |       |      |
|              |      |           | > vehicle         |       |      |
|              |      |           | > assignment and  |       |      |
|              |      |           | > transit access. |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 9\.          | D    | > No      | > In response to  |       |      |
| Assessment   |      | > C       | > the draft       |       |      |
| of           |      | ompliance | > report, DDOT    |       |      |
| Compliance   |      | > A       | > submitted       |       |      |
| by Grantee   |      | ssessment | > documentation   |       |      |
|              |      | >         | > to the FTA      |       |      |
|              |      | Conducted | > Region V Civil  |       |      |
|              |      |           | > Rights Officer  |       |      |
|              |      |           | > that it has     |       |      |
|              |      |           | > conducted an    |       |      |
|              |      |           | > assessment of   |       |      |
|              |      |           | > compliance in   |       |      |
|              |      |           | > accordance with |       |      |
|              |      |           | > FTA Circular    |       |      |
|              |      |           | > 4702.1 and that |       |      |
|              |      |           | > it has          |       |      |
|              |      |           | > established a   |       |      |
|              |      |           | > process to      |       |      |
|              |      |           | > conduct the     |       |      |
|              |      |           | > assessments on  |       |      |
|              |      |           | > a periodic      |       |      |
|              |      |           | > basis.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 10\. Other   | ND   | Ins       | In response to    | ##### |      |
| Areas of     |      | ufficient | the draft report  | ####  |      |
| Title VI     | ND   | Mult      | DDOT submitted to |       |      |
| Co           |      | i-lingual | the FTA Region V  | ##### |      |
| nsiderations | ND   | F         | Civil Rights      | ####  |      |
|              |      | acilities | Officer examples  |       |      |
| Changes in   | ###  |           | of materials to   | ##### |      |
| Service      | #### |           | be used by DDOT   | ####  |      |
| Features     | ## D |           | to assist         |       |      |
|              |      |           | non-English       | ##### |      |
| Information  |      |           | speaking persons  | ####  |      |
| D            |      |           | who wish to use   |       |      |
| issemination |      |           | the transit       | ##### |      |
|              |      |           | system, as        | ####  |      |
| Minority     |      |           | required by FTA   |       |      |
| Re           |      |           | Circular 4702.1   | ##### |      |
| presentation |      |           |                   | ####  |      |
| on           |      |           | Advisory comment: |       |      |
| Dec          |      |           | FTA encourages    | ##### |      |
| ision-making |      |           | DDOT to follow    | ####  |      |
| Bodied       |      |           | the DOT LEP       |       |      |
|              |      |           | guidance when     | ##### |      |
| M            |      |           | providing         | ####  |      |
| ulti-lingual |      |           | language          |       |      |
| Facilities   |      |           | assistance.       | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
|              |      |           |                   |       |      |
|              |      |           |                   | ##### |      |
|              |      |           |                   | ####  |      |
+--------------+------+-----------+-------------------+-------+------+
| 11\.         | D    | > No      | > DDOT must       | 90    |      |
| Monitoring   |      | > M       | > submit to the   | Days  |      |
| Procedures   |      | onitoring | > FTA Region V    |       |      |
|              |      | > P       | > Civil Rights    |       |      |
|              |      | rocedures | > Officer         |       |      |
|              |      |           | > documentation   |       |      |
|              |      |           | > of procedures   |       |      |
|              |      |           | > to implement an |       |      |
|              |      |           | > internal        |       |      |
|              |      |           | > monitoring      |       |      |
|              |      |           | > process.        |       |      |
|              |      |           | > Further, DDOT   |       |      |
|              |      |           | > must provide    |       |      |
|              |      |           | > documentation   |       |      |
|              |      |           | > that it has     |       |      |
|              |      |           | > initiated the   |       |      |
|              |      |           | > internal        |       |      |
|              |      |           | > monitoring      |       |      |
|              |      |           | > process and has |       |      |
|              |      |           | > a schedule of   |       |      |
|              |      |           | > dates for       |       |      |
|              |      |           | > periodic        |       |      |
|              |      |           | > monitoring of   |       |      |
|              |      |           | > bus services    |       |      |
|              |      |           | > and transit     |       |      |
|              |      |           | > amenities for   |       |      |
|              |      |           | > the next three  |       |      |
|              |      |           | > years.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 12\. Title   | D    | I         | DDOT must submit  | ##    |      |
| VI           |      | ncomplete | to the FTA Region | ##### |      |
| Complaints   |      | Title VI  | V Civil Rights    | ## 90 |      |
|              |      | Complaint | Officer a         |  Days |      |
|              |      | Process   | complaint process |       |      |
|              |      |           | that conforms     |       |      |
|              |      |           | fully to the      |       |      |
|              |      |           | requirements      |       |      |
|              |      |           | found in FTA      |       |      |
|              |      |           | Circular 4702.1.  |       |      |
+--------------+------+-----------+-------------------+-------+------+

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

NR = Not Reviewed;

VIII. []{#__RefHeading___Toc95819653 .anchor}A**[TTENDEES]{.underline}**

+-------------+---------------------+----------+----------------------+
| **NAME**    | **T                 | **       | **E-MAIL**           |
|             | ITLE/ORGANIZATION** | PHONE/** |                      |
|             |                     |          |                      |
|             |                     | **FAX**  |                      |
+=============+=====================+==========+======================+
| Norman L    | Director, Detroit   | 313-     | <norwhi@dd           |
| White       | Department of       | 833-7671 | ot.ci.detroit.mi.us> |
|             | Transportation      |          |                      |
|             | (DDOT)              | 313-     |                      |
|             |                     | 833-5523 |                      |
+-------------+---------------------+----------+----------------------+
| Karmun P    | Manager, DDOT       | 313-     | [karnew@             |
| Newby       |                     | 833-0262 | ddot.ci.detroit.mi.u |
|             |                     |          | s](mailto:karnew@ddo |
|             |                     | 313-     | t.ci.detroit.mi.us ) |
|             |                     | 833-5338 |                      |
+-------------+---------------------+----------+----------------------+
| Stamina     | Manager Contract    | 313-     | <stabro@dd           |
| Brooks      | Compliance, DDOT    | 833-7695 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-5338 |                      |
+-------------+---------------------+----------+----------------------+
| Lovevett    | General Manager,    | 313-     | <lovwil@dd           |
| Williams    | DDOT                | 578-8220 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-5523 |                      |
+-------------+---------------------+----------+----------------------+
| Natalie     | Senior Social       | 313-     | <natsta@dd           |
| Starks      | Planning            | 833-0151 | ot.ci.detroit.mi.us> |
|             | Specialist, DDOT    |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-5493 |                      |
+-------------+---------------------+----------+----------------------+
| Arthur      | Operations, DDOT    | 313-     | <artdav@dd           |
| Davis       |                     | 833-7631 | ot.ci.detroit.mi.us> |
+-------------+---------------------+----------+----------------------+
| Rubi Dixon  | Principal SPDS,     | 313-     |                      |
|             | DDOT                | 833-7694 |                      |
+-------------+---------------------+----------+----------------------+
| Rovella     | Manager, DDOT       | 313-     | <rovphi@dd           |
| Phillips    |                     | 833-7025 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-0160 |                      |
+-------------+---------------------+----------+----------------------+
| Robert      | Superintendent,     | 313-     | <robvan@dd           |
| Vandervoort | DDOT                | 833-7676 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-9845 |                      |
+-------------+---------------------+----------+----------------------+
| Charles     | MIS Manager, DDOT   | 313-     | <chuck@dd            |
| Wilson, Jr. |                     | 833-7707 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-1628 |                      |
+-------------+---------------------+----------+----------------------+
| Jon Grebe   | Technical           | 313-     | <jongre@dd           |
|             | Consultant, DDOT    | 833-1667 | ot.ci.detroit.mi.us> |
+-------------+---------------------+----------+----------------------+
| Althea K    | Customer Relations  | 313-     | <alejoh@dd           |
| Johnson     | Manager, DDOT       | 833-7898 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-3542 |                      |
+-------------+---------------------+----------+----------------------+
| Elaine      | Human Resources     | 313-     | <elatow@dd           |
| Tower       | Manager, DDOT       | 833-3542 | ot.ci.detroit.mi.us> |
+-------------+---------------------+----------+----------------------+
| Donnal      | General Manager     | 313-     | <donmih@dd           |
| Mihal       | Operations, DDOT    | 833-7388 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-5523 |                      |
+-------------+---------------------+----------+----------------------+
| Spurgeon    | Security Manager,   | 313-     | <spudot@dd           |
| Dotson      | DDOT                | 833-7110 | ot.ci.detroit.mi.us> |
|             |                     |          |                      |
|             |                     | 313-     |                      |
|             |                     | 833-7832 |                      |
+-------------+---------------------+----------+----------------------+
| David       | Equal Opportunity   | 202-     | <david.sc            |
| Schneider   | Specialist, Federal | 493-0175 | hneider@fta.dot.gov> |
|             | Transit             |          |                      |
|             | Administration      |          |                      |
|             | (FTA)               |          |                      |
+-------------+---------------------+----------+----------------------+
| John Potts  | Lead Reviewer, The  | 504-     | <johnpo              |
|             | DMP Group (DMP)     | 283-7661 | tts@thedmpgroup.com> |
|             |                     |          |                      |
|             |                     | 504-     |                      |
|             |                     | 283-0791 |                      |
+-------------+---------------------+----------+----------------------+
| Donald      | Reviewer, DMP       | 202-     | [don                 |
| Lucas       |                     | 726-2630 | ald.lucas@thedmpgrou |
|             |                     |          | p.com](mailto:royale |
|             |                     | 202-     | iii@thedmpgroup.com) |
|             |                     | 726-1830 |                      |
+-------------+---------------------+----------+----------------------+
| Bridgett    | Reviewer, DMP       | 202-     | <bridgett.ga         |
| Gagné       |                     | 726-2630 | gne@thedmpgroup.com> |
|             |                     |          |                      |
|             |                     | 202-     |                      |
|             |                     | 726-1830 |                      |
+-------------+---------------------+----------+----------------------+