**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**MTA NEW YORK CITY TRANSIT**

**(NYCT)**

**NEW YORK, NY**

**Final Report**

**November 2003**

**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___Toc51057800)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc51057801)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc51057802)

IV\. BACKGROUND INFORMATION [5](#__RefHeading___Toc51057803)

V. SCOPE AND METHODOLOGY [8](#__RefHeading___Toc51057804)

VI\. FINDINGS AND RECOMMENDATIONS [17](#__RefHeading___Toc51057805)

1\. List of Active Complaints and Lawsuits
[17](#__RefHeading___Toc51057806)

2\. Pending Applications for Financial Assistance
[18](#__RefHeading___Toc51057807)

3\. Summary of Civil Rights Compliance Reviews
[18](#__RefHeading___Toc51057808)

4\. FTA Civil Rights Assurance [19](#__RefHeading___Toc51057809)

5\. DOT Title VI Assurance [20](#__RefHeading___Toc51057810)

6\. Fixed-Facility (Environmental Justice) Impact Analysis
[20](#__RefHeading___Toc51057811)

7\. Demographic and Service Profile Maps, Overlays and Charts
[23](#__RefHeading___Toc51057812)

8\. Service Standards and Policies [24](#__RefHeading___Toc51057813)

9\. Assessment of Compliance by Grantees
[27](#__RefHeading___Toc51057814)

10\. Other Areas of Title VI Considerations
[29](#__RefHeading___Toc51057815)

11\. Internal Monitoring Procedures 29

12\. Title VI Complaints [36](#__RefHeading___Toc51057817)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[39](#__RefHeading___Toc51057818)

VIII\.
ATTENDEES\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....42

I.  []{#__RefHeading___Toc51057800 .anchor}GENERAL INFORMATION

Grant Recipient: MTA New York City Transit

130 Livingston Street

Brooklyn, NY 11201

City/State: New York, New York

Grantee No: 1786

Executive Official: Mr. Lawrence G. Reuter

President

MTA New York City Transit

130 Livingston Street

Brooklyn, NY 11201

Report Prepared By: MILLIGAN & CO., LLC

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

Mulberry Atrium North

Philadelphia, PA 19103

Site Visit Dates: August 12, 2003 to August 15, 2003

Compliance Review

Team Members: Denise Bailey Jim Buckley

Lead Reviewer Reviewer

Milligan & Co. Milligan & Co.

Joseph Herzog Sandra Swiacki

> Reviewer Reviewer

Milligan & Co. Milligan & Co.

Norris Smith

Reviewer

Milligan & Co.

II. []{#__RefHeading___Toc51057801 .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 C.A. (9), October 1,
2002; and 49 U.S.C. 5332, "Non-Discrimination."

New York City Transit (NYCT) 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
NYCT's Title VI Program and were the basis for the selection of
compliance elements that were reviewed in this document.

[]{#__RefHeading___Toc51057802 .anchor}**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 New York City Transit (NYCT)
Title VI Program was necessary.

The Office of Civil Rights authorized Milligan & Co., LLC to conduct the
Title VI Compliance Review of NYCT. The primary purpose of this
Compliance Review was to determine the extent to which NYCT 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 NYCT.

#### 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

-   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___Toc51057803 .anchor}IV. BACKGROUND INFORMATION

New York City Transit (NYCT) was created by the New York State
legislature in 1953 to operate all New York city-owned subway and bus
lines. The transit facilities are owned by the city of New York and
leased to and operated by the NYCT. Under New York State Public
Authorities Law 1201, NYCT is a separate public corporation.

New York City Transit (NYCT) is the largest transit system in the
nation, carrying over 7.1 million unlinked passenger trips on an average
weekday. It serves a population of over eight million people in all five
boroughs of the city of New York and provides subway, bus, and
paratransit service.

The Metropolitan Transportation Authority (MTA) was created by the State
Legislature in 1968 and became NYCT\'s parent agency. NYCT along with
the Long Island Railroad, Metro North Railroad and Long Island Bus are
operating subsidiaries of the MTA. These operators share a common Board
of Directors with the MTA. In the past, the operators received grants
directly from the FTA. All grants are now made with the MTA on behalf of
its subsidiaries.

New York City's first underground subway system began operating in 1904.
The current subway system provides extensive daily 24-hour service in
Manhattan, Brooklyn, Queens, and the Bronx to 468 stations along 656
mainline miles of track. NYCT operates 6,464 subway cars in a complex
combination of express and local services on a variety of structures
(subways, elevated lines, and open cuts). The subway carries
approximately 4.6 million unlinked passenger trips on an average
weekday. NYCT also operates the Staten Island Railway (SIR). SIR has a
14.3-mile two-track route from southern Staten Island to the St. George
terminal, an intermodal connection to the ferry to Manhattan. There are
approximately 44 rail cars and 23 passenger stations that serve
approximately 11,000 daily customers.

NYCT has an active fleet of 4,513 buses. Since 1994, the entire bus
fleet has been lift-equipped. During rush hour, service is provided
along a network of 244 routes (206 local and 38 express) consisting of
1,671 route miles and over 14,000 bus stops. The bus fleet carries
approximately 2.4 million unlinked passenger trips on an average
weekday. With the exception of 18 buses that are over 12 years old, the
entire bus fleet is funded with 100 percent local funds.

The basic adult fare for the NYCT subways and local buses is \$2.00. The
fare for NYCT express bus service is \$4.00. NYCT's primary fare
instrument is a stored-value MetroCard for use on buses and in all
subway stations. This medium permits a passenger to transfer without
charge between the bus and subway systems. Senior citizens, persons with
disabilities and Medicare cardholders are eligible for reduced fares for
all subway and regular bus service. Express bus reduced fares are
available on weekdays during off-peak hours and all day on weekends and
holidays. Reduced fares are 50 percent of the posted single ride fare.

Access-A-Ride is the complementary paratransit service for transit in
New York City. This service was started by NYCDOT. Administrative
responsibility was transferred to the Metropolitan Transportation
Authority (MTA) when the program was expanded to serve the ADA needs of
New York City Transit. Private contractors operate the program. A total
fleet of 843 vehicles is currently used for the service.

The general demographic characteristics of the NYCT service area by
borough is indicated below:

**Racial/ Ethnic Breakdown of NYCT Service Area by Borough**

######### 2000 Census

+-----------+-----------+-------+--------+--------+--------+---------+
| **Racial/ | ####      | ##    | ####   | ###    | #### Q | #### R  |
| Ethnic    |  NYCT Ser | ## Br |  Kings | # New  | ueens  | ichmond |
| Group**   | vice Area | onx C |        | York C | County |  County |
|           |           | ounty | ####   | ounty  |        |         |
|           | ##        |  Tota | County | Total/ | ##     | **T     |
|           | ## Total/ | l/ Pe |        |        | # **To | otal/** |
|           |           | rcent | **To   | **Per  | tal/** |         |
|           | ###       |       | tal**/ | cent** |        | **Pe    |
|           | # Percent |       |        |        | **Per  | rcent** |
|           |           |       | #### P |        | cent** |         |
|           |           |       | ercent |        |        |         |
+-----------+-----------+-------+--------+--------+--------+---------+
| #         | ####      | 19    | 8      | 7      | #### 7 | ####    |
| ### White | 2,801,267 | 3,651 | 54,532 | 03,873 | 32,895 | 316,316 |
|           |           |       |        |        |        |         |
|           | 35.0%     | 14.5% | 34.7%  | 45.8%  | 32.9%  | 71.3%   |
+-----------+-----------+-------+--------+--------+--------+---------+
| #         | ####      | 41    | 8      | 2      | #### 4 | ####    |
| ### Black | 1,962,154 | 6,338 | 48,583 | 34,698 | 22,831 |  39,704 |
|           |           |       |        |        |        |         |
|           | 24.5%     | 31.2% | 34.4%  | 15.3%  | 19.0%  | 8.9%    |
+-----------+-----------+-------+--------+--------+--------+---------+
| #### Amer | ##        | 3,488 | 4,494  | 2,465  | ####   | #       |
| ican Indi | ## 17,321 |       |        |        |  6,275 | ### 599 |
| an /Alask |           | 0.26% | 0.18%  | 0.16%  |        |         |
| an Native | 0.22%     |       |        |        | 0.28%  | 0.13%   |
+-----------+-----------+-------+--------+--------+--------+---------+
| #### Asia | 783,058   | 39032 | #### 2 | 1      | ####   | ####    |
| n/Pacific |           |       | 00,348 | 43,863 | 390164 |  24,905 |
|  Islander | 9.8%      | 2.9%  |        |        |        |         |
|           |           |       | 7.5%   | 9.3%   | 17.5%  | 5.6%    |
| ####      |           |       |        |        |        |         |
+-----------+-----------+-------+--------+--------+--------+---------+
| #### Hi   | ####      | ##    | 4      | 4      | #### 5 | ####    |
| spanic Or | 2,160,554 | ## 64 | 87,878 | 17,816 | 56,605 |  53,550 |
| igin (of  |           | 4,705 |        |        |        |         |
| any race) | 27.0%     |       | 19.8%  | 27.2%  | 25.0%  | 12.1%   |
|           |           | 48.4% |        |        |        |         |
+-----------+-----------+-------+--------+--------+--------+---------+
| #         | 283,924   | 3     | 84,745 | 34,480 | #### 1 | ###     |
| ### Other |           | 5,436 |        |        | 20,609 | # 8,654 |
| /Two or M | 3.5%      |       | 3.4%   | 2.2%   |        |         |
| ore Races |           | 2.7%  |        |        | 5.4%   | 1.9%    |
+-----------+-----------+-------+--------+--------+--------+---------+
| ###       | **8,      | **1   | *      | *      | ##     | ####    |
| # Total P | 008,278** | ,332, | *2,465 | *1,537 | ## 2,2 | 443,728 |
| opulation |           | 650** | ,326** | ,195** | 29,379 |         |
+-----------+-----------+-------+--------+--------+--------+---------+
| ####      | *         | **85. | **65   | **54   | ####   | ####    |
| *Total Mi | *65.02%** | 47%** | .34%** | .21%** | 67.13% |  28.71% |
| norities* |           |       |        |        |        |         |
+-----------+-----------+-------+--------+--------+--------+---------+

[]{#__RefHeading___Toc51057804 .anchor}V. SCOPE AND METHODOLOGY

#### Scope

The Title VI Compliance Review of NYCT 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.  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.

```{=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; and

d.  information on 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

[Data Collection]{.underline}

An initial interview was conducted with the Region II Civil Rights
Officer to discuss specific Title VI issues and concerns regarding NYCT.
A desk review was conducted to examine documents regarding Title VI
issues that were previously submitted to FTA. A detailed letter was also
sent to NYCT advising it of the site visit and indicating information
that would be needed and issues that would be discussed.

In the letter, NYCT was requested to provide the following background
information:

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

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

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

-   Any studies or surveys conducted by NYCT, 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, NYCT was requested to provide an update of the following
General Reporting Requirements (Chapter III, Section 2 of FTA Circular
4702.1) since its March 2002 Title VI submittal to FTA.

-   A list of any active lawsuits and complaints

```{=html}
<!-- -->
```
-   Pending grant applications

```{=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

NYCT 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 March 2002 Title VI
submittal to FTA Region II.

-   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 populations
    based on 2000 census tract data or TAZ, and which show transit
    services (e.g., bus routes, rail lines, 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 NYCT 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 NYCT for each bus route and rail line 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 rail
    stations and bus stops.

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

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

```{=html}
<!-- -->
```
-   Passenger boardings by bus stop and rail stations

-   Maximum load points by route and rail line

-   Fleet inventory for buses and rail cars, by garage or shop, 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}
<!-- -->
```
-   Inventory of rail transit stations that indicates: location in a
    minority or non-minority area (ranked from highest concentration of
    minorities to the lowest concentration of minorities); date of the
    station opening; list of amenities; any design features that impact
    maintenance and security; number of trips per route (identified as
    minority and non-minority) serving the station on an average weekday

-   NYCT criteria for ranking stations to determine allocation of
    personnel and resources (e.g., weekday boardings, number of bus
    trips, etc.)

-   Actual operating and capital expenditures by rail station for the
    past three years in the following areas: routine maintenance;
    capital improvements; security (Station Agent or Police); labor
    hours per station for maintenance and security

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

In addition, NYCT 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

```{=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 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

```{=html}
<!-- -->
```
-   Description of NYCT's internal monitoring procedure to insure that
    its level and quality of service is in compliance with Title VI,
    along with copies of NYCT'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 available to the public that describe the
    process for filing complaints.

[Site Visit]{.underline}

The site visit to NYCT took place August 12 to August 14, 2003. The exit
conference, scheduled for August 15, 2003, occurred on September 3,
2003, due to the power blackout on August 14-15, 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. The focus of the site visit
then turned to the status of the information requested in the letter
notifying NYCT of the Compliance Review. Arrangements were also made for
a tour of NYCT facilities and interviews with NYCT's staff and community
representatives.

During the site visit, the review team conducted tours of four subway
stations located in both minority and non-minority communities to
compare their condition, maintenance, transit amenities, and
rehabilitation or modernization. These stations on the A Line included
Utica, Hoyt, Jay Street and Broadway/Nassau. The review team also
conducted tours of four operating depots to assess vehicle condition,
fleet age, fuel type, and the presence of safety-related signage and
information in languages other than English. The depots included three
that serve minority communities (Mother Clara Hale, Jackie Gleason, and
Fresh Pond) and one that served a non-minority community (126^th^ St.).
Lastly, the site visit included a tour of the 100^th^ Street Depot that
was recently renovated and scheduled to reopen in September 2003.

Interviews were conducted with NYCT's staff to provide information on
the extent to which Title VI requirements are incorporated in the
planning and implementation of service by NYCT. The interviews also
focused on staff efforts to make communications and information
available in non-English formats for minority groups, as required.
Interviews were also conducted with leaders within the community to gain
insight on how the minority community is represented and participates in
NYCT's planning process. Those interviewed included representatives from
the Permanent Citizens' Advisory Committee, Community Board 12 in
Harlem, and Community Board 13 in Coney Island.

At the exit conference, the Lead Reviewer and NYCT's management
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___Toc51057805 .anchor}VI. FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on New York City Transit's (NYCT)
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___Toc51057806 .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 NYCT, no
deficiencies were found with FTA requirements for a List of Active
Complaints and Lawsuits. At the time of the Compliance Review site
visit, there was only one active Title VI complaint that was filed with
the United States Department of Transportation (DOT) in November 2000 by
West Harlem Environmental Action, Inc. (WE ACT) and other individual
complainants.

The complaint alleges discrimination against African-American and Latino
residents of Northern Manhattan in the development and operation of bus
parking lots and bus depots. The complaint specifically alleges that a
disproportionately high number of MTA/NYCT's bus depots in New York City
are located in predominantly non-white neighborhoods in Northern
Manhattan. Furthermore, indoor bus depots, together with parking lots
that are used for outdoor bus storage, are "eyesores" that "contribute
significantly to localized air pollution impacts" and expose African
American and Latino residents of Northern Manhattan to
disproportionately high health risks from diesel exhaust. A formal
response to the allegations was submitted by MTA to the DOT in March
2001. At the time of the site visit, the complaint was still pending
resolution.

2.  []{#__RefHeading___Toc51057807 .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 NYCT, no
deficiencies were found with FTA requirements for Pending Applications
for Financial Assistance. At the site visit, NYCT provided a list of its
pending applications for financial assistance from the Transportation
Electronic Award and Management (TEAM) system.

3.  []{#__RefHeading___Toc51057808 .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 NYCT, no
deficiencies were found with FTA requirements for Summary of Civil
Rights Compliance Reviews. Neither FTA nor any other oversight agency
has conducted a civil rights review in the past three years. The FTA
Triennial Review conducted in December 2002 examined Civil Rights
requirements and found no deficiencies with FTA requirements for the
Title VI Program. However, two areas, Disadvantaged Business Enterprise
(DBE) and Equal Employment Opportunity (EEO), were not covered during
the Triennial Review since both programs are the primary responsibility
of the MTA.

4.  []{#__RefHeading___Toc51057809 .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 NYCT, no
deficiencies were found with FTA requirements for FTA Civil Rights
Assurance. At the site visit, NYCT provided a copy of its most recently
signed FTA Civil Rights Assurance dated March 25, 2002.

5.  []{#__RefHeading___Toc51057810 .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 NYCT, no
deficiencies were found with FTA requirements for DOT Title VI
Assurance. At the site visit, NYCT provided a copy of its most recently
signed DOT Title VI Assurance dated March 25, 2002.

6.  []{#__RefHeading___Toc51057811 .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 environmental assessment or environmental impact
statement.

**Finding:** During this Title VI Compliance Review of NYCT,
deficiencies were found with FTA requirements for Fixed Facility Impact
Analysis. In its 2002 Title VI submission, in lieu of a section
addressing fixed-facility impact analysis, NYCT has a section entitled
"Environmental Assessment." In this section, NYCT lists three federally
funded construction projects for which it conducted environmental
assessments (EA). These projects were identified as: Atlantic Terminal
Complex Rehabilitation, 72^nd^ St. Station Rehabilitation, and
Rehabilitation of Roosevelt Ave/74^th^ St. Station Complex. NYCT
additionally notes that federally funded projects classified as
Categorical Exclusions do not require the preparation of an
environmental assessment. For these projects, no fixed facility impact
analysis was conducted. Through discussions with FTA's Office of Civil
Rights and Office of Planning, it was determined that there was not an
exemption from conducting a fixed-facility impact analysis if a project
is a Categorical Exclusion.

More recent projects for which environmental assessments were conducted
were reviewed at the site visit. These included the Grand Avenue Depot
and Central Maintenance Facility II project and the New Corona
Maintenance Shop, Car Wash, and Yard Reconfiguration project.
Additionally, in its response to the WE ACT complaint, MTA included the
environmental assessment from the 100^th^ St. Bus Depot Replacement. An
analysis was done to compare the required elements of a fixed-facility
impact analysis from FTA Circular 4702.1 to the information included in
the environmental assessments reviewed on-site.

  ---------------------- -------------------- -------------------- ----------------
  **4702.1 FFIA          **Grand Avenue EA**  **New Corona EA**    **100th St.
  Element**                                                        Depot EA**

  Discussion of          Discusses potential  Discusses potential  Discusses
  potential impacts on   temporary impacts    temporary impacts    potential
  minority communities   during and after     during and after     temporary
  and minority-owned     construction, not    construction, not    impacts during
  businesses during and  specifically to      specifically to      and after
  after construction     minority communities minority communities construction,
                         or businesses.       or businesses.       not specifically
                                                                   to minority
                                                                   communities or
                                                                   businesses.

  Discussion of all      Discussion of during Discussion of during Discussion of
  potential negative     and after potential  and after potential  during and after
  environmental impact,  negative impacts.    negative impacts.    potential
  such as noise, air, or Negatives noted      Negatives noted      negative
  water pollution        during construction  during construction  impacts.
                         include dust, noise. include dust, noise. Negatives noted
                                                                   during
                                                                   construction
                                                                   include
                                                                   temporary
                                                                   pedestrian
                                                                   detours, dust,
                                                                   noise,
                                                                   vibration,
                                                                   short-term
                                                                   utility
                                                                   interruptions.

  Detailed list of       Noted that no        Noted that no        Noted that there
  minority-owned         businesses would be  businesses would be  would be no
  businesses and         affected temporarily affected temporarily disruption to
  households that will   or permanently by    or permanently by    existing
  be affected by the     the project. No      the project. No      businesses and
  construction project   specific listing of  specific listing of  that access
                         households and       households and       would be
                         businesses affected  businesses affected  maintained. No
                         by potential         by potential         specific listing
                         negative impacts     negative impacts     of households
                         noted in above       noted in above       and businesses
                         element.             element.             affected by
                                                                   potential
                                                                   negative impacts
                                                                   noted in above
                                                                   element.

  Description of other   Evaluated, concluded Evaluated, concluded No negative
  significant changes or that there would be  that there would be  impacts noted,
  impacts on the         no                   no                   positive impacts
  minority community,    disproportionately   disproportionately   of new depot on
  such as increased      high and adverse     high and adverse     community (less
  traffic, reductions in impacts on human     impacts on human     on-street
  the amount of          health and the       health and the       employee
  available parking,     environment.         environment.         parking,
  etc.                                                             reduction of
                                                                   on-street bus
                                                                   queuing) noted.

  Description of         No adverse effects   No adverse effects   Evaluation of
  measures to mitigate   identified that      identified that      community's
  any identified adverse would necessitate    would necessitate    alternative
  social, economic, or   mitigation.          mitigation.          solutions
  environmental effect                                             (no-build, three
  of the proposed                                                  floors with a
  construction project.                                            cellar, four
                                                                   floor
                                                                   structure).
  ---------------------- -------------------- -------------------- ----------------

This comparison shows that much of the fixed-facility impact analysis is
conducted in the EA process, but where impacts are identified the
detailed information on minority households and businesses is not
included. In each of the environmental assessments evaluated in the
above chart, an analysis of racial and economic make-up of the project
area was included in the "Environmental Justice" section.

**Corrective Actions and Schedule:** Within 90 days, NYCT must submit to
the FTA Region II Civil Rights Officer a written process or procedure to
ensure that a fixed-facility impact analysis is conducted for all
federally funded projects in compliance with FTA requirements. In its
future Title VI submissions, NYCT should note if this information was
prepared as the result of an environmental assessment and attach the
detailed sections (in lieu of summary section) so that FTA can determine
that all elements are addressed.

#### 

7.  []{#__RefHeading___Toc51057812 .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 NYCT, no
deficiencies were found with FTA requirements for Demographic and
Service Profile Maps, Overlays and Charts. In its Title VI submittal and
information provided at the site visit, NYCT provided integrated maps
and overlays that met with the Title VI Requirements, as follows:

-   **Base Maps and Overlays --** For each of the five counties in its
    service area (New York, Queens, Kings, Bronx, and Richmond), NYCT
    provided a legible scaled base map that identified each census tract
    by number. It also included separate maps for each county that
    identified subway service, bus routes, major streets and highways,
    major trip generators, and maintenance and garage facilities. Each
    of these maps included a color-coded integrated overlay that denoted
    minority and non-minority census tracts.

-   **Population/Racial Distribution Charts --** For each of the five
    counties in its service area, NYCT provided population distribution
    charts that follow the format suggested in FTA Circular 4702.1.
    Additionally, NYCT provided maps and overlays that capture the
    income analysis for each of the five counties.

8.  []{#__RefHeading___Toc51057813 .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 NYCT,
deficiencies were found with FTA requirements for Service Standards and
Policies. In its Title VI submittal and in information provided at the
site visit, it was determined that NYCT currently only has two of the
five recommended FTA service standard indicators in place. The results
of this review are summarized in the following table:

+-----------------+-------------------------+--------------------------+
| **FTA Service   | **NYCT Policy**         | #### Comments            |
| Standard**      |                         |                          |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | **Bus** -- Service      | > At least 1/3 of each   |
| Load** - A      | guidelines are          | > subway route's total   |
| ratio of the    | established by the      | > mileage is in a        |
| number of       | number of riders        | > minority census tract  |
| passengers on a | passing the maximum     | > or traffic analysis    |
| vehicle to the  | load point (MLP).       | > zone, therefore, all   |
| number of seats | During peak periods,    | > NYCT subway routes are |
|                 | feeder routes are       | > classified under Title |
|                 | scheduled for 70        | > VI as minority routes. |
|                 | passengers per bus at   |                          |
|                 | the MLP; 60 for grid    |                          |
|                 | routes; 50 during       |                          |
|                 | midday and weekends; 35 |                          |
|                 | in the evening; and 25  |                          |
|                 | per bus at the MLP in   |                          |
|                 | the owl period.         |                          |
|                 |                         |                          |
|                 | **Subway** --           |                          |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | Subsequent to the site  | It is described in the   |
| Assignment      | visit, NYCT submitted a | Title VI submission that |
| -**The process  | draft policy to the     | buses are not assigned   |
| by which        | review team and FTA     | to a particular route    |
| vehicles are    | that provided the       | within a depot, but are  |
| assigned to     | standard for average    | assigned to a certain    |
| routes          | age of buses assigned   | depot. This was          |
| throughout the  | to depots to be 7.5     | confirmed at the bus     |
| system due to   | years.                  | depot visits conducted   |
| variations      |                         | during the site review.  |
| among vehicles  |                         | In general, new buses    |
| (age, size,     |                         | are assigned depots with |
| amenities,      |                         | the oldest buses,        |
| etc.).          |                         | however some variances   |
|                 |                         | in this may occur due to |
|                 |                         | type of equipment (CNG,  |
|                 |                         | etc). Age of fleet in    |
|                 |                         | each depot is tracked.   |
|                 |                         | Additionally, subsequent |
|                 |                         | to the site review, NYCT |
|                 |                         | provided information in  |
|                 |                         | its draft policy on      |
|                 |                         | routine and overhaul bus |
|                 |                         | maintenance activities.  |
+-----------------+-------------------------+--------------------------+
| **Vehicle       | **Bus** -- headways in  |                          |
| Headway** -     | terms of minutes        |                          |
|                 | include 60, 30, 20, 15, |                          |
| The time        | 12, 10, 6, 7.5, and 5   |                          |
| interval        | and under. Frequency is |                          |
| between two     | determined by the       |                          |
| vehicles        | application of loading  |                          |
| traveling in    | standards to counted    |                          |
| the same        | levels of riders.       |                          |
| direction on    |                         |                          |
| the same route  | A sliding scale is      |                          |
|                 | applied for feeder and  |                          |
|                 | grid routes during      |                          |
|                 | peak, midday, evening   |                          |
|                 | and owl.                |                          |
|                 |                         |                          |
|                 | Express Service -- 30   |                          |
|                 | minutes for peak and    |                          |
|                 | midday; and 60 minutes  |                          |
|                 | for evening and         |                          |
|                 | weekends.               |                          |
|                 |                         |                          |
|                 | #### Subway -- 10       |                          |
|                 | minutes for weekday rus |                          |
|                 | h, midday and Saturday; |                          |
|                 |  12 minutes for evening |                          |
|                 | s and Sundays; and 20 m |                          |
|                 | inutes for owl service. |                          |
+-----------------+-------------------------+--------------------------+
| **Distribution  | Subsequent to the site  | > NYCT conducts a        |
| of Transit      | review, NYCT provided a | > quarterly Passenger    |
| Amenities** -   | draft policy with       | > Environment Survey     |
|                 | additional information  | > (PES) where it         |
| Criteria for    | on how it approaches    | > attempts to quantify   |
| installation of | the selection of subway | > how amenable and       |
| items of        | stations for            | > comfortable the        |
| comfort and     | modernization, ADA      | > transit environment is |
| convenience     | accessibility           | > to its customers. This |
| available to    | improvements, elevators | > survey evaluates items |
| the general     | and escalators, but     | > such as functioning    |
| public          | provided no standards   | > equipment, customer    |
|                 | for these amenities,    | > information,           |
|                 | other than an analysis  | > cleanliness, etc. In   |
|                 | of which stations had   | > its Title VI           |
|                 | completed activities in | > submission, the        |
|                 | the above areas.        | > description of transit |
|                 |                         | > amenities is limited   |
|                 | It is noted that New    | > to whether the station |
|                 | York City Department of | > has been modernized,   |
|                 | Transportation (NYCDOT) | > if it is ADA           |
|                 | is responsible for the  | > accessible, and if     |
|                 | placement and           | > escalators, elevators, |
|                 | maintenance of bus      | > and token clerks are   |
|                 | stops and shelters in   | > present. In its draft  |
|                 | the service area,       | > standards policy       |
|                 | therefore this          | > submitted to the       |
|                 | potential amenity was   | > review team and FTA    |
|                 | not evaluated under     | > subsequent to the site |
|                 | this review of NYCT.    | > review, it was noted   |
|                 |                         | > that the presence of   |
|                 |                         | > token clerks was no    |
|                 |                         | > longer in the transit  |
|                 |                         | > amenities standards.   |
+-----------------+-------------------------+--------------------------+
| **Transit       | > Subsequent to the     | > In the Title VI        |
| Access** - The  | > site review, NYCT     | > submission, detailed   |
| distance a      | > submitted to the      | > analysis of transit    |
| person must     | > review team and FTA a | > access was presented,  |
| travel to gain  | > draft policy on       | > but no established     |
| access to       | > transit access that   | > standard was provided. |
| transit service | > notes that the        |                          |
|                 | > typical industry      |                          |
|                 | > practice (not a       |                          |
|                 | > formal standard) for  |                          |
|                 | > transit access        |                          |
|                 | > distance is ¼ mile.   |                          |
+-----------------+-------------------------+--------------------------+

**Corrective Actions and Schedule:** Within 90 days, NYCT must submit to
the FTA Region II Civil Rights Officer the finalized service standards
for vehicle assignment and transit access that were provided in draft
form. Additionally, NYCT should submit standards for transit amenities.

Additionally, NYCT should consider expanding its definition of "transit
amenity" to include additional items of comfort and convenience, as it
does in its Passenger Environment Survey.

9.  []{#__RefHeading___Toc51057814 .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 NYCT,
deficiencies were found with FTA requirements for Assessment of
Compliance by Grantees. During the site review, NYCT provided
information on their budgeting process, planning process and project
development criteria. However, the review team could not determine how
NYCT evaluates system wide changes and proposed improvements at the
planning and programming stages to determine whether the overall
benefits and costs of such changes or improvements are distributed
equally, and are not discriminatory. Additionally, there was no evidence
that NYCT makes determinations of compliance with Title VI a part of
local decision-making processes and continuing project management and
contract administration responsibilities.

One topic examined in this area was the implementation of the Subway
Station Rehabilitation Program. The objective of this program is to
bring each station into a state of good repair that addresses all
structural problems and creates an esthetically pleasing customer
environment. NYCT classifies its subway stations as minority or
non-minority based on the demographics of the community surrounding each
station. NYCT provided the review team with written station selection
criteria and design guidelines for the rehabilitation program; however,
the review team was not able to determine that an assessment was done on
the timing and costs of these improvements to demonstrate that these
improvements are equally distributed. It was noted that each of the 468
subway stations would be modernized by the end of the program. The
timeframe for the completion of this program exceeds 20 years, and the
review team suggested that these improvements, along with other system
improvements and changes, should be evaluated at shorter intervals to
adequately assess compliance with Title VI.

**Corrective Actions and Schedule:** Within 90 days, NYCT must submit to
the FTA Region II Civil Rights Officer documentation that it has
developed procedures and guidelines for monitoring compliance with Title
VI in accordance with FTA requirements.

10. []{#__RefHeading___Toc51057815 .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 NYCT, no
deficiencies were found with FTA requirements for Changes in Service
Features. According to the most recent Title VI Program and information
provided at the site visit, NYCT implemented a number of service changes
during the period of July 1998 through June 2002. NYCT provided
documentation that it made adequate efforts to assess the impact of
service changes on minority riders. An analysis of the proposed service
changes, including descriptions and rationale were provided to the
review team. A review of this analysis indicated that the majority of
service changes during this period were implemented to improve service
and therefore had a positive impact on minority riders.

######## 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 NYCT, no
> deficiencies were found with FTA requirements for Information
> Dissemination. Adequate documentation was provided to demonstrate that
> NYCT regularly communicates with minority groups on changes related to
> transit service and improvements. Documentation of these efforts
> included samples of informational notices and brochures that were
> developed and distributed to the riding public, and transcripts and
> correspondence from public hearings and community meetings. NYCT also
> demonstrated that it utilizes a variety of ethnic media to advertise
> construction projects in the community and to notify riders of service
> changes. Additionally, many of the communication methods were seen
> during site visits to Community Board 12 and 13 and the Permanent
> Citizens Advisory Committee.

######## 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 NYCT, an advisory
comment was made with FTA requirements for Minority Representation on
Decision-Making Bodies. A board comprised of 17 members governs the MTA.
Members are nominated by the Governor, with four recommended by New York
City's mayor and one each by the county executives of Nassau, Suffolk,
Westchester, Dutchess, Orange, Rockland, and Putnam Counties. The
members representing the latter four counties cast one collective vote.
The Board also has six rotating non-voting seats held by representatives
of organized labor and the Permanent Citizens Advisory Committee (PCAC).
The New York State Senate confirms all Board Members. Information on the
PCAC provided in the Title VI submission states that it serves as a
voice for users of MTA transit and commuter facilities.

According to the most recent Title VI submission, minorities represent
8.7 percent (2 of 23) of the MTA Board Members and 6.25 percent (2 of
32) of the PCAC. During the site visit, no documentation was provided to
demonstrate efforts made to encourage minorities to participate on such
boards, councils, or committees. Subsequent to the site visit, NYCT/MTA
submitted information that they have no involvement in, nor do they feel
that they have the authority to influence, the make-up of MTA's Board.

**Advisory Comment:** While NYCT has no authority to encourage minority
participation on MTA governing boards, FTA encourages NYCT to advise
those officials responsible for appointing board members of the
requirements of Circular 4702.1, under Chapter III part 4 ( C ),
[Minority Representation on Decisionmaking Bodies.]{.underline}

######## 

######## 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 NYCT,
deficiencies were found with FTA requirements for Multilingual
Facilities. According to their Title VI Program, public information
regarding transit services is primarily produced in English and Spanish.
In addition, other languages are occasionally used for specific
situations. These languages include Creole, Arabic, Chinese, French,
Greek, Hebrew, Hindi, Italian, Japanese, Portuguese, Urdu, Polish,
Korean and Russian. NYCT also utilizes an outside interpreting agency,
Language Line Services, to provide callers with travel information in
over 140 languages. The Title VI submission also notes that signs
depicting emergency evacuation procedures or health and safety related
warnings were in both English and Spanish.

During the site visit, evidence of various multilingual communications
including maps, signage, advertisements for construction projects,
service change notices, and informational brochures were provided and
viewed during facility visits. However, a sampling of vehicles and
facilities during the on-site tours failed to confirm the consistent use
of Spanish in safety and emergency evacuation procedures, as NYCT's
Title VI submission states. It was noted that most safety signage is
written in English with an accompanying pictograph.

Subsequent to the site review, NYCT submitted a draft Policy for
Translating Customer Information Materials. This policy included
sections on service change information, safety messages, fare policy
information, and distribution of customer information materials.
Distribution of this policy is noted as being to the Marketing and
Service Information Division, Government and Community Relations
Division, Operations Planning Division, Division of Stations, Department
of Subways, and Customer Relations Unit, Department of Buses.

Additionally, during the site visit, information was shared with NYCT on
the Federal Register notice regarding Limited English Proficiency.

**Corrective Actions and Schedule:** Within 90 days, NYCT must submit to
the FTA Region II Civil Rights Officer documentation that the draft
policy has been finalized and implemented.

11. 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 NYCT,
deficiencies were found with FTA requirements for Internal Monitoring
Procedures. At the time of the site visit, NYCT had not implemented the
required "level of service" and "quality of service" monitoring
procedures.

At the time of the site review, for level of service monitoring, NYCT
provided various analyses that had been conducted to determine equity.
However, this analysis was not done in accordance with FTA Circular
4702.1. For example, in the area of Transit Access, NYCT selected a
random sample of 20 minority census tracts and 20 non-minority census
tracts and compared the transit access results against each other. The
method in the circular 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 an established standard. As
described in Section 8 above, no established standard was provided for
three of the five required service indicators.

Subsequent to the site review, NYCT provided a draft document that
included their standards for vehicle assignment and transit access and
also compared achievements for minority routes/depots to this standard.
The analysis for vehicle assignment showed that the standard was 7.5
years and the average age of vehicles assigned to minority depots
(defined by NYCT as a depot that has at least 65.02% minority bus routes
originating it) was 5.7 years. This met and exceeded the standard. For
transit access, comparing the results of a sample of 20 minority census
tracts to the standard distance of .25 mile yielded an average actual
distance of .16 miles, which met and exceeded the standard.

For transit amenities, no standard was provided, but a draft analysis
comparing minority to non-minority results for the amenities of station
modernization, ADA accessibility, presence of elevators, and presence of
escalator was provided. A summary of the results is shown in the table
below:

  -------------- -------------- -------------- -------------- --------------
                 Modernized     ADA Accessible Elevator       Escalator

  Minority       32.2%          8.2%           9.4%           11.8%
  Stations                                                    
  Completed                                                   

  Non-Minority   39.4%          9.4%           8.5%           16%
  Stations                                                    
  Completed                                                   
  -------------- -------------- -------------- -------------- --------------

In addition to providing the data on the stations modernized and
accessible, NYCT performed a statistical analysis on the data to
determine the probability that a station chosen for upgrades would be
minority or non-minority. However, the Circular does not address the
probability of the distribution of amenities; rather it focuses on the
actual results and if they are unequal.

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 the conduct of a survey of riders to determine travel
patterns, travel time, and fare for the three most-traveled
destinations. A comparison is then done on minority versus non-minority
quality of service. The 2002 Title VI submission stated that each of
MTA's agencies had submitted this data and there were no inequities
found. However, no details on the samples selected, or the results of
the analysis for NYCT were provided in the submission or during the site
review.

Subsequent to the site review, NYCT provided draft information on the
results of quality of service monitoring conducted from 20 minority and
20 non-minority census tracts. The analysis covered a rating of service
attributes, average peak hour travel time, number of transfers, total
cost per trip, and total cost per mile of trip. In each of the areas,
except for number of transfers, the results from minority tracts were
better than those from non-minority.

**Corrective Actions and Schedule:** Within 90 days, NYCT must submit to
the FTA Region II Civil Rights Officer documentation that its draft
procedures for level and quality of service monitoring have been
finalized and that the level of service monitoring includes the
following:

-   Sampling of at least 10% of census tracts for level of service
    monitoring

-   Monitoring of transit amenities against a set standard.

12. []{#__RefHeading___Toc51057817 .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 NYCT,
deficiencies were found with FTA requirements for Title VI Complaints.
NYCT provided information from representatives of Customer Service,
Client Services and Marketing, Government and Community Relations, and
Counsel offices on the intake and processing of service complaints for
NYCT. Discussions were held on what NYCT considers to be a Title VI
complaint and on instructions for employees who handle complaints that
are or could be Title VI in nature. At the time of the site review NYCT
did not have a formal written procedure in place for the processing of
service complaints.

Additionally, 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. During the site visit, NYCT provided the review team with
an "Equal Employment Opportunity is the Law" poster that references
Title VI. However, the information on the poster primarily addresses
employment discrimination and appears to apply to employees rather than
the riding public.

Subsequent to the site review, NYCT submitted to the review team and FTA
a draft policy on Title VI complaint procedures. Included in this policy
are definitions, responsibilities for implementation, instructions on
how to file a complaint, complaint processing procedures, Title VI
training, and monitoring.

**[Corrective Actions and Schedule]{.underline}:** Within 90 days, NYCT
must submit to the FTA Region II Civil Rights Officer the finalized
complaint procedure for the filing of Title VI complaints and
information on its implementation. Additionally, NYCT must submit to the
FTA Region II Civil Rights Officer documentation that the complaint
procedure has been made available to the public.

[]{#__RefHeading___Toc51057818 .anchor}VII. SUMMARY OF FINDINGS AND
CORRECTIVE ACTIONS

+--------------+------+---------------------+-----------+------+-----+
| **Title VI   | **   | Description of      | **C       | **   | **D |
| Requirements | Site | Deficiencies        | orrective | Resp | ate |
| For Transit  | Re   |                     | Ac        | onse | Cl  |
| Providers**  | view |                     | tion(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\.          | D    | NYCT does not       | Submit to | 90   |     |
| Fi           |      | address Fixed       | the FTA   |      |     |
| xed-Facility |      | Facility Impact     | Region II |      |     |
| Impact       |      | Analyses            | RCRO      |      |     |
| Analysis     |      | specifically in     | written   |      |     |
|              |      | their Title VI      | process   |      |     |
|              |      | submission. They    | or        |      |     |
|              |      | address             | procedure |      |     |
|              |      | Environmental       | to ensure |      |     |
|              |      | Assessments (EAs ), | that a    |      |     |
|              |      | which are not       | fixed     |      |     |
|              |      | performed for       | -facility |      |     |
|              |      | Federally funded    | impact    |      |     |
|              |      | projects that       | analysis  |      |     |
|              |      | receive a           | is        |      |     |
|              |      | categorical         | conducted |      |     |
|              |      | exclusion. No such  | for all   |      |     |
|              |      | exemption is        | federally |      |     |
|              |      | included in the     | funded    |      |     |
|              |      | Title VI Circular.  | projects  |      |     |
|              |      | The EAs reviewed do | in        |      |     |
|              |      | not address some of | c         |      |     |
|              |      | the points          | ompliance |      |     |
|              |      | identified in the   | with FTA  |      |     |
|              |      | Title VI Circular,  | requ      |      |     |
|              |      | such as detailed    | irements. |      |     |
|              |      | list of minority    |           |      |     |
|              |      | households and      |           |      |     |
|              |      | businesses that     |           |      |     |
|              |      | will be affected by |           |      |     |
|              |      | the construction    |           |      |     |
|              |      | project.            |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 7\.          | ND   |                     |           |      |     |
| Demographic  |      |                     |           |      |     |
| and Service  |      |                     |           |      |     |
| Maps,        |      |                     |           |      |     |
| Overlays and |      |                     |           |      |     |
| Charts       |      |                     |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 8\. Service  | D    | -   Draft service   | Within 90 | 90   |     |
| Standards    |      |     standards were  | days,     |      |     |
| and Policies |      |     provided for    | NYCT must |      |     |
|              |      |     vehicle         | submit to |      |     |
|              |      |     assignment and  | the FTA   |      |     |
|              |      |     transit access. | Region II |      |     |
|              |      |     No standards    | Civil     |      |     |
|              |      |     were submitted  | Rights    |      |     |
|              |      |     for transit     | Officer   |      |     |
|              |      |     amenities.      | the       |      |     |
|              |      |                     | finalized |      |     |
|              |      |                     | service   |      |     |
|              |      |                     | standards |      |     |
|              |      |                     | for       |      |     |
|              |      |                     | vehicle   |      |     |
|              |      |                     | a         |      |     |
|              |      |                     | ssignment |      |     |
|              |      |                     | and       |      |     |
|              |      |                     | transit   |      |     |
|              |      |                     | access    |      |     |
|              |      |                     | that were |      |     |
|              |      |                     | provided  |      |     |
|              |      |                     | in draft  |      |     |
|              |      |                     | form.     |      |     |
|              |      |                     | Addi      |      |     |
|              |      |                     | tionally, |      |     |
|              |      |                     | NYCT      |      |     |
|              |      |                     | should    |      |     |
|              |      |                     | submit    |      |     |
|              |      |                     | standards |      |     |
|              |      |                     | for       |      |     |
|              |      |                     | transit   |      |     |
|              |      |                     | a         |      |     |
|              |      |                     | menities. |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 9\.          | D    | -   No evidence of  | Submit to | 90   |     |
| Assessment   |      |     the process     | the FTA   |      |     |
| of           |      |     used to         | Region II |      |     |
| Compliance   |      |     establish       | RCRO      |      |     |
| by Grantee   |      |     internal        | docu      |      |     |
|              |      |     guidelines for  | mentation |      |     |
|              |      |     making          | of        |      |     |
|              |      |     determinations  | developed |      |     |
|              |      |     of compliance   | p         |      |     |
|              |      |     with Title VI   | rocedures |      |     |
|              |      |     as part of      | and       |      |     |
|              |      |     local           | g         |      |     |
|              |      |     decision-making | uidelines |      |     |
|              |      |     process and     | for       |      |     |
|              |      |     continuing      | m         |      |     |
|              |      |     project         | onitoring |      |     |
|              |      |     management and  | c         |      |     |
|              |      |     contract        | ompliance |      |     |
|              |      |     administration  | with      |      |     |
|              |      |                     | Title VI  |      |     |
|              |      |   responsibilities. | in        |      |     |
|              |      |                     | a         |      |     |
|              |      | -   No evidence of  | ccordance |      |     |
|              |      |     evaluation of   | with FTA  |      |     |
|              |      |     system wide     | requ      |      |     |
|              |      |     service changes | irements. |      |     |
|              |      |     and proposed    |           |      |     |
|              |      |     improvements at |           |      |     |
|              |      |     the planning    |           |      |     |
|              |      |     and programming |           |      |     |
|              |      |     stages to       |           |      |     |
|              |      |     determine       |           |      |     |
|              |      |     whether the     |           |      |     |
|              |      |     overall costs   |           |      |     |
|              |      |     and benefits    |           |      |     |
|              |      |     are distributed |           |      |     |
|              |      |     equally and are |           |      |     |
|              |      |     not             |           |      |     |
|              |      |     discriminatory. |           |      |     |
|              |      |     (For example,   |           |      |     |
|              |      |     impact of       |           |      |     |
|              |      |     station         |           |      |     |
|              |      |     modernization   |           |      |     |
|              |      |     selection       |           |      |     |
|              |      |     criteria).      |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 10\. Other   | D    | -   Description of  | \- Within | 90   |     |
| Areas of     |      |     when            | 90 days,  |      |     |
| Title VI     |      |     multilingual    | NYCT must | 90   |     |
| Co           |      |     communications  | submit to |      |     |
| nsiderations |      |     are used in     | the FTA   |      |     |
|              |      |     Title VI plan   | Region II |      |     |
|              |      |     does not        | Civil     |      |     |
|              |      |     reflect what    | Rights    |      |     |
|              |      |     was observed in | Officer   |      |     |
|              |      |     practice in the | docu      |      |     |
|              |      |     area of safety  | mentation |      |     |
|              |      |     and             | that the  |      |     |
|              |      |                     | draft     |      |     |
|              |      |  evacuation-related | policy    |      |     |
|              |      |     signage and     | has been  |      |     |
|              |      |     information.    | finalized |      |     |
|              |      |     Subsequent to   | and       |      |     |
|              |      |     the site visit  | imp       |      |     |
|              |      |     a draft         | lemented. |      |     |
|              |      |     procedure for   |           |      |     |
|              |      |     multi-lingual   |           |      |     |
|              |      |     communications  |           |      |     |
|              |      |     was submitted.  |           |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 11\.         | D    | -   NYCT submitted  | Within 90 | 90   |     |
| Monitoring   |      |     draft           | days,     |      |     |
| Procedures   |      |     procedures for  | NYCT must |      |     |
|              |      |     level and       | submit to |      |     |
|              |      |     quality of      | the FTA   |      |     |
|              |      |     service         | Region II |      |     |
|              |      |     monitoring.     | Civil     |      |     |
|              |      |                     | Rights    |      |     |
|              |      |                     | Officer   |      |     |
|              |      |                     | docu      |      |     |
|              |      |                     | mentation |      |     |
|              |      |                     | that its  |      |     |
|              |      |                     | draft     |      |     |
|              |      |                     | p         |      |     |
|              |      |                     | rocedures |      |     |
|              |      |                     | for level |      |     |
|              |      |                     | and       |      |     |
|              |      |                     | quality   |      |     |
|              |      |                     | of        |      |     |
|              |      |                     | service   |      |     |
|              |      |                     | m         |      |     |
|              |      |                     | onitoring |      |     |
|              |      |                     | have been |      |     |
|              |      |                     | finalized |      |     |
|              |      |                     | and that  |      |     |
|              |      |                     | the level |      |     |
|              |      |                     | of        |      |     |
|              |      |                     | service   |      |     |
|              |      |                     | m         |      |     |
|              |      |                     | onitoring |      |     |
|              |      |                     | includes  |      |     |
|              |      |                     | the       |      |     |
|              |      |                     | f         |      |     |
|              |      |                     | ollowing: |      |     |
|              |      |                     |           |      |     |
|              |      |                     | -         |      |     |
|              |      |                     |  Sampling |      |     |
|              |      |                     |     of at |      |     |
|              |      |                     |     least |      |     |
|              |      |                     |     10%   |      |     |
|              |      |                     |     of    |      |     |
|              |      |                     |           |      |     |
|              |      |                     |    census |      |     |
|              |      |                     |           |      |     |
|              |      |                     |    tracts |      |     |
|              |      |                     |     for   |      |     |
|              |      |                     |     level |      |     |
|              |      |                     |     of    |      |     |
|              |      |                     |           |      |     |
|              |      |                     |   service |      |     |
|              |      |                     |     m     |      |     |
|              |      |                     | onitoring |      |     |
|              |      |                     |           |      |     |
|              |      |                     | -   M     |      |     |
|              |      |                     | onitoring |      |     |
|              |      |                     |     of    |      |     |
|              |      |                     |           |      |     |
|              |      |                     |   transit |      |     |
|              |      |                     |           |      |     |
|              |      |                     | amenities |      |     |
|              |      |                     |           |      |     |
|              |      |                     |   against |      |     |
|              |      |                     |     a set |      |     |
|              |      |                     |           |      |     |
|              |      |                     | standard. |      |     |
+--------------+------+---------------------+-----------+------+-----+
| 12\. Title   | D    | Subsequent to the   | Within 90 | 90   |     |
| VI           |      | site review, NYCT   | days,     |      |     |
| Complaints   |      | submitted a draft   | NYCT must |      |     |
|              |      | policy for Title VI | submit to |      |     |
|              |      | complaints.         | the FTA   |      |     |
|              |      |                     | Region II |      |     |
|              |      |                     | Civil     |      |     |
|              |      |                     | Rights    |      |     |
|              |      |                     | Officer   |      |     |
|              |      |                     | the       |      |     |
|              |      |                     | finalized |      |     |
|              |      |                     | complaint |      |     |
|              |      |                     | procedure |      |     |
|              |      |                     | for the   |      |     |
|              |      |                     | filing of |      |     |
|              |      |                     | Title VI  |      |     |
|              |      |                     | c         |      |     |
|              |      |                     | omplaints |      |     |
|              |      |                     | and       |      |     |
|              |      |                     | in        |      |     |
|              |      |                     | formation |      |     |
|              |      |                     | on its    |      |     |
|              |      |                     | implem    |      |     |
|              |      |                     | entation. |      |     |
|              |      |                     | Addi      |      |     |
|              |      |                     | tionally, |      |     |
|              |      |                     | NYCT must |      |     |
|              |      |                     | submit to |      |     |
|              |      |                     | the FTA   |      |     |
|              |      |                     | Region II |      |     |
|              |      |                     | Civil     |      |     |
|              |      |                     | Rights    |      |     |
|              |      |                     | Officer   |      |     |
|              |      |                     | docu      |      |     |
|              |      |                     | mentation |      |     |
|              |      |                     | 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;

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

+-----------+------------------------+----------+--------------------+---+
| **NAME**  | **ORGANIZATION/TITLE** | *        | **E-MAIL**         |   |
|           |                        | *PHONE** |                    |   |
+-----------+------------------------+----------+--------------------+---+
| John      | FTA/Region II Civil    | 212-     | <john.p            |   |
| Prince    | Rights Officer         | 668-2170 | rince@fta.dot.gov> |   |
+-----------+------------------------+----------+--------------------+---+
| David     | FTA/Equal Opportunity  | 202-     | <david.schn        |   |
| Schneider | Specialist             | 493-0175 | eider@fta.dot.gov> |   |
+-----------+------------------------+----------+--------------------+---+
| Ken Neal  | MTA/Director, Civil    | 718-     | <KNEAL@mtahq.org>  |   |
|           | Rights                 | 243-7568 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Sarah     | MTA Grant              | 212-     | <SRIOS@MTAHQ.ORG>  |   |
| Rios      | Management/Director    | 878-7080 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Robert    | NYCT/Senior Director   | 718-     | <ronewho@nyct.com> |   |
| Newhouser | System Data & Research | 694-3353 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Alla      | NYCT/Director System   | 718-     | <ALREDDY@NYCT.COM> |   |
| Reddy     | Data & Research        | 694-3778 |                    |   |
|           | Operations Planner     |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Ted Basia | NYCT/VP Operat Supt,   | 718-     | <Thbasia@nyct.com> |   |
|           | Department of Buses    | 927-7600 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Robin     | MTA Legal/Associate    | 212-     | <r                 |   |
| Bergstrom | Counsel                | 878-7317 | bergstr@mtahq.org> |   |
+-----------+------------------------+----------+--------------------+---+
| Rhonda    | MTA Legal/Senior       | 212-     | <rmoll@mtahq.org>  |   |
| Moll      | Employment Counsel     | 878-1036 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Dona      | NYCT DOB/ACMO,R&D      | 718-     | <                  |   |
| Lowell    |                        | 927-8620 | dalowell@nyct.com> |   |
+-----------+------------------------+----------+--------------------+---+
| Barbara   | NYCT/EVP               | 718-     | <ba                |   |
| Spencer   |                        | 243-3052 | spenc013@nyct.com> |   |
+-----------+------------------------+----------+--------------------+---+
| Gwen      | MTA/Assistant Director | 718-     | <gwhalst@nyct.com> |   |
| Harleston |                        | 694-1711 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Naeem Din | MTA/Deputy Director    | 718-     | <ndin@mtahq.org>   |   |
|           | Civil Rights           | 694-5205 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Larry     | NYCT Office of         | 718-     | <LAHIRSC@NYCT.COM> |   |
| Hirsch    | Management and         | 694-3078 |                    |   |
|           | Budget/Unit Head,      |          |                    |   |
|           | Revenue Budget         |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Richard   | NYCT/Senior Director   | 718-     | <rideces@nytc.com> |   |
| DeCesare  | Administration and     | 243-7475 |                    |   |
|           | Finance                |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Craig     | NYCT Subways           | 718-     | <CRStewa@NYCT.com> |   |
| Stewart   | Department/Chief       | 243-4243 |                    |   |
|           | Officer                |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Robert    | NYCT Subways           | 718-     | <RoKarlo@NYC.com>  |   |
| Karlovits | Department/Senior      | 243-4333 |                    |   |
|           | Director Long Range    |          |                    |   |
|           | Planning               |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| John      | NYCT Subways/RTO/Chief | 718-     |                    |   |
| Johnson   | Trans Officer          | 243-3206 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| A.L.      | NYCT/ACMO              | 718-     |                    |   |
| Gagliard  |                        | 319-5711 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Douglas   | MTA/Director Community | 212-     | <d                 |   |
| Sussman   | Affairs                | 878-7469 | sussman@mtahq.org> |   |
+-----------+------------------------+----------+--------------------+---+
| Chris     | NYCT Department of     | 718-     | <CHRLAKE@NYCT.COM> |   |
| Lake      | Buses/ACTO Customer    | 927-7661 |                    |   |
|           | Relations              |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Jennifer  | NYCT Buses/CTO         | 718-     | <Jsincla@NYCT.com> |   |
| Sinclair  |                        | 927-7605 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Collette  | MTA NYCT/Principal     | 646-     | <co                |   |
| Ericsson  | Engineer               | 252-3513 | ericsson@nyct.com> |   |
+-----------+------------------------+----------+--------------------+---+
| Lois      | NYCT/Director,         | 718-     | <ltendle@nyct.com> |   |
| Tendler   | Government and         | 694-5127 |                    |   |
|           | Community Relations    |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| #### [NAM | **[ORGANI              | **       | *                  | [ |
| E]{.mark} | ZATION/TITLE]{.mark}** | [Phone]{ | *[E-MAIL]{.mark}** | ] |
|           |                        | .mark}** |                    | { |
|           |                        |          |                    | . |
|           |                        |          |                    | m |
|           |                        |          |                    | a |
|           |                        |          |                    | r |
|           |                        |          |                    | k |
|           |                        |          |                    | } |
+-----------+------------------------+----------+--------------------+---+
| Connie    | NYCT/Chief Client      | 718-     | <codepal@nyct.com> |   |
| Depalma   | Services and Marketing | 694-5795 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Fred      | NYCT/Chief Officer     | 718-     | <FBenjam@nyct.com> |   |
| Benjamin  | Customer Service       | 243-4703 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Gricelda  | NYCT/Assistant Chief   | 718-     | <grcespe@nyct.com> |   |
| Cespedes  | Station Officer        | 243-4174 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Anthony   | MTA/Deputy General     | 212-     | <a                 |   |
| Semancik  | Counsel                | 878-7248 | semanci@mtahq.org> |   |
+-----------+------------------------+----------+--------------------+---+
| Adrienne  | NYCT/Assistant         | 718-     | <ADTAUB@NYCT.com>  |   |
| Taub      | Director               | 694-5125 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| John Hein | NYCT DOB/General       | 212-     | <johein@nyct.com>  |   |
|           | Manager                | 544-4160 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Willie    | NYCT DOB/General       | 212-     |                    |   |
| Quijano   | Superintendent         | 690-9619 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Domingo   | NYCT DOB/Director      | 718-     | <DSANTO@nyct.com>  |   |
| Santos    | Engineering Support    | 927-7730 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| J.        | NYCT DOB/Director      | 212-     | <JAnder@nyct.com>  |   |
| Anderson  |                        | 690-9471 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Kenneth   | NYCT DOB/Staff Analyst | 718-     | <kedarke@nyct.com> |   |
| F. Darke  |                        | 566-5946 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Daniel    | NYCT DOB/General       | 212-     | <DASmal@nyct.com>  |   |
| Smaller   | Superintendent         | 690-9600 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Charles   | NYCT/AGM               | 212-     | <chsmith@nyct.com> |   |
| Smith     |                        | 712-4649 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Roberto   | NYCT/Construction      | 212-     |                    |   |
| Espinoza  | Manager                | 289-1354 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Louis     | NYCT/G/S               | 212-     |                    |   |
| B         |                        | 712-4696 |                    |   |
| rattaglia |                        |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Joseph    | NYCY/General Manager   | 212-     | <jsmith2@nyct.com> |   |
| Smith     |                        | 712-5100 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Cordell   | NYCT/General           | 212-     | <coroger@nyct.com> |   |
| V. Rogers | Superintendent         | 360-5025 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| John      | NYCT/Superintendent    | 212-     | <Jmcnam3@nyct.com> |   |
| McNamara  | Maintenance            | 369-7711 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Anna Peck | NYCT/AGM               | 212-     | <APECK@nyct.com>   |   |
|           |                        | 860-2873 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| #### NAME | **ORGANIZATION/TITLE** | *        | **E-MAIL**         |   |
|           |                        | *Phone** |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Henry C.  | NYCT/Assistant General | 718-     | <Heweism@NYCT.COM> |   |
| W         | Manager                | 437-6330 |                    |   |
| eismantel |                        |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Robert B. | NYCT/General           | 718-     |                    |   |
| Rogers    | Superintendent         | 871-7170 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Anthony   | NYCT/AGS               | 718-     |                    |   |
| A.        |                        | 851-5865 |                    |   |
| Zanatta   |                        |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Ray       | NYCT/General           | 718-     |                    |   |
| Silvery   | Superintendent         | 851-5865 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Carlos    | NYCT DOB/General       | 718-     |                    |   |
| Cruz      | Superintendent         | 851-5828 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Dorothy   | NYCT/General           | 718-     |                    |   |
| Spence    | Superintendent         | 334-8606 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Jim       | NYCT/Admin Manager     | 718-     |                    |   |
| Miller    |                        | 334-8629 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Nick      | NYCT/AGM               | 718-     |                    |   |
| Sensevere |                        | 334-8622 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Anthony   | NYCT/General           | 718-     |                    |   |
| J. Tatta  | Superintendent         | 334-8604 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Gwen      | NYCT/General           | 718-     |                    |   |
| Thompson  | Superintendent         | 334-8603 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Jim Dubbs | NYCT/Assistant         | 718-     |                    |   |
|           | Director Government    | 694-5141 |                    |   |
|           | and Community          |          |                    |   |
|           | Relations              |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Michael   | NYCT/General           | 718-     |                    |   |
| Clarke    | Superintendent         | 334-8642 |                    |   |
|           | Maintenance            |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Joseph    | NYCT/AGM               | 718-     |                    |   |
| D'Auria   |                        | 334-8641 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Brian     | NYCT/General           | 718-     |                    |   |
| Brennan   | Superintendent         | 334-8624 |                    |   |
|           | Maintenance Support    |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Andrew G. | NYCT Department of     | 718-     |                    |   |
| Janusas   | Buses/Director, CNG    | 851-3817 |                    |   |
|           | Systems Operations     |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Kenneth   | NYCT Department of     | 718-     |                    |   |
| J. Daube  | Buses/General Manager  | 334-8625 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Aidee     | City of New York       | \(646\)  | <cam               |   |
| Camacho   | Community Board 12,    | 408-4826 | achoa@hra.nyc.gov> |   |
|           | Assistant Chair        |          |                    |   |
|           | Traffic and            |          |                    |   |
|           | Transportation         |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Anita     | City of New York       |          |                    |   |
| Barbers   | Community Board 12     |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Steve     | City of New York       | 212-     | <Steve.si          |   |
| Simon     | Community Board 12     | 568-7491 | mon@parks.nyc.gov> |   |
|           |                        |          |                    |   |
|           |                        | 212-     |                    |   |
|           |                        | 468-0220 |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Zead      | City of New York       | 212-     | <Z                 |   |
| Ramadan   | Community Board 12     | 568-8500 | ead@earthlink.net> |   |
|           | Manhattan/Chairman     |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Gregoria  | City of New York       | 212-     |                    |   |
| Feliciano | Community Board        | 568-8500 |                    |   |
|           | 12/District Manager    |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| #### NAME | **ORGANIZATION/TITLE** | *        | **E-MAIL**         |   |
|           |                        | *Phone** |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Charles   | City of New York       | 718-     | <dm@com            |   |
| Re        | Brooklyn Community     | 266-3001 | munityboard13.org> |   |
| ichenthal | Board 13/District      |          |                    |   |
|           | Manager                |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Beverly   | Permanent Citizens     | 212-     |                    |   |
| Dolinsky  | Advisory               | 878-7087 |                    |   |
|           | Committee/Executive    |          |                    |   |
|           | Director               |          |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Denise    | Milligan & Company,    | 215-     | <dbaile            |   |
| Bailey    | LLC/Principal          | 496-9100 | y@milligancpa.com> |   |
|           |                        | X 127    |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Jim       | Milligan & Company,    | 410-     | <JBuckle           |   |
| Buckley   | LLC/Reviewer           | 732-4626 | y@milligancpa.com> |   |
+-----------+------------------------+----------+--------------------+---+
| Sandra    | Milligan & Company,    | 215-     | <s                 |   |
| Swiacki   | LLC/Reviewer           | 735-4557 | swiacki48@aol.com> |   |
+-----------+------------------------+----------+--------------------+---+
| Joseph    | Milligan & Company,    | 215-     | <jherzo            |   |
| Herzog    | LLC/Reviewer           | 496-9100 | g@milligancpa.com> |   |
|           |                        | X 124    |                    |   |
+-----------+------------------------+----------+--------------------+---+
| Norris    | Milligan & Company,    | 215-     | <sps_nes@msn.com>  |   |
| Smith     | LLC /Reviewer          | 301-627- |                    |   |
+-----------+------------------------+----------+--------------------+---+