**Limited Scope**

**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**CHICAGO TRANSIT AUTHORITY**

**(CTA)**

**Chicago, Illinois**

**Final Report**

**August 2002**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**MILLIGAN & COMPANY, LLC**

**&**

**THE DMP GROUP, INC.**

[TABLE OF CONTENTS]{.underline}

I. GENERAL INFORMATION [1](#__RefHeading___Toc17858983)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc17858984)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc17858985)

Purpose [3](#purpose)

Objectives [5](#objectives)

Report Organization [5](#report-organization)

IV\. BACKGROUND INFORMATION [7](#__RefHeading___Toc17858989)

Description of Chicago Transit Authority
[7](#description-of-chicago-transit-authority)

1997/1998 Service Reductions [10](#service-reductions)

Community Response [13](#community-response)

Initial FTA Review and CTA Response
[15](#initial-fta-review-and-cta-response)

V. SCOPE AND METHODOLOGY [19](#__RefHeading___Toc17858998)

Scope [19](#scope)

Methodology [19](#methodology)

VI\. FINDINGS AND RECOMMENDATIONS [23](#__RefHeading___Toc17859001)

Evaluation of System Wide Service Changes
[23](#evaluation-of-system-wide-service-changes)

Inform Minority Communities of Service Changes
[27](#inform-minority-communities-of-service-changes)

VII\. ATTENDEES [29](#__RefHeading___Toc17859004)

VIII SUMMARY OF COMPLAINANT INTERVIEWS [31](#__RefHeading___Toc17859005)

IX\. CHRONOLOGY OF DOCUMENTS REVIEWED [36](#__RefHeading___Toc17859006)

I.  []{#__RefHeading___Toc17858983 .anchor}GENERAL INFORMATION

    Grant Recipient: Chicago Transit Authority (CTA)

    City/State: Chicago, Illinois

Grantee Number: 1182

Executive Official: Frank Kruesi, President

Chicago Transit Authority

Merchandise Mart Plaza

P.O. Box 3555

Chicago, Illinois 60654

On Site Liaison: Pamela Beavers, General Manager, DBE

and Civil Rights

Report Prepared by: Milligan & Company, LLC

> 105 North 22^nd^ Street (Second Floor)
>
> Philadelphia, PA 19103
>
> &
>
> The DMP Group, Inc.

2423 Killdeer Street

New Orleans, Louisiana 70122

Site Visit Dates: April 23, 2002 -- April 25, 2002

Compliance Review Team

Members: John F. Potts, Lead Reviewer, The DMP Group, Inc.

> Jim Buckley, Reviewer, Milligan & Company, LLC
>
> Joseph Herzog, Reviewer, Milligan & Company, LLC
>
> Royal "Ed" Spurlark, Reviewer, The DMP Group, Inc.

II. []{#__RefHeading___Toc17858984 .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 22 of the Master Agreement, Federal Transit Administration
    C.A. (3), October 1, 1996; and 49 U.S.C. 5332, "Non-Discrimination".

The Chicago Transit Authority (CTA) 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. The program guidelines
of FTA Circular 4702.1 define the components that must be addressed and
incorporated in CTA's Title VI Program.

III. []{#__RefHeading___Toc17858985 .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 Follow-Up Compliance Review of the Chicago Transit
Authority (CTA) Title VI Program was necessary.

The Office of Civil Rights conducted a full scope Title VI Compliance
Review of CTA in late 1999 following receipt of complaints filed against
CTA as the result a series of service reductions made between October
5,1997 and April 28, 1998. The complainants alleged that the service
reductions disproportionately affected minority communities. The Title
VI Compliance Review report issued on June 8, 2000 concluded, among its
findings, that CTA did not comply with Title VI guidance in the
implementation of the service reductions. More detail on the full
results of this report is provided in Section III of this report. CTA
responded to FTA with an analysis of the June 2000 report and argued
that, using the criteria established in FTA Circular 4702.1, the service
reductions and service restorations made between 1997 and 1998 were not
discriminatory and maintained an equitable level and quality of service
in the minority and non-minority communities. In 2002, following
continued interest by the complainants, the Office of Civil Rights
authorized Milligan & Co., LLC to conduct the Limited Scope Title VI
Compliance Review of CTA. The primary purpose of this Compliance Review
was to determine the extent to which the service reductions implemented
by CTA met the Program-Specific requirements, in accordance with FTA
Circular 4702.1, Program Guidelines for Federal Transit Administration
Recipients, as represented to FTA. Specifically, Chapter III, Section 3
(a) (3) (c) of the Circular states that grantees should:

*Evaluate system-wide service changes and proposed improvements at the
planning and programming stages to determine whether the overall
benefits and cost of such changes or improvements are distributed
equally, and are not discriminatory.*

Further, Chapter III, Section 3 (a) (4) (b) of the Circular states that
grantees should:

*Provide a description of the methods used to inform minority
communities of service changes (e.g., public notices, public hearings,
other formal or informal public discussions, presentations, meetings,
etc.) relating to transit service and improvements.*

This Limited Scope Compliance Review did not directly investigate any
individual complaints of discrimination by CTA nor did it adjudicate
these issues in behalf of any party.

## Objectives

The objectives of this Limited Scope Title VI Compliance review were:

-   Review background data and analysis that resulted in the
    implementation of major service reductions in 1997 and 1998.

-   Review the methodology and conclusions of FTA's Title VI Compliance
    Review conducted in 1999 and 2000.

-   Interview FTA staff in Headquarters and the Chicago Region V Office
    to obtain input and background.

-   Interview CTA staff responsible for Title VI, service planning and
    community relations to understand the basis for the service
    reductions and CTA's efforts to assure nondiscrimination.

-   Conduct field visits of areas affected most severely by the
    reduction and elimination of transit service.

-   Interview complainants to understand their ongoing concerns.

-   Prepare a report of findings on the issue of compliance with Title
    VI guidelines in the implementation of service reductions by CTA.

## Report Organization

This report is organized into the following remaining sections:

-   Background Information

    -   Description of Chicago Transit Authority

    -   1997/1998 Service Reductions

    -   Community Response

    -   Initial FTA Review and CTA Response

-   Findings and Recommendations

-   Attendees

```{=html}
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```
-   Summary of Complainant Interviews

-   Chronology of Documents Reviewed.

IV. []{#__RefHeading___Toc17858989 .anchor}BACKGROUND INFORMATION

## Description of Chicago Transit Authority

In 1914, all of the local street railway companies in Chicago
consolidated to become Chicago Surface Lines (CSL). In 1924, another
group of small companies made up of the Chicago and South Side Rapid
Transit Companies (formed in 1892), Lake Street Elevated Railroad
Company (1893), Metropolitan West Side Elevated Railroad Company (1895),
and Northwestern Elevated Railroad Company (1900) consolidated to form
the Chicago Rapid Transit Company (CRT). These two consolidated
companies and the acquisition of the Chicago Motor Coach System created
the Chicago Transit Authority (CTA) on October 1, 1952.

Today, CTA is responsible for bus, rail, and paratransit service in the
City of Chicago and 38 adjoining suburban communities. CTA is one of the
three service boards of the Regional Transportation Authority (RTA) that
was created in 1973 to provide for the funding of Chicago area transit
operators. All three service boards of the RTA are required to meet
statutory fare recovery ratios of 50%.

A seven member board governs CTA. The Mayor of Chicago appoints four
members with the advice and consent of the Chicago City Council. The
Governor of Illinois appoints the remaining three board members with
advice and consent of the State Senate.

![](media/image1.wmf)

CTA operates with a Citizens Advisory Board nominated by the CTA Board
of Directors. This board represents citywide ridership groups and the
City's population in general. CTA has two advisory committees dealing
with disability access issues. Membership on the committees is comprised
of representatives of various disability access interest groups,
transportation providers for the disabled, plus public agency
representatives.

CTA operates 1,900 buses over 134 transit routes, totaling over 1,937
route miles. These buses complete over 23,500 trips each day, providing
more than 1.5 million daily rides. The bus fleet operates from eight bus
garages located throughout the City. An additional facility, South
Shops, performs all heavy bus maintenance.

CTA provides rail service on seven routes extending radially from the
"Loop" located in downtown Chicago. CTA operates a fleet of 1,190 rapid
transit cars operating over seven routes and 222 miles of track. CTA
trains complete approximately 1,452 trips each weekday serving 143
stations. The fleet is maintained at ten rail maintenance facilities
providing cleaning and routine scheduled maintenance services and defect
repairs. Skokie Shops, the heavy rail maintenance facility, does all
major rail car repair, rehabilitation and unit rebuilding.

CTA also provides demand responsive paratransit service for qualified
disabled riders to meet with the complementary paratransit requirements
of the Americans With Disabilities Act (ADA). Registered users arrange
individually with one of four contract service providers or with one of
eight taxicab companies, and CTA reimburses the provider at the
contracted trip rate.

In 2000, CTA provided over 479.5 million passenger trips, including
302.1 million on bus, 176.2 million on rail, and 1.2 million on
paratransit. The last complete change in the CTA fare structure was
effective December 1991, and established the current adult base cash
fare for bus and rail service at \$1.50.

CTA\'s fare for the paratransit service for persons with disabilities is
the same as the fare for fixed route service. CTA charges a 25-cent
surcharge for express bus service on certain specified routes. CTA
offers discounted fares to persons with disabilities, the elderly,
Medicare cardholders, students and children.

## 1997/1998 Service Reductions

In 1996, as a result of ongoing budget deficits, the elimination of
Federal operating assistance and ridership declines, CTA proposed a
number of bus system and rail system service reductions. The *CTA
Service Restructuring Proposal, May 1997* was the product of a study
undertaken as a joint effort by the consulting firm, Booz-Allen &
Hamilton, Inc., and CTA planning staff.

According to the *Restructuring Proposal*, the service changes reduced
service by about ten percent while affecting current travel patterns of
only 3.3 percent of riders. Initially, it was anticipated that the
reductions would eliminate 15 bus routes and rail "night owl service"
(which is defined as service operating between 1:00 a.m. and 4:00 a.m.)
on three rail lines. Additionally, weekend service on the Cermak/Douglas
branch of the Blue Line, and Blue Line was proposed for elimination. In
addition to the elimination of 15 bus routes, 74 bus routes were subject
to reduced service hours and/or modification. The *Restructuring*
*Proposal* also called for implementing, on a pilot basis, "flexible"
routes, using small buses or vans to replace service in areas of low
ridership. The service reductions were projected to save CTA \$24.8
million in operating expenses annually. The following tables from the
*Restructuring Proposal* summarize the service changes and ridership
impacts.

+---------+-----+----------+----------+----+----+----------+--------+
| ####    |     |          |          |    |    |          |        |
| ##### T |     |          |          |    |    |          |        |
| able 13 |     |          |          |    |    |          |        |
|         |     |          |          |    |    |          |        |
| **      |     |          |          |    |    |          |        |
| SERVICE |     |          |          |    |    |          |        |
| CHANGE  |     |          |          |    |    |          |        |
| SU      |     |          |          |    |    |          |        |
| MMARY** |     |          |          |    |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
|         |     | **       |          |    |    |          |        |
|         |     | Proposed |          |    |    |          |        |
|         |     | Service  |          |    |    |          |        |
|         |     | C        |          |    |    |          |        |
|         |     | hanges** |          |    |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **Days  | **P | **No. of | **No. of | *  |    | **Daily  | **As   |
| of      | res | Routes   | Routes   | *N |    | P        | P      |
| Week**  | ent | with     | with     | o. |    | assenger | ercent |
|         | No. | Days or  | Route    | of |    | Trips    | of All |
|         | of  | Hours of | Segments | Ro |    | Affected | Daily  |
|         | Ro  | Service  | Elim     | ut |    | by       | CTA    |
|         | ute | R        | inated** | es |    | Redu     | Pas    |
|         | s** | educed** |          | wi |    | ctions** | senger |
|         |     |          |          | th |    |          | T      |
|         |     |          |          | A  |    |          | rips** |
|         |     |          |          | ll |    |          |        |
|         |     |          |          | S  |    |          |        |
|         |     |          |          | er |    |          |        |
|         |     |          |          | vi |    |          |        |
|         |     |          |          | ce |    |          |        |
|         |     |          |          | El |    |          |        |
|         |     |          |          | im |    |          |        |
|         |     |          |          | in |    |          |        |
|         |     |          |          | at |    |          |        |
|         |     |          |          | ed |    |          |        |
|         |     |          |          | ** |    |          |        |
|         |     |          |          |    |    |          |        |
|         |     |          |          | ** |    |          |        |
|         |     |          |          | *P |    |          |        |
|         |     |          |          | ha |    |          |        |
|         |     |          |          | se |    |          |        |
|         |     |          |          | I  |    |          |        |
|         |     |          |          | \- |    |          |        |
|         |     |          |          | -P |    |          |        |
|         |     |          |          | ha |    |          |        |
|         |     |          |          | se |    |          |        |
|         |     |          |          | I  |    |          |        |
|         |     |          |          | I* |    |          |        |
|         |     |          |          | ** |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **Rapid |     |          |          |    |    |          |        |
| Tr      |     |          |          |    |    |          |        |
| ansit** |     |          |          |    |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **We    | 7   | 3        | 0        | 0  | 0  | 500      | \<0.1% |
| ekday** |     |          |          |    |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **Sat   | 6   | 2        | 1        | n  | n  | 7,200    | 1.0%   |
| urday** |     |          |          | /a | /a |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **S     | 6   | 2        | 1        | n  | n  | 5,400    | 1.2%   |
| unday** |     |          |          | /a | /a |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **Bus** |     |          |          |    |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **We    | 134 | 69       | 14       | 10 | 5  | 40,000   | 3.0%   |
| ekday** |     |          |          |    |    |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **Sat   | 100 | 74       | 9        | n  | n  | 32,700   | 4.6%   |
| urday** |     |          |          | /a | /a |          |        |
+---------+-----+----------+----------+----+----+----------+--------+
| **S     | 91  | 60       | 7        | n  | n  | 22,400   | 4.8%   |
| unday** |     |          |          | /a | /a |          |        |
+---------+-----+----------+----------+----+----+----------+--------+

(CTA / Booz-Allen & Hamilton Service Restructuring Proposal - Page 92 --
May 1997)

+--------+----------+----------+---------+---------+----------------+
| ###### |          |          |         |         |                |
| ### Ta |          |          |         |         |                |
| ble 14 |          |          |         |         |                |
|        |          |          |         |         |                |
| **     |          |          |         |         |                |
| IMPACT |          |          |         |         |                |
| OF     |          |          |         |         |                |
| S      |          |          |         |         |                |
| ERVICE |          |          |         |         |                |
| C      |          |          |         |         |                |
| HANGES |          |          |         |         |                |
| IN     |          |          |         |         |                |
| SE     |          |          |         |         |                |
| LECTED |          |          |         |         |                |
| P      |          |          |         |         |                |
| ERIODS |          |          |         |         |                |
| OF     |          |          |         |         |                |
| SER    |          |          |         |         |                |
| VICE** |          |          |         |         |                |
+--------+----------+----------+---------+---------+----------------+
| **Pe   |          | **Daily  |         |         | **Percent of   |
| riod** |          | P        |         |         | Total System   |
|        |          | assenger |         |         | Passenger      |
|        |          | Trips    |         |         | Trips in       |
|        |          | Af       |         |         | Period**       |
|        |          | fected** |         |         |                |
+--------+----------+----------+---------+---------+----------------+
|        |          | **Rail** | **Bus** | **Com   |                |
|        |          |          |         | bined** |                |
+--------+----------+----------+---------+---------+----------------+
| **Wee  | **       | 0        | 6,300   | 6,300   | 2.0%           |
| kday** | Midday** |          |         |         |                |
|        |          |          |         |         |                |
|        | **10a.m. |          |         |         |                |
|        | --2      |          |         |         |                |
|        | p.m.**   |          |         |         |                |
+--------+----------+----------+---------+---------+----------------+
|        | **E      | 0        | 4,200   | 4,200   | 3.6%           |
|        | vening** |          |         |         |                |
|        |          |          |         |         |                |
|        | **7p.m.- |          |         |         |                |
|        | mi       |          |         |         |                |
|        | dnight** |          |         |         |                |
+--------+----------+----------+---------+---------+----------------+
|        | **Owl**  | 500      | 1,500   | 2,000   | 8.7%           |
|        |          |          |         |         |                |
|        | **M      |          |         |         |                |
|        | idnight- |          |         |         |                |
|        | -5a.m.** |          |         |         |                |
+--------+----------+----------+---------+---------+----------------+
| **Sa   |          | 7,200    | 32,400  | 39,900  | 5.6%           |
| turday |          |          |         |         |                |
| -- All |          |          |         |         |                |
| day**  |          |          |         |         |                |
+--------+----------+----------+---------+---------+----------------+
| **     |          | 5,400    | 22,400  | 27,800  | 6.0%           |
| Sunday |          |          |         |         |                |
| -- All |          |          |         |         |                |
| day**  |          |          |         |         |                |
+--------+----------+----------+---------+---------+----------------+

> (CTA/ Booz-Allen & Hamilton Service Restructuring Proposal -- Page 93
> -- May 1997)

In response to the proposal submitted by Booz-Allen & Hamilton, CTA
conducted public hearings on "Proposed Service Realignments." The first
hearing was held on the evening of May 21, 1997 from 7:00 p.m. to 9:45
p.m. at Malcolm X College in Chicago. A transcript of the hearing was
reviewed during this Follow-up Compliance Review. Fourteen members of
CTA's senior management team were present, including then President of
CTA, David Mosena. Thirty-eight individuals gave testimony on the
service reduction plan during the public hearing. Most of the testimony
was presented by individuals and elected representatives of the
Northwest and Southwest sides of Chicago in opposition to the proposed
changes.

A second public hearing was conducted by CTA on June 30, 1997 at the
J.R. Thompson Center in Chicago from 6:00 p.m. to 12:50 a.m. Attendance
at the public hearing exceeded 700 persons and CTA received testimony
from 145 people in attendance. Eight members of CTA senior management
staff were in attendance, with Valerie Jarrett, Chairman of the CTA
Board, presiding. Similar to the first public hearing, most comments
were against the reduction plan and represented individuals from the
near Northwest and Southwest sides of Chicago. CTA also received written
comments from 775 persons concerning the scheduled service reductions.
CTA documents stated that a third public hearing and community meetings
were held where the public was invited to express it views. No documents
were provided to the Review team on these meetings.

In June of 1997, CTA completed a Title VI assessment of the proposed bus
and rail service changes, comparing the impact of the reductions and
service eliminations on minority and non-minority routes, using the
definition and approach detailed in FTA C. 4702.1. This assessment
followed the receipt of a letter from the President of the Hispanic
Housing Development Corporation of Chicago regarding the service
reductions. The result of the Title VI assessment were:

-   Minority routes comprised 54 percent of all bus routes. Fifty-four
    of the routes affected by the restructuring on weekdays were
    minority routes.

-   Minority riders accounted for 64 percent of all weekday bus trips in
    January 1997. Of the riders affected by the restructuring on
    weekdays, 63% occurred on minority routes.

-   Minority bus routes accounted for 63.7 percent of total bus service
    hours. In 1998, minority routes accounted for 63.5 percent of total
    bus service hours.

-   Four of CTA's seven rail lines are minority routes. Two of the three
    lines that received service reductions are minority routes.
    According to CTA, the four rail lines serving minority areas are the
    longest and have the most service, both before and after the
    reductions.

On July 9, 1997 the Board of Directors of CTA approved Ordinance No.

97-88 adopting the *Restructuring Proposal* with ten minor changes. The
Board adopted the service changes at a public meeting with several
hundred members of the public present. The approved service changes
included:

  ----------------- ------------------ ------------------ -----------------
                    **Eliminated**     **Reduction**      **Totals**

  **Bus Routes**    10                 91                 101

  **Bus w/ Flexible 5                  0                  5
  Startup**                                               

  **Rail**                                                

  **Purple Line**   Owl Service        1                  1

  **Green Line**    Owl Service        1                  1

  **Blue Line       Owl & Weekend      1                  1
  (Douglas                                                
  Branch)**                                               

  **TOTALS**        15                 94                 109
  ----------------- ------------------ ------------------ -----------------

> (Summary taken from Ordinance No. 97-88)

The service reduction plan was implemented in three stages, beginning in
October of 1997. The second round of reductions occurred in December of
1997, and the third and final round of reductions occurred on April 26,
1998. Altogether, these service reductions became the largest service
reduction ever made in CTA history.

## Community Response

Many members of the affected communities and area community action
associations impacted by the service reductions were in active
consultation with both CTA and Region V Office of FTA concerning
perceived disparities in transit service following the reductions.
Service reductions were first implemented in bus service on October 6,
1997 and completed on December 28, 1997. Reduction in rail service
occurred on April 26, 1998.

Throughout 1997, 1998, and 1999, the Neighborhood Capital Budget Group
(NCBG) prepared and disseminated a number of articles concerning CTA,
its funding mechanism, budget cycle, and responsiveness, or their lack
thereof, to the community. NCBG and its sister organization, "The
Campaign for Better Transit", are not-for-profit community action
agencies with a primary mission of supporting community action
throughout Chicago's neighborhoods on budgetary matters that have the
potential to polarize or limit neighborhood access to City services.

With the reduction of rail service in April 1998, many of the
communities located in the area of the Douglas Branch of the Blue Line
began to express concerns of adverse impacts.

On October 8, 1998, a Title VI complaint (#98-235) was submitted to FTA
by a consortium of agencies located on Chicago's near West side under
the name of the "Douglas L Coalition c/o Lawndale Community Action
Group". The following organizations were signatories to the complaint:

-   Joe Ann Bradley, Lawndale Community Action Group

-   Juan Soto, Pilsen Neighbors Council

-   Alberto Sanchez, Eighteenth Street Business Association

-   Dr. Joyce Bowen, North Lawndale Family Network

-   Frank Aguilar, Little Village Chamber of Commerce

The complaint alleged that CTA\'s 1997-98 service reductions had
adversely impacted these communities by "disconnecting minority
communities from the greater metropolitan area." Specifically, the
complaint alleged that the service reductions impact on African American
and Latino neighborhoods deprived members of these communities from
having access to job opportunities, health care and recreational
activities east of these neighborhoods (downtown). Each agency sited the
loss of weekend service on the Douglas (Blue line) rail line and the
simultaneous loss of feeder bus routes as having an adverse impact on
each neighborhood and alleged that similar impacts were not occurring in
non-minority neighborhoods in Chicago.

Ms. Esmeralda Ruiz of West Fullerton Street in Chicago, Illinois
submitted a separate Title VI complaint (#98-248) to FTA on November 24,
1998. Ms. Ruiz's complaint stated that: "These service cuts divide
minority communities from the City as a whole." Further, Ms. Ruiz stated
that the discontinuation of weekend and night service on the Douglas
branch of the Blue line and the simultaneous reduction of bus service
affected mostly African-American and Latino people.

## Initial FTA Review and CTA Response

FTA received both complaints and responded to each complainant during
December of 1998. During the following months, with information provided
by the complainants and with supporting documentation provided by the
FTA Region V Office, the Director of the Office of Civil Rights in
Washington D.C. issued a letter to CTA scheduling a Title VI Compliance
Review of CTA. A preliminary meeting between CTA, FTA staff and the FTA
contractor, CompuCon, Inc. of Alexandria, Virginia, was scheduled for
April 1999. FTA then developed an Investigative Plan in order to proceed
with a Title VI Review of CTA. A detailed letter was sent to CTA on
April 27, 1999, scheduling a full Title VI Compliance Review that
included a site visit on August 8, 1999. The letter also included a list
of items needed from CTA.

The materials requested by FTA were received and reviewed by FTA's
contractor. Based on CompuCon's review of these materials, on July 28,
1999, CTA was found to be in compliance in 11 out of 26 areas, measured
through the materials submitted prior to conducing the on-site
Compliance Review. CompuCon identified eight areas requiring
verification that would take place during the Compliance Review site
visit on August 8, 1999.

  ------------------------------------------- ---------------------------
  **Compliance Standing**                     **No. of Compliance
                                              Elements**

  In Compliance                               11

  Partial Compliance                          2

  Non-compliance                              5

  Need for Verification                       8

  Total                                       26
  ------------------------------------------- ---------------------------

(CompuCon Incorporated, July 28, 1999 Compliance Review Status Report)

Areas identified as not in compliance or in partial compliance included:

+-------------------------------------------+------------+------------+
| **Title VI Requirements for Transit       | **Partial  | **Not in** |
| Providers**                               | Co         |            |
|                                           | mpliance** | **Co       |
|                                           |            | mpliance** |
+-------------------------------------------+------------+------------+
| A list of active lawsuits or complaints   | **X**      |            |
+-------------------------------------------+------------+------------+
| A fixed-facility impact assessment        |            | **X**      |
| analysis                                  |            |            |
+-------------------------------------------+------------+------------+
| A description of the process used to      | **X**      |            |
| inform minority communities about planned |            |            |
| service changes                           |            |            |
+-------------------------------------------+------------+------------+
| A listing of service changes planned for  |            | **X**      |
| three years after the submission of the   |            |            |
| Title VI plan. For each planned service   |            |            |
| change, a statement about the effect of   |            |            |
| these planned changes on minority         |            |            |
| communities and minority riders           |            |            |
+-------------------------------------------+------------+------------+
| A description of the process to be used   |            | **X**      |
| to conduct internal monitoring of the     |            |            |
| Title VI compliance                       |            |            |
+-------------------------------------------+------------+------------+
| Any documentation of efforts to monitor   |            | **X**      |
| service for compliance with established   |            |            |
| service standards                         |            |            |
+-------------------------------------------+------------+------------+
| Any documents of analysis performed to    |            | **X**      |
| compare level/quality of service in       |            |            |
| minority vs. non-minority areas           |            |            |
+-------------------------------------------+------------+------------+

> (CompuCon Incorporated July 28, 1999 Compliance Review Status Report)

CompuCon also used the data provided by CTA to complete a report
entitled *An Analysis of Racial and Ethnic Disparities in Public Bus and
Rail Transportation - Chicago Transit Authority,* dated June 8, 2000.
The stated purpose of the analysis was to "determine whether and how
changes in CTA's rail and bus routes affected the minority ridership and
minority communities". CompuCon applied a statistical analysis to
examine what it called "change", "negative change" and "non-negative
change" to minority and non-minority routes as a result of the service
reductions. CompuCon applied the statistical analysis to two
"definitions" of minority routes, of which one conformed to Circular
4702.1. The other "definition" constituted an alternative approach to
defining minority and non-minority routes. Using the "definition" that
conformed to the Circular, CompuCon applied the statistical analysis to
two calculations of minority and non-minority routes: one based on a
list that CTA provided to CompuCon defining minority and non-minority
routes and one based on a CompuCon computed list based on its own
interpretation of CTA data. Using the CompuCon computed list, the report
concluded that "minority routes are more likely to have experienced
*negative* changes and less likely to have faced *non-negative*
changes". Using the CTA list, the report concluded that "there is no
statistically significant difference in the negative changes in routes
between minority and non-minority routes" and that "Minority routes, in
fact, are *more* likely than non-minority routes to face non-negative
changes....". The statistical analysis on two of the other three
calculations of minority and non-minority routes also produced
conclusions that could be interpreted as having a discriminatory impact.

The results of the report led the FTA Director of Civil Rights to issue
a letter to CTA on July 19, 2000 citing "serious Title VI concerns"
resulting from the study conducted by CompuCon. On September 8, 2000,
Frank Kruesi, President of the CTA, responded to FTA with additional
information and data that the analysis completed by CompuCon was the
result of misinterpretation of data provided by CTA.

Following on-going concerns from the complainants in 2001 and 2002, FTA
made a determination to conduct this Follow-Up Limited Scope Title VI
Compliance Review in 2002.

V.  []{#__RefHeading___Toc17858998 .anchor}Scope and METHODOLOGY

## Scope

This limited scope Title VI Compliance Review of CTA focused on the
extent to which the service reductions implemented by CTA met the
Program-Specific requirements, in accordance with FTA Circular 4702.1,
Program Guidelines for Federal Transit Administration Recipients, as
represented to FTA. Specifically, Chapter III, Section 3 (a) (3) (c) of
the Circular states that grantees should:

*Evaluate system-wide service changes and proposed improvements at the
planning and programming stages to determine whether the overall
benefits and cost of such changes or improvements are distributed
equally, and are not discriminatory.*

Further, Chapter III, Section 3 (a) (4) (b) of the Circular states that
grantees should:

*Provide a description of the methods used to inform minority
communities of service changes (e.g., public notices, public hearings,
other formal or informal public discussions, presentations, meetings,
etc.) relating to transit service and improvements.*

## Methodology

The initial step of this Limited Scope Compliance Review consisted of
consultation with the FTA Office of Civil Rights Headquarters staff
regarding the decision to conduct a Limited Scope Compliance Review of
CTA. Relevant documents from FTA's files in Headquarters were collected
and reviewed as background. Next, CTA's Executive Vice President for
Management and Performance was contacted to coordinate dates for the
site visit. A site visit agenda was prepared and sent to CTA,
identifying the staff to be interviewed and the areas that would be
covered during the on-site portion of the Review.

Prior to the Entrance Conference, the Review team met with the following
officials from FTA's Region V Office to obtain background information
and a briefing on current issues:

-   Joel Ettinger, Regional Administrator

-   Louise Carter, Director, Office of Operations and Program Management

-   Rhonda Reed, Director, Office of Planning (prior Region V Civil
    Rights Officer)

An Entrance Conference was conducted at the beginning of the site visit
with Dorval Carter, CTA's Executive Vice President for Management and
Performance; Pam Beavers, CTA's General Manager for DBE and Civil
Rights; Mary Kay Christopher, General Manager, Service Planning; Barbara
Lesser, Chief Counsel; and the Review team. During the Entrance
Conference, the Review team explained the goals of the Review and the
needed cooperation of staff members.

Following the Entrance Conference, there was a detailed examination of
documents assembled for the Review team by the CTA's General Manager for
DBE and Civil Rights. A chronology of documents analyzed by the Review
team is provided in Section IX of this report.

Individual interviews were then conducted with the following members of
CTA management staff to inquire about the events leading up to and
following the implementation of the service reductions:

-   Mary Kay Christopher, General Manager, Service Planning

-   Pam Beavers, General Manager, DBE and Civil Rights

-   Paul Gross, General Manager, Data Services

-   Elsa Guitierrez, Service Planner

-   Kathleen Hermann, Attorney

Specific details of the service reductions were discussed and
considerable attention was devoted to the *CTA Service Restructuring
Proposal, May 1997* presentation.

The Review team then conducted field visits to better understand the
areas impacted by the service reductions and to observe bus and rail
service currently in place. Members of the Review team rode the Douglas
branch of the Blue Line ("Night Owl" and weekend service was eliminated)
and traveled along the entire length of the 21X bus route, which serves
as a temporary replacement for the Douglas branch. The Review team also
observed the corridors served by other areas affected by the service
reductions, such as along Michigan Avenue and Martin Luther King Drive
on the Southside. During these field visits, the Review team observed
vehicle loads, businesses and distances to alternate bus or rail
service.

Finally, the Review team conducted extensive interviews with the
following complainants and other interested parties concerning the
service reductions and the current status of the complaints:

-   Joe Ann Bradley, Executive Director, The Community Action Group

-   Jacqueline C. Leavy, Executive Director, Neighborhood Capital Budget
    Group

-   Dorothy Gibbs, Women's Support Group Coordinator, Chicago
    Commons/Mary McDowell House

-   Blunnett Thompson, Counselor, Mary McDowell House

-   Delores Bond, Counselor, Mary McDowell House

-   Roberto A. Cornelio, Executive Director, Little Village Chamber of
    Commerce

-   Oscar R. Iracheta, President, Eighteenth Street Business Association

A summary of the comments from the interested parties is provided in
Section VIII.

At the end of the site visit, an exit briefing was held with CTA senior
management staff and the Review team. During this briefing, the Review
team requested additional documents and discussed the next steps,
including the development of this report of findings.

VI. []{#__RefHeading___Toc17859001 .anchor}FINDINGS AND RECOMMENDATIONS

The findings and recommendations focused on the extent to which the
service reductions implemented by CTA met the Program-Specific
requirements, in accordance with FTA Circular 4702.1, Program Guidelines
for Federal Transit Administration Recipients, as represented to FTA.
Specifically, Chapter III, Section 3 (a) (3) (c) and Chapter III,
Section 3 (a) (4) (b) of the Circular.

## 

## Evaluation of System Wide Service Changes

[Basic Requirement]{.underline}: Grantees must Evaluate system-wide
service changes and proposed improvements at the planning and
programming stages to determine whether the overall benefits and cost of
such changes or improvements are distributed equally, and are not
discriminatory.

The implementation of the 1997/1998 service reductions did not appear to
have violated Title VI of the Civil Rights Act of 1964. Based on the
definition of minority and non-minority routes found in FTA Circular
4702.1, the quantity of the service reductions on minority routes was
generally proportional to the quantity of service reductions on
non-minority routes. The following table from the CTA's Title VI
Assessment of the service reductions was prepared on June 2, 1997 and
updated through September 3, 1997, summarizes the reduction in vehicle
hours of service for minority and non-minority bus.

**Proposed Bus Service Changes\***

**Minority vs. Non-Minority Bus Routes**

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td rowspan="2"></td>
<td colspan="3"><p><strong>Weekday Vehicle Hours</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
<td colspan="3"><p><strong>Saturday Vehicle Hours</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
<td colspan="3"><p><strong>Sunday Vehicle Hours</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
<td colspan="3"><p><strong>Combined</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
</tr>
<tr class="even">
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
</tr>
<tr class="odd">
<td><h1 id="minority">Minority</h1></td>
<td>3,275</td>
<td>2,951</td>
<td>-9.9%</td>
<td>502</td>
<td>435</td>
<td>-13.3%</td>
<td>435</td>
<td>371</td>
<td>-14.8%</td>
<td>4,212</td>
<td>3,757</td>
<td>-10.8%</td>
</tr>
<tr class="even">
<td><strong>Non-Minority</strong></td>
<td>1,871</td>
<td>1,665</td>
<td>-11.0%</td>
<td>228</td>
<td>197</td>
<td>-13.0%</td>
<td>188</td>
<td>167</td>
<td>-11.2%</td>
<td>2,286</td>
<td>2,029</td>
<td>-11.2%</td>
</tr>
</tbody>
</table>

\*CTA/Booz-Allen & Hamilton -- Title VI Assessment, prepared 06/02/97
and revised thru 09/03/97

Overall, bus service hours were reduced by 11.0 percent, with service on
minority routes reduced by 10.8 percent and service on non-minority
routes reduced by 11.2 percent. In other words, minority bus service was
reduced, in percentage terms, less than non-minority bus service. When
disaggregated by weekday, Saturday, and Sunday, minority bus service was
reduced less on weekdays (9.9 percent for minority routes versus 11.0
percent for non-minority routes) and more on Saturdays (13.3 percent
versus 13.0 percent) and Sundays (14.8 percent versus 11.2 percent).
Some of the differential on weekends can be explained by such things as
the elimination of service on Route 1-Indiana/Hyde Park, which was a
minority route that had decent ridership but was duplicative of service
provided by two key routes (Route 3-King Drive and Route 4-Cottage
Grove).

The next table (also from CTA/Booz-Allen) summarizes the impact of the
service reductions on rail service.

**Proposed Rail Service Changes\***

**Minority vs. Non-Minority Rail Lines**

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td rowspan="2"></td>
<td colspan="3"><p><strong>Weekday Pay Hours</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
<td colspan="3"><p><strong>Saturday Pay Hours</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
<td colspan="3"><p><strong>Sunday Pay Hours</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
<td colspan="3"><p><strong>Combined</strong></p>
<p><strong>(000’s Omitted)</strong></p></td>
</tr>
<tr class="even">
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
<td><p><strong>Before</strong></p>
<p><strong>Cuts</strong></p></td>
<td><strong>After Cuts</strong></td>
<td><strong>% Change</strong></td>
</tr>
<tr class="odd">
<td><h1 id="minority-1">Minority</h1></td>
<td>447</td>
<td>443</td>
<td>-1.2%</td>
<td>85</td>
<td>75</td>
<td>-13.3%</td>
<td>91</td>
<td>80</td>
<td>-14.3%</td>
<td>625</td>
<td>598</td>
<td>-4.5%</td>
</tr>
<tr class="even">
<td><strong>Non-Minority</strong></td>
<td>159</td>
<td>157</td>
<td>-1.0%</td>
<td>19</td>
<td>19</td>
<td>-1.7%</td>
<td>15</td>
<td>15</td>
<td>-3.7%</td>
<td>193</td>
<td>191</td>
<td>-1.3%</td>
</tr>
</tbody>
</table>

\*CTA/Booz-Allen & Hamilton -- Title VI Assessment, prepared 06/02/97
and revised thru 09/03/97

Overall, rail service hours were reduced by 3.7 percent, with service on
minority routes reduced by 4.5 percent and service on non-minority
routes reduced by 1.3 percent. When disaggregated by weekday, Saturday,
and Sunday, minority rail service was reduced slightly more on weekdays
(1.2 percent for minority routes versus 1.0 percent for non-minority
routes) and substantially more on Saturdays (13.3 percent versus 1.7
percent) and Sundays (14.3 percent versus 3.7 percent). With the
reduction, minority route rail service hours went from being 76.4
percent of all service hours to 75.8 percent of all service hours. By
far the most significant factor in the disparity in the reduction in
rail service was the elimination of weekend service on the Douglas
Branch of the Blue Line. The *Restructuring Proposal* stated that
weekend service on the Douglas Branch was the least efficient of the
rail lines and easily served by alternative bus service and the main
branch of the Blue Line, which was only two miles away. During the
interviews with CTA staff, it was revealed that this rail line segment
was very old and in drastic need of repair. Some of the structures were
in such poor condition that train speeds were reduced to ten miles per
hour. CTA staff indicated that if renovation of the line was not
undertaken, it would not have been operable. The Review team confirmed
the poor condition of the structure and the train speeds during a tour
of the segment during the site visit. Shortly after service on the line
was discontinued on weekends, CTA sought and received FTA funding
approval to renovate the line. Work is currently ongoing, with most of
it being done on weekends to accelerate the completion at a lower
overall cost. Therefore, the elimination of weekend service on this
segment will ultimately benefit the community with improved service.

In a letter dated September 8, 2000 to the FTA, CTA clarified that the
analysis performed by CompuCon resulted from a misinterpretation of the
data tables. Further, CTA recalculated its identification of which CTA
bus routes were minority routes and which were non-minority routes using
new GIS technology, not available during the initial assessment. This
new analysis resulted in list of routes mirroring the original CTA list,
with the exception of seven of the 139 routes. Consequently, the
appropriate conclusion of the statistical analysis is that "there is no
statistically significant difference in the negative changes in routes
between minority and non-minority routes" and that "Minority routes, in
fact, are *more* likely than non-minority routes to face non-negative
changes....".

CTA followed the requirements of the Circular in conducting a Title VI
assessment prior to implementing the service reductions. At the site
visit, CTA provided documentation that it conducted an assessment of the
service hour impacts of the proposed service changes during June through
September 1997. It did not identify any disparities that affected
minorities more than non-minorities. Our review of the assessment
confirms CTA's conclusions.

## Inform Minority Communities of Service Changes

[Basic Requirement]{.underline}: Grantees must provide a description of
the methods used to inform minority communities of service changes
(e.g., public notices, public hearings, other formal or informal public
discussions, presentations, meetings, etc.) relating to transit service
and improvements.

[Findings]{.underline}: CTA followed the minimum Title VI requirements
with respect to informing members of the minority community of the
planned service reductions. According to CTA officials, three public
hearings were held along with a series of community meetings. During
this review, CTA provided documentation of two public hearings but no
information to document the third public hearing or the community
meetings. In a metropolitan area such as Chicago, two public hearings is
indeed a minimal effort. Additionally, it appears that CTA acted with
very little regard for community concerns, as evidenced by its decision
to go forward with the overwhelming majority of its *Restructuring
Proposal* in spite of significant opposition and turnout of over 700
persons at a single public hearing.

The complainants continue to be frustrated by what they perceive to be
CTA's lack of effort at communicating with minority community
representatives particularly as it relates to the impact on businesses
and residents on weekends in the area of the Douglas Branch of the Blue
Line. CTA staff told the Review team that it had recently formed a
committee of interested parties to address concerns regarding the
closure of the Douglas Branch on weekends. However, CTA never provided
any documentation such as the names of persons on the committee, the
purpose of the committee or minutes from meetings that had been held.
During interviews with interested parties, several representatives
stated that they were vaguely aware of such a committee, but had no
specific information from CTA. Community leaders expressed concern that
the late formation of the Douglas Branch committee precluded meaningful
input by the community. Other key comments obtained during the
interviews with interested parties were:

-   Elimination of owl and weekend service on the Douglas Branch had the
    biggest impact on communities

-   CTA needed to improve its effort to solicit community input

-   Leaders believed that some residents must walk more than ¼ mile to
    transit

-   Efforts to communicate in alternative formats (i.e., Spanish,
    Braille, for the deaf or illiterate) were not adequate

-   Community leaders didn't trust CTA

While these comments don't show that CTA has failed to meet the outreach
efforts described in the Circular, it is clear that CTA should improve
its community outreach efforts to ensure that minority residents are
heard and that policymakers consider their concerns.

VII. []{#__RefHeading___Toc17859004 .anchor}Attendees

+---------------+--------------------+---------+---------------------+
| **Name**      | **Title**          | **Phon  | ######### Email     |
|               |                    | e/Fax** |                     |
+---------------+--------------------+---------+---------------------+
| Mary Kay      | General Manager,   | 312-4   | *\@                 |
| Christopher   | Service Planning - | 32-7042 | transitchicago.com* |
|               | CTA                |         |                     |
+---------------+--------------------+---------+---------------------+
| Pam Beavers   | General Manager,   | 312-6   | *\@                 |
|               | DBE & Civil        | 64-7200 | transitchicago.com* |
|               | Rights - CTA       | X3525   |                     |
+---------------+--------------------+---------+---------------------+
| Barbara       | Chief Counsel -    | 312-6   | *\@                 |
| Lesser        | CTA                | 64-7200 | transitchicago.com* |
|               |                    | X3264   |                     |
+---------------+--------------------+---------+---------------------+
| Dorval Carter | Executive Vice     | 312-2   | *\@                 |
|               | President          | 22-6134 | transitchicago.com* |
|               | Management &       |         |                     |
|               | Performance -- CTA |         |                     |
+---------------+--------------------+---------+---------------------+
| Elsa          | Service Planner -  | 312-7   | *\@                 |
| Guitierrez    | CTA                | 33-7000 | transitchicago.com* |
|               |                    | X6847   |                     |
+---------------+--------------------+---------+---------------------+
| Paul Gross    | General Manager,   | 312-7   | *\@                 |
|               | Data Services -    | 33-7000 | transitchicago.com* |
|               | CTA                | X7032   |                     |
+---------------+--------------------+---------+---------------------+
| Kathleen      | Attorney -- CTA    | 312-2   | *\@                 |
| Herrmann      |                    | 22-6137 | transitchicago.com* |
+---------------+--------------------+---------+---------------------+
| Joel Ettinger | Regional           | 312-2   | <Joel.et            |
|               | Administrator, FTA | 52-2789 | tinger@fta.dot.gov> |
|               | (Region V)         |         |                     |
|               |                    | 312-8   |                     |
|               |                    | 86-0351 |                     |
+---------------+--------------------+---------+---------------------+
| Louise Carter | Director, Office   | 312-3   | <louise.            |
|               | of Operations and  | 53-2883 | carter@fta.dot.gov> |
|               | Program Management |         |                     |
|               | -- FTA (Region V)  | 312-8   |                     |
|               |                    | 86-0351 |                     |
+---------------+--------------------+---------+---------------------+
| Rhonda Reed   | Director, Office   | 312-3   | <rhond              |
|               | of Planning - FTA  | 53-2865 | a.reed@fta.dot.gov> |
|               | (Region V)         |         |                     |
|               |                    | 312-8   |                     |
|               |                    | 86-0351 |                     |
+---------------+--------------------+---------+---------------------+
| Joe Ann       | Executive Director | 773-7   |                     |
| Bradley       | -- The Community   | 62-5960 |                     |
|               | Action Group       |         |                     |
+---------------+--------------------+---------+---------------------+
| Jacqueline C. | Executive Director | 312-9   | <jleavy@ncbg.org>   |
| Leavy         | -- Neighborhood    | 39-7198 |                     |
|               | Capital Budget     |         |                     |
|               | Group              | 312-9   |                     |
|               |                    | 39-7480 |                     |
+---------------+--------------------+---------+---------------------+
| Dorothy Gibbs | Women's Support    | 773-3   |                     |
|               | Group Coordinator  | 76-5242 |                     |
|               | -- Chicago         |         |                     |
|               | Commons/Mary       |         |                     |
|               | McDowell House     |         |                     |
+---------------+--------------------+---------+---------------------+
| Blunnett      | Counselor -- Mary  | 773-4   |                     |
| Thompson      | McDowell House     | 20-3137 |                     |
+---------------+--------------------+---------+---------------------+
| Delores Bond  | Counselor -- Mary  | 773-4   |                     |
|               | McDowell House     | 20-9558 |                     |
+---------------+--------------------+---------+---------------------+
| Roberto A.    | Executive Director | 773-5   | <rcornelio@la       |
| Cornelio      | -- Little Village  | 21-5387 | villitachamber.com> |
|               | Chamber of         |         |                     |
|               | Commerce           | 773-5   |                     |
|               |                    | 21-5252 |                     |
|               |                    |         |                     |
|               |                    | 630-9   |                     |
|               |                    | 88-0214 |                     |
+---------------+--------------------+---------+---------------------+
| Oscar R.      | President --       | 312-2   | <oir                |
| Iracheta      | Eighteenth Street  | 43-3722 | achetaesba@aol.com> |
|               | Business           |         |                     |
|               | Association        | 312-2   |                     |
|               |                    | 43-3220 |                     |
|               |                    |         |                     |
|               |                    | 312-2   |                     |
|               |                    | 96-3722 |                     |
+---------------+--------------------+---------+---------------------+
| John Potts    | Lead Reviewer --   | 504-2   | <johnpot            |
|               | The DMP Group,     | 83-7661 | ts@thedmpgroup.com> |
|               | Inc.               |         |                     |
|               |                    | 504-2   |                     |
|               |                    | 83-0791 |                     |
+---------------+--------------------+---------+---------------------+
| Jim Buckley   | Reviewer --        | 410-7   | <jbuckl             |
|               | Milligan &         | 32-4626 | ey@milligancpa.com> |
|               | Company, LLC       |         |                     |
+---------------+--------------------+---------+---------------------+
| Joseph Herzog | Reviewer --        | 215-4   | <jherz              |
|               | Milligan &         | 96-9100 | og@milligancpa.com> |
|               | Company, LLC       | X124    |                     |
+---------------+--------------------+---------+---------------------+
| Royal Ed      | Reviewer - The DMP | 301-6   | <royalei            |
| Spurlark      | Group, Inc.        | 81-0258 | ii@thedmpgroup.com> |
|               |                    |         |                     |
|               |                    | 301-6   |                     |
|               |                    | 81-5586 |                     |
+---------------+--------------------+---------+---------------------+

[]{#__RefHeading___Toc17859005 .anchor}VIIi. Summary of complainant
Interviews

+--------------------------+----------+-------+------+-------+-------+
| KEY WORD SUMMARY OF      | **The    | **The | *    | **L   | **    |
| TITLE VI INTERVIEWS WITH | Neig     | Comm  | *Chi | ittle | Eight |
| COMMUNITY ORGANIZATIONS  | hborhood | unity | cago | Vi    | eenth |
| IN CHICAGO RESULTING     | Capital  | A     | C    | llage | S     |
| FROM 1997/1998 SERVICE   | Budget   | ction | ommo | Ch    | treet |
| CUTS                     | Group**  | Gr    | ns** | amber | Bus   |
|                          |          | oup** |      | of    | iness |
|                          |          |       |      | Comme | Ass   |
|                          |          |       |      | rce** | ociat |
|                          |          |       |      |       | ion** |
+==========================+==========+=======+======+=======+=======+
| **Review Questions**     |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 1.  Title VI, as applied |          |       |      |       |       |
|     to public            |          |       |      |       |       |
|     transportation       |          |       |      |       |       |
|     services requires    |          |       |      |       |       |
|     the CTA to ensure    |          |       |      |       |       |
|     that changes made to |          |       |      |       |       |
|     its bus and rail     |          |       |      |       |       |
|     services do not      |          |       |      |       |       |
|     adversely impact the |          |       |      |       |       |
|     minority community   |          |       |      |       |       |
|     more than the        |          |       |      |       |       |
|     service area viewed  |          |       |      |       |       |
|     in its entirety.     |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| Service reduction at the |          |       |      |       |       |
| Chicago Transit          |          |       |      |       |       |
| Authority (CTA) occurred |          |       |      |       |       |
| between October 1997 and |          |       |      |       |       |
| April of 1998. They      |          |       |      |       |       |
| included the elimination |          |       |      |       |       |
| of "owl" service and     |          |       |      |       |       |
| reductions of weekend    |          |       |      |       |       |
| service on neighborhood  |          |       |      |       |       |
| rail lines (green, blue, |          |       |      |       |       |
| etc.) as well as the     |          |       |      |       |       |
| elimination of 10 bus    |          |       |      |       |       |
| routes and the           |          |       |      |       |       |
| establishment of 5       |          |       |      |       |       |
| others with "flexible    |          |       |      |       |       |
| service."                |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| a.  Please describe the  | Bus &    | Bus & | Bus  | Bus   | Rail  |
|     impact of these      | Rail     | Rail  | Ser  | Se    | Ser   |
|     service cuts on your | Service  | Se    | vice | rvice | vices |
|     community?           | (Owl &   | rvice | (Owl | (Owl  | (Owl  |
|                          | Weekend) | (Owl  | &    | &     | and   |
|                          |          | &     | Week | Wee   | Wee   |
|                          |          | Wee   | end) | kend) | kend) |
|                          |          | kend) |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| b.  Please describe the  | Limited  | Li    | Lim  | Li    | Li    |
|     current availability |          | mited | ited | mited | mited |
|     of bus and rail      |          |       | to   |       |       |
|     services, available  |          |       | 6:00 |       |       |
|     to your community,   |          |       | am   |       |       |
|     provided by the CTA. |          |       | to   |       |       |
|                          |          |       | 8:00 |       |       |
|                          |          |       | pm   |       |       |
+--------------------------+----------+-------+------+-------+-------+
| c.  Based on the current | Solicit  | So    | 1    | So    | Mitig |
|     services being       | C        | licit | 2:00 | licit | ation |
|     provided by the CTA  | ommunity | Comm  | am   | Comm  |       |
|     in your community,   | Input    | unity | or   | unity |       |
|     what could the CTA   |          | Input | Owl  | Input |       |
|     do to improve on its |          |       | Ser  |       |       |
|     current service?     |          |       | vice |       |       |
|                          |          |       | on   |       |       |
|                          |          |       | 51St |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 2.  The CTA in the       |          |       |      |       |       |
|     process of improving |          |       |      |       |       |
|     the (Douglas) Blue   |          |       |      |       |       |
|     Line and has a full  |          |       |      |       |       |
|     funding agreement    |          |       |      |       |       |
|     from FTA to complete |          |       |      |       |       |
|     the work.            |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| a.  With the completion  | Yes      | Yes   | No;  | No;   | Yes   |
|     of this project,     | (2005)   | (     | Bus  | Bus   | (     |
|     will access to       | How do   | 2005) | I    | Issue | 2005) |
|     public               | we get   | How   | ssue |       | How   |
|     transportation be    | from now | do we |      |       | do we |
|     improved within you  | to then  | get   |      |       | get   |
|     community?           |          | from  |      |       | from  |
|                          |          | now   |      |       | now   |
|                          |          | to    |      |       | to    |
|                          |          | then  |      |       | then  |
+--------------------------+----------+-------+------+-------+-------+
| b.  What service is      | Owl &    | Owl & | Owl  | Owl & | Mitig |
|     needed in your       | Weekend  | We    | &    | We    | ation |
|     community that is    |          | ekend | Wee  | ekend |       |
|     available in other   |          |       | kend |       |       |
|     minority and         |          |       |      |       |       |
|     non-minority         |          |       |      |       |       |
|     communities?         |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 3.  The CTA has made     |          |       |      |       |       |
|     service adjustments  |          |       |      |       |       |
|     to its bus service   |          |       |      |       |       |
|     since the 1997/98    |          |       |      |       |       |
|     bus service cuts.    |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| a.  How have the         | Limited  | Li    | Lim  | Li    | Li    |
|     adjustments affected | Public   | mited | ited | mited | mited |
|     service in your      | Transit  | P     | Pu   | P     | P     |
|     community?           | Options  | ublic | blic | ublic | ublic |
|                          |          | Tr    | Tra  | Tr    | Tr    |
|                          |          | ansit | nsit | ansit | ansit |
|                          |          | Op    | Opt  | Op    | Op    |
|                          |          | tions | ions | tions | tions |
+--------------------------+----------+-------+------+-------+-------+
| b.  What service is      | 1997/98  | 19    | 1    | 19    | 19    |
|     needed in your       | Service  | 97/98 | 2:00 | 97/98 | 97/98 |
|     community that is    | Levels   | Se    | am   | Se    | Se    |
|     available in other   |          | rvice | or   | rvice | rvice |
|     minority and         |          | L     | Owl  | L     | L     |
|     non-minority         |          | evels | Ser  | evels | evels |
|     communities?         |          |       | vice |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 4.  Please describe the  | Limited  | Li    | None | None  | None  |
|     CTA's process during | Access   | mited |      |       |       |
|     1997/98 to           | under    | A     |      |       |       |
|     incorporate or       | Mecinia  | ccess |      |       |       |
|     examine comment(s)   | Admini   | under |      |       |       |
|     provided by affected | stration | Me    |      |       |       |
|     individuals,         |          | cinia |      |       |       |
|     communities or       |          | Admi  |      |       |       |
|     organizations to     |          | nistr |      |       |       |
|     proposed service     |          | ation |      |       |       |
|     changes.             |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| a.  Has that process     | March    | March | NO   | March | March |
|     changed since the    | 2002 New | 2002  |      | 2002  | 2002  |
|     1997/98 service      | Advisory | New   |      | New   | New   |
|     cuts?                | C        | Adv   |      | Adv   | Adv   |
|                          | ommittee | isory |      | isory | isory |
|                          |          | Comm  |      | Comm  | Comm  |
|                          |          | ittee |      | ittee | ittee |
+--------------------------+----------+-------+------+-------+-------+
| 5.  Are you aware of the | YES      | NO    | NO   | NO    | NO    |
|     Metropolitan         |          |       |      |       |       |
|     Planning             |          |       |      |       |       |
|     Organization's (MPO) |          |       |      |       |       |
|     activities in your   |          |       |      |       |       |
|     area?                |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 6.  What is the name of  | CATS     | Did   | Did  | Did   | Did   |
|     the MPO in your      |          | not   | not  | not   | not   |
|     area?                |          | know  | know | know  | know  |
+--------------------------+----------+-------+------+-------+-------+
| 7.  Do you or any        | YES      | NO    | NO   | NO    | NO    |
|     members of your      |          |       |      |       |       |
|     organization         |          |       |      |       |       |
|     participate in the   |          |       |      |       |       |
|     planning activities  |          |       |      |       |       |
|     of your MPO?         |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 8.  Do you believe that  | NO       | NO    | NO   | NO    | NO    |
|     your community has   |          |       |      |       |       |
|     adequate access to   |          |       |      |       |       |
|     public transit?      |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 9.  In other words, do   | YES      | YES   | YES  | YES   | YES   |
|     residents of your    |          |       |      |       |       |
|     community frequently |          |       |      |       |       |
|     have to walk more    |          |       |      |       |       |
|     than 1/4 of a mile   |          |       |      |       |       |
|     to reach a bus or to |          |       |      |       |       |
|     reach their          |          |       |      |       |       |
|     destination?         |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 10. Does the CTA         | YES      | YES   | NO   | NO    | YES   |
|     advertise planned    |          |       |      |       |       |
|     service changes to   |          |       |      |       |       |
|     the communities that |          |       |      |       |       |
|     will be affected?    |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| If yes, by what means    | Sun      | Sun   | N/A  | N/A   | Radio |
| are you informed?        | Times    | Times |      |       |       |
|                          | and      | and   |      |       |       |
|                          | Tribune  | Tr    |      |       |       |
|                          |          | ibune |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 10.1 Do you have any     | -   Neig | Cultu | Cons | Keep  | \-    |
| recommendations on other | hborhood | rally | ider | se    | -Esta |
| formats that would       |     News | sens  | ways | rvice | blish |
| improve the grantees     |          | itive | to   | c     | pr    |
| outreach efforts?        |    Media | fo    | r    | hange | ocess |
|                          |          | rmats | each | bull  | for   |
|                          | -   Bi   | with  | l    | etins | obta  |
|                          | -Lingual | comm  | arge | in    | ining |
|                          |     new  | unity | il   | Sp    | comm  |
|                          | spapers, | input | lite | anish | unity |
|                          |          |       | rate | avai  | input |
|                          |    radio |       | po   | lable | in    |
|                          |     and  |       | pula | after | ad    |
|                          |     te   |       | tion | the   | vance |
|                          | levision |       |      | se    | of    |
|                          |          |       |      | rvice | se    |
|                          | -   News |       |      | c     | rvice |
|                          |          |       |      | hange | ch    |
|                          |  outlets |       |      | has   | anges |
|                          |     for  |       |      | been  |       |
|                          |     Non  |       |      | impl  | []{.  |
|                          | -English |       |      | ement | mark} |
|                          |          |       |      | ed*.* |       |
|                          | speakers |       |      |       |       |
|                          |          |       |      |       |       |
|                          | -        |       |      |       |       |
|                          |    Radio |       |      |       |       |
|                          |     for  |       |      |       |       |
|                          |          |       |      |       |       |
|                          | Visually |       |      |       |       |
|                          |          |       |      |       |       |
|                          | Impaired |       |      |       |       |
|                          |          |       |      |       |       |
|                          | -        |       |      |       |       |
|                          | Targeted |       |      |       |       |
|                          |     di   |       |      |       |       |
|                          | sability |       |      |       |       |
|                          |          |       |      |       |       |
|                          |   groups |       |      |       |       |
|                          |          |       |      |       |       |
|                          |    i.e., |       |      |       |       |
|                          |     deaf |       |      |       |       |
|                          |     pop  |       |      |       |       |
|                          | ulation, |       |      |       |       |
|                          |     etc  |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 11\. Does the CTA        | NO       | NO    | NO   | NO    | NO;   |
| adequately communicate   |          |       |      |       | once  |
| with minorities who do   |          |       |      |       | pr    |
| not speak English? Is    |          |       |      |       | inted |
| public information       |          |       |      |       | En    |
| (e.g., signs, brochures, |          |       |      |       | glish |
| etc.) available in       |          |       |      |       | n     |
| Spanish or other         |          |       |      |       | otice |
| languages spoken in your |          |       |      |       | in    |
| community?               |          |       |      |       | Sp    |
|                          |          |       |      |       | anish |
|                          |          |       |      |       | news  |
|                          |          |       |      |       | paper |
+--------------------------+----------+-------+------+-------+-------+
| KEY WORD SUMMARY OF      | **The    | **The | *    | **L   | **    |
| TITLE VI INTERVIEWS WITH | Neig     | Comm  | *Chi | ittle | Eight |
| COMMUNITY ORGANIZATIONS  | hborhood | unity | cago | Vi    | eenth |
| IN CHICAGO RESULTING     | Capital  | A     | C    | llage | S     |
| FROM 1997/1998 SERVICE   | Budget   | ction | ommo | Ch    | treet |
| CUTS                     | Group**  | Gr    | ns** | amber | Bus   |
|                          |          | oup** |      | of    | iness |
|                          |          |       |      | Comme | Ass   |
|                          |          |       |      | rce** | ociat |
|                          |          |       |      |       | ion** |
+--------------------------+----------+-------+------+-------+-------+
| 12\. The Federal Transit |          |       |      |       |       |
| Administration is        |          |       |      |       |       |
| committed to ensure that |          |       |      |       |       |
| Title VI compliance is   |          |       |      |       |       |
| secured for every member |          |       |      |       |       |
| of service areas         |          |       |      |       |       |
| affected by the grants   |          |       |      |       |       |
| it makes to local        |          |       |      |       |       |
| transportation agencies  |          |       |      |       |       |
| (CTA).                   |          |       |      |       |       |
+--------------------------+----------+-------+------+-------+-------+
| Are their specific       | Restore  | Re    | Res  | Re    | Re    |
| suggestions that you or  | 1997/98  | store | tore | store | store |
| your organization have   | Service  | 19    | Prog | 19    | 19    |
| to ensure that affected  | Cuts and | 97/98 | rams | 97/98 | 97/98 |
| communities have greater | Parti    | Se    | that | Se    | Se    |
| input to or receive      | cipation | rvice | Sup  | rvice | rvice |
| consideration during,    | in       | Cuts  | port | Cuts  | Cuts  |
| the planning phase of    | Service  | and   | the  | and   | and   |
| proposed service         | Planning | Par   | Elde | Par   | Par   |
| changes?                 |          | ticip | rly, | ticip | ticip |
|                          |          | ation | Preg | ation | ation |
|                          |          | in    | nant | in    | in    |
|                          |          | Se    | Mot  | Se    | Se    |
|                          |          | rvice | hers | rvice | rvice |
|                          |          | Pla   | and  | Plan  | Pla   |
|                          |          | nning | Chil | ning. | nning |
|                          |          |       | dren | R     | or    |
|                          |          |       | for  | educe | Mitig |
|                          |          |       | Em   | Hea   | ation |
|                          |          |       | ploy | dways |       |
|                          |          |       | ment | d     |       |
|                          |          |       | and  | uring |       |
|                          |          |       | Med  | Rush  |       |
|                          |          |       | ical | Hours |       |
|                          |          |       | Serv |       |       |
|                          |          |       | ices |       |       |
+--------------------------+----------+-------+------+-------+-------+
| 13\. Do you have any     | NO TRUST | NO    | VI   | NO    | NO    |
| other comments or        | OF CTA   | TRUST | EWED | TRUST | TRUST |
| suggestions regarding    |          | OF    | AS A | OF    | OF    |
| ways that the CTA can    |          | CTA   | P    | CTA   | CTA   |
| better serve or          |          |       | OLIT |       |       |
| communicate with         |          |       | ICAL |       |       |
| minority communities?    |          |       | I    |       |       |
|                          |          |       | SSUE |       |       |
|                          |          |       | / NO |       |       |
|                          |          |       | T    |       |       |
|                          |          |       | RUST |       |       |
|                          |          |       | OF   |       |       |
|                          |          |       | CTA  |       |       |
+--------------------------+----------+-------+------+-------+-------+

IX. []{#__RefHeading___Toc17859006 .anchor}Chronology of documents
    reviewed

  ----------------- ---------------- -------------- ------------------------- ----------------------- ----- ----- ----- ------- ------- ------- ------- --------- --------- --------- ---------
  **CTA Title VI                                                                                                                                                                      
  Chronology of                                                                                                                                                                       
  Data Received and                                                                                                                                                                   
  Reviewed by the                                                                                                                                                                     
  DMP Group In                                                                                                                                                                        
  Completing this                                                                                                                                                                     
  Report**                                                                                                                                                                            

  ***Received***    ***Dated***      ***Agency***   ***Title***                                                                                                                        

                    1-Sep-90         CTA            CTA Service Standards                                                                                                              
                                                    (Transit Operations                                                                                                               
                                                    Division; Planning &                                                                                                              
                                                    Development Service                                                                                                               
                                                    Planning Section                                                                                                                  
                                                    OP-x90045)                                                                                                                        

                    11-Nov-91        CTA            CTA Operations Planning                                                                                                            
                                                    Division \[Bus and Rail                                                                                                           
                                                    \[OP-x91088\] Recommended                                                                                                         
                                                    1992 Service Reduction                                                                                                            
                                                    Package\]                                                                                                                         

                    25-Nov-91        CTA            (Revised) CTA Operations                                                                                                          
                                                    Planning Division \[Bus                                                                                                           
                                                    and Rail \[OP-x91095\]                                                                                                            
                                                    Criteria for Recommended                                                                                                          
                                                    1992 Service Reduction                                                                                                            
                                                    Package\]                                                                                                                         

                    **1-May-92**     **CTA**        **CTA 1989-91 Service                                                                                         ** **     ** **     ** **
                                                    Delivery in Compliance                                                                                                            
                                                    with Title VI of the 1964                                                                                                         
                                                    Civil Rights Act**                                                                                                                

                    1-Nov-92         CTA            Recommended Service for                                                                                                            
                                                    the New Midway Rapid                                                                                                              
                                                    Transit Line and                                                                                                                  
                                                    Associated Bus Service                                                                                                            
                                                    Changes                                                                                                                           

                    28-Feb-94        CTA            CTA Service Delivery                                                                                                               
                                                    Planning \[Orange Line                                                                                                            
                                                    Feeder Bus Service                                                                                                                
                                                    \[PSP-x94013\] Proposed                                                                                                           
                                                    Service Adjustments\]                                                                                                             

                    30-Mar-94        CTA            CTA Service Delivery                                                                                                               
                                                    Planning \[Bus Service                                                                                                            
                                                    Related to Orange Line                                                                                                            
                                                    \[PSP-x94019\]                                                                                                                    
                                                    Elimination of Express                                                                                                            
                                                    Routes\]                                                                                                                          

                    29-Apr-94        CTA            CTA Planning Service                                                                                                               
                                                    Planning \[Bus Service                                                                                                            
                                                    related to Orange Line                                                                                                            
                                                    \[PSP-x94033\] Proposed                                                                                                           
                                                    Service Adjustments\]                                                                                                             

                    29-Apr-94        CTA            CTA Planning Service                                                                                                               
                                                    Planning \[Green Line                                                                                                             
                                                    Reconstruction                                                                                                                    
                                                    \[PSP-x94032\]                                                                                                                    
                                                    Recommended Station                                                                                                               
                                                    Placement\]                                                                                                                       

                    27-May-94        CTA            CTA Service Delivery                                                                                                               
                                                    Planning \[All Night                                                                                                              
                                                    (Owl)                                                                                                                             
                                                    Service\[PSP-x94036\]\]                                                                                                           

                    25-Oct-94        CTA            CTA Service Delivery                                                                                                               
                                                    Planning \[Brown Line                                                                                                             
                                                    \[PSPx-94055\] RTO                                                                                                                
                                                    Operation\]                                                                                                                       

                    1-Dec-94         CTA            CTA Environmental                                                                                                                  
                                                    Assessment \[Construct                                                                                                            
                                                    Central Warehouse \"Goose                                                                                                         
                                                    Park\"\]                                                                                                                          

                    31-Dec-94        CTA            CTA Service Delivery                                                                                                               
                                                    Planning \[Rail System                                                                                                            
                                                    \[Skip Stop Service                                                                                                               
                                                    Elimination\]                                                                                                                     
                                                    PSPx-94058\]                                                                                                                      

                    **1-May-95**     **CTA**        **CTA 1992-94 Service                                                                                         ** **     ** **     ** **
                                                    Delivery in Compliance                                                                                                            
                                                    with Title VI of the 1964                                                                                                         
                                                    Civil Rights Act**                                                                                                                

  ** **             **29-Jun-95**    **CTA**        **Title VI Program                                                                                                                
                                                    Guidelines for FTA                                                                                                                
                                                    Recipients (CTA 1992-1994                                                                                                         
                                                    Service Delivery in                                                                                                               
                                                    Compliance with Title VI                                                                                                          
                                                    of the 1964 Civil Rights                                                                                                          
                                                    Act)**                                                                                                                            

  ** **             23-Feb-96        CTA            CTA Service Planning                                                                                                               
                                                    \[Bus and Rail System                                                                                                             
                                                    \[PSP-x96011\] Green Line                                                                                                         
                                                    Reopening\]                                                                                                                       

                    15-Jul-96        CTA            Memo to David Mosena,                                                                                                              
                                                    President CTA re: 1997                                                                                                            
                                                    Service Economies - A                                                                                                             
                                                    Look Back to the 1992                                                                                                             
                                                    Program                                                                                                                           

                    5-Nov-96         BAH            CTA Bus Routes: Summary                                                                                                            
                                                    Analysis \--Owl & Night                                                                                                           
                                                    Routes                                                                                                                            

  30-Apr-02         1-Jan-97         CTA            Weekday Service Increases                                                                                                          
                                                    between January 1997 and                                                                                                          
                                                    April 1998                                                                                                                        

                    9-Jan-97         BAH            Alternative Service                                                                                                                
                                                    Analysis: Re-inventing                                                                                                            
                                                    CTA\'s Transportation                                                                                                             
                                                    Services (DRAFT Report)                                                                                                           

  ** **             **1-May-97**     **BAH**        **CTA Service                                                                               ** **   ** **     ** **     ** **     ** **
                                                    restructuring Proposal by                                                                                                         
                                                    Booz-Allen and Hamilton,                                                                                                          
                                                    Inc**                                                                                                                             

                    16-May-97        CTA            CTA Letter from Valerie                                                                                                            
                                                    B. Jarrett, Chairman-CTA                                                                                                          
                                                    to Hipolito (Paul Roldan,                                                                                                         
                                                    President Hispanic                                                                                                                
                                                    Housing Development Corp.                                                                                                         

  ** **             **21-May-97**    **CTA**        **Transcription of CTA                                                                                                  ** **     ** **
                                                    Public Hearing on                                                                                                                 
                                                    Proposed Service                                                                                                                  
                                                    Realignments by Halsell &                                                                                                         
                                                    Halsell Court Reporters**                                                                                                         

  **30-Apr-02**     **2-Jun-97**     **BAH**        **CTA Proposed Bus                                                                                            ** **     ** **     ** **
                                                    Service Changes (Minority                                                                                                         
                                                    vs. Non-Minority Bus                                                                                                              
                                                    Routes) by Booz-Allen &                                                                                                           
                                                    Hamilton**                                                                                                                        

  ** **             **2-Jun-97**     **BAH**        **CTA Proposed Rail                                                                                           ** **     ** **     ** **
                                                    Service Changes (Minority                                                                                                         
                                                    vs. Non-Minority Rail                                                                                                             
                                                    Routes) by Booz-Allen &                                                                                                           
                                                    Hamilton**                                                                                                                        

                    1-Jul-97         CTA            Evaluation of CTA Service                                                                                                          
                                                    Restructuring Package                                                                                                             
                                                    (Bus Service by Hour                                                                                                              
                                                    (Saturdays)) by CTA Bus                                                                                                           
                                                    and Rail Service Planning                                                                                                         

                    1-Jul-97         CTA            Evaluation of CTA Service                                                                                                         
                                                    Restructuring Package                                                                                                             
                                                    (Bus Service by Hour                                                                                                              
                                                    (Sunday/Holidays)) by CTA                                                                                                         
                                                    Bus and Rail Service                                                                                                              
                                                    Planning                                                                                                                          

  **CTA Title VI                                                                                                                                                                      
  Chronology of                                                                                                                                                                       
  Data Received and                                                                                                                                                                   
  Reviewed by the                                                                                                                                                                     
  DMP Group In                                                                                                                                                                        
  Completing this                                                                                                                                                                     
  Report**                                                                                                                                                                            

  ***Received***    ***Dated***      ***Agency***                             ***Title***                                                                                              

                    1-Jul-97         CTA                                      Evaluation of CTA                                                                                        
                                                                              Service Restructuring                                                                                   
                                                                              Package (Bus Service by                                                                                 
                                                                              Hour (Weekdays)) by CTA                                                                                 
                                                                              Bus and Rail Service                                                                                    
                                                                              Planning                                                                                                

                    9-Jul-97         CTA                                      Journal of the                                                                                           
                                                                              Proceedings of Chicago                                                                                  
                                                                              Transit Board \[Regular                                                                                 
                                                                              Meeting\]                                                                                               

  ** **             **9-Jul-97**     **CTA**                                  **Ordinance No. 97088                                                     ** **     ** **     ** **     ** **
                                                                              (An Ordinance                                                                                           
                                                                              Authorizing                                                                                             
                                                                              Implementation of                                                                                       
                                                                              Service Changes)**                                                                                      

  ** **             **22-Jul-97**    **CTA**                                  **Memo to Staff                                                                                         ** **
                                                                              participating in                                                                                        
                                                                              Service Restructuring                                                                                   
                                                                              Proposal - June 30,                                                                                     
                                                                              1997 - Public Hearing                                                                                   
                                                                              J.R. Thompson Center**                                                                                  

                    1-Dec-97         NWRG                                     CTA Customer                                                                                             
                                                                              Satisfaction Survey by                                                                                  
                                                                              Northwest Research                                                                                      
                                                                              Group, Inc.                                                                                             

  ***30-Apr-02***   ***1-May-98***   ***CTA***                                ***CTA 1995-1997                                                          *** ***   *** ***   *** ***   *** ***
                                                                              Service Delivery In                                                                                     
                                                                              Compliance with Title                                                                                   
                                                                              VI of the 1964 Civil                                                                                    
                                                                              Rights Act***                                                                                           

                    22-May-98        FTA                                      Briefing Paper from                                                                                      
                                                                              Joel P. Ettinger -                                                                                      
                                                                              TRO-5                                                                                                   

                    19-Jun-98        CTA                                      Transit Service                                                                                          
                                                                              Improvement Strategy                                                                                    
                                                                              \[Key Bus Routes\]                                                                                      
                                                                              (DRAFT Report)                                                                                          

  ** **             **1-Aug-98**     **CATS**                                 **Destination 2020                                                                            ** **     ** **
                                                                              Regional Transportation                                                                                 
                                                                              Plan prepared by                                                                                        
                                                                              Chicago Area                                                                                            
                                                                              Transportation Study                                                                                    
                                                                              (CATS/MPO)**                                                                                            

                    14-Sep-98        NCBG                                     Neighborhood Capital                                                                                     
                                                                              Budget Group (NCBG) CTA                                                                                 
                                                                              Service Cuts: Summary                                                                                   

                    8-Oct-98         DLC                                      Complaint Letter from                                                                                   
                                                                              Joe Ann Bradley,                                                                                        
                                                                              Community Action Group                                                                                  
                                                                              (Lawndale), Juan Soto,                                                                                  
                                                                              Pilsen Neighbors                                                                                        
                                                                              Council, Alberto                                                                                        
                                                                              Sanchez, ESBA, Dr.                                                                                      
                                                                              Joyce Bowen, North                                                                                      
                                                                              Lawndale Family                                                                                         
                                                                              Network, Frank Aguliar,                                                                                 
                                                                              Little Village Chamber                                                                                  
                                                                              of Commerce                                                                                             

                    1-Nov-98         CTA                                      Board Adopted Changes -                                                                                  
                                                                              Bus - Since 11/1/98                                                                                     

                    8-Dec-98         FTA                                      FTA Letter from Akira                                                                                   
                                                                              Sano, Team Leader OCR,                                                                                  
                                                                              to the Douglas L.                                                                                       
                                                                              Coalition c/o Alberto                                                                                   
                                                                              Sanchez, ESBA, Dr.                                                                                      
                                                                              Joyce Brown, NLFN, Joe                                                                                  
                                                                              Ann Bradley, LCAG, Juan                                                                                 
                                                                              Soto, PNC, Re: ***Title                                                                                 
                                                                              VI Complaint 98-235***                                                                                  

                    15-Dec-98        FTA                                      FTA Letter from Akira                                                                                    
                                                                              Sano, Team Leader OCR,                                                                                  
                                                                              to Ms. Esmeralda Ruiz                                                                                   
                                                                              Re: ***Title VI                                                                                         
                                                                              Complaint 98-235***                                                                                     

                    21-Dec-98        FTA                                      FTA Letter from Akira                                                                                    
                                                                              Sano, Team Leader OCR.                                                                                  
                                                                              To Mr. Frank Kruesi,                                                                                    
                                                                              President CTA Re:                                                                                       
                                                                              ***Title VI Complaints                                                                                  
                                                                              98-235 and 98-248***                                                                                    

                    27-Apr-99        FTA                                      FTA Letter from Arthur                                                                                   
                                                                              Andrew Lopez, Director                                                                                  
                                                                              of OCR to Mr. Frank                                                                                     
                                                                              Kruesi, President CTA                                                                                   
                                                                              Re: Title VI Compliance                                                                                 
                                                                              Review                                                                                                  

                    1-Jun-99         NCBG                                     \"Is There Equal Access                                                                                 
                                                                              for All to Public                                                                                       
                                                                              Transportation in                                                                                       
                                                                              Metropolitan Chicago?                                                                                   
                                                                              \"A Discussion Paper                                                                                    
                                                                              Prepared for The Human                                                                                  
                                                                              Relations Foundation of                                                                                 
                                                                              Chicago by NCBG June                                                                                    
                                                                              1999                                                                                                    

                    22-Jun-99        CTA                                      Bus System Title VI                                                                                      
                                                                              Monitoring Report                                                                                       
                                                                              Winter 1998-1999                                                                                        

  30-Apr-02         21-Jun-99        CTA                                      Summary of Service                                                                                       
                                                                              Improvements between                                                                                    
                                                                              May 1998 and March 1999                                                                                 

                    21-Jun-99        CTA                                      Minority/Non-Minority                                                                                    
                                                                              Representativeness of                                                                                   
                                                                              1997 CTA Customer                                                                                       
                                                                              Satisfaction Survey                                                                                     

                    21-Jun-99        CTA                                      CTA Title VI Analysis                                                                                    
                                                                              TAZ Sample Origins 1990                                                                                 
                                                                              Census (MAP) \# 000008                                                                                  

                    22-Jun-99                                                 Service Restructuring                                                                                   
                                                                              1997 and 1998 (Rail                                                                                     
                                                                              Fleet Assignment, April                                                                                 
                                                                              1999 Bus Ridership by                                                                                   
                                                                              Route, Rail Ridership                                                                                   
                                                                              by Branch and Line                                                                                      
                                                                              12/98)                                                                                                  

                    25-Jun-99        CTA                                      Letter from Frank                                                                                        
                                                                              Kruesi, President CTA                                                                                   
                                                                              to Arthur Andrew Lopez,                                                                                 
                                                                              Director OCR on Title                                                                                   
                                                                              VI Compliance Review                                                                                    

  ** **             **28-Jul-99**    **CC**                                   **Report on the                                                   ** **   ** **     ** **     ** **     ** **
                                                                              \"Current Status of CTA                                                                                 
                                                                              Compliance Review by                                                                                    
                                                                              Compucon Inc.**                                                                                         

  30-Apr-02         1-Dec-99         NWRG                                     CTA Customer                                                                                             
                                                                              Satisfaction Survey by                                                                                  
                                                                              Northwest Research                                                                                      
                                                                              Group, Inc. (Technical                                                                                  
                                                                              Report MR00-01)                                                                                         

  ** **             **8-Jun-00**     **CC**                                   **An Analysis of Racial                                                                                 
                                                                              and Ethnic Disparities                                                                                  
                                                                              in Public Bus and Rail                                                                                  
                                                                              Transportation Chicago                                                                                  
                                                                              Transit Authority by                                                                                    
                                                                              CompuCon, Inc.**                                                                                        

  **CTA Title VI                                                                                                                                                                      
  Chronology of                                                                                                                                                                       
  Data Received and                                                                                                                                                                   
  Reviewed by the                                                                                                                                                                     
  DMP Group In                                                                                                                                                                        
  Completing this                                                                                                                                                                     
  Report**                                                                                                                                                                            

  ***Received***    ***Dated***      ***Agency***                             ***Title***                                                                                             

                    8-Sep-00         CTA                                      CTA Letter from Frank                                                                                   
                                                                              Kruesi to Arthur Andrew                                                                                 
                                                                              Lopez Re: ***Title VI                                                                                   
                                                                              Complaint No. 98-235***                                                                                 

  ** **             **1-Jul-01**     **CTA**                                  **CTA 1998-2000 Title                     ** **   ** **   ** **   ** **   ** **     ** **     ** **     ** **
                                                                              VI Program Update**                                                                                     

                    1-Jul-01         CTA                                      CTA Service Standards                                                                                    
                                                                              (Transit Operations                                                                                     
                                                                              Division; Planning &                                                                                    
                                                                              Development Service                                                                                     
                                                                              Planning PSP-x01005                                                                                     

                    23-Aug-01        FTA                                      FTA Letter to Ms. Joe                                                                                    
                                                                              Ann Bradley Re: Title                                                                                   
                                                                              ***VI Complaint Case                                                                                    
                                                                              #98-235***                                                                                              

                    10-Sep-01        CFBT                                     Complaint Letter from                                                                                    
                                                                              Robert McNeil, Research                                                                                 
                                                                              Director, Campaign for                                                                                  
                                                                              Better Transit                                                                                          

                    1-Oct-01         CFBT                                     Complaint Letter from                                                                                    
                                                                              Sara Duda, Research and                                                                                 
                                                                              Outreach Coordinator,                                                                                   
                                                                              Campaign for Better                                                                                     
                                                                              Transit                                                                                                 

                    2-Oct-01         ESBA                                     Complaint Letter from                                                                                    
                                                                              Oscar R. Iracheta,                                                                                      
                                                                              President, Eighteenth                                                                                   
                                                                              Street Business                                                                                         
                                                                              Association                                                                                             

                    4-Oct-01         CC                                       Complaint Letter from                                                                                    
                                                                              Dorothy Gibbs, Women\'s                                                                                 
                                                                              Support                                                                                                 
                                                                              Group-Coordinator,                                                                                      
                                                                              Chicago Common                                                                                          

                    8-Oct-01         BNL                                      Complaint Letter from                                                                                    
                                                                              Anna M. Ware, Training                                                                                  
                                                                              Manager, Bethel New                                                                                     
                                                                              Life, Inc.                                                                                              

  ** **             **1-Nov-01**     **MS**                                   **Flexible Service                                                        ** **     ** **     ** **     ** **
                                                                              Design in Four                                                                                          
                                                                              Demonstration Areas                                                                                     
                                                                              (Final Report) by                                                                                       
                                                                              MultiSystems**                                                                                          

                                     CTA                                      Title VI Program Update                                                                                  
                                                                              (Bates Number 29-39)                                                                                    

                                     CTA                                      Title VI Program Update                                                                                  
                                                                              (Bates Number 7-10)                                                                                     

                                                                              Service Restructuring                                                                                    
                                                                              1997 and 1998 (Bates                                                                                    
                                                                              Numbers 50-59)                                                                                          

                                                                              Service Restructuring                                                                                    
                                                                              1997 and 1998 (Bates                                                                                    
                                                                              Numbers 61)                                                                                             

                                                                              Service Restructuring                                                                                    
                                                                              1997 and 1998 (Bates                                                                                    
                                                                              Numbers 62-63)                                                                                          

                                                                                                                                                                                       
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