**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**ALAMEDA-CONTRA COSTA TRANSIT DISTRICT**

**(AC TRANSIT)**

**Oakland, California**

**Final Report**

**November 2004**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**THE DMP GROUP, INC.**

**Subcontractor to**

**MILLIGAN & CO., LLC**

[Table of Contents]{.underline}

I. GENERAL INFORMATION [1](#__RefHeading___Toc485799033)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc485799034)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc485799035)

IV\. BACKGROUND INFORMATION [5](#__RefHeading___Toc485799036)

V. SCOPE AND METHODOLOGY [10](#__RefHeading___Toc485799037)

VI\. FINDINGS AND RECOMMENDATIONS [17](#refheading___toc485799038)

1\. List of Active Complaints and Lawsuits
[17](#__RefHeading___Toc485799039)

2\. Pending Applications for Financial Assistance
[18](#__RefHeading___Toc485799040)

3\. Summary of Civil Rights Compliance Reviews
[18](#__RefHeading___Toc485799041)

4\. FTA Civil Rights Assurance [19](#__RefHeading___Toc485799042)

5\. DOT Title VI Assurance [20](#__RefHeading___Toc485799043)

6\. Fixed-Facility (Environmental Justice) Impact Analysis
[20](#__RefHeading___Toc485799044)

7\. Demographic and Service Profile Maps, Overlays and Charts
[21](#__RefHeading___Toc485799045)

8\. Service Standards and Policies [22](#__RefHeading___Toc485799046)

9\. Assessment of Compliance by Grantees
[24](#__RefHeading___Toc485799047)

10\. Other Areas of Title VI Considerations
[26](#__RefHeading___Toc485799048)

11\. Internal Monitoring Procedures [29](#__RefHeading___Toc485799049)

12\. Title VI Complaints [30](#__RefHeading___Toc485799050)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[32](#__RefHeading___Toc485799051)

VIII\. ATTENDEES [34](#__RefHeading___Toc485799052)

I.  []{#__RefHeading___Toc485799033 .anchor}GENERAL INFORMATION

Grant Recipient: Alameda-Contra Costa Transit District

1600 Franklin Street

Oakland, California 94612

City/State: Oakland, California

Grantee No: 1632

Executive Official: Mr. Richard C. Fernandez

General Manager

Alameda-Contra Costa Transit District

1600 Franklin Street

Oakland, California 94612

Report Prepared By: MILLIGAN & CO., LLC

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

Mulberry Atrium North

Philadelphia, PA 19103

THE DMP GROUP, INC.

2423 Killdeer Street

New Orleans, LA 70122

Site Visit Dates: May 6, 2003 -- May 8, 2003

Compliance Review

Team Members: John Potts Royal Spurlark

Lead Reviewer Reviewer

The DMP Group, Inc. The DMP Group, Inc

II. []{#__RefHeading___Toc485799034 .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 Alameda-Contra Costa Transit District (AC Transit) is a recipient of
FTA funding assistance and is therefore subject to the Title VI
compliance conditions associated with the use of these funds pursuant to
FTA Circular 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 AC Transit's Title VI Program and were the basis for the
selection of compliance elements that were reviewed in this document.

[]{#__RefHeading___Toc485799035 .anchor}PURPOSE AND OBJECTIVES

**Purpose**

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

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

#### Objectives

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

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

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

```{=html}
<!-- -->
```
-   To ensure that opportunities to participate in the transit planning
    and decision-making process are provided to persons without regard
    to race, color, or national origin;

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

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

III. []{#__RefHeading___Toc485799036 .anchor}BACKGROUND INFORMATION

**Alameda-Contra Costa Transit District (AC Transit)**

The citizens of Alameda and Contra Costa Counties voted to establish the
Alameda-Contra Costa Transit District (AC Transit) in November of 1956
to acquire and replace the bankrupted Key System, a private company that
had been regulated by the California Public Utilities Commission. AC
Transit is a publicly owned fixed route public transit system serving
communities in the East Bay. By 1974, AC Transit's service area
stretched from the western Contra Costa County cities of San Pablo and
Richmond to the southern cities of Fremont and Newark. Today, AC Transit
serves thirteen cities in Alameda and Contra Costa Counties, including
Alameda, Albany, Berkeley, El Cerrito, Emeryville, Fremont, Hayward,
Newark, Oakland, Piedmont, Richmond, San Leandro, and San Pablo. AC
Transit also provides service to nine unincorporated areas, including
Ashland, Castro Valley, Cherryland, El Sobrante, Fairview, Kensington,
Irvington, North Richmond, and San Lorenzo.

An elected seven member Board of Directors that represents the member
jurisdictions aligned into five wards governs AC Transit. One board
member is elected from each ward and two additional members are elected
"at large" from the service area. The General Manager, General Counsel,
and District Secretary report to the Board. Staff reporting to the
General Manager includes the Deputy General Manager, Chief Operating
Officer, Deputy General Manager of Service Development, and Chief
Financial Officer.

AC Transit's Board of Directors and staff appear to be committed to the
principals and goals of Title VI. In November of 2000, AC Transit hosted
a forum on Environmental Justice in transportation for the San Francisco
Bay Area, the first such conference in the Region. On December 13, 2001,
the Board adopted Resolution No. 2033 affirming the commitment of the
Alameda-Contra Costa Transit District to social and environmental
justice and to involvement of the people of Alameda and Contra Costa
Counties in making decisions pertaining to transit policy, service
design and operations. Further, a review of AC Transit documents such as
its *FY 2001 -- 2010 Short Range Transit Plan* (SRTP), dated March 2002,
showed frequent references to Title VI and Environmental Justice
requirements as important considerations in the development of service
plans, vehicle assignments and other service delivery elements.

AC Transit directly operates fixed route bus service within its service
area. Paratransit service in the East Bay is provided through a
consortium program developed by BART and AC Transit. AC Transit is one
of the operators of the system and MV Transportation, a private company,
is the other. AC Transit operates from four bus divisions; Richmond
(Division 3-fixed route), Emeryville (Division 2-fixed route), East
Oakland (Division 4-fixed route and paratransit) and Hayward (Division
6-fixed route) with a fleet of 767 vehicles that include:

-   1984 40-foot Gillig buses (97)

-   1989/1996 60-foot New Flyer articulated buses (60)

-   1988 35-foot New Flyer buses (29)

-   1988 40-foot New Flyer buses (79)

-   1990/1992 40-foot Gillig buses (109)

-   1991 30-foot Gillig buses (61)

-   1997/1998 40-foot NABI buses (203)

-   2000 40-foot NABI low floor buses (44)

-   2000 45-foot MCI coaches (52)

-   2003 40-foot Van Hool low floor buses (1)

-   2003 60-foot Van Hool low floor articulated bus (1)

-   1996 28-foot El Dorado paratransit vehicles (31)

At the time of the site visit, AC Transit was expecting the arrival of
additional 40-foot low floor buses and 60-foot low floor articulated
buses from Van Hool.

In early 2004, the AC Transit Board announced that it was considering
service cuts for the third time in two years to reduce a \$17 million
budget deficit that is the result of recent economic conditions. AC
Transit is attempting to sell the new Van Hool buses to another transit
operator to recover the costs.

AC Transit's central dispatch is located at the Emeryville Division,
while Central Maintenance & Stores (CMF) is located at a separate
facility in East Oakland. AC Transit maintains the Transbay Transit
Terminal in downtown San Francisco. In March 2001, the Eastmont
TownCenter Transit Center was completed. This facility, located next to
a police station, is a major transfer station that makes it easier and
safer for passengers to transfer and provides off-street parking for
layovers. The system's administrative offices are located in downtown
Oakland at 1600 Franklin Street.

AC Transit reported the following statistics in its 2001 submission to
the National Transportation Database (NTD). AC Transit traveled over 218
million passenger miles providing over 70 million unlinked trips. AC
Transit reported an operating budget of approximately \$197 million, and
operating revenues to cover expenses of 23 percent from the fare box,
three percent in state funding, 70 percent in local funds, and four
percent from miscellaneous revenue sources. AC Transit also reported
over \$31 million in capital requirements in 2001, which represented 75
percent federal assistance and 25 percent local match.

AC Transit's typical fare for a one-way trip is \$1.50. Half fare
(\$0.75) is available to the elderly and persons with disabilities
during all service hours. AC Transit service coordinates with the
region's rail system, the San Francisco Bay Area Rapid Transit (BART),
and provides multi-modal transfers at numerous BART stations.

AC Transit reported that no Title VI complaints were filed against it in
the past three years. The AC Transit Title VI Program Update submittal
was due to FTA in 2003. In order to take the necessary corrective
actions and to benefit from the technical assistance of this Title VI
Compliance Review, AC Transit requested a 90-day extension to submit the
Program Update. The FTA Region IX Civil Rights Officer concurred in the
extension.

According to the 2000 Census, the population for the nine-county San
Francisco Bay Area is 6.783 million persons. The AC Transit service area
includes 13 cities in Alameda and Contra Costa counties and nine
unincorporated areas in the Bay region. According to AC Transit's NTD
report, the population of the service area is 1.4 million persons, 21
percent of the total region.

The following table shows the racial/ethic breakdown of the San
Francisco Bay Area and the city of Oakland, and counties of Alameda and
Contra Costa.

[]{.mark}

**Racial/ Ethnic Breakdown of San Francisco Bay Area and**

**The AC Transit Service Area**

######### 2000 Census

+-------------------------------+------------------+------------------+
| **Racial/ Ethnic Group**      | ##               | #### AC Tran     |
|                               | ## San Francisco | sit Service Area |
|                               |  Bay Area Total/ |                  |
|                               |                  | #### Total/      |
|                               | #                |                  |
|                               | ### Percent[^1]  | #### Percent[^2] |
+-------------------------------+------------------+------------------+
| #### White                    | #### 3,941,700   | #### 607,600     |
|                               |                  |                  |
|                               | 58%              | 44%              |
+-------------------------------+------------------+------------------+
| #### Black                    | #### 511,100     | #### 255,000     |
|                               |                  |                  |
|                               | 8%               | 18%              |
+-------------------------------+------------------+------------------+
| #### Amer                     | **43,500**       | #### 9,200       |
| ican Indian and Alaska Native |                  |                  |
|                               | 1%               | 1%               |
+-------------------------------+------------------+------------------+
| #### Asian, Native            | **1,326,200**    | **288,000**      |
|  Hawaiian or Pacific Islander |                  |                  |
|                               | 20%              | 21%              |
+-------------------------------+------------------+------------------+
| #### Some Other Race          | **627,000** 9%   | **138,600**      |
|                               |                  |                  |
|                               |                  | 10%              |
+-------------------------------+------------------+------------------+
| #### Two or More Races        | #### 334,300     | #### 79,300      |
|                               |                  |                  |
|                               | 5%               | 6%               |
+-------------------------------+------------------+------------------+
| #### Hispanic Origin\*        | #### 1,315,200   | #### 284,000     |
|                               |                  |                  |
| Includes Hispanics of some    | 19%              | 21%              |
| other race or two or more     |                  |                  |
| races                         |                  |                  |
+-------------------------------+------------------+------------------+
| #### Total Population         | #### 6,783,800   | **1,381,100**    |
+-------------------------------+------------------+------------------+

As shown above, minorities represent 56% of the AC Transit service area
as compared to 42% of the entire region.

IV. []{#__RefHeading___Toc485799037 .anchor}SCOPE AND METHODOLOGY

#### Scope

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

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

```{=html}
<!-- -->
```
a.  A list of active Title VI lawsuits or complaints;

b.  A description of pending applications for financial assistance;

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

d.  A signed FTA Civil Rights Assurance;

e.  A signed standard DOT Title VI Assurance; and

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

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

```{=html}
<!-- -->
```
a.  demographic and service profile maps, overlays and charts;

b.  service standards and policies;

c.  assessment of compliance by grantees;

d.  Other areas of Title VI considerations.

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

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

#### Methodology

An initial interview was conducted in the Region IX Civil Rights Officer
to discuss specific Title VI issues and concerns regarding AC Transit.
Documents regarding Title VI issues previously submitted to FTA were
examined. Following the desk review, a detailed letter was sent to AC
Transit advising it of the site visit and indicating additional
information that would be needed and issues that would be discussed.

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

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

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

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

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

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

-   A list of any active lawsuits and complaints

```{=html}
<!-- -->
```
-   Pending grant applications from other (not FTA) Federal agencies

```{=html}
<!-- -->
```
-   Other civil rights compliance reviews during the last three years

```{=html}
<!-- -->
```
-   Fixed facility analysis and, if needed, a program or other measures
    to mitigate any identified adverse impact on the minority community

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

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

```{=html}
<!-- -->
```
-   Map overlays which show areas with significant minority population
    using 2000 census tract data or TAZ, and which show transit services
    (e.g., bus routes, transit centers, garages, etc.)

```{=html}
<!-- -->
```
-   A population/racial distribution chart which shows the number and
    percentage of each minority group population in each 2000 census
    tract or TAZ

```{=html}
<!-- -->
```
-   Service Standards adopted by AC Transit for use in measuring the
    level of service provided to minority and non-minority communities.
    This should include standards for vehicle load, vehicle assignment,
    vehicle headway, distribution of transit amenities, and transit
    access

```{=html}
<!-- -->
```
-   Information collected by AC Transit for each bus route to monitor
    service for compliance with established service standards, e.g.,
    vehicle load factor analyses, vehicle assignment sheets, vehicle
    headways, amenities, such those provided at rail stations and bus
    stops, etc.

```{=html}
<!-- -->
```
-   Results of any analysis performed to compare the level and quality
    of services in minority and non-minority areas

```{=html}
<!-- -->
```
-   Ridership by route

```{=html}
<!-- -->
```
-   Passenger boarding's by bus stop

-   Maximum load points by route

```{=html}
<!-- -->
```
-   Fleet inventory for buses, by garage that indicates vehicle type,
    vehicle number, age and key amenities, e.g., air conditioning,
    wheelchair lifts/ramps, soft seating, etc.

```{=html}
<!-- -->
```
-   Inventory of bus stop shelters and benches which indicates their
    location and any amenities such as benches, lights and telephones

```{=html}
<!-- -->
```
-   Listing of service changes in the past three years, including
    increases/decreases in headways, additions / deletions / extensions
    / contractions of routes.

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

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

```{=html}
<!-- -->
```
-   Description of the methods used to inform minority communities of
    planned service changes

```{=html}
<!-- -->
```
-   A racial breakdown of all non-elected boards, advisory councils, and
    committees and a description of efforts to encourage minorities to
    participate on these boards, councils and committees

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

```{=html}
<!-- -->
```
-   Description of AC Transit's internal monitoring procedure to insure
    that its level and quality of service is in compliance with Title
    VI, along with copies of AC Transit's "level of service" and
    "quality of service" evaluations, including recommendations for
    addressing disparities, if any are identified

```{=html}
<!-- -->
```
-   Description of the existing Title VI or service complaint process
    and copies of materials that are made available to the public which
    describe the process for filing complaints.

The site visit to AC Transit occurred May 6 to May 8, 2003. The
individuals participating in the review are listed in Section VIII of
this report. At the entrance conference, the purpose of the Title VI
Compliance Review and the review process were discussed. A detailed
schedule for conducting the on-site visit was discussed. After the
entrance conference, the site visit focused on the status of the
information requested in the letter notifying AC Transit of the
Compliance Review. Arrangements were also made for a tour of AC
Transit's facilities and bus routes, observation of vehicle assignments
to routes, review of actual headways and ridership on sample majority
and minority routes and interviews with AC Transit's staff.

Five AC Transit facilities were toured, including the Eastmont
TownCenter Transit Center, the Central Maintenance Facility, and the
Richmond, Emeryville, and East Oakland bus garages. Several bus routes
were toured, including Routes 72/72L, 73, 82/82L, and 40/40L, 43. On the
third day of the site visit, the review team examined the assignment and
condition of vehicles from the East Oakland bus garage. []{.mark}

Interviews were conducted with AC Transit staff to provide information
on the extent to which Title VI AC Transit incorporates requirements in
the planning and implementation of service. The interviews also focused
on staff efforts to make communications and information available in
non-English formats for minority groups, as required.

V.  []{#refheading___toc485799038 .anchor}FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on AC Transit\'s compliance with
both the General Reporting Requirements and the Program-Specific
Requirements. This section describes the requirements and findings at
the time of the Compliance Review site visit. In summary, deficiencies
were identified in five of the twelve areas examined. It does appear
that AC Transit actively considers Title VI issues in most of its
transit planning and operations activities, however, AC Transit does not
collect data, monitor service or conduct assessments in accordance with
FTA requirements.

#### 

#### Findings of the General Reporting Requirements

1.  []{#__RefHeading___Toc485799039 .anchor}List of Active Complaints
    and Lawsuits

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for List of Active
Complaints and Lawsuits. At the time of the site visit, AC Transit
indicated that there were no Title VI complaints and lawsuits filed
against AC Transit. In its most recent Title VI submittal, made in 2000,
AC Transit reported on its active complaints and lawsuits (all EEO
related). AC Transit was advised to report on active Title VI complaints
and lawsuits in future submittals.

2.  []{#__RefHeading___Toc485799040 .anchor}Pending Applications for
    Financial Assistance

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for Pending Applications
for Financial Assistance. In information provided at the site visit, AC
Transit did report on its pending applications for financial assistance
by other Federal agencies, in conformance with FTA Circular 4702.1. AC
Transit does not have any pending applications for Federal funds from
any agency other than FTA. In its most recent Title VI submittal, made
in 2000, AC Transit reported on its FTA-funded grants. AC Transit was
advised to report on all pending applications for financial assistance,
and all financial assistance currently provided by other Federal
agencies in future submittals.

3.  []{#__RefHeading___Toc485799041 .anchor}Summary of Civil Rights
    Compliance Reviews

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for Summary of Civil
Rights Compliance Reviews. In the past three years, FTA has not
conducted any other Civil Rights compliance review of AC Transit. The
most recent FTA Triennial Review conducted in February 2002 examined
Civil Rights requirements and identified a deficiency with the FTA
requirements for Title VI because AC Transit could not document that it
had conducted periodic Title VI compliance assessments in accordance
with FTA Circular 4702.1. In its most recent Title VI submittal, made in
2000, AC Transit reported on the FTA approval of its Equal Employment
Opportunity (EEO) Program. AC Transit was advised to report on civil
rights compliance review activities conducted in the last three years in
future submittals.

4.  []{#__RefHeading___Toc485799042 .anchor}FTA Civil Rights Assurance

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for FTA Civil Rights
Assurance. The FTA Civil Rights Assurance is incorporated in the Annual
Certifications and Assurances submitted annually to FTA through the
Transportation Electronic Award and Management (TEAM) system.

5.  []{#__RefHeading___Toc485799043 .anchor}DOT Title VI Assurance

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for DOT Title VI
Assurance. At the site visit and in its most recent Title VI submittal,
made in 2000, AC Transit reported that it had properly executed its
"one-time" DOT Title VI Assurance in 1993.

6.  []{#__RefHeading___Toc485799044 .anchor}Fixed-Facility
    (Environmental Justice) Impact Analysis

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for Fixed-Facility/
Environmental Justice Impact Analysis. At the site visit, AC Transit
provided documentation that it had conducted a
fixed-facility/environmental justice impact analysis for its most recent
construction project, the Eastmont Town Center Mall Transit Center. In
its most recent Title VI submittal, made in 2000, AC Transit did not
report on any fixed-facility/environmental justice impact analysis. AC
Transit was advised to report on its fixed-facility/environmental
justice analyses in future submittals.

In 2003, AC Transit began Phase I of its plan to implement Bus Rapid
Transit (BRT) service. Phase I is the introduction of the San Pablo
Rapid Bus service operating on the former 72 line. This service does not
contemplate any major fixed facilities. In Phase II of the BRT service
deployment plan, BRT service will be introduced by combining both the
40/40L and the 82/82L lines. AC Transit has done a
fixed-facility/environmental justice analysis on the Phase II service
and reports that there are no significant fixed-facility/environmental
justice impacts in the BRT implementation.

#### 

#### Findings of the Program Specific Requirements for Transit Providers

7.  []{#__RefHeading___Toc485799045 .anchor}Demographic and Service
    Profile Maps, Overlays and Charts

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

**Findings:** During this Title VI Compliance Review of AC Transit,
deficiencies were found with FTA requirements for Demographic and
Service Profile Maps, Overlays and Charts. During the site visit, AC
Transit demonstrated that it had the data and capabilities to produce
Base Maps and Overlays, as required by the Circular. Staff indicated
that it would submit the maps following the site visit.

**Corrective Actions and Schedules:** Within 90 days, AC Transit must
submit to the FTA Region IX Civil Rights Officer:

-   **Base Maps -** A legible scaled map of the transit service area
    that identifies each census tract by number, major streets and
    highways and fixed transit facilities and identifies the major
    activity centers/transit trip generators.

```{=html}
<!-- -->
```
-   **Overlays --** Additional maps showing minority population
    encompassing the entire service area showing the total minority
    population for each census tract and a transit service map showing
    all bus routes with their origins and destinations.

8.  []{#__RefHeading___Toc485799046 .anchor}Service Standards and
    Policies

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

(1) Vehicle Load or Load Factor

(2) Vehicle Assignment

(3) Distribution of Transit Amenities

(4) Vehicle Headway

(5) Transit Access

**Findings:** During this Title VI Compliance Review of AC Transit,
deficiencies were found with FTA requirements for Service Standards and
Policies. The most recent document containing service standards is AC
Transit's *FY 2001-2010 Short Range Transit Plan* (SRTP) that has
service standards for three of the five required factors. AC Transit
also has Board Policy No. 508 adopted in 1989 and revised in 2002 (Bus
Stop Policy) and Board Policy No. 550 adopted in 1994 (Service
Effectiveness Standards Policy) that contain standards and the
procedures for application of standards. Other documents that address
service standards are the Transit Facilities Standards Manual, dated
March 23, 1983 and the Guide for Including Public Transit in Land Use
Planning dated April 6, 1983. The AC Transit service standards required
for Title VI are summarized in the following table:

+----------------------+-------------------------+---+---------------------+
| **FTA Service        | **AC Transit Policy**   |   | #### Comments       |
| Standard**           |                         |   |                     |
+======================+=========================+===+=====================+
| **Vehicle Load** - A | Policy No. 550 uses a   |   | > Must have a       |
| ratio of the number  | measure of passengers   |   | > quantifiable      |
| of passengers on a   | per revenue hour as a   |   | > standard defining |
| vehicle to the       | determinant of          |   | > vehicle load      |
| number of seats      | effectiveness.          |   | > standards as a    |
|                      |                         |   | > ratio of the      |
|                      |                         |   | > number of         |
|                      |                         |   | > passengers on a   |
|                      |                         |   | > vehicle to the    |
|                      |                         |   | > number of seats.  |
+----------------------+-------------------------+---+---------------------+
| **Vehicle            | The SRTP states that AC |   | Not quantifiable to |
| Assignment** -       | Transit should match    |   | determine equitable |
|                      | the size and type of    |   | distribution        |
| The process by which | bus with anticipated    |   | consistent with     |
| vehicles are         | services in the areas   |   | Title VI; No        |
| assigned to routes   | in which the buses      |   | consideration in    |
| throughout the       | operate.                |   | policy of vehicle   |
| system due to        |                         |   | type, e.g., CNG vs. |
| variations among     |                         |   | Diesel powered      |
| vehicles (age, size, |                         |   | buses or age.       |
| amenities, etc.).    |                         |   |                     |
+----------------------+-------------------------+---+---------------------+
| **Distribution of    | Board Policy No. 508    | > |                     |
| Transit Amenities**  | uses service type and   |   |                     |
| -                    | density to determine    | M |                     |
|                      | bus stop spacing, as    | u |                     |
| Criteria for         | follows, shown by       | s |                     |
| installation of      | density:                | t |                     |
| items of comfort and |                         | > |                     |
| convenience          | -   20,000 and over =   |   |                     |
| available to the     |     300-1,250 feet      | h |                     |
| general public       |     apart               | a |                     |
|                      |                         | v |                     |
|                      | -   20,000-10,000 =     | e |                     |
|                      |     500-1,500 feet      | > |                     |
|                      |     apart               |   |                     |
|                      |                         | s |                     |
|                      | -   Less than 10,000 =  | t |                     |
|                      |     500 -- 2,600 feet   | a |                     |
|                      |     apart               | n |                     |
|                      |                         | d |                     |
|                      | []{.mark}               | a |                     |
|                      |                         | r |                     |
|                      |                         | d |                     |
|                      |                         | s |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | f |                     |
|                      |                         | o |                     |
|                      |                         | r |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | s |                     |
|                      |                         | h |                     |
|                      |                         | e |                     |
|                      |                         | l |                     |
|                      |                         | t |                     |
|                      |                         | e |                     |
|                      |                         | r |                     |
|                      |                         | s |                     |
|                      |                         | , |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | a |                     |
|                      |                         | n |                     |
|                      |                         | d |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | o |                     |
|                      |                         | t |                     |
|                      |                         | h |                     |
|                      |                         | e |                     |
|                      |                         | r |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | a |                     |
|                      |                         | m |                     |
|                      |                         | e |                     |
|                      |                         | n |                     |
|                      |                         | i |                     |
|                      |                         | t |                     |
|                      |                         | i |                     |
|                      |                         | e |                     |
|                      |                         | s |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | s |                     |
|                      |                         | u |                     |
|                      |                         | c |                     |
|                      |                         | h |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | a |                     |
|                      |                         | s |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | t |                     |
|                      |                         | r |                     |
|                      |                         | a |                     |
|                      |                         | n |                     |
|                      |                         | s |                     |
|                      |                         | f |                     |
|                      |                         | e |                     |
|                      |                         | r |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | c |                     |
|                      |                         | e |                     |
|                      |                         | n |                     |
|                      |                         | t |                     |
|                      |                         | e |                     |
|                      |                         | r |                     |
|                      |                         | s |                     |
|                      |                         | , |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | b |                     |
|                      |                         | u |                     |
|                      |                         | s |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | a |                     |
|                      |                         | r |                     |
|                      |                         | r |                     |
|                      |                         | i |                     |
|                      |                         | v |                     |
|                      |                         | a |                     |
|                      |                         | l |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | i |                     |
|                      |                         | n |                     |
|                      |                         | f |                     |
|                      |                         | o |                     |
|                      |                         | r |                     |
|                      |                         | m |                     |
|                      |                         | a |                     |
|                      |                         | t |                     |
|                      |                         | i |                     |
|                      |                         | o |                     |
|                      |                         | n |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | a |                     |
|                      |                         | n |                     |
|                      |                         | d |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | t |                     |
|                      |                         | r |                     |
|                      |                         | a |                     |
|                      |                         | n |                     |
|                      |                         | s |                     |
|                      |                         | i |                     |
|                      |                         | t |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | p |                     |
|                      |                         | r |                     |
|                      |                         | i |                     |
|                      |                         | o |                     |
|                      |                         | r |                     |
|                      |                         | i |                     |
|                      |                         | t |                     |
|                      |                         | y |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | t |                     |
|                      |                         | r |                     |
|                      |                         | a |                     |
|                      |                         | f |                     |
|                      |                         | f |                     |
|                      |                         | i |                     |
|                      |                         | c |                     |
|                      |                         | > |                     |
|                      |                         |   |                     |
|                      |                         | s |                     |
|                      |                         | i |                     |
|                      |                         | g |                     |
|                      |                         | n |                     |
|                      |                         | a |                     |
|                      |                         | l |                     |
|                      |                         | s |                     |
|                      |                         | . |                     |
+----------------------+-------------------------+---+---------------------+

+----------------------+-----------------------------------------------+
| **FTA Service        | **AC Transit Policy**                         |
| Standard**           |                                               |
|                      |                                               |
| **(continued)**      |                                               |
+----------------------+-----------------------------------------------+
| **Vehicle Headway**  | > The SRTP describes that route type and      |
| -                    | > population density determines the           |
|                      | > frequency, as follows, by route type:       |
| The time interval    |                                               |
| between two vehicles | -   Core trunk and major corridor = 10 minute |
| traveling in the     |     peak                                      |
| same direction on    |                                               |
| the same route       | -   Core crosstown = 15 minute peak           |
|                      |                                               |
|                      | -   Core feeder = 30 minute peak              |
|                      |                                               |
|                      | -   Coverage based crosstown = 30 minute peak |
|                      |                                               |
|                      | -   Coverage based feeder = 30 minute peak    |
|                      |                                               |
|                      | -   Owl (modified trunk route) = 30-60 minute |
|                      |                                               |
|                      | > []{.mark}                                   |
+----------------------+-----------------------------------------------+
| **Transit Access** - | > The SRTP describes that population density  |
| The distance a       | > per square mile determines the distance     |
| person must travel   | > between routes, as follows:                 |
| to gain access to    |                                               |
| transit service      | -   20,000 and over = ¼ mile                  |
|                      |                                               |
|                      | -   20,000-10,000 = ¼ to ½ mi.                |
|                      |                                               |
|                      | -   10,000-5,000 = ½ mile                     |
|                      |                                               |
|                      | -   5,000-0 = 1 mile                          |
|                      |                                               |
|                      | > []{.mark}                                   |
+----------------------+-----------------------------------------------+

**Corrective Actions and Schedules:** Within 90 days, AC Transit must
submit to the FTA Region IX Civil Rights Officer service standards that
have been adopted by the governing board, for the following factors:

-   Vehicle load

-   Vehicle assignment, taking into consideration the age and type of
    equipment

-   Transit amenities other than bus stops

9.  []{#__RefHeading___Toc485799047 .anchor}Assessment of Compliance by
    Grantees

**Requirement:** To develop procedures and guidelines for monitoring
compliance with Title VI. At a minimum, periodic compliance assessments
must be conducted to determine whether the transit service provided to
minority communities and minority users is consistent with the
objectives of FTA's Title VI program.

**Finding:** During this Title VI Compliance Review of AC Transit,
deficiencies were found with FTA requirements for Assessment of
Compliance by Grantees. During the site visit, AC Transit produced no
documentation of the periodic Title VI assessments in accordance with
the Circular. AC Transit's 2000 Title VI submittal included a listing of
minority and non-minority routes in accordance with the definition of
the Circular. However, AC Transit does not routinely collect the data,
nor does it have complete service standards, as described above,
necessary to assess Title VI compliance. The review team spent
considerable time describing the assessment requirements and staff
indicated that it had performed the assessments in the past in its
earlier Title VI submittals, but acknowledged that it had not conducted
the assessments in the recent past.

The assessment must address both transit services (e.g., load factors
and headways or frequencies) and related benefits, including the
placement of bus shelters. This requirement applies to any shelters or
bus stops used by AC Transit buses, as a shelter is a transit amenity.
AC Transit no longer owns or maintains bus shelters in the cities of
Albany, Berkeley, Emeryville, Fremont, Hayward, Newark and San Leandro.
The shelters in these cities were transferred to each city in 1996. In
1999, using Bay Air Quality Management District funding, AC Transit
executed a *Transit Shelter Implementation Agreement* with an outdoor
advertising company and the cities to install and maintain existing and
new bus shelters with and without advertising along bus routes in the
cities noted above. The *Agreement* describes the process for selecting
locations of shelters and defines that AC Transit is administratively
responsible for the contract and receives a fee of \$75,000 per year
(adjusted annually for inflation) from advertising revenues to
administer the *Agreement*. AC Transit was advised that as the FTA
recipient it is responsible for assuring that all transit amenities
related to its service are distributed in an equitable manner in both
minority and non-minority communities.

During the site visit, the review team conducted limited checks to
determine if the quality and quantity of service provided to the
minority community and the majority community met Title VI objectives
for equity. The review team checked vehicle loads, vehicle assignments
and transit amenities. No disparities were apparent from the limited on
site assessment. In fact, as mentioned earlier, AC Transit appears to
incorporate Title VI considerations into service planning decisions,
however, it does not follow or document the procedures outlined in FTA
Circular 4702.1.

**Corrective Actions and Schedules:** Within 90 days, AC Transit must
submit to the FTA Region IX Civil Rights Officer documentation that it
has conducted an assessment of compliance in accordance with FTA
requirements and that it has established a process to conduct the
assessments on a periodic basis.

10. []{#__RefHeading___Toc485799048 .anchor}Other Areas of Title VI
    Considerations

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

######## []{.mark}

######## Changes in Service Features

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for Changes in Service
Features. In its 2000 Title VI submittal and its *Short Range Transit
Plan*, AC Transit did identify and consider the impacts on minorities
prior to making decisions on fare increases and service changes.

######## 

######## Information Dissemination

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

> **Finding:** During this Title VI Compliance Review of AC Transit, no
> deficiencies were found with FTA requirements for Information
> Dissemination. AC Transit Board Policy No. 502, dated December 13,
> 2001 includes Resolution No. 2033 affirming the commitment of AC
> transit to social and environmental justice. The Policy includes a
> detailed Community Involvement Program that addresses enhanced
> relations with minority and community-based organizations. AC Transit
> communicates with a number of minority groups in a variety of media
> for the purpose of informing customers on proposed and planned service
> changes. AC Transit provided examples of notices for public hearings
> held in locations convenient to minority groups and bulletins
> distributed throughout the system to notify riders of service changes.
> AC Transit's Marketing and Communications Department maintains a
> listing of representatives of over 100 organizations, including a
> number of minority organizations to maintain communications. AC
> Transit provides information on service changes and improvements
> directly to these groups, as well as through an extensive community
> outreach effort that involves surveys, brochure distribution, public
> meetings, a speaker's bureau, newspaper articles, website and other
> specialized outreach efforts.

######## 

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

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for Minority
Representation on Decision-Making Bodies. This requirement does not
apply to the seven-member Board of Directors since this is an elected
board.

######## Multilingual Facilities

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

**Finding:** During this Title VI Compliance Review of AC Transit, no
deficiencies were found with FTA requirements for Multilingual
Facilities. AC Transit documented that it has signage and materials
available in multiple languages. Chinese (Mandarin) and Korean are the
major non-English languages spoken in the AC Transit service area. Upon
request, AC Transit attempts to provide information in other languages
in the following priority order: Spanish, Chinese (other dialects),
Korean, Tagalog, Vietnamese, Farsi and Laotian. The AC Transit Marketing
and Communications Department is constantly seeking and creating
relationships with members of those communities with dual language
skills to act in support of their fellow members' language based needs.
The availability of materials in other languages is noted on all printed
materials.

11. []{#__RefHeading___Toc485799049 .anchor}Internal Monitoring
    Procedures

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

**Findings:** During this Title VI Compliance Review of AC Transit,
deficiencies were found with FTA requirements for Internal Monitoring
Procedures. At the time of the site visit, AC Transit had not
implemented the required "level of service" and "quality of service"
monitoring procedures. No staff resources were devoted to this area in
the past three years. The review team provided technical assistance on
what was expected. At the end of the site visit, AC Transit indicated
that it had a better understanding of what was required and that it
would have no difficulty meeting this requirement given the availability
of adequate staff.

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

[]{#__RefHeading___Toc485799050 .anchor}

12. Title VI Complaints

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

**Finding:** During this Title VI Compliance Review of AC Transit,
deficiencies were found with FTA requirements for Title VI Complaints.
At the site visit, AC Transit provided a document called AC *Transit
Customer Relations Process.* The document describes the process for
receiving and handling questions, complaints and commendations from AC
Transit customers. The document describes a three-phased process of
entering the comment into a database system known as Whoopie, sending
the comment to the appropriate party for resolution and the last phase
to close the comment in the database. The resolution phase describes a
specific discussion of ADA related issues but does not make any mention
of Title VI issues. At the site visit, AC Transit indicated that there
were no outstanding Title VI complaints against it.

**Corrective Action and Schedule**: Within 90 days, AC Transit must
submit to the FTA Region IX Civil Rights Officer a complaint procedure
for the filing of Title VI complaints. Additionally, AC Transit must
submit to the FTA Region IX Officer documentation that the complaint
procedure has been made available to the public.

VI. []{#__RefHeading___Toc485799051 .anchor}SUMMARY OF FINDINGS AND
    CORRECTIVE ACTIONS

+--------------+------+-----------+-------------------+-------+------+
| **Title VI   | **   | **De      | **Corrective      | **Res | **   |
| Requirements | Site | scription | Action(s)**       | ponse | Date |
| For Transit  | Re   | of        |                   | D     | Clos |
| Providers**  | view | Defic     |                   | ays/D | ed** |
|              | F    | iencies** |                   | ate** |      |
|              | indi |           |                   |       |      |
|              | ng** |           |                   |       |      |
+==============+======+===========+===================+=======+======+
| 1\. List of  | ND   |           |                   |       |      |
| Active       |      |           |                   |       |      |
| Complaints   |      |           |                   |       |      |
| and Lawsuits |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 2\. List of  | ND   |           |                   |       |      |
| Pending      |      |           |                   |       |      |
| Grant        |      |           |                   |       |      |
| Applications |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 3\. Summary  | ND   |           |                   |       |      |
| of           |      |           |                   |       |      |
| Compliance   |      |           |                   |       |      |
| Reviews      |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 4\. Signed   | ND   |           |                   |       |      |
| Civil Rights |      |           |                   |       |      |
| Assurance    |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 5.  Signed   | ND   |           |                   |       |      |
|     DOT      |      |           |                   |       |      |
|     Title VI |      |           |                   |       |      |
|              |      |           |                   |       |      |
|    Assurance |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 6\.          | ND   |           |                   |       |      |
| Fi           |      |           |                   |       |      |
| xed-Facility |      |           |                   |       |      |
| Impact       |      |           |                   |       |      |
| Analysis     |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 7\.          | D    | > No      | AC Transit must   | 90    |      |
| Demographic  |      | > Title   | submit to the FTA | Days  |      |
| and Service  |      | > VI      | Region IX Civil   |       |      |
| Maps,        |      | > Service | Rights Officer:   |       |      |
| Overlays and |      | > Maps or |                   |       |      |
| Charts       |      | >         | -   **Base Maps   |       |      |
|              |      |  Overlays |     -** A legible |       |      |
|              |      |           |     scaled map of |       |      |
|              |      |           |     the transit   |       |      |
|              |      |           |     service area  |       |      |
|              |      |           |     that          |       |      |
|              |      |           |     identifies    |       |      |
|              |      |           |     each census   |       |      |
|              |      |           |     tract by      |       |      |
|              |      |           |     number, major |       |      |
|              |      |           |     streets and   |       |      |
|              |      |           |     highways and  |       |      |
|              |      |           |     fixed transit |       |      |
|              |      |           |     facilities    |       |      |
|              |      |           |     and           |       |      |
|              |      |           |     identifies    |       |      |
|              |      |           |     the major     |       |      |
|              |      |           |     activity      |       |      |
|              |      |           |                   |       |      |
|              |      |           |   centers/transit |       |      |
|              |      |           |     trip          |       |      |
|              |      |           |     generators.   |       |      |
|              |      |           |                   |       |      |
|              |      |           | ```{=html}        |       |      |
|              |      |           | <!-- -->          |       |      |
|              |      |           | ```               |       |      |
|              |      |           | -   **Overlays    |       |      |
|              |      |           |     --**          |       |      |
|              |      |           |     Additional    |       |      |
|              |      |           |     maps showing  |       |      |
|              |      |           |     minority      |       |      |
|              |      |           |     population    |       |      |
|              |      |           |     encompassing  |       |      |
|              |      |           |     the entire    |       |      |
|              |      |           |     service area  |       |      |
|              |      |           |     showing the   |       |      |
|              |      |           |     total         |       |      |
|              |      |           |     minority      |       |      |
|              |      |           |     population    |       |      |
|              |      |           |     for each      |       |      |
|              |      |           |     census tract  |       |      |
|              |      |           |     and a transit |       |      |
|              |      |           |     service map   |       |      |
|              |      |           |     showing all   |       |      |
|              |      |           |     bus routes    |       |      |
|              |      |           |     with their    |       |      |
|              |      |           |     origins and   |       |      |
|              |      |           |     destinations. |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 8\. Service  | D    | > Service | AC Transit must   | 90    |      |
| Standards    |      | >         | submit to the FTA | Days  |      |
| and Policies |      | Standards | Region IX Civil   |       |      |
|              |      | > Not     | Rights Officer    |       |      |
|              |      | >         | service standards |       |      |
|              |      |  Adequate | that have been    |       |      |
|              |      |           | adopted by the    |       |      |
|              |      |           | governing board,  |       |      |
|              |      |           | for the following |       |      |
|              |      |           | factors:          |       |      |
|              |      |           |                   |       |      |
|              |      |           | -   Vehicle load  |       |      |
|              |      |           |                   |       |      |
|              |      |           | -   Vehicle       |       |      |
|              |      |           |     assignment,   |       |      |
|              |      |           |     taking into   |       |      |
|              |      |           |     consideration |       |      |
|              |      |           |     the age and   |       |      |
|              |      |           |     type of       |       |      |
|              |      |           |     equipment     |       |      |
|              |      |           |                   |       |      |
|              |      |           | -   Transit       |       |      |
|              |      |           |     amenities     |       |      |
|              |      |           |     other than    |       |      |
|              |      |           |     bus stops     |       |      |
|              |      |           |                   |       |      |
|              |      |           | []{.mark}         |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 9\.          | D    | > No      | > AC Transit must | 90    |      |
| Assessment   |      | > C       | > submit          | Days  |      |
| of           |      | ompliance | > documentation   |       |      |
| Compliance   |      | > A       | > to the FTA      |       |      |
| by Grantee   |      | ssessment | > Region IX Civil |       |      |
|              |      | >         | > Rights Officer  |       |      |
|              |      | Conducted | > that it has     |       |      |
|              |      |           | > conducted an    |       |      |
|              |      |           | > assessment of   |       |      |
|              |      |           | > compliance in   |       |      |
|              |      |           | > accordance with |       |      |
|              |      |           | > FTA             |       |      |
|              |      |           | > requirements    |       |      |
|              |      |           | > and that it has |       |      |
|              |      |           | > established a   |       |      |
|              |      |           | > process to      |       |      |
|              |      |           | > conduct the     |       |      |
|              |      |           | > assessments on  |       |      |
|              |      |           | > a periodic      |       |      |
|              |      |           | > basis.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 10\. Other   | ND   |           |                   |       |      |
| Areas of     |      |           |                   |       |      |
| Title VI     |      |           |                   |       |      |
| Co           |      |           |                   |       |      |
| nsiderations |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 11\.         | D    | > No      | > AC Transit must | 90    |      |
| Monitoring   |      | > M       | > submit to the   | Days  |      |
| Procedures   |      | onitoring | > FTA Region IX   |       |      |
|              |      | > P       | > Civil Rights    |       |      |
|              |      | rocedures | > Officer         |       |      |
|              |      |           | > documentation   |       |      |
|              |      |           | > of procedures   |       |      |
|              |      |           | > to implement an |       |      |
|              |      |           | > internal        |       |      |
|              |      |           | > monitoring      |       |      |
|              |      |           | > process.        |       |      |
|              |      |           | > Further, AC     |       |      |
|              |      |           | > Transit must    |       |      |
|              |      |           | > provide         |       |      |
|              |      |           | > documentation   |       |      |
|              |      |           | > that it has     |       |      |
|              |      |           | > initiated the   |       |      |
|              |      |           | > internal        |       |      |
|              |      |           | > monitoring      |       |      |
|              |      |           | > process and has |       |      |
|              |      |           | > a schedule of   |       |      |
|              |      |           | > dates for       |       |      |
|              |      |           | > periodic        |       |      |
|              |      |           | > monitoring of   |       |      |
|              |      |           | > bus services    |       |      |
|              |      |           | > and transit     |       |      |
|              |      |           | > amenities for   |       |      |
|              |      |           | > the next three  |       |      |
|              |      |           | > years.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 12\. Title   | D    | P         | AC Transit must   | 90    |      |
| VI           |      | rocedures | submit to the FTA | Days  |      |
| Complaints   |      | for Title | Region IX Civil   |       |      |
|              |      | VI        | Rights Officer a  |       |      |
|              |      | C         | complaint         |       |      |
|              |      | omplaints | procedure for the |       |      |
|              |      | I         | filing of Title   |       |      |
|              |      | nadequate | VI complaints.    |       |      |
|              |      |           | Additionally, AC  |       |      |
|              |      |           | Transit must      |       |      |
|              |      |           | submit            |       |      |
|              |      |           | documentation     |       |      |
|              |      |           | that the          |       |      |
|              |      |           | complaint         |       |      |
|              |      |           | procedure has     |       |      |
|              |      |           | been made         |       |      |
|              |      |           | available to the  |       |      |
|              |      |           | public.           |       |      |
+--------------+------+-----------+-------------------+-------+------+

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

NR = Not Reviewed;[]{#__RefHeading___Toc485799052 .anchor}

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

  ---------------------------------------------------------------------------------------------------------------------------------
  **NAME**       **TITLE/ORGANIZATION**   **PHONE**      **FAX**        **E-MAIL**
  -------------- ------------------------ -------------- -------------- -----------------------------------------------------------
  Joan Martin    Manager, Capital         510-891-7253   510-891-7107   <jmartin@actransit.org>
                 Planning and Grants                                    
                 Administration, AC                                     
                 Transit                                                

  Kenneth C.     General Counsel, AC      510-891-7178   510-891-4724   <kscheidi@actransit.org>
  Scheidig       Transit                                                

  Christina      Associate Transportation 510-891-4859                  <cverdin@actransit.org>
  Verdin         Planning, AC Transit                                   

  Tina Spencer   Manager of Long Range    510-891-4754   510-891-4874   <tspencer@actransit.org>
                 Planning, AC Transit                                   

  Joseph         Chief Transportation     510-891-7215                  [jschlenk@actransit.org](mailto:jschlenker@actransit.org)
  Schlenker      Officer, AC Transit                                    

  Kathleen Kelly Deputy General Manager,  510-891-4716   510-891-4874   <kkelly@actransit.org>
                 Service Development, AC                                
                 Transit                                                

  Jim Gleich     Deputy General Manager,  510-891-7185   510-891-7157   <jgleich@actransit.org>
                 AC Transit                                             

  Gregory Hunter Director of Service      510-891-4871   510-891-4818   <ghunter@actransit.org>
                 Supervision, AC Transit                                

  Howard Der     Associate Transportation 510-891-7208   510-891-4874   <hder@actransit.org>
                 Planner, AC Transit                                    

  Derrin Jourdan Civil Rights Officer,    415-744-2729   415-744-2726   <derrin.jourdan@fta.dot.gov>
                 FTA Region IX                                          

  John Potts     Lead Reviewer, The DMP   504-283-7661   504-283-0791   <johnpotts@thedmpgroup.com>
                 Group, Inc.                                            

  Royal "Ed"     Reviewer, The DMP Group, 301-681-0258   301-681-5586   <royaleiii@thedmpgroup.com>
  Spurlark       Inc.                                                   
  ---------------------------------------------------------------------------------------------------------------------------------

[^1]: Census 2000, Data Summary #3, Planning Section, Metropolitan
    Planning Commission, October 2002

[^2]: AC Transit Service Deployment Plan (Draft), Environmental Science
    Associates, May 3, 2002