**Limited Scope**

**TITLE VI LIMITED ENGLISH PROFICIENCY**

**COMPLIANCE ASSESSMENT**

**OF THE**

**REGIONAL TRANSPORTATION DISTRICT**

**DENVER, COLORADO**

**(RTD)**

**Final Report**

**February 2007**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**THE DMP GROUP**

**5600 Colorado Avenue N.W.**

**Washington, DC 20011**

**[TABLE OF CONTENTS]{.underline}**

**I. GENERAL INFORMATION [2](#__RefHeading___Toc145129552)**

**II. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc145129553)**

**III. PURPOSE AND OBJECTIVES [2](#__RefHeading___Toc145129554)**

**IV. BACKGROUND INFORMATION [2](#__RefHeading___Toc145129555)**

**V. SCOPE AND METHODOLOGY [2](#__RefHeading___Toc145129556)**

**VI. FINDINGS AND RECOMMENDATIONS [2](#__RefHeading___Toc145129557)**

1\. Conduct Assessment of LEP Needs [2](#__RefHeading___Toc145129558)

2\. Efforts to Provide Language Assistance Services
[2](#__RefHeading___Toc145129559)

3\. Development and Implementation of Language Assistance Plan
[2](#__RefHeading___Toc145129560)

4\. Monitor/Update Language Assistance Plan
[2](#__RefHeading___Toc145129561)

**VII. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[2](#__RefHeading___Toc145129562)**

**VIII. ATTENDEES [2](#__RefHeading___Toc145129563)**

###  {#section .unnumbered}

I.  []{#__RefHeading___Toc145129552 .anchor}GENERAL INFORMATION

Grant Recipient: Regional Transportation District (RTD)

City/State: Denver, Colorado

Grantee No: 1136

Executive: Clarence W. Marsella

> General Manager
>
> RTD
>
> 1600 Blake Street
>
> Denver, Colorado 80202-1399

Report Prepared By: THE DMP GROUP

5600 Colorado Avenue N.W.

Washington, DC 20011

Site Visit Dates: July 25-27, 2006

Compliance Assessment

Team Members: Maxine A. Marshall, Lead Reviewer

John F. Potts, Reviewer

II. []{#__RefHeading___Toc145129553 .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 and assessments. The Regional Transportation District
(RTD) 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 the following:

-   Title VI of the Civil Rights Act of 1964, as amended (42 U.S.C.
    2000d),

-   49 U.S.C. Section 5332,

-   FTA Circular 4702.1, "Title VI Program Guidelines for Urban Mass
    Transportation Recipients,\" May 26, 1988

-   U.S. DOT "Policy Guidance Concerning Recipients' Responsibilities to
    Limited English Proficient (LEP) Persons", (70 FR 74087, December
    14, 2005)

The goal of Title VI is to ensure that Federal funds are not used in a
manner that discriminates on the basis of race, color, or national
origin. This Compliance Assessment was limited to the DOT requirement to
ensure that persons with Limited English Proficiency (LEP) have
meaningful access to programs and activities that are administered by
recipients and subrecipients. Grantee guidance related to LEP
requirements are found in FTA Circular 4702.1 and the U.S. DOT "Policy
Guidance Concerning Recipients' Responsibilities to Limited English
Proficient (LEP) Persons". The specific requirements that serve as the
basis for this Compliance Assessment are provided below.

**Relevant Sections of FTA Circular 4702.1, Title VI Program Guidelines
for FTA Recipients, include:**

-   **Chapter III, Data Collection and Reporting Requirements, Part 3 a.
    \[4\] (d) Multilingual Facilities.** *(Applies to grantees in
    service areas with populations over 200,000)* 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. For example, in service areas with a significant
    Hispanic population, the transit agency should discuss the steps
    taken to communicate with the community. Efforts should include
    steps such as the utilization of schedules, signs, etc., written in
    Spanish, as well as providing Spanish-speaking employees. Likewise,
    the publication of public hearing notices in languages other than
    English or the use of interpreters should also be noted. In cases
    where a transit agency posts signs warning the general public about
    dangerous situations (e.g., the electrified rail), information must
    be in languages and/or signs when a significant number of the
    population is non-English speaking.

-   **Chapter VIII, Public Information, Part 2, (c) Multilingual
    Requirements.** Where a significant number or portion of the
    population eligible to be served needs service or information in a
    language other than English to participate in FTA assisted programs,
    the recipient shall take every reasonable step to provide
    information in appropriate languages.

**Relevant Sections of the US Department of Transportation Guidance to
Recipients on Special Language Services to Limited English Proficient
(LEP) Beneficiaries include:**

-   **Chapter I -- Introduction --** Recipients of Federal Financial
    assistance have an obligation to reduce language barriers that can
    preclude meaningful access by LEP persons to important government
    services. In certain circumstances, failure to ensure that LEP
    persons can effectively participate in or benefit from federally
    assisted programs and activities may violate the prohibition under
    Title VI of the Civil Rights Act of 1964.

-   **Chapter V -- Determination of Recipient Obligation to Provide LEP
    Services --** Recipients are required to take reasonable steps to
    ensure meaningful access to their programs and activities by LEP
    persons. The starting point is an individualized assessment that
    balances the following four factors: (1) the number or proportion of
    LEP persons eligible to be served or likely to be encountered by a
    program, activity, or service of the recipient or grantee; (2) the
    frequency with which LEP individuals come in contact with the
    program; (3) the nature and importance of the program, activity, or
    service provided by the recipient to people's lives; and (4) the
    resources available to the recipient and costs.

-   **Chapter VI -- Selecting Language Assistance Services.** Recipients
    may provide language services in either oral or written form.
    Quality and accuracy of the language service is critical in order to
    avoid potential serious consequences to the LEP person and to the
    recipient.

-   **Chapter VII -- Implementation Plan on Language Assistance of LEP
    Persons --** After completing the four-factor analysis and deciding
    what language assistance services are appropriate, recipients should
    develop an implementation plan to address the identified needs of
    the LEP populations it services. The plan should identify LEP
    individuals who need language assistance and should include
    information about the ways in which language assistance will be
    provided. Staff members must be trained to understand their
    obligations to provide meaningful access to information and services
    for LEP persons. The recipient must notify LEP persons of services
    available free of charge and the recipient should have a process for
    monitoring and updating the LEP Plan on an ongoing basis.

    I.  []{#__RefHeading___Toc145129554 .anchor}PURPOSE AND OBJECTIVES

Purpose

The Federal Transit Administration (FTA) Office of Civil Rights
periodically conducts discretionary reviews of grant recipients and
subrecipients to determine whether they are honoring their commitments,
as represented by certification, to comply with the requirements of 49
U.S.C. 5332. In keeping with its regulations and guidelines, FTA
determined that a Limited Scope Compliance Assessment of RTD was
necessary.

The Office of Civil Rights authorized The DMP Group to conduct the Title
VI LEP Compliance Assessment of RTD. The Compliance Assessment was not
an investigation to determine the merit of any specific discrimination
complaints filed against RTD.

#### Objectives

The Objectives of the Title VI LEP Compliance Assessment are:

-   To determine if the grantee has conducted an assessment of the
    special language needs of persons with Limited English Proficiency;

-   To identify what efforts the grantee has made to provide language
    assistance services;

-   To determine if the grantee has developed and implemented a language
    assistance plan; and

-   To assess the grantee's efforts to monitor and update its language
    assistance plan.

[]{#__RefHeading___Toc145129555 .anchor}IV. BACKGROUND INFORMATION

The Regional Transportation District (RTD) provides public mass transit
service to the Denver, Colorado metropolitan area. In 1969, the Colorado
General Assembly created the Regional Transportation District as a
political subdivision of the State "to develop, maintain and operate a
public mass transportation system for the benefit of the inhabitants of
the District".

RTD boundaries include all of Denver, Boulder, Broomfield and Jefferson
Counties, the urbanized portions of Adams, Arapahoe, and Douglas
Counties and a portion of Weld County. Nearly 2.4 million people, or
approximately 55 percent of the population of Colorado, reside within
RTD's 2,327 square mile area.

Since 1983, RTD has been governed by a fifteen-member Board of Directors
who are elected by their constituents to serve four-year terms. The RTD
Board is responsible for setting District policy, adopting the agency's
annual budget, and establishing short and long-range transit goals and
plans in concert with local, state, and federal agencies.

RTD owns a fleet of 1,071 buses for its fixed route bus service. RTD
directly operates 654 buses and leases the remaining buses to private
operators. Bus service is provided on 174 regular fixed routes
throughout the service area. The core bus service includes local routes,
express routes, and regional and limited stop routes. One of RTD's most
recognized bus routes is the FREE MallRide Shuttle. This Shuttle
operates in downtown Denver, 21 hours per day on weekdays, with
frequencies as short as one and one-quarter minutes during rush hours.
The Shuttle is currently operated with 36 ultra low emission
hybrid-electric vehicles that each carries 115 passengers. At the time
of the site visit, RTD also operated a fleet of 70 light rail vehicles
over nearly 15.8 miles on two lines of light rail providing service to
23 stations. RTD light rail services began on the 5.3-mile Central
Corridor Light Rail Line in 1994. The Southwest light Rail Line opened
to the public on July 14, 2000.

In 2005, RTD had average weekday boardings on all services of 290,701
riders for a total annual number of over 86 million trips. RTD directly
employed approximately 2,500 persons and hired private contractors with
an additional workforce of nearly 1,400 persons.

RTD is completing its portion of a \$1.67 billion highway expansion and
light rail project capital project, known locally as T-REX, that was
approved by voters in 1999. FTA approved a \$525 million Full Funding
Grant Agreement for T-REX in 2000. Major transit projects of T-REX
included a light rail maintenance facility and a 19-mile light rail
line, operating primarily along Interstate 25. The maintenance facility
was completed in 2004 and the light rail line, known as the Southeast
Corridor, is expected to open in November 2006.

In 2004, RTD initiated a new capital program, known as FasTracks.
FasTracks\
will cost \$4.7 billion to construct over 12 years and will be funded by
a region-wide sales tax, federal funds, and local funds. FasTracks
includes**:**

-   119 miles of new light rail and commuter rail

```{=html}
<!-- -->
```
-   18 miles of bus rapid transit service

-   21,000 new parking spaces at rail and bus stations

-   Expanded bus service in all areas

The following table shows the LEP breakdown in the RTD service area,
which is comprised of 38 municipalities in six counties plus two
city/county jurisdictions:

**LEP Breakdown in the RTD Service Area**

######### 2000 Census

+--------------------------+---------+---------+-----------+---------+
| **Racial/ Ethnic Group   | #       | #       | ####      | ##      |
| Who Report Speaking      | ### RTD | ### RTD |  State of | ## Stat |
| English "Not Well" or    |         |         |  Colorado | e of Co |
| "Not At All"**           | ###     | ###     |           | lorado  |
|                          | # Servi | # Servi |           | Percent |
|                          | ce Area | ce Area |           |         |
|                          |         |         |           |         |
|                          |         | ####    |           |         |
|                          |         | Percent |           |         |
+--------------------------+---------+---------+-----------+---------+
| #### Spanish             | **9     | *       | **        | *       |
|                          | 3,990** | *3.92** | 123,115** | *3.07** |
+--------------------------+---------+---------+-----------+---------+
| #### Other Indo-European | **      | *       | *         | **.25** |
|                          | 7,789** | *0.32** | *10,155** |         |
+--------------------------+---------+---------+-----------+---------+
| #### Asian or Pacific    | **1     | *       | *         | **.33** |
|                          | 1,019** | *0.46** | *13,280** |         |
+--------------------------+---------+---------+-----------+---------+
| #                        | **      | *       | **1,855** | **.05** |
| ### Some Other Languages | 1,435** | *0.06** |           |         |
+--------------------------+---------+---------+-----------+---------+
| ####                     |         |         |           |         |
+--------------------------+---------+---------+-----------+---------+
| #### Subtotal            | **11    | *       | **        | *       |
|                          | 4,233** | *4.76** | 148,405** | *3.70** |
+--------------------------+---------+---------+-----------+---------+
| ####                     |         |         |           |         |
+--------------------------+---------+---------+-----------+---------+
| #### Total Population    | **2,39  |         | **4,      |         |
|                          | 9,413** |         | 006,285** |         |
+--------------------------+---------+---------+-----------+---------+

[]{.mark}

[]{.mark}

The population of RTD's service area is nearly 2.4 million. Over 95
percent of the population reported in the 2000 census that they speak
English "very well". The data and the maps developed by RTD's planning
staff during the site visit show that, by far, Spanish was the language
spoken by most individuals who reported that they spoke English either
"not well" or "not at all". Some census tracts showed concentrations of
Spanish speaking LEP persons as high as 68 percent. These maps also
identified census tracts with higher than expected concentrations of
persons who spoke Russian (up to nine percent), Korean (up to six
percent) and Vietnamese (up to six percent). As shown on the table, the
RTD service area contains a larger proportion of LEP persons than those
found statewide.

[]{#__RefHeading___Toc145129556 .anchor}V. SCOPE AND METHODOLOGY

#### Scope

The Title VI LEP Compliance Assessment of RTD examined the following
requirements as specified in the DOT Guidance (issued on December 14,
2005) to Recipients on Special Language Services to Limited English
Proficient (LEP) Beneficiaries:

-   **Chapter I -- Introduction --** Recipients of Federal Financial
    assistance have an obligation to reduce language barriers that can
    preclude meaningful access by LEP persons to important government
    services. In certain circumstances, failure to ensure that LEP
    persons can effectively participate in or benefit from federally
    assisted programs and activities may violate the prohibition under
    Title VI of the Civil Rights Act of 1964.

-   **Chapter V -- Determination of Recipient Obligation to Provide LEP
    Services --** Recipients are required to take reasonable steps to
    ensure meaningful access to their programs and activities by LEP
    persons. The starting point is an individualized assessment that
    balances the following four factors: (1) the number or proportion of
    LEP persons eligible to be served or likely to be encountered by a
    program, activity, or service of the recipient or grantee; (2) the
    frequency with which LEP individuals come in contact with the
    program; (3) the nature and importance of the program, activity, or
    service provided by the recipient to people's lives; and (4) the
    resources available to the recipient and costs.

-   **Chapter VI -- Selecting Language Assistance Services.** Recipients
    may provide language services in either oral or written form.
    Quality and accuracy of the language service is critical in order to
    avoid potential serious consequences to the LEP person and to the
    recipient.

-   **Chapter VII -- Implementation Plan on Language Assistance of LEP
    Persons --** After completing the four-factor analysis and deciding
    what language assistance services are appropriate, recipients should
    develop an implementation plan to address the identified needs of
    the LEP populations it services. The plan should identify LEP
    individuals who need language assistance and should include
    information about the ways in which language assistance will be
    provided. Staff members must be trained to understand their
    obligations to provide meaningful access to information and services
    for LEP persons. The recipient must notify LEP persons of services
    available free of charge and the recipient should have a process for
    monitoring and updating the LEP Plan on an ongoing basis.

#### Methodology

Initial interviews were conducted with the FTA Headquarters Civil Rights
staff and the FTA Region VIII Civil Rights Officer to discuss specific
Title VI LEP issues and concerns regarding RTD. Following these
discussions, an agenda letter was sent to RTD advising it of the site
visit and indicating additional information that would be needed and
issues that would be discussed.

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

1.  Current Description of RTD's service area, including general
    population and other demographic information using Census 2000 (or
    more recent) data.

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

3.  Any studies or surveys conducted by RTD, its consultants or other
    interested parties (colleges or universities, community groups,
    etc.) regarding multilingual communications during the past three
    years.

4.  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
    (from most recent Title VI Update).

5.  Map overlays which show areas with significant minority population
    using 2000 census tract data or TAZ, and which show transit services
    (e.g., bus routes, rail lines, transit centers, garages, etc.), from
    most recent Title VI Update.

6.  A population/racial distribution chart that shows the number and
    percentage of each minority group population in each 2000 census
    tract or TAZ (from most recent Title VI Update).

7.  Any assessments conducted by RTD of the language needs of the
    population and communities served.

8.  The results and actions taken, if any, following the language
    assessment.

9.  Listing of media used to make public transit information available
    to the public, such as, newspapers, system maps, brochures,
    postings, radio, and/or television.

10. Listings and samples of information provided in languages other than
    English. This includes descriptions of the extent to which bilingual
    persons and/or materials are used to assist non-English-speaking
    persons.

11. Contact information for community groups that represent
    non-English-speaking communities.

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

13. Complaints and/or lawsuits regarding multilingual communications.

RTD assembled most of the documents prior to the site visit and provided
them to the Compliance Assessment team for advance review. RTD did not
provide the requested items 4-9 or items 11-12. Following an initial
review of the documents, the Review team developed a detailed schedule
for the site visit.

The site visit to RTD occurred July 25-27, 2006. An Entrance Conference
was conducted at the beginning of the Compliance Assessment with RTD's
General Manager, senior management, staff and the contractor Review
team. FTA's Equal Opportunity Specialist from FTA Headquarters' Office
of Civil Rights participated in the Entrance Conference via
teleconference. During the Entrance Conference, the Review team
explained the goals of the Assessment and the needed cooperation of
staff members. A film on Limited English Proficiency was viewed and the
detailed schedule for conducting the on-site visit was discussed.

Following the Entrance Conference, the Review team met with the staff
responsible for assembling the documents requested for the site visit.
The staff provided some of the items requested prior to the site visit,
including maps and overlays and a listing of community contacts. In the
afternoon, RTD managers responsible for interfacing with the public were
interviewed by the Review team to understand procedures currently in
place for assuring meaningful access to RTD services for LEP
individuals. During the second day of the site visit, the Review team
conducted field visits of major bus routes, transit centers, transfer
points for shuttle bus services, and selected light rail lines and
stations. The purpose of the field visits was to observe riders and the
types of public information available in different parts of the RTD
service area. Review team members also arranged and conducted several
telephone interviews with community representatives to obtain
perceptions on language assistance services and needs from groups
representing Hispanic, Vietnamese, and Korean communities.

[]{.mark}

At the end of the site visit, an Exit Conference for the Compliance
Assessment was held with RTD senior management staff, and the contractor
Review team. At the Exit Conference, initial findings and corrective
actions were discussed.

[]{#__RefHeading___Toc145129557 .anchor}VI. FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Assessment focused on RTD's compliance with the
DOT requirements to ensure that persons with Limited English Proficiency
(LEP) have meaningful access to programs and activities that are
administered by recipients and subrecipients. This section describes the
requirements and findings at the time of the Compliance Assessment site
visit. In summary, four requirements were reviewed and three
deficiencies were identified. At the time of the site visit, RTD did not
document that it: 1) conducted an assessment of LEP needs; 2) developed
and implemented a Language Assistance Plan; and 3) had procedures in
place to monitor and update the Language Assistance Plan.

1.  []{#__RefHeading___Toc145129558 .anchor}Conduct Assessment of LEP
    Needs

**Requirement:** In accordance with Chapter V of US Department of
Transportation Guidance to Recipients on Special Language Services to
LEP Beneficiaries *-- Determination of Recipient Obligation to Provide
LEP Services: Recipients are required to take reasonable steps to ensure
meaningful access to their programs and activities by LEP persons. The
starting point is an individualized assessment that balances the
following four factors: (1) The number or proportion of LEP persons
eligible to be served or likely to be encountered by a program,
activity, or service of the recipient or grantee; (2) the frequency with
which LEP individuals come in contact with the program; (3) the nature
and importance of the program, activity, or service provided by the
recipient to people's lives; and (4) the resources available to the
recipient and costs.*

**Findings:** During this Title VI Compliance Assessment of RTD,
deficiencies were found regarding RTD's compliance with U.S. DOT
guidance to Conduct an Assessment of LEP Needs.

Since 2001, RTD had made an effort to identify the number or proportion
of LEP persons likely to use its services as a part of RTD's *Bus and
Light Rail Customer Satisfaction & Trip Characteristics* studies.
Surveys were made available in Spanish and included language
characteristic questions. The most recent surveys were conducted in 2005
for bus service and in Spring 2006 for light rail. Both studies asked
riders if they spoke a language other than English on a regular basis at
home. If the passenger responded positively to this question, they were
asked which language they spoke at home and whether they spoke or read
English very well, well, not well or not at all. The results are
presented in the following table:

**Findings of Bus and Light Rail Passenger Surveys**

**Conducted in 2005 and 2006**

+---------------------------------+-----------------+------------------+
|                                 | Bus Service     | Light Rail       |
+---------------------------------+-----------------+------------------+
| Speak Another Language at Home  | 15%             | 8%               |
+---------------------------------+-----------------+------------------+
| Of those above, what            |                 |                  |
| percentage:                     |                 |                  |
+---------------------------------+-----------------+------------------+
| Spoke Spanish at Home           | 70%             | 41%              |
+---------------------------------+-----------------+------------------+
| Of those above, what            |                 |                  |
| percentage:                     |                 |                  |
+---------------------------------+-----------------+------------------+
| -   Speak English Not Well or   | 35%             | 0%               |
|     Not at All                  |                 |                  |
+---------------------------------+-----------------+------------------+
| -   Read English Not Well or    | 33%             | 0%               |
|     Not at All                  |                 |                  |
+---------------------------------+-----------------+------------------+
| Of those who speak another      |                 |                  |
| language, what percentage:      |                 |                  |
+---------------------------------+-----------------+------------------+
| Spoke Other Languages           | 30%             | 59%              |
+---------------------------------+-----------------+------------------+
| Of those above, what            |                 |                  |
| percentage:                     |                 |                  |
+---------------------------------+-----------------+------------------+
| -   Speak English Not Well or   | 5%              | 14%              |
|     Not at All                  |                 |                  |
+---------------------------------+-----------------+------------------+
| -   Read English Not Well or    | 5%              | 14%              |
|     Not at All                  |                 |                  |
+---------------------------------+-----------------+------------------+

As this data shows, only a small percentage of RTD riders meet the LEP
criteria of speaking English "not well" or "not at all".

This data collection effort was a starting point in the Assessment of
LEP needs. The conduct of the survey addressed the second part of the
assessment requirement: *to identify the frequency with which LEP
individuals come in contact with the services*. However, prior to the
site visit, RTD had not completed the other parts of the assessment
requirements, to determine:

-   The number or proportion of LEP persons eligible to be served by a
    program, activity, or service of the recipient or grantee

-   The nature and importance of the program, activity, or service
    provided by the recipient to people's lives; and

-   The resources available to the recipient and costs.

During the site visit, RTD's planning staff developed maps and data
tables showing the number and proportion of LEP persons eligible to be
served by RTD. Using 2000 census data, RTD determined the following:

**LEP Breakdown in the RTD Service Area**

######### 2000 Census

+------------------------------------+----------------+----------------+
| **Racial/ Ethnic Group Who Report  | #### RTD       | #### RTD       |
| Speaking English "Not Well" or     |                |                |
| "Not At All"**                     | ###            | ###            |
|                                    | # Service Area | # Service Area |
|                                    |                |                |
|                                    |                | #### Percent   |
+------------------------------------+----------------+----------------+
| #### Spanish                       | **93,990**     | **3.92**       |
+------------------------------------+----------------+----------------+
| #### Other Indo-European           | **7,789**      | **0.32**       |
+------------------------------------+----------------+----------------+
| #### Asian or Pacific              | **11,019**     | **0.46**       |
+------------------------------------+----------------+----------------+
| #### Some Other Languages          | **1,435**      | **0.06**       |
+------------------------------------+----------------+----------------+
| ####                               |                |                |
+------------------------------------+----------------+----------------+
| #### Subtotal                      | **114,233**    | **4.76**       |
+------------------------------------+----------------+----------------+
| ####                               |                |                |
+------------------------------------+----------------+----------------+
| #### Total Population              | **2,399,413**  | **100**        |
+------------------------------------+----------------+----------------+

These maps identified census tracts with higher than expected
concentrations of persons who spoke Russian (up to nine percent), Korean
(up to six percent) and Vietnamese (up to six percent). The highest
concentrations were of people who spoke Spanish (as high as 68 percent).

The remaining elements of the assessment to be conducted are: 1) to
determine the nature and importance of RTD services; and 2) identify the
resources available to meet the needs of LEP persons in the service
area.

In an effort to assess the LEP needs first hand, the Review team toured
areas and rode bus and rail services in the RTD service area and
interviewed representatives of several groups that serve LEP persons.
The findings of these efforts confirmed that RTD needed to make
additional efforts to complete its assessment of LEP needs and develop a
Language Assistance Plan.

The Review team selected corridors and transit facilities to tour in the
RTD service area following an analysis of census data and maps showing
areas of high concentrations of LEP persons. The Review team toured the
following areas/facilities:

-   Market Street Bus Terminal/Transit Center

-   Civil Center Bus Terminal

-   North and South Federal Boulevard (bus routes 30 and 31)

-   East Colfax Avenue (bus routes 15 and 15L)

-   Green Valley Ranch area

-   Montbello area

-   Westminster Park n Ride

-   Evans/Federal bus hub

-   Federal & Colfax bus station

-   Airport Boulevard & 40^th^ Ave. Park n Ride

-   Montbello Park n Ride

-   Stapleton Transfer Center

-   East Metro RTD bus garage

-   "C" and "D" light rail lines

-   Littleton/Mineral station

-   I-25 & Broadway station

-   30^th^ & Downing station

-   Colfax at Auraria station

-   New Light Rail line corridor, along I-25 to Route 470 (end of line)

During the tours of areas served by RTD, the Review team saw evidence of
bilingual information on buses and stations throughout the service area.
Regardless of the community served, the written bilingual material was
consistent, usually limited to fare information and information on how
to use the Ticket Vending Machines at the rail stations. Even in areas
that appeared to have high concentrations of Spanish speaking LEP
persons (e.g., signs on stores were in Spanish and signs posted on the
nearby public school were in Spanish), RTD had made no effort to have
additional information available in Spanish.

It was noted that RTD was using International Symbols for the new
Southeast Light Rail stations signage to mitigate the need to translate
English.

During the Compliance Review site visit, interviews were conducted with
the following community groups:

-   Escuela Tlateloco -- a mono-lingual (Spanish) K-12 school

-   Cross Community Coalition

-   Clinica Tepeyac

-   Vietnamese Elderly Association

-   Korean Association of Colorado

The Review team also attempted to reach the Russian American Chamber but
was unsuccessful. The first three groups provide services to Hispanic
persons that range from 50 percent to 90 percent LEP. The school,
Escuela Tlateloco, served children of new immigrants, preparing them for
the Denver Public Schools. Over 90 percent of the parents of Escuela
Tlateloco students did not speak English at all. The Cross Community
Coalition provided services to 10,000 persons, of whom 47 percent
identify Spanish as their only or primary language and the Clinica
Tepeyac, a medical clinic, served 5,000 patients, of whom 80 percent are
LEP and 50 percent rely on RTD.

Only one of these groups (The Cross Community Coalition) was familiar
with RTD's efforts to serve the needs of Hispanic LEP persons. That
group indicated that RTD had worked in partnership with the community to
develop service to meet the needs of the community, located along the
40^th^ Street Corridor. One of the other groups (Escuela Tlateloco)
stated that RTD routes did not adequately serve the area (Green Valley
Ranch), some routes end at 7:00 p.m., and notices were not posted in
Spanish and, further, signs at the Park-n-Ride lots in the area were in
English only. The Clinica Tepeyac was not aware of RTD's efforts and
said it could benefit from more materials available in Spanish.

The representative from the Vietnamese Elderly Association stated that
there were approximately 10,000 Vietnamese in Denver mostly concentrated
in the Aurora and South Federal areas. The representative stated that at
least 50 percent of the persons served are LEP and they have experienced
difficulty riding RTD service. During the telephone interview, the
representative offered to work with RTD to help identify the LEP needs
of the Vietnamese community.

The representative of the Korean American Association indicated that
there were approximately 30,000 Korean people in Denver and that, among
the older residents, approximately 50 percent did not speak English.
This group was not aware of any interaction RTD had had with the Korean
Community. The representative stated that most members of the Korean
community were able to use RTD services and that younger members had
demonstrated how to use the RTD website and share information on how to
ride the bus to and from the Colorado Avenue corridor. It was noted that
many Korean students (most of whom speak English) regularly used RTD
buses.

Following the issuance of the Draft Report, the RTD submitted a response
to this deficiency stating:

> *RTD will develop and implement a survey instrument to conduct a
> comprehensive assessment of its LEP Needs, in accordance with Chapter
> VI of the U.S. Department of Transportation Guidance to Recipients on
> Special Language Services to LEP Beneficiaries.*
>
> *RTD will begin, but may not complete -- a comprehensive assessment
> within 120 days from the final report of the Title VI/LEP Compliance
> Review. If that is the case, RTD may propose a revised schedule based
> on those recommendations.*

**Corrective Actions and Schedules**: Consistent, with the RTD's
response to the\
Draft Report, within 120 days, RTD must submit to the FTA Office of
Civil Rights Equal Opportunity Specialist documentation that it has
completed or is in the process of completing an Assessment of LEP Needs,
in accordance with Chapter V of US Department of Transportation Guidance
to Recipients on Special Language Services to LEP Beneficiaries. RTD
must report quarterly on its progress, until the Assessment is
completed.

2.  []{#__RefHeading___Toc145129559 .anchor}Efforts to Provide Language
    Assistance Services

**Requirement:** In accordance with Chapter VI of US Department of
Transportation Guidance to Recipients on Special Language Services to
LEP Beneficiaries: *Recipients may provide language services in either
oral or written form. Quality and accuracy of the language service is
critical in order to avoid potential serious consequences to the LEP
person and to the recipient.*

[]{.mark}

**Finding:** During this Title VI Compliance Assessment of RTD, no
deficiencies were found regarding RTD's compliance with U.S. DOT
requirements regarding Efforts to Provide Language Assistance Services.
Denver RTD had made significant efforts to provide language services in
both oral and written forms for its customers and members of the
community affected by RTD capital projects.

Efforts to communicate orally include utilization of bilingual staff in
its Telephone Information Center. RTD paid a "premium" wage for up to 12
of its 40 telephone information center operators to be proficient in
both English and Spanish. These telephone information center operators
not only responded directly to customer calls regarding transit services
and schedules, they also provided assistance to bus and light rail
dispatchers and controllers, as needed. RTD's practice was for a bus or
rail operator to contact his/her respective dispatcher when they
encountered a LEP person with which they were unable to communicate. The
dispatch office also employed several dispatchers and supervisors who
were bilingual and would be able to speak to the passenger directly.
However, the bilingual positions in these functions were not designed to
provide service during all RTD service hours. If a bilingual dispatcher
was not available, the bilingual staff at the telephone information
center would be contacted to provide oral communication assistance. The
telephone information center staff was not trained interpreters but had
been tested and received training to insure that they were proficient in
both English and Spanish. It is also important to note that RTD employed
a number of bilingual bus and rail operators. RTD did not have data on
the language capabilities of its staff. It was assumed that most of the
bilingual staff spoke English and Spanish, but during discussions, it
was revealed that some staff also spoke German and other European
languages. In addition to the use of bilingual telephone information
center operators, RTD also had contracted with local interpreter
services, as needed, for RTD meetings, community meetings and other
events sponsored by RTD. These companies included:

-   Translation Links

-   Cosmopolitan Business Communications, Inc.

-   Escalante International Group

-   CSD Sign Language Interpreters

Another way that RTD had communicated orally with LEP persons was
through its community outreach efforts in corridors with Hispanic
concentrations. The Public Information Office of the Fastracks Program
described extensive and innovative efforts to communicate with residents
who would be impacted by construction projects in their neighborhoods.
Rather than hold traditional style public hearings, RTD staff took
additional efforts to reach LEP persons. RTD assembled teams of workers,
at least one of which was bilingual, to go door to door to speak to
residents about the construction projects. They also held small "block
or yard parties" to attract LEP persons in a manner which was consistent
with their cultural experience.

During the site visit, RTD bus operations staff identified a manual
titled *Basic Spanish for Transit Employees*, developed by the Colorado
Department of Transportation that was distributed by the RTD Operations
Training Department in the past. It was unclear if any training
accompanied the distribution of the manual and there was no
documentation that operators received any training on ways to
communicate with LEP persons.

Finally, immediately following the site visit, the Manager of Special
Services, the office responsible for general public Call-n-Ride
services, developed and distributed English/Spanish Phrase Cards for all
of the drivers.

RTD's efforts to communicate in written format were also quite
extensive. RTD had included English and Spanish notes in all of its
public timetables. Further, RTD's *Guide to Riding RTD Buses and Light
Rail* had a pull-down feature that provided for English and Spanish
instructions in a tri-fold brochure. RTD had similarly provided detailed
information in both Spanish and English in a brochure called the
*Longmont Transit Network*. The area of Longmont had a significant
Hispanic community, served by local bus routes, Call-n-Ride services and
Special Seasonal services. RTD was in the process of installing new bus
stop signs, all of which would contain route and fare information in
English and Spanish.

All RTD notices for public hearings and meetings included the following
language:

> ***Communication Assistance***
>
> *The following communication assistance is available for Proposed
> Service Change Public Hearings:*

-   *Language Interpreters*

-   *Sign-language interpreters*

-   *Assisted-listening devices*

> *Please notify RTD of the communication assistance you require at
> least 48 hours in advance of an RTD meeting you wish to attend by
> calling 303.299.2004*

Other media used by RTD to communicate in English and Spanish included:

-   Rider Alerts

-   Interior Cards on bus and light rail vehicles

-   All safety information in bus and light rail vehicles

-   Fare brochures

-   Print ads

-   Monthly Read-n-Ride newsletters

-   Pass by mail notices

-   Light rail station ticket vending machines

-   Shelter boards at bus stops

-   Signs and posters at light rail stations

It should be noted that all of these materials were available in English
and Spanish only. However, RTD's website included a translation service,
using software called SystranLinks. On many pages or links from RTD's
website ([www.rtd-denver.com](http://www.rtd-denver.com/)), users could
click on a dropdown menu to translate the information on the page into
three or four different languages. The other languages were French,
Italian, Spanish, and sometimes, German. It should be noted that the
translation link did not appear on RTD website's home page nor was it
available on some links that were provided in *pdf* format, such as the
current Public Notice or the link to changes in bus service that would
take effect with the opening of the new Southeast Light Rail service on
November 19, 2006. The translation link was available on the *How to
Ride Guide*, but not on a new RTD service to provide travel training
called *My Ride*. Finally, it was noted that the translation link was
not included in RTD Automated Information kiosks located at the Denver
International Airport or in the RTD main office in downtown Denver.

3\. []{#__RefHeading___Toc145129560 .anchor}Development and
Implementation of a Language Assistance Plan

**Requirement:** In accordance with Chapter VII of US Department of
Transportation Guidance to Recipients on Special Language Services to
LEP Beneficiaries: *Recipients should develop an implementation plan to
address the identified needs of the LEP populations it services. The
plan should identify LEP individuals who need language assistance and
should include information about the ways in which language assistance
will be provided.*

**Finding:** During this Title VI Compliance Review of RTD, deficiencies
were found regarding RTD's compliance with U.S. DOT requirements for the
Development and Implementation of a Language Assistance Plan. While the
RTD had devoted considerable effort and resources to communicating with
Spanish speaking LEP persons, it had not developed any type of written
Language Assistance Plan to provide a consistent and well thought out
approach to serving the needs of LEP persons in the RTD service area.

One department in RTD, the Rail Operations Department, provided a copy
of its Standard Operating Procedure (SOP) 101.9, entitled: *Non-English
Speaking Passengers*. The SOP was issued on January 1, 2001, superseding
the November 25, 1997 SOP. The notice was issued to Light Rail
Maintenance Employees, Light Rail Transportation Employees, Light Rail
Transportation Controllers/Supervisors and Safety. The Overview of the
SOP stated:

> *In order to meet the FTA guidelines for non-English speaking
> passengers of the Regional Transportation District, a plan has been
> established to address those passengers who do not speak English well
> enough to communicate their transit needs.*

The SOP described procedures directing Rail Operations employees to call
the Operations Control Center when they encountered a non-English
speaking passenger. The SOP advised that the Rail Operations Control
Center would attempt to communicate with the passenger first. If needed,
the Telephone Information Center would be called next and, finally, the
Bus Operations Dispatch Center. The SOP had a separate section for
Emergency Situations. This section stated that the when notified of an
emergency involving a party that did not speak English, the Rail
Operations Control Center must notify the First Responders and inform
them of the language barrier.

The Assistant General Manager for Rail Operations noted that this
procedure was included in training for all Light Rail Employees.

During the site visit, the Review team discussed this procedure with
management of the Bus Operations Department and Contract Services
Department. The managers of these departments were not aware of any
similar SOP for their employees. It was important to note that RTD had
an extensive network of private contractors. As previously stated, in
2005, RTD directly employed 2,510 persons and hired private contractors
with an additional workforce of 1,390.

The Rail Operations SOP was a good starting point for providing
consistent guidance to all RTD and contracted employees on how to
provide language assistance.

A complete Language Assistance Plan should be developed by RTD to
identify LEP individuals who need language assistance and should include
information about the ways in which language assistance would be
provided. The plan should address which, if any, LEP populations other
than Spanish were significant and which printed materials, if any,
should be translated into these languages. Similarly, the plan should
identify if additional resources should be made available for oral
communication in languages other than Spanish. The plan should also
address all modes of service, including LEP procedures for private
operators and other private contractors, such as RTD's security detail.
Finally, the plan should address the ways in which RTD personnel and
contractors would be educated on the LEP procedures.

Following the issuance of the Draft Report, the RTD submitted a response
to this deficiency stating:

> *RTD will develop a Language Assistance Plan... in accordance with
> Chapter VII of the U.S. Department of Transportation Guidance to
> Recipients on Special Language Services to LEP Beneficiaries.*
>
> *RTD will complete the Language Assistance Plan within 60 days from
> the submission of the completed assessment, or additional time as
> required.*

**Corrective Actions and Schedules**: Consistent with RTD's response to
the Draft Report, within 60 days from the submission of the completed
assessment, RTD must submit to the FTA Office of Civil Rights Equal
Opportunity Specialist documentation of a Language Assistance Plan to
address the identified needs of the LEP populations it services, in
accordance with Chapter VII of US Department of Transportation Guidance
to Recipients on Special Language Services to LEP Beneficiaries.

4.  []{#__RefHeading___Toc145129561 .anchor}Monitor/Update Language
    Assistance Plan

> **Requirement:** In accordance with Chapter VII of US Department of
> Transportation Guidance to Recipients on Special Language Services to
> LEP Beneficiaries: *Recipients should have a process for monitoring
> and updating the LEP Plan, on an ongoing basis.*

**Finding:** During this Title VI Compliance Review of RTD, deficiencies
were found regarding RTD's compliance with U.S. DOT requirements to
Monitor and Update its Language Assistance Plan. As previously
discussed, RTD did not have a Language Assistance Plan, therefore, no
process was in place to monitor and update the plan on an ongoing basis.

Following the issuance of the Draft Report, the RTD submitted a response
to this deficiency stating:

> *The Task Force will develop and incorporate into a separate section
> within the Language Assistance Plan, procedures describing RTD's
> process for monitoring and updating the Language Assistance Plan on an
> ongoing basis.*
>
> *RTD will complete the Language Assistance Plan within 30 days from
> the submission of the completed assessment.*

**Corrective Actions and Schedules**: Consistent with RTD's response,
Within 30 days from the submission of the Language Assistance Plan, RTD
must submit to the FTA Office of Civil Rights Equal Opportunity
Specialist a section in its Language Assistance Plan describing its
process for monitoring and updating the plan on an ongoing basis.

[]{.mark}

[]{#__RefHeading___Toc145129562 .anchor}VII. SUMMARY OF FINDINGS AND
CORRECTIVE ACTIONS

+--------------+------+-----------+-------------------+--------+-----+
| **DOT LEP    | **   | **De      | **Corrective      | **Re   | **D |
| Requirements | Site | scription | Action(s)**       | sponse | ate |
| For Transit  | Re   | of        |                   | Days/  | Cl  |
| Providers**  | view | Defic     |                   | Date** | ose |
|              | F    | iencies** |                   |        | d** |
|              | indi |           |                   |        |     |
|              | ng** |           |                   |        |     |
+==============+======+===========+===================+========+=====+
| 1\. Conduct  | D    | > No LEP  | > RTD must submit | ###### | []{ |
| Assessment   |      | > Needs   | > to the FTA      | ### 12 | .ma |
| of LEP Needs |      | > A       | > Office of Civil | 0 Days | rk} |
|              |      | ssessment | > Rights Equal    |        |     |
|              |      | >         | > Opportunity     | ####   |     |
|              |      | Conducted | > Specialist      | #####  |     |
|              |      |           | > documentation   |        |     |
|              |      |           | > that it has     | ###    |     |
|              |      |           | > completed or is | ###### |     |
|              |      |           | > in the process  |  Submi |     |
|              |      |           | > of completing   | t Quar |     |
|              |      |           | > an Assessment   | terly  |     |
|              |      |           | > of LEP Needs,   | Report |     |
|              |      |           | > in accordance   | s Unti |     |
|              |      |           | > with Chapter V  | l Comp |     |
|              |      |           | > of US           | leted  |     |
|              |      |           | > Department of   |        |     |
|              |      |           | > Transportation  |        |     |
|              |      |           | > Guidance to     |        |     |
|              |      |           | > Recipients on   |        |     |
|              |      |           | > Special         |        |     |
|              |      |           | > Language        |        |     |
|              |      |           | > Services to LEP |        |     |
|              |      |           | > Beneficiaries   |        |     |
+--------------+------+-----------+-------------------+--------+-----+
| 2\.          | ND   |           |                   |        |     |
| Reasonable   |      |           |                   |        |     |
| Efforts to   |      |           |                   |        |     |
| Provide      |      |           |                   |        |     |
| Language     |      |           |                   |        |     |
| Assistance   |      |           |                   |        |     |
| Services     |      |           |                   |        |     |
+--------------+------+-----------+-------------------+--------+-----+
| 3\. Language | D    | > No      | > RTD must submit | 60     |     |
| Assistance   |      | >         | > to the FTA      | Days   |     |
| Plan         |      |  Language | > Office of Civil | from   |     |
| Developed    |      | > A       | > Rights Equal    | the    |     |
| and          |      | ssistance | > Opportunity     | Subm   |     |
| Implemented  |      | > Plan    | > Specialist      | ission |     |
|              |      | >         | > documentation   | of the |     |
|              |      | Developed | > of a Language   | Com    |     |
|              |      | > and     | > Assistance Plan | pleted |     |
|              |      | > Im      | > to address the  | Asse   |     |
|              |      | plemented | > identified      | ssment |     |
|              |      |           | > needs of the    |        |     |
|              |      |           | > LEP populations | Submit |     |
|              |      |           | > it services, in | Qua    |     |
|              |      |           | > accordance with | rterly |     |
|              |      |           | > Chapter VII of  | R      |     |
|              |      |           | > US Department   | eports |     |
|              |      |           | > of              | Until  |     |
|              |      |           | > Transportation  | Com    |     |
|              |      |           | > Guidance to     | pleted |     |
|              |      |           | > Recipients on   |        |     |
|              |      |           | > Special         |        |     |
|              |      |           | > Language        |        |     |
|              |      |           | > Services to LEP |        |     |
|              |      |           | > Beneficiaries   |        |     |
+--------------+------+-----------+-------------------+--------+-----+
| 4\.          | D    | > No      | > RTD must submit | 30     |     |
| Mo           |      | > P       | > to the FTA      | Days   |     |
| nitor/Update |      | rocedures | > Office of Civil | from   |     |
| Plan         |      | > to      | > Rights Equal    | the    |     |
|              |      | > Monit   | > Opportunity     | Subm   |     |
|              |      | or/Update | > Specialist a    | ission |     |
|              |      | > the     | > section in its  | of the |     |
|              |      | >         | > Language        | Com    |     |
|              |      |  Language | > Assistance Plan | pleted |     |
|              |      | > A       | > describing its  | Asse   |     |
|              |      | ssistance | > process for     | ssment |     |
|              |      | > Plan    | > monitoring and  |        |     |
|              |      |           | > updating the    | Submit |     |
|              |      |           | > plan on an      | Qua    |     |
|              |      |           | > ongoing basis   | rterly |     |
|              |      |           |                   | R      |     |
|              |      |           |                   | eports |     |
|              |      |           |                   | Until  |     |
|              |      |           |                   | Com    |     |
|              |      |           |                   | pleted |     |
+--------------+------+-----------+-------------------+--------+-----+

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

NR = Not Reviewed;

VIII. []{#__RefHeading___Toc145129563
      .anchor}A**[ttenDEES]{.underline}**

+-------------+--------------------+---------+------------------------+
| **NAME**    | **TITLE/**         | **P     | **E-MAIL**             |
|             |                    | HONE/** |                        |
|             | **ORGANIZATION**   |         |                        |
|             |                    | **FAX** |                        |
+=============+====================+=========+========================+
| Clarence    | General            | 303.2   | Cal.m                  |
| Marsella    | Manager/CEO, RTD   | 99.2300 | arsella@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2363 |                        |
+-------------+--------------------+---------+------------------------+
| Kenn Hardin | Business           | 303.2   | Kenn                   |
|             | Opportunity &      | 99.2111 | .hardin@rtd-denver.com |
|             | Outreach Officer,  |         |                        |
|             | RTD                | 303.2   |                        |
|             |                    | 99.2183 |                        |
+-------------+--------------------+---------+------------------------+
| Elizabeth   | Assistant General  | 303.2   | Liz.rao@rtd-denver.com |
| A. Rao      | Manager, Planning  | 99.2485 |                        |
|             | and Development,   |         |                        |
|             | RTD                | 303.2   |                        |
|             |                    | 99.2452 |                        |
+-------------+--------------------+---------+------------------------+
| Pauletta    | FasTracks Public   | 303.2   | Pauletta.              |
| Tonilas     | Information        | 99.2469 | tonilas@rtd-denver.com |
|             | Manager, RTD       |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2425 |                        |
+-------------+--------------------+---------+------------------------+
| Steve       | Operating Division | 303.2   | Steve                  |
| Gleske      | Maintenance        | 99.6960 | .gleske@rtd-denver.com |
|             | Manager, District  |         |                        |
|             | Shops, RTD         | 303.2   |                        |
|             |                    | 99.6060 |                        |
+-------------+--------------------+---------+------------------------+
| Martha      | Operations         | 303.2   | Marth                  |
| Hecox       | Administration     | 99.2551 | a.hecox@rtd-denver.com |
|             | Manager,           |         |                        |
|             | Operations         | 303.2   |                        |
|             | Department, RTD    | 99.2061 |                        |
+-------------+--------------------+---------+------------------------+
| Ronald W.   | Assistant General  | 303.2   | Ron.do                 |
| Dodsworth   | Manager, Bus       | 99.2554 | dsworth@rtd-denver.com |
|             | Operations         |         |                        |
|             | Department, RTD    | 303.2   |                        |
|             |                    | 99.2061 |                        |
+-------------+--------------------+---------+------------------------+
| Bill Bell   | Manager, Light     | 303.2   | Bi                     |
|             | Rail               | 99.3440 | ll.bell@rtd-denver.com |
|             | Transportation,    |         |                        |
|             | RTD                | 303.2   |                        |
|             |                    | 99.3806 |                        |
+-------------+--------------------+---------+------------------------+
| Lloyd D.    | Assistant General  | 303.2   | Llo                    |
| Mack        | Manager, Rail      | 99.3420 | yd.mack@rtd-denver.com |
|             | Operations         |         |                        |
|             | Department, RTD    | 303.2   |                        |
|             |                    | 99.3498 |                        |
+-------------+--------------------+---------+------------------------+
| Brian       | Special Services   | 303.2   | Brian.m                |
| Matthews    | Manager,           | 99.2155 | atthews@rtd-denver.com |
|             | Contracted         |         |                        |
|             | Services           | 303.2   |                        |
|             | Department, RTD    | 99.2227 |                        |
+-------------+--------------------+---------+------------------------+
| Zachariah   | Services           | 303.2   | Zachariah.va           |
| Van Gemert  | Development        | 99.2830 | ngemert@rtd-denver.com |
|             | Applications       |         |                        |
|             | Expert, Customer   | 303.2   |                        |
|             | Services           | 99.2227 |                        |
|             | Department, RTD    |         |                        |
+-------------+--------------------+---------+------------------------+
| Tony        | Assistant General  | 303.2   | Tony.m                 |
| McCaulay    | Manager, Customer  | 99.2487 | ccaulay@rtd-denver.com |
|             | Services           |         |                        |
|             | Department, RTD    | 303.2   |                        |
|             |                    | 99.2008 |                        |
+-------------+--------------------+---------+------------------------+
| Larry       | Manager,           | 303.2   | Larry                  |
| Butler      | Paratransit        | 99.2152 | .butler@rtd-denver.com |
|             | Services, RTD      |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2992 |                        |
+-------------+--------------------+---------+------------------------+
| Bill Porter | Manager, Service   | 303.2   | William                |
|             | Planning and       | 99.2146 | .porter@rtd-denver.com |
|             | Scheduling, RTD    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2227 |                        |
+-------------+--------------------+---------+------------------------+
| Jessie      | Senior Service     | 303.2   | Jessie                 |
| Carter      | Planner, RTD       | 99.2028 | .carter@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2227 |                        |
+-------------+--------------------+---------+------------------------+
| Lorraine    | Bus Stop Program   | 303.2   | Lorraine               |
| Taylor      | Supervisor, RTD    | 99.6440 | .taylor@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.6500 |                        |
+-------------+--------------------+---------+------------------------+
| Mike Turner | Manager, Community | 303.2   | Mike                   |
|             | Involvement, RTD   | 99.2366 | .turner@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2452 |                        |
+-------------+--------------------+---------+------------------------+
| Pat Pugh    | Senior Manager,    | 303.2   | P                      |
|             | Marketing, RTD     | 99.2720 | at.pugh@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2008 |                        |
+-------------+--------------------+---------+------------------------+
| Susanne     | Senior Market      | 303.2   | Susann                 |
| Henry       | Research Analyst,  | 99.2110 | e.henry@rtd-denver.com |
|             | RTD                |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2600 |                        |
+-------------+--------------------+---------+------------------------+
| John Pung   | Market Research    | 303.2   | Jo                     |
|             | Manager, RTD       | 99.2142 | hn.Pung@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2600 |                        |
+-------------+--------------------+---------+------------------------+
| George      | Acting Education & | 303.2   | George.k               |
| Kuzirian    | Development        | 99.2215 | uzirian@rtd-denver.com |
|             | Specialist, RTD    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.3020 |                        |
+-------------+--------------------+---------+------------------------+
| Manny       | Senior Manager,    | 303.2   | Manuel.                |
| Herrara III | Human Resources,   | 99.2100 | herrara@rtd-denver.com |
|             | RTD                |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2015 |                        |
+-------------+--------------------+---------+------------------------+
| David A.    | Manager, Public    | 303.2   | David                  |
| Genova      | Safety, RTD        | 99.4038 | .genova@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.3110 |                        |
+-------------+--------------------+---------+------------------------+
| Cesar Ochoa | Service Planner,   | 303.2   | Cesa                   |
|             | RTD                | 99.2268 | r.ochoa@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2227 |                        |
+-------------+--------------------+---------+------------------------+
| Bob Daines  | Grant Coordinator, | 303.6   | Robert                 |
|             | RTD                | 83.6934 | .daines@rtd-denver.com |
|             |                    |         |                        |
|             |                    | 303.2   |                        |
|             |                    | 99.2338 |                        |
+-------------+--------------------+---------+------------------------+
| David       | Equal Opportunity  | 202.4   | David                  |
| Schneider   | Specialist, Office | 93.0175 | .schneider@fta.dot.gov |
|             | of Civil Rights,   |         |                        |
| (via        | FTA                | 202.3   |                        |
| tele        |                    | 66.3475 |                        |
| conference) |                    |         |                        |
+-------------+--------------------+---------+------------------------+
| John Potts  | Reviewer, DMP      | 504.2   | Joh                    |
|             |                    | 82.7949 | npotts@thedmpgroup.com |
+-------------+--------------------+---------+------------------------+
| Maxine      | Lead Reviewer, DMP | 504.2   | Maxine.ma              |
| Marshall    |                    | 82.7949 | rshall@thedmpgroup.com |
+-------------+--------------------+---------+------------------------+