**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**BROWARD COUNTY BOARD OF COMMISSIONERS - BROWARD COUNTY MASS TRANSIT
DIVISION**

**(Broward County Transit)**

**Pompano Beach, FL**

**Final Report**

**June 2005**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**MILLIGAN & CO., LLC**

[Table of Contents]{.underline}

I. GENERAL INFORMATION [1](#__RefHeading___Toc94498676)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc94498677)

III\. PURPOSE AND OBJECTIVES 3

IV\. BACKGROUND INFORMATION [5](#__RefHeading___Toc94498678)

V. SCOPE AND METHODOLOGY [9](#__RefHeading___Toc94498679)

VI\. FINDINGS AND RECOMMENDATIONS [16](#__RefHeading___Toc94498680)

1\. List of Active Complaints and Lawsuits
[16](#__RefHeading___Toc94498681)

2\. Pending Applications for Financial Assistance
[16](#__RefHeading___Toc94498682)

3\. Summary of Civil Rights Compliance Reviews
[17](#__RefHeading___Toc94498683)

4\. FTA Civil Rights Assurance [17](#__RefHeading___Toc94498684)

5\. DOT Title VI Assurance [18](#__RefHeading___Toc94498685)

6\. Fixed-Facility Impact Analysis [18](#__RefHeading___Toc94498686)

7\. Demographic and Service Profile Maps, Overlays and Charts
[21](#refheading___toc94498687)

8\. Service Standards and Policies [23](#__RefHeading___Toc94498688)

9\. Assessment of Compliance by Grantees
[25](#__RefHeading___Toc94498689)

10\. Other Areas of Title VI Considerations
[27](#__RefHeading___Toc94498690)

11\. Internal Monitoring Procedures [31](#__RefHeading___Toc94498691)

12\. Title VI Complaints [33](#__RefHeading___Toc94498692)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[36](#__RefHeading___Toc94498693)

VIII\.
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I.  []{#__RefHeading___Toc94498676 .anchor}GENERAL INFORMATION

Grant Recipient: Broward County Board of Commissioners -- Broward County
Mass Transit Division

City/State: Pompano Beach, FL

Grantee No: 1082

Executive Official: Mr. Robert Roth

> Director of Mass Transit
>
> Broward County Board of Commissioners -- Broward County Mass Transit
> Division\
> 3201 West Copans Road\
> Pompano Beach, Florida 33069

Report Prepared By: MILLIGAN & CO., LLC

105-107 N. 22^nd^ Street

Mulberry Atrium North

Philadelphia, PA 19103

Site Visit Dates: December 14-16, 2004

Compliance Review

Team Members: Jim Buckley

> Lead Reviewer Milligan & Co., LLC

Diane King

> Reviewer

Milligan & Co., LLC

Sandra Swiacki

> Reviewer

Milligan & Co., LLC

Ann Marie Byrnes

> Reviewer

Milligan & Co., LLC

II. []{#__RefHeading___Toc94498677 .anchor}JURISDICTION AND AUTHORITIES

The Federal Transit Administration (FTA) Office of Civil Rights is
authorized by the Secretary of Transportation to conduct civil rights
compliance reviews. Reviews are undertaken to ensure compliance of
applicants, recipients, and subrecipients with Title VI of the Civil
Rights Act of 1964, as amended (42 U.S.C. 2000d); Section 12 of the
Master Agreement, Federal Transit Administration M.A. (10), October 1,
2003; and 49 U.S.C. 5332, "Non-Discrimination."

The Broward County Board of Commissioners -- Broward County Mass Transit
Division (Broward County 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 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 Broward County Transit's Title VI Program and were the
basis for the selection of compliance elements that were reviewed.

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

**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 Broward County Board of
Commissioners -- Broward County Mass Transit Division (Broward County
Transit) Title VI Program was necessary.

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

#### 

#### Objectives

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

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

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

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

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

-   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.

    []{#__RefHeading___Toc94498678 .anchor}IV. BACKGROUND INFORMATION

Broward County Transit is the public transit provider for Broward
County. The Broward County Transit service area covers 410 square miles
and a population of over 1.6 million. Based on BCT's Annual Transit
Ridership Report for Fiscal Year 2004, Broward County Transit uses a
fleet of approximately 275 buses. BCT's traditional fixed route service
accounted for 90% of the total Broward County Mass Transit ridership,
delivering 36.3 million passenger trips resulting in 12.9 million
revenue miles. All but five of Broward County Transit's 40 routes
operate seven days a week. Routes run from as early as 5:00 am to as
late as midnight.

Broward County Transit provides coverage of much of the urbanized area
of Broward County. The system connects with Miami-Dade Transit in south
Broward and north Miami-Dade counties at various locations. These
include Aventura Mall, Pro Player Stadium, and the Golden Glades transit
center. Broward County Transit also connects with Palm Tran in Palm
Beach County at locations such as Boca Town Center and Mizner Park and
along Hillsborough Boulevard in north Broward. Effective March 23, 2004,
through an agreement executed between the South Florida Regional
Transportation Authority (SFRTA/Tri-Rail) and Broward County, the County
transferred its Tri-Rail feeder services to the SFRTA.

In the late 1990's, Broward County Transit embraced a strategy of
strengthening its main trunk line routes and replacing many neighborhood
services with Community Transit routes, operated by the local
municipalities. Those efforts resulted from implementation of the
recommendations of the Broward County Transit Needs Study, which was a
10-year master plan similar to the 10-year plan supported by the
FY2005-2009 Transit Development Plan. The Community Bus service is based
on local ridership demand and is provided through a partnership between
individual cities and Broward County Transit using inter-local
agreements.

Broward County Transit also offers a Water Bus service. This service is
designed to connect with Broward County Transit's fixed route system.
Currently it connects with six fixed routes. A two million dollar
federal grant enabled Broward County Transit to purchase eight electric
hybrid ferryboats. Service is provided along the New River and
Intracoastal Waterway in the downtown Forth Lauderdale area. The service
operates between the hours of 9:00 am and 12:30 am. Broward County
Transit offers a \$5 per day daily pass in addition to 7- Day and 31-Day
passes for both the Water Bus and the Broward County Transit fixed route
buses.

The Mass Transit Division administrative offices are located at the
Copans Road complex in Pompano Beach, which opened in February 1985. In
addition to housing the operations offices for the northern part of the
County, this facility has the capacity to park and maintain
approximately 165 buses. The bus garage at Ravenswood Road in Dania
Beach has the capacity to park and maintain up to 150 buses, and control
operations in the southern part of the County.

Broward County Transit has several prominent fixed facilities. These
include the Broward Central Terminal in the downtown Fort Lauderdale and
the West Regional Terminal on Broward Boulevard. Facilities are also
located at major shopping malls (i.e. Sawgrass Mills, Lauderhill Mall),
as well as at on-street transfer points such as Park Drive in Margate.
New neighborhood transit centers are being developed in communities such
as Miramar, Coral Springs, Pompano Beach and Hollywood.

[]{.mark}

Broward County Transit offers a basic fare of \$1.00. Seniors, the
disabled and youths, which include children and students in the K-12
category, are offered a half-fare of \$0.50. Children less than 40
inches tall (shorter than the fare box) ride for free. Broward County
Transit also offers a cost-savings pass for daily, unlimited travel
during a specified period of time, known as the Buz Pass. The cost of
the Buz Pass ranges from \$2.50 to \$32.00, for daily to monthly passes,
respectively.

[]{.mark}

FTA-funded projects that are underway include:

-   **Administrative Building**: Construction of a new administrative
    building to support its administrative staff.

-   **Convention Connection**: Implementation of a shuttle service
    linking the Port, Convention Center, WaterBus station and nearby
    hotels along 17^th^ Street causeway. The match for this project is
    soft match from Toll revenue credits from the FDOT.

-   **Capital Purchases**: Replacement of 25 40-foot buses, 25 minibuses
    for Community Bus service, support vehicles, buses, maintenance
    equipment and bus washer.

**Racial Breakdown of Broward County Transit Service Area**

######### 2000 Census

+-------------------------------------------------+--------------------+
| **Racial/ Ethnic Group**                        | ####               |
|                                                 |  Broward County Tr |
|                                                 | ansit Service Area |
|                                                 |                    |
|                                                 | #### Total/        |
|                                                 |                    |
|                                                 | #### Percent       |
+-------------------------------------------------+--------------------+
| #### White                                      | #### 1,145,287     |
|                                                 |                    |
|                                                 | *70.6%*            |
+-------------------------------------------------+--------------------+
| #### Black or African American                  | #### 333,304       |
|                                                 |                    |
|                                                 | *20.5%*            |
+-------------------------------------------------+--------------------+
| #### American Indian & Alaska Native            | #### 3,867         |
|                                                 |                    |
|                                                 | *.2%*              |
+-------------------------------------------------+--------------------+
| #### Asian                                      | 36,581             |
|                                                 |                    |
| ####                                            | *2.3%*             |
+-------------------------------------------------+--------------------+
| #### Native Hawaiian & Other Pacific Islander   | 916                |
|                                                 |                    |
|                                                 | *.1%*              |
+-------------------------------------------------+--------------------+
| #### Other                                      | 48,642             |
|                                                 |                    |
|                                                 | *3.0%*             |
+-------------------------------------------------+--------------------+
| #### Two or more races                          | 54,421             |
|                                                 |                    |
|                                                 | *3.4%*             |
+-------------------------------------------------+--------------------+
| #### Total Population                           | **1,623,018**      |
+-------------------------------------------------+--------------------+
| #### *Total Minorities*                         | **477,731**        |
|                                                 |                    |
|                                                 | **29.4%**          |
+-------------------------------------------------+--------------------+

[]{#__RefHeading___Toc94498679 .anchor}V. SCOPE AND METHODOLOGY

#### Scope

The Title VI Compliance Review of Broward County 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:

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a.  list of active Title VI lawsuits or complaints;

b.  description of pending applications for financial assistance;

c.  summary of recent civil rights compliance review activities;

d.  signed FTA Civil Rights Assurance;

e.  signed standard DOT Title VI Assurance; and

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

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

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a.  demographic and service profile maps, overlays and charts;

b.  service standards and policies;

c.  assessment of compliance by grantees; and

d.  information on other areas of Title VI considerations.

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

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

#### Methodology

[Data Collection]{.underline}

Initial discussions were conducted with the Region IV Civil Rights
Officer to review specific Title VI issues and concerns regarding
Broward County Transit. A detailed letter was also sent to Broward
County Transit advising the agency of the site visit, indicating
information that would be needed and issues that would be discussed.

In the letter, Broward County Transit was requested to provide the
following background information:

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

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

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

-   Any studies or surveys conducted by Broward County 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

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

In the letter, Broward County Transit was requested to provide an update
of the following General Reporting Requirements (Chapter III, Section 2
of FTA Circular 4702.1) since its January 2000 Title VI submittal to
FTA.

-   A list of any active lawsuits and complaints

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-   Pending grant applications

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-   Other civil rights compliance reviews during the last three years

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

Broward County Transit was also requested to provide the following
information and updates on the Program-Specific Requirements in
accordance with Chapter III, Section 3 of FTA Circular 4702.1, since its
2000 Title VI submittal to FTA.

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

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

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

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-   Service standards adopted by Broward County 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

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-   Information collected by Broward County 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, and amenities, such as those provided at
    bus stops

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-   Results of any analysis performed to compare the level and quality
    of services in minority and non-minority areas

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-   Ridership by route

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-   Passenger boardings by bus stop

-   Maximum load points by route

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

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-   Inventory of bus stops which indicates their location and any
    amenities

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

In addition, Broward County Transit was requested to provide the
following other Program- Specific Requirements in accordance with
Chapter III, Section 4, Chapter IV, Section II and Chapter VII, Section
2 of FTA Circular 4702.1:

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

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

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

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

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

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

[Site Visit]{.underline}

The site visit to Broward County Transit took place December 14-16,
2004. The exit conference was held December 16, 2004. The individuals
participating in the review are listed in Section VIII of this report.
At the entrance conference, the purpose of the Title VI Compliance
Review and the review process were discussed. A detailed schedule for
conducting the on-site visit was discussed. The focus of the site visit
then turned to the status of the information requested in the letter
notifying Broward County Transit of the Compliance Review. Arrangements
were also made for a tour of Broward County Transit facilities and
interviews with Broward County Transit's staff and community
representatives.

During the site visit, the review team conducted tours of four bus
routes, two considered to be minority routes, Route 72 and 36, and two
considered to be non-minority routes, Route 34 and 10. Routes 72 and 36
converged at the Sawgrass Mall, which is a major trip generator for
Broward County Transit. It is important to note that the labels of
non-minority and minority routes for the tours were approximated with
Broward County Transit staff, as the determination of minority routes
had to be determined by Broward County Transit based on the first day's
review of reporting requirements. Distribution of amenities, vehicles
assigned, and the review team observed ridership and operating
characteristics of these routes and transit centers. Further, although
the non-minority routes approximated were selected based on the guidance
as defined by FTA Circular 4702.1, the review team observed that most of
the riders were minorities.

Interviews were conducted with Broward County Transit's staff to provide
information on the extent to which Title VI requirements are
incorporated in the planning and implementation of service by Broward
County Transit. The interviews also focused on staff efforts to make
communications and information available to persons with limited English
proficiency.

[]{.mark}

Interviews were also conducted with representatives of community
organizations to gain insight on how the minority community is
represented and participates in Broward County Transit's planning
process. Those interviewed included representatives from the National
Association for the Advancement of Colored People -- North Broward
Branch, the Broward County Office of Economic Development, and Hispanic
Unity of Florida.

At the exit conference FTA representatives, Broward County Transit
staff, and the review team discussed the results of the site visit and
the next steps, which included the submittal of additional data and
documentation needed to meet FTA requirements for Title VI.

[]{#__RefHeading___Toc94498680 .anchor}VI. FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on Broward County 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.

1.  []{#__RefHeading___Toc94498681 .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 that alleges discrimination on the basis of race, color,
or national origin with respect to service or other transit benefits.

**Finding:** During this Title VI Compliance Review of Broward County
Transit, no deficiencies were found with FTA requirements for a List of
Active Complaints and Lawsuits. There we no active complaints or
lawsuits filed against Broward County Transit at the time of the site
visit.

2.  []{#__RefHeading___Toc94498682 .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 Broward County
Transit, no deficiencies were found with FTA requirements for Pending
Applications for Financial Assistance. Prior to the site visit, Broward
County Transit provided information on its pending and active FTA
grants. At time of the site visit, the agency had no pending grants.

3.  []{#__RefHeading___Toc94498683 .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 Broward County
Transit, no deficiencies were found with FTA requirements for Summary of
Civil Rights Compliance Reviews. FTA conducted a Triennial Review of
Broward County Transit in May 2003. There were no findings reported in
the area of Title VI at the time of that report.

4.  []{#__RefHeading___Toc94498684 .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 Broward County
Transit, no deficiencies were found with FTA requirements for FTA Civil
Rights Assurance. Broward County Transit provided a copy of its most
recent FTA Civil Rights Assurance signed October 17, 1989 by Nicki
Englander Grossman, Chairman of the Broward County Commission at that
time. An updated assurance will be included with its next Title VI
submission in 2005.

5.  []{#__RefHeading___Toc94498685 .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 Broward County
Transit, no deficiencies were found with FTA requirements for DOT Title
VI Assurance. Broward County Transit provided a copy of its most recent
DOT Title VI Assurance signed October 17, 1989 by Nicki Englander
Grossman.

6.  []{#__RefHeading___Toc94498686 .anchor}Fixed-Facility Impact
    Analysis

**Requirement:** For construction projects, all applicants, recipients
and subrecipients shall conduct a fixed-facility impact analysis (FFIA)
to assess the effects on minority communities. This information can be
included in the documents supporting a request for a Categorical
Exclusion, or an environmental assessment or environmental impact
statement.

**Finding:** During this Title VI Compliance Review of Broward County
Transit, deficiencies were found with the requirement to conduct a fixed
facility impact analysis of construction projects. Broward County
Transit staff provided a list of nine upcoming construction projects to
be implemented. Of the nine projects, five are renovations and
maintenance projects at current facilities. Those facilities are:

Transit Fixed Maintenance and Administrative Facilities

-   Copans Road Bus Facility

-   Ravenswood Road Bus Facility

Bus Terminals/Transfer Facilities

-   Broward Central Bus Terminal

-   West Regional Bus Terminal

-   Lauderhill Mall.

Of these five projects, only two, (the Copans Road Bus Facility and the
Lauderhill Mall) are proposed to undergo renovations in the very near
future. BCT has received site plan approval from the City of Pompono
Beach, Florida, on its proposed Copans Road Bus Facility construction
project.

The additional four projects are proposed transit centers, designed to
increase mobility and reduce congestion along major corridors by
providing commuters with convenient, safe mobility options. Each
transfer location will act as a catalyst for mixed-use development, such
as restaurants, childcare centers, video stores, dry cleaners, and ATM
machines, thereby promoting economic opportunities. These facilities
will be located as follows:

-   Coral Springs -- to be located in the Coral Springs Medical Center
    parking lot at the intersection of Northwest 33^rd^ Street and Coral
    Hills Drive

-   Hollywood -- to be located adjacent to the Florida East Coast
    Railroad clear zone, on South 21^st^ Avenue between Tyler Street and
    Fillmore Street, one block north of Hollywood Boulevard

-   Miramar -- to be located as part of the City's new Town Center
    Complex on Miramar Boulevard between Hiatus Road and Red Road
    (construction has already begun on this project)

-   Pompano Beach -- to be located at Martin Luther King Boulevard and
    Dixie Highway.

Broward County staff determined that since the first five projects will
be additional construction on existing facilities the requirement to
conduct a fixed facility impact analysis does not apply. Further,
although the last four projects will be new build-outs in the service
area, it is not the intent of Broward County Transit to use federal
funds to construct these facilities. Therefore, Broward County Transit
is operating under the assumption that the fixed facility impact
analyses requirements will not apply.

[]{.mark}

In response, the FTA Office of Civil Rights determined that fixed
facility impact analysis is required for construction projects,
regardless of whether they involve new construction or rehabilitation,
renovation, or additions to existing facilities. In the case of
rehabilitation or renovation, Broward County Transit should conduct a
fixed facility impact analyses where additional land must be acquired or
where the height or footprint of a building will be substantially
altered. Although Broward County does not intend to use Federal funds to
construct the proposed transit centers, the Civil Rights Restoration Act
of 1988 dictates that the provisions of Title VI encompass the entire
institution in question. Therefore, all of the services and activities
of Broward County Transit, including the construction of the transit
centers, are subject to Title VI and the FTA's guidance under Circular
4702.1.

Subsequent to the draft report, BCT provided copies of the application
for a categorical exclusion under 771.117(d) of FTA's NEPA regulations
for the Copans Road bus facility. This document includes a section on
community disruption and environmental justice which indicates that the
nearest access to residential unites from the construction is
approximately one half mile away and is separated by Florida's turnpike,
therefore no residential community or community resources will be
affected by the proposed project. (See attachment 1 to the final
report).

7.  []{#refheading___toc94498687 .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.

**Finding:** During this Title VI Compliance Review of Broward County
Transit, deficiencies were found with FTA requirements for Demographic
and Service Profile Maps, Overlays, and Charts. Broward County Transit
provided several maps that depicted the minority census tracts (using
2000 census data) in their service area. Information provided at the
site visit included integrated maps and overlays that partially met the
Title VI requirements, as follows:

-   **Base Maps and Overlays --** For its service area, Broward County
    Transit provided a legible, scaled base map that identified each
    census tract by number. It also included separate maps that
    identified bus routes, major streets and highways, major trip
    generators, and maintenance and garage facilities. A separate map
    was provided which included a color-coded integrated overlay that
    denoted minority and non-minority census tracts. However, none of
    the base maps provided shows the total minority population for each
    census tract expressed in raw numbers and as a percentage for that
    tract based on the 2000 Census. Further, the overlay provided, which
    included transit routes, census tracts and major trip generators,
    did not include those transit routes provided via the Community Bus
    Service program. The Community Bus service is a system operated by
    local municipalities using federally funded Broward County Transit
    vehicles.

-   **Population/Racial Distribution Charts --** For its service area,
    Broward County Transit did not provide population distribution
    charts that follow the format suggested in FTA Circular 4702.1.

Subsequent to the draft report, BCT provided new service maps and
overlays that are consistent with the guidance provided in FTA's Title
VI Circular 4602.1

8.  []{#__RefHeading___Toc94498688 .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) Vehicle Headway

(4) Distribution of Transit Amenities

(5) Transit Access

**Finding:** During this Title VI Compliance Review of Broward County
Transit, deficiencies were found with FTA requirements for Service
Standards. Broward County Transit provided multiple sources of
information, which contained some of the service standards updated at
various times. These sources of information included the 1990 Title VI
Plan, the 1996 and 2004 Transit Development Plans, and the 2000 Title VI
Update.

In its 2000 Title VI Update, Broward County Transit indicated that it
had updated its service standards as reflected in the 1996 Transit
Development Plan (1996 TDP), which was an update of its 1990 Title VI
Plan. Those standards have been most recently updated in the December
2004 major update of the Broward County Transit Development Plan (2004
TDP). After a review of documents and interviews with Broward County
Transit staff, the review team attempted to determine which document(s)
addressed Broward County Transit's current service standards as
prescribed by FTA Circular 4702.1. The following table summarizes those
determinations at the time of the site visit:

+-----------------+-------------------------+--------------------------+
| **FTA Service   | **Broward County        | #### Comments            |
| Standard**      | Transit Policy**        |                          |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | In the 1996 TDP,        | > Broward County Transit |
| Load** - A      | maximum average load    | > provided ridership     |
| ratio of the    | factors are defined as  | > statistics for each    |
| number of       | follows:                | > route, which includes  |
| passengers on a |                         | > percent of bus seats   |
| vehicle to the  | -   Base period -- 100% | > occupied.              |
| number of seats |                         |                          |
|                 | -   Express -- 100%     |                          |
|                 |                         |                          |
|                 | -   Cross Country --    |                          |
|                 |     125%                |                          |
|                 |                         |                          |
|                 | -   \> 40% Elderly --   |                          |
|                 |     100%                |                          |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | The 1990 Title VI plan  | This practice was        |
| Assignment      | states that vehicles    | confirmed via the bus    |
| -**The process  | are assigned throughout | assignment sheets        |
| by which        | the system. Routes are  | provided subsequent to   |
| vehicles are    | assigned to each        | the site visit.          |
| assigned to     | transit operation       | Additionally, a review   |
| routes          | facility based on a     | of the age of fleet at   |
| throughout the  | geographic basis.       | the Copans and           |
| system, taking  |                         | Ravenswood garage showed |
| into            | *Note:* In accordance   | an average age of 6.7    |
| consideration   | with union guidelines,  | years and 5.25 years,    |
| variations      | operators with          | respectively. The        |
| among vehicles  | seniority are allowed   | average age of the       |
| (age, size,     | to choose the vehicle   | entire fleet is          |
| amenities,      | and route assignment of | approximately 6 years.   |
| etc.).          | preference on a daily   |                          |
|                 | basis. As such, buses   |                          |
|                 | are rotated among       |                          |
|                 | transit facilities      |                          |
|                 | every three months.     |                          |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | In the 2004 TDP, route  | > Sample of current      |
| Headway** -     | headways range from 15  | > headways conformed to  |
|                 | to 90 minutes with core | > standards.             |
| The time        | routes operating on 15  |                          |
| interval        | to 30 minute headways.  |                          |
| between two     |                         |                          |
| vehicles        | ####                    |                          |
| traveling in    |                         |                          |
| the same        |                         |                          |
| direction on    |                         |                          |
| the same route  |                         |                          |
+-----------------+-------------------------+--------------------------+

+-----------------+-------------------------+--------------------------+
| **FTA Service   | **Broward County        | #### Comments            |
| Standard**      | Transit Policy**        |                          |
+=================+=========================+==========================+
| **Distribution  | No standard or policy   | > Broward County Transit |
| of Transit      | provided.               | > provided extensive     |
| Amenities** -   |                         | > information on the     |
|                 | *Note:* The             | > number and location of |
| Criteria for    | undocumented policy is  | > its bus stops. The     |
| installation of | that each bus stop be   | > review team verified   |
| items of        | marked with a sign at a | > this information       |
| comfort and     | minimum. The placement  | > during its field       |
| convenience     | of shelters and benches | > visits.                |
| available to    | are controlled by the   |                          |
| the general     | local municipalities.   |                          |
| public          | Some shelters contain   |                          |
|                 | trash cans, ADA         |                          |
|                 | landings, pull ins and  |                          |
|                 | solar lights.           |                          |
+-----------------+-------------------------+--------------------------+
| **Transit       | No standard or policy   | > []{.mark}              |
| Access** - The  | provided.               |                          |
| distance a      |                         |                          |
| person must     |                         |                          |
| travel to gain  |                         |                          |
| access to       |                         |                          |
| transit service |                         |                          |
+-----------------+-------------------------+--------------------------+

Subsequent to the draft report, BCT provided service standards for
transit access and transit amenities and has reviewed and documented the
other service standards as part of its Title VI plan (see Attachment 1
to the final report).

9.  []{#__RefHeading___Toc94498689 .anchor}Assessment of Compliance by
    Grantees

**Requirement:** The recipient is required to develop procedures and
guidelines for monitoring compliance with Title VI. This includes
evaluating system wide changes and improvements at the planning and
programming stages to determine if the overall benefits and costs of
such changes are distributed equally. Additionally, compliance
assessments must be conducted to determine if the transit service
provided to minority communities and minority users is consistent with
the objectives of FTA's Title VI program.

Subsequent to the draft report, BCT provided service standards for
transit access and transit amenities and has reviewed and documented the
other service standards as part of its Title VI plan (see Attachment 1
to the final report)

**[9. Assessment of Compliance by Grantees]{.underline}**

**Requirement:** The recipient is required to develop procedures and
guidelines for monitoring compliance with Title VI. This includes
evaluating system wide changes and improvements at the planning and
programming stages to determine if the overall benefits and costs of
such changes are distributed equally. Additionally, compliance
assessments must be conducted to determine if 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 Broward County
Transit, deficiencies were found with respect to FTA requirements for
assessment of compliance with Title VI. Broward County Transit staff was
unable to provide documentation that the agency performed any
assessments to monitor compliance with Title VI for any of these system
changes.

The review team concluded that Broward County Transit does not have a
defined process or procedure in place to conduct periodic assessments to
monitor compliance with Title VI, nor does Broward County Transit
evaluate system wide changes and proposed improvements at the planning
and programming stages to determine if the overall benefits and costs of
such changes or improvements are distributed equally, and are not
discriminatory. Lastly, there was no evidence that Broward County
Transit makes determinations of compliance with Title VI a part of local
decision-making processes and continuing project management and contract
administration responsibilities.

[]{.mark}

Subsequent to the draft report, BCT submitted procedures to assess
compliance with Title VI. Whenever service changes take place which
increase or decrease total annual vehicle revenue miles by at least 10%,
BCT will determine equitable treatment to minority and non-minority
routes. Every three years, BCT will perform service assessments for
Title VI compliance. BCT will solicit comment from affected communities
in response to proposed service changes. (Full procedures included in
Attachment 1 to the Final Report).

10. []{#__RefHeading___Toc94498690 .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]{.underline}**

**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 Broward County
Transit, deficiencies were found with FTA requirements for Changes in
Service Features. Over the three-year period from 2002 to 2004, Broward
County Transit provided documentation of approximately 60 forms of
service changes, which included the reduction or increase of headways on
selected routes and the contracting or rerouting of various routes.
[]{.mark}However, Broward County Transit provided no documentation of
assessing the effects of these changes.

Subsequent to the draft report, BCT provided an assessment of the
effects of service changes made during 2005 on minority and non-minority
users (see Attachment 1 for text of the assessment). The review
indicated that there was no significant difference in the decrease in
revenue miles and revenue hours experienced by minority and non-minority
communities as a result of recent 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 Broward County
> Transit, no deficiencies were found with FTA requirements for
> Information Dissemination. Documentation was provided to demonstrate
> that Broward County Transit communicates with minority groups on
> changes related to transit service and improvements. Minority
> communities are provided with information regarding service changes
> both as part of Broward County Transit's general information
> dissemination efforts, and where a service change impacts a minority
> community, as part of a targeted informational effort. Dissemination
> methods include posted rider alerts, postings on Broward County
> Transit's website, public hearings when necessary, and community
> meetings. If public hearings are necessary, they are held at
> facilities that are transit-accessible. Broward County Transit's
> efforts also include advertisements in local minority-focused
> publications.
>
> At the site visit, representatives from Broward County Transit
> presented its training and communications schedule for 2003 and the
> Annual Calendar of Events of the Marketing and Communications
> Department, which detail minority contacts for various organizations,
> community groups and minority events through which Broward County
> Transit disseminates transit information.

######## 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 Broward County
Transit, no deficiencies were found with respect to FTA requirements for
Minority Representation on Decision-Making Bodies.

As a department of Broward County, Broward County Transit is governed by
the County Commission. The Commission is comprised of nine members
elected from single member districts. Each Commissioner must be a
resident of the particular district for which seat he/she seeks
election. Each year the Commission elects a mayor who will serve as the
County's official representative. According to the latest board
revision, minorities represent 22 percent (2 of 9) of the Commission.

[]{.mark}

In addition, the Commission has responsibility for appointing minorities
and the physically disabled to various decision-making bodies in the
community, including organizations that may have input into the polices
and plans of Broward County Transit, such as the Metropolitan Planning
Organization and the South Florida Regional Planning Council. From a
total of 12 appointments to decision-making bodies with input into the
policies and plans of Broward County Transit, the Commission appointed
five (42%) minorities.

######## 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 Broward County
Transit, no deficiencies were found with FTA requirements for
Multilingual Facilities.

During the site visit, evidence of various multilingual communications,
including schedules, signage, and public notices, were provided and
viewed during facility visits. Broward County Transit works with the
appropriate language representatives on its translations to ensure that
not only the wording, but also the meaning and dialect are correct so
that the documents can be easily understood. Due to the diverse Broward
County Transit service area, there are three primary languages used by
the ridership: English, Spanish, and Creole. Broward County Transit has
implemented a system of route language assignment based on the language
uses of the population in which the route traverses. All vehicles on
Broward County Transit routes have the capability to provide transit
information in at least two languages, English being the common language
on all routes.

11. []{#__RefHeading___Toc94498691 .anchor}Internal Monitoring
    Procedures

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

**Findings:** During this Title VI Compliance Review of Broward County
Transit, deficiencies were found with FTA requirements for Internal
Monitoring Procedures. At the time of the site visit, Broward County
Transit had not implemented the required "level of service" and "quality
of service" monitoring procedures.

Broward County Transit provided several types of analysis and data
collection that it conducts for measuring route performance against
established standards. In past years, it conducted various on-board
surveys of transit passengers that analyzed trip characteristics
(boarding locations, alighting locations, zones crossed), transfer
rates, fare payment methods, average fare per boarding, and
satisfaction. As noted in the previous section on Service Standards and
Policies, Broward County Transit does keep an extensive inventory of its
bus stops. Using these methods, Broward County Transit collects
information that can be used to monitor performance of the transit
system in accordance with FTA Circular 4702.1.

The reviewers discussed the method in the circular that specifies
selecting a sample size of at least 10 percent of all census tracts in
the service area and assessing the performance of minority areas against
established standards. It was further discussed that to complete this
required monitoring, Broward County Transit needed to identify its
minority and non-minority transit routes as defined in FTA Circular
4702.1. The identification of such routes should be performed during the
preparation of the base maps and overlays.

For quality of service monitoring, FTA Circular 4702.1 requires the
selection of an appropriate sample size of minority and non-minority
census tracts, and a survey of riders to determine travel patterns,
travel time, and fares for the three most frequented destinations.

While Broward County Transit is collecting much of the data that can
serve as input to internal monitoring, an analysis of the minority and
non-minority routes and tracts was not performed.

Subsequent to the draft report, BCT submitted the results of its level
and quality of service monitoring (see Attachment 1 for full text).
Level of service monitoring found that transit service provided to the
minority community met or exceeded BCT's system-wide service standards.
Quality of service monitoring found that the peak hour travel time,
number of transfers required, and cost per mile from minority and
non-minority areas to popular destinations were comparable

12. []{#__RefHeading___Toc94498692 .anchor}Title VI Complaints

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

**Finding:** During this Title VI Compliance Review of Broward County
Transit, deficiencies were found with FTA requirements for Title VI
Complaints. Broward County Transit's Customer Service and Information
Center handle service complaints. Representatives from this department
provided information on the intake and processing of service complaints.
This included instructions to employees on how to categorize complaints.
While there was no specific category for Title VI or Civil Rights
complaints, a description was provided on how these complaints are
categorized (facilities, fares, service-related) and then forwarded to a
specific investigator based on the source of the complaint, route and
operator. Service complaints are recorded and tracked in a database
system developed by Broward County Transit and for review.

It is also noted that the County has a department titled the Civil
Rights Division. Any member of the public, including transit users, may
file a complaint with this Division. The Division will work with the
respective department to resolve the complaint. Information for
contacting this Division is included in the *Broward County Commission
At Your Service 2004, Your Guide to County Government Services* booklet.
The public may also contact the District Commissioners' offices, which
forwards the complaint to the Division.

No evidence was provided to demonstrate how the public is made aware of
their right to file a Title VI complaint or the procedure for doing so.
While there are contact numbers on the back of the bus schedules, no
specific mention is made of a customer's right to file a civil rights
complaint as it relates to Broward County Transit. Additionally, no
posters were found during the site visit that included information on
Broward County Transit's Title VI program or the procedures for filing a
complaint.

Subsequent to the draft report, BCT developed written procedures on
Title VI discrimination complaints and posted the procedures for filing
a complaint on BCT buses and will be printed in all future publications
developed by BCT. BCT also purchased and displayed posters in English
and Spanish to be posted in prominent places throughout BCT Transit
facilities. (Copies of these documents are included in Attachment 1).

[]{#__RefHeading___Toc94498693 .anchor}VII. SUMMARY OF FINDINGS AND
CORRECTIVE ACTIONS

+--------------+------+--------------------+------------+------+-----+
| **Title VI   | **   | **Description of   | **         | **   | **D |
| Requirements | Site | Deficiencies**     | Corrective | Resp | ate |
| For Transit  | Re   |                    | A          | onse | Cl  |
| Providers**  | view |                    | ction(s)** | D    | ose |
|              | F    |                    |            | ays/ | d** |
|              | indi |                    |            | Da   |     |
|              | ng** |                    |            | te** |     |
+==============+======+====================+============+======+=====+
| 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 DOT | ND   |                    |            |      |     |
| Title VI     |      |                    |            |      |     |
| Assurance    |      |                    |            |      |     |
+--------------+------+--------------------+------------+------+-----+
| 6\.          | ND   |                    |            |      |     |
| Fi           |      |                    |            |      |     |
| xed-Facility |      |                    |            |      |     |
| Impact       |      |                    |            |      |     |
| Analysis     |      |                    |            |      |     |
+--------------+------+--------------------+------------+------+-----+
| 7\.          | D    | > Maps do not      | > Submit   | Comp | 6   |
| Demographic  |      | > include:         | > to the   | lete | /05 |
| and Service  |      |                    | > FTA      |      |     |
| Maps,        |      | -   Minority       | > Region   |      |     |
| Overlays and |      |     population of  | > IV Civil |      |     |
| Charts       |      |     each census    | > Rights   |      |     |
|              |      |     tract          | > Officer: |      |     |
|              |      |                    |            |      |     |
|              |      | -   Community bus  | -   D      |      |     |
|              |      |     routes         | emographic |      |     |
|              |      |                    |            |      |     |
|              |      | Population         |    service |      |     |
|              |      | distribution chart |            |      |     |
|              |      | not provided.      |    profile |      |     |
|              |      |                    |     maps   |      |     |
|              |      |                    |     and    |      |     |
|              |      |                    |            |      |     |
|              |      |                    |   overlays |      |     |
|              |      |                    |     that   |      |     |
|              |      |                    |            |      |     |
|              |      |                    |    include |      |     |
|              |      |                    |     the    |      |     |
|              |      |                    |            |      |     |
|              |      |                    |   minority |      |     |
|              |      |                    |            |      |     |
|              |      |                    | population |      |     |
|              |      |                    |     of     |      |     |
|              |      |                    |     each   |      |     |
|              |      |                    |     census |      |     |
|              |      |                    |     tract  |      |     |
|              |      |                    |     and    |      |     |
|              |      |                    |            |      |     |
|              |      |                    |  Community |      |     |
|              |      |                    |     Bus    |      |     |
|              |      |                    |     routes |      |     |
|              |      |                    |            |      |     |
|              |      |                    | -          |      |     |
|              |      |                    | Population |      |     |
|              |      |                    |     di     |      |     |
|              |      |                    | stribution |      |     |
|              |      |                    |     chart. |      |     |
+--------------+------+--------------------+------------+------+-----+
| 8\. Service  | D    | > Following        | Submit to  | Comp | 6   |
| Standards    |      | > standards not    | the FTA    | lete | /05 |
| and Policies |      | > formally         | Region IV  |      |     |
|              |      | > defined:         | Civil      |      |     |
|              |      |                    | Rights     |      |     |
|              |      | -   Distribution   | Officer    |      |     |
|              |      |     of Transit     | adopted    |      |     |
|              |      |     Amenities      | service    |      |     |
|              |      |                    | standards  |      |     |
|              |      | -   Transit Access | for        |      |     |
|              |      |                    | vehicle    |      |     |
|              |      | Review the five    | a          |      |     |
|              |      | service standards  | ssignment, |      |     |
|              |      | to ensure they     | di         |      |     |
|              |      | reflect the        | stribution |      |     |
|              |      | standards          | of transit |      |     |
|              |      | currently          | amenities, |      |     |
|              |      | implemented by     | and        |      |     |
|              |      | Broward County     | transit    |      |     |
|              |      | Transit.           | access.    |      |     |
+--------------+------+--------------------+------------+------+-----+
| 9\.          | D    | > No evidence of   | Submit to  | Comp | 6   |
| Assessment   |      | > the process used | the FTA    | lete | /05 |
| of           |      | > to establish     | Region IV  |      |     |
| Compliance   |      | > internal         | Civil      |      |     |
| by Grantee   |      | > guidelines for   | Rights     |      |     |
|              |      | > making           | Officer    |      |     |
|              |      | > determinations   | procedures |      |     |
|              |      | > of compliance    | and        |      |     |
|              |      | > with Title VI as | guidelines |      |     |
|              |      | > part of local    | for        |      |     |
|              |      | > decision-making  | monitoring |      |     |
|              |      | > process and      | compliance |      |     |
|              |      | > continuing       | with Title |      |     |
|              |      | > project          | VI in      |      |     |
|              |      | > management and   | accordance |      |     |
|              |      | > contract         | with FTA   |      |     |
|              |      | > administration   | req        |      |     |
|              |      | > responsibilities | uirements. |      |     |
|              |      | >                  |            |      |     |
|              |      | > No evidence of   | Submit to  |      |     |
|              |      | > evaluation of    | the FTA    |      |     |
|              |      | > system wide      | Region IV  |      |     |
|              |      | > service changes  | Civil      |      |     |
|              |      | > and proposed     | Rights     |      |     |
|              |      | > improvements at  | Officer    |      |     |
|              |      | > the planning and | doc        |      |     |
|              |      | > programming      | umentation |      |     |
|              |      | > stages to        | evidencing |      |     |
|              |      | > determine        | that an    |      |     |
|              |      | > whether the      | evaluation |      |     |
|              |      | > overall costs    | on the     |      |     |
|              |      | > and benefits are | impact of  |      |     |
|              |      | > distributed      | system     |      |     |
|              |      | > equally and are  | service    |      |     |
|              |      | > not              | changes on |      |     |
|              |      | > discriminatory.  | the        |      |     |
|              |      |                    | minority   |      |     |
|              |      |                    | community  |      |     |
|              |      |                    | was        |      |     |
|              |      |                    | performed. |      |     |
+--------------+------+--------------------+------------+------+-----+
| 10\. Other   | D    | Service changes    | Submit to  | Comp | 6   |
| Areas of     |      | are not analyzed   | the FTA    | lete | /05 |
| Title VI     | ND   | for impacts on     | Region IV  |      |     |
| Co           |      | minority           | Civil      |      |     |
| nsiderations | ND   | communities or     | Rights     |      |     |
|              |      | riders.            | Officer    |      |     |
| Changes in   | ND   |                    | doc        |      |     |
| Service      |      |                    | umentation |      |     |
| Features     |      |                    | that       |      |     |
|              |      |                    | evidences  |      |     |
| Information  |      |                    | that an    |      |     |
| D            |      |                    | assessment |      |     |
| issemination |      |                    | of the     |      |     |
|              |      |                    | effects of |      |     |
| Minority     |      |                    | service    |      |     |
| Re           |      |                    | changes on |      |     |
| presentation |      |                    | minority   |      |     |
| on           |      |                    | transit    |      |     |
| Dec          |      |                    | users and  |      |     |
| ision-making |      |                    | c          |      |     |
| Bodied       |      |                    | ommunities |      |     |
|              |      |                    | has been   |      |     |
| M            |      |                    | im         |      |     |
| ulti-lingual |      |                    | plemented. |      |     |
| Facilities   |      |                    |            |      |     |
+--------------+------+--------------------+------------+------+-----+
| 11\.         | D    | > Broward County   | Submit to  | Comp | 6   |
| Monitoring   |      | > Transit did not  | the FTA    | lete | /05 |
| Procedures   |      | > provide          | Region IV  |      |     |
|              |      | > documentation of | Civil      |      |     |
|              |      | > completion of    | Rights     |      |     |
|              |      | > level and        | Officer    |      |     |
|              |      | > quality of       | doc        |      |     |
|              |      | > service          | umentation |      |     |
|              |      | > monitoring.      | that it    |      |     |
|              |      |                    | has        |      |     |
|              |      |                    | i          |      |     |
|              |      |                    | mplemented |      |     |
|              |      |                    | procedures |      |     |
|              |      |                    | for level  |      |     |
|              |      |                    | and        |      |     |
|              |      |                    | quality of |      |     |
|              |      |                    | service    |      |     |
|              |      |                    | m          |      |     |
|              |      |                    | onitoring. |      |     |
+--------------+------+--------------------+------------+------+-----+
| 12\. Title   | D    | Complaint          | Submit to  | Comp | 6   |
| VI           |      | procedures not     | the FTA    | lete | /05 |
| Complaints   |      | made available to  | Region IV  |      |     |
|              |      | the public.        | Civil      |      |     |
|              |      |                    | Rights     |      |     |
|              |      |                    | Officer    |      |     |
|              |      |                    | doc        |      |     |
|              |      |                    | umentation |      |     |
|              |      |                    | 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; AC = Advisory
Comment

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

+-------------+-----------------------+----------+--------------------+
| **NAME**    | *                     | *        | **E-MAIL**         |
|             | *ORGANIZATION/TITLE** | *PHONE** |                    |
+-------------+-----------------------+----------+--------------------+
| Frank       | FTA/Region IV Civil   | 404-     | <frank.b           |
| Billue      | Rights Officer        | 562-3528 | illue@fta.dot.gov> |
|             |                       |          |                    |
| (Via        |                       |          |                    |
| tele        |                       |          |                    |
| conference) |                       |          |                    |
+-------------+-----------------------+----------+--------------------+
| David       | FTA/Equal Opportunity | 202-     | <david.schn        |
| Schneider   | Specialist            | 493-0175 | eider@fta.dot.gov> |
|             |                       |          |                    |
| (Via        |                       |          |                    |
| tele        |                       |          |                    |
| conference) |                       |          |                    |
+-------------+-----------------------+----------+--------------------+
| Robert Roth | Broward County        | 954-     | <                  |
|             | Transit/Director      | 357-8361 | rroth@broward.org> |
+-------------+-----------------------+----------+--------------------+
| Lorraine    | Broward County        | 954-     | lo                 |
| Smith       | Transit/Assistant     | 357-8360 | rsmith@broward.org |
|             | Director              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Diane       | Broward County        | 954-     | dd                 |
| DeLyons     | Transit/Compliance &  | 357-8481 | elyons@broward.org |
| Shuler      | Admin Services        |          |                    |
|             | Transit Manager       |          |                    |
+-------------+-----------------------+----------+--------------------+
| Chris       | Broward County        | 954-     | <cw                |
| Walton      | Transit/Associate     | 357-8381 | alton@broward.org> |
|             | Director              |          |                    |
+-------------+-----------------------+----------+--------------------+
| Peter Wolz  | Broward County        | 954-     | <                  |
|             | T                     | 357-7714 | pwolz@broward.org> |
|             | ransit/Superintendent |          |                    |
+-------------+-----------------------+----------+--------------------+
| Debbie      | Broward County        | 954-     | d                  |
| Byrnes      | Transit/Associate     | 357-6647 | byrnes@broward.org |
|             | planner               |          |                    |
+-------------+-----------------------+----------+--------------------+
| Beth Chavez | Broward County        | 954-     | <bc                |
|             | Transit/Community     | 357-6394 | havez@broward.org> |
|             | Services Department   |          |                    |
|             | Deputy Director       |          |                    |
+-------------+-----------------------+----------+--------------------+
| Catondra    | Broward County        | 954-     | <                  |
| Noye        | Transit/Transit       | 357-8369 | cnoye@broward.org> |
|             | Manager               |          |                    |
+-------------+-----------------------+----------+--------------------+
| Phyllis     | Broward County        | 954-     | <p                 |
| Berry       | Transit/Manager --    | 357-8366 | berry@broward.org> |
|             | Marketing &           |          |                    |
|             | Communications        |          |                    |
+-------------+-----------------------+----------+--------------------+
| Justin      | Broward County        | 954-     | <jb                |
| Begley      | Transit/Associate     | 357-8337 | egley@broward.org> |
|             | Planner               |          |                    |
+-------------+-----------------------+----------+--------------------+
| Bob Fossa   | Broward County        | 954-     | <r                 |
|             | Transit/Senior        | 357-8336 | fossa@broward.org> |
|             | Planner               |          |                    |
+-------------+-----------------------+----------+--------------------+
| Andrea      | Broward County        | 954-     | <ab                |
| Busada      | Transit/Contract      | 357-8494 | usada@broward.org> |
|             | --Grant Admin III     |          |                    |
+-------------+-----------------------+----------+--------------------+
| Ed          | Broward County        | 954-     | <dwisni            |
| Wisniewski  | Transit/Paratransit   | 357-8321 | ewski@broward.org> |
|             | Manager               |          |                    |
+-------------+-----------------------+----------+--------------------+
| John A.     | Broward County        | 954-     | jramos@broward.org |
| Ramos       | MPO/Associate Planner | 357-6657 |                    |
+-------------+-----------------------+----------+--------------------+
| Rebecca     | Broward County        | 954-     | <rho               |
| Horwitz     | Transit/Finance &     | 357-6780 | rwitz@broward.org> |
|             | Business Operations   |          |                    |
|             | Transit Manager       |          |                    |
+-------------+-----------------------+----------+--------------------+
| Roosevelt   | Broward County        | 954-     | <rwa               |
| Walters     | Transit/Specialist    | 357-8364 | lters@broward.org> |
|             | III                   |          |                    |
+-------------+-----------------------+----------+--------------------+
| Wanda Del   | Broward County/EEO    | 954-     | wd                 |
| Toro        | Division              | 357-7800 | eltoro@broward.org |
+-------------+-----------------------+----------+--------------------+
| Jim Buckley | Milligan & Company,   | 410-     | <jbuckle           |
|             | LLC/Lead Reviewer     | 732-4626 | y@milligancpa.com> |
+-------------+-----------------------+----------+--------------------+
| Diane King  | Milligan & Company,   | 215-     | <dkin              |
|             | LLC/Reviewer          | 496-9100 | g@milligancpa.com> |
|             |                       | X 135    |                    |
+-------------+-----------------------+----------+--------------------+
| Sandra      | Milligan & Company,   | 215-     | <sswiack           |
| Swiacki     | LLC/Reviewer          | 496-9100 | i@milligancpa.com> |
|             |                       | x120     |                    |
+-------------+-----------------------+----------+--------------------+
| Ann Marie   | Milligan & Company,   | 215-     | abyrn              |
| Byrnes      | LLC/Reviewer          | 496-9100 | es@milligancpa.com |
|             |                       | x151     |                    |
+-------------+-----------------------+----------+--------------------+