**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**Greater Richmond Transit Company**

**(GRTC)**

**Richmond, Virginia**

**Final Report**

**February 2005**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**THE DMP GROUP, INC.**

**Subcontractor to**

**MILLIGAN & CO., LLC**

[Table of Contents]{.underline}

I. GENERAL INFORMATION [1](#__RefHeading___Toc485799033)

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

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

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

V. SCOPE AND METHODOLOGY [9](#__RefHeading___Toc485799037)

VI\. FINDINGS AND RECOMMENDATIONS [18](#__RefHeading___Toc485799038)

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

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

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

4\. FTA Civil Rights Assurance [21](#__RefHeading___Toc485799042)

5\. DOT Title VI Assurance [21](#__RefHeading___Toc485799043)

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

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

8\. Service Standards and Policies [23](#__RefHeading___Toc485799046)

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

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

11\. Internal Monitoring Procedures [32](#__RefHeading___Toc485799049)

12\. Title VI Complaints [33](#__RefHeading___Toc485799050)

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

VIII\. ATTENDEES [36](#__RefHeading___Toc485799052)

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

Grant Recipient: Greater Richmond Transit Company

City/State: Richmond, VA

Grantee No: 1458

Executive Official: Mr. Rollo Axton

> Chief Executive Officer
>
> Greater Richmond Transit Company
>
> 101 S. Davis Avenue
>
> P.O. Box 27323
>
> Richmond, VA 23261-7323

Report Prepared By: MILLIGAN & CO., LLC

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

Mulberry Atrium North

Philadelphia, PA 19103

THE DMP GROUP

2423 Killdeer Street

New Orleans, LA 70122

Site Visit Dates: October 4 -- 6, 2004

Compliance Review

Team Members: John Potts Dana Lucas

Lead Reviewer Reviewer

The DMP Group The DMP Group

Donald Lucas

Reviewer

The DMP Group

II. []{#__RefHeading___Toc485799034 .anchor}JURISDICTION AND AUTHORITIES

The Federal Transit Administration (FTA) Office of Civil Rights is
authorized by the Secretary of Transportation to conduct civil rights
compliance reviews. Reviews are undertaken to ensure compliance of
applicants, recipients, and subrecipients with Title VI of the Civil
Rights Act of 1964, as amended (42 U.S.C. 2000d); Section 22 of the
Master Agreement, Federal Transit Administration C.A. (3), October 1,
1996; and 49 U.S.C. 5332, "Non-Discrimination".

The Greater Richmond Transit Company (GRTC) is a recipient of FTA
funding assistance and is therefore subject to the Title VI compliance
conditions associated with the use of these funds pursuant to FTA
Circular 4704.1, "Title VI Program Guidelines for Grant Recipients,"
dated July 26, 1988; Part II, Section 117(a) of the FTA Agreement; and
FTA Circular 4702.1, "Title VI Program Guidelines for Federal Transit
Administration Recipients," dated May 26, 1988. The program guidelines
of FTA Circular 4702.1 define the components that must be addressed and
incorporated in GRTC's Title VI Program and were the basis for the
selection of compliance elements that were reviewed in this document.

[]{#__RefHeading___Toc485799035 .anchor}PURPOSE AND OBJECTIVES

**Purpose**

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

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

#### 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;

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

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

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

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

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

[Greater Richmond Transit Company]{.underline}

Public transit service in the Richmond urbanized area is provided by the
Greater Richmond Transit Company (GRTC). GRTC is a non-profit
corporation owned by the City of Richmond and the County of
Chesterfield. The GRTC Board of Directors is appointed by the Richmond
City Council and the Chesterfield County Board of Supervisors on an
annual basis. The six-member Board of GRTC contracts with Professional
Transit Management (PTM) for executive management services. Three staff
members---the Chief Executive Officer, the Operations Manager, and the
Chief Operating Officer---are employees of PTM.

GRTC directly operates the fixed routes with its own employees and
vehicles. A contractor, Laidlaw Transit Services, operates complementary
paratransit service in the fixed route service area. GRTC owns the
paratransit vehicles and retains the responsibility for determining ADA
paratransit eligibility. GRTC also manages a Welfare-to-Work service
called "C-VAN" for

Residents of the City of Richmond and the Counties of Henrico,
Chesterfield (including the City of Colonial Heights), and Hanover.
Until recently, Virginia Overland Transportation Company, operates the
C-VAN service. In August 2004, GRTC brought specialized service
in-house. In FY2000, GRTC began operating four deviated fixed local
routes and two express routes, called "LINK" for Chesterfield County. In
FY 2002 Chesterfield County eliminated all local services. In FY2002,
the County declined to fund the express routes, and they were
discontinued.

GRTC operates a network of 41 fixed routes, including commuter express.
Service is provided seven days a week, including holidays. The ADA
paratransit service, known as CARE, operates during the same days and
hours of service as the corresponding fixed routes.

On August 29, 2004, GRTC increased its fare on all routes by 25 cents.
The current base adult fare for local fixed route service is \$1.50 cash
or \$1.25 when tickets are purchased in prepaid books of ten. Transfers
are 15 cents in cash or 10 cents with a ticket. The commuter express
fare is \$1.75 cash or \$1.50 per prepaid ticket. Virginia Commonwealth
University purchases fixed route transit services for its students. A
reduced fare of 75 cents for regular fixed routes is offered to elderly
and disabled persons and Medicare cardholders during all hours. On
September 28, 2004 the ADA paratransit fare for CARE service was reduced
to \$15.00 per book for six trips. No individual tickets are sold.

GRTC has 193 vehicles in its fixed route fleet. The current peak
requirement is 147. The fleet includes eleven Ford vans that were
purchased to initiate six new transit routes in Chesterfield County. In
May 2003, all but two express routes were eliminated when Chesterfield
County declined to provide funding at the end of the pilot project. The
fleet consists of the following:

[Model]{.underline} [Year]{.underline} [Number]{.underline}

GMC Savana Van 2004 5

Ford E350 Van 2004 10

Bluebird Excel 2003 3

Gillig Low Floor 2003 17

Gillig Phantom 2003 16

Ford E450 Van 2001 3

Gillig Low Floor 2001 14

Ford E450 Van 2000 8

Ford E350 Van 2000 3

Gillig Low Floor 2000 16

Gillig Phantom 2000 25

Gillig Phantom 1998 32

Gillig Phantom 1997 21

Gillig Phantom 1996 20

GRTC also owns 50 Ford vans that are operated by Laidlaw for ADA
paratransit service.

GRTC's National Transit Database Report for FY2003 provided the
following financial and operating statistics for its fixed route and
paratransit service:

  -------------------------- -------------------- -----------------------
                             **Fixed-Route        **Paratransit Service**
                             Service**            

  Unlinked Passengers        11,843,548           199,529

  Revenue Hours              440,166              120,509

  Operating Expenses         \$26,595,285         \$3,436,052
  -------------------------- -------------------- -----------------------

During the past three years, GRTC purchased 33 replacement buses and
received three diesel buses in exchange for three electric buses that
had chronic power problems. GRTC initiated new service in suburban
Henrico County and began one express route to Petersburg. GRTC
commissioned the following analyses and feasibility studies related to
transit needs: regional taxi service, downtown electric streetcar
service, and redevelopment of sites for a new maintenance and
administrative facility. GRTC implemented a Geographic Information
System and installed transfer issuing/reading machines (TRIMs) and
associated software. To improve safety and security, GRTC conducted a
number of emergency response drills and installed surveillance cameras
on vehicles. Current projects include installation of automated
scheduling, dispatching, and customer information software and
installation of new bus shelters and other amenities throughout the
system.

The following table shows the racial/ethic breakdown of the GRTC service
area, which includes the City of Richmond, and Henrico and Chesterfield
Counties:

[]{.mark}

**Racial/ Ethnic Breakdown of the City of Richmond and the**

**GRTC Service Area**

######### 2000 Census

+--------------------+-----------+-----------+-----------+-----------+
| **Racial/ Ethnic   | #         | #         | ####      | ####      |
| Group**            | ### City  | ### Henri |  Chesterf |  GRTC Ser |
|                    | of Richmo | co County | ield Coun | vice Area |
|                    | nd Total/ |  Total/ P | ty Total/ |           |
|                    |           | ercent^1^ |           | ##        |
|                    | #### Per  |           | #### P    | ## Total/ |
|                    | cent[^1]  | ####      | ercent^1^ |           |
|                    |           |           |           | #### Pe   |
|                    |           |           |           | rcent[^2] |
+--------------------+-----------+-----------+-----------+-----------+
| #### White         | *         | *         | *         | ###       |
|                    | *69,800** | *93,343** | *72,524** | # 235,667 |
|                    |           |           |           |           |
|                    | 36%       | 62%       | 68%       | 52%       |
+--------------------+-----------+-----------+-----------+-----------+
| #### Black         | ###       | ###       | ###       | ###       |
|                    | # 111,850 | #  41,846 | #  21,869 | # 175,565 |
|                    |           |           |           |           |
|                    | 57%       | 28%       | 21%       | 39%       |
+--------------------+-----------+-----------+-----------+-----------+
| ##                 | **478**   | **630**   | **389**   | #         |
| ## American Indian |           |           |           | ### 1,497 |
|  and Alaska Native | 0%        | 0%        | 0%        |           |
|                    |           |           |           | 0%        |
+--------------------+-----------+-----------+-----------+-----------+
| #### Asian,        | **2,462** | **6,001** | **2,828** | *         |
|  Native Hawaiian o |           |           |           | *11,291** |
| r Pacific Islander | 1%        | 4%        | 3%        |           |
|                    |           |           |           | 3%        |
+--------------------+-----------+-----------+-----------+-----------+
| #### Hawaiia       | **155**   | **42**    | **62**    | **259**   |
| n/Pacific Islander |           |           |           |           |
|                    | 0%        | 0%        | 0%        | **0%**    |
+--------------------+-----------+-----------+-----------+-----------+
| ##                 | #         | #         | #         | ##        |
| ## Hispanic Origin | ### 4,987 | ### 4,101 | ### 4,627 | ## 13,715 |
|                    |           |           |           |           |
|                    | 3%        | 3%        | 4%        | 3%        |
+--------------------+-----------+-----------+-----------+-----------+
| ##                 | **5,758** | **4,353** | **4,063** | *         |
| ## Some Other Race | 3%        | 3%        | 4%        | *14,174** |
|                    |           |           |           |           |
|                    |           |           |           | 3%        |
+--------------------+-----------+-----------+-----------+-----------+
| ###                | **        | **        | **        | **        |
| # Total Population | 195,490** | 150,316** | 106,362** | 452,168** |
+--------------------+-----------+-----------+-----------+-----------+

GRTC serves the City of Richmond and portions of Chesterfield and
Henrico Counties. The population for the entire Richmond MPO Planning
District was 865,941 according to the 2000 U.S Census. The population of
GRTC's service area is 452,168. As shown above, Blacks represent 39
percent of the GRTC service area, and other minorities represent nine
percent, for a total minority representation of 48 percent.

In the City of Richmond, there is a higher concentration of minorities,
with Blacks representing 57 percent of the population, and other
minorities representing seven percent of the population, for a total
minority population of 64 percent.

In Henrico and Chesterfield counties, the minority representation is
lower in comparison to the total GRTC service area and the City of
Richmond. The minority representation in the Henrico and Chesterfield
counties is 38 percent and 32 percent, respectively.

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

#### Scope

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

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

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a.  A list of active Title VI lawsuits or complaints;

b.  A description of pending applications for financial assistance;

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

d.  A signed FTA Civil Rights Assurance;

e.  A signed standard DOT Title VI Assurance; and

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

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

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

b.  service standards and policies;

c.  assessment of compliance by grantees;

d.  Other areas of Title VI considerations.

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

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

#### Methodology

An initial interview was conducted with the Region III Civil Rights
Officer to discuss specific Title VI issues and concerns regarding GRTC.
Following this discussion, a detailed letter was sent to GRTC advising
it of the site visit and indicating additional information that would be
needed and issues that would be discussed.

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

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

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

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

-   Any studies or surveys conducted by GRTC, 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.

-   GRTC By-laws

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

-   A list of any active lawsuits and complaints

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-   Pending grant applications

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-   Other civil rights compliance reviews during the last three years

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

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

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

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

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

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-   Service Standards adopted by GRTC for use in measuring the level of
    service provided to minority and non-minority communities. This
    should include standards for vehicle load, vehicle assignment,
    vehicle headway, distribution of transit amenities, and transit
    access

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-   Information collected by GRTC for each bus route to assess service
    for compliance with established service standards, e.g., vehicle
    load factor analyses, vehicle assignment sheets, vehicle headways,
    amenities, such those provided at rail stations and bus stops, etc.

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-   Ridership by route

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-   Passenger boardings by bus stop

-   Maximum load points by route

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

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-   Inventory of bus stop shelters and benches which indicates their
    location and any amenities such as benches, lights and telephones

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

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

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

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

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

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

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

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

The site visit to GRTC occurred October 4-6, 2004. The individuals
participating in the review are listed in Section VIII of this report.
At the entrance conference, the purpose of the Title VI Compliance
Review and the review process were discussed. A detailed schedule for
conducting the on-site visit was discussed. After the entrance
conference, the site visit focused on the status of the information
requested in the letter notifying GRTC of the Compliance Review.
Arrangements were also made for a tour of GRTC's facilities and bus
routes, observation of vehicle assignments to routes, review of actual
headways and ridership on sample majority and minority routes, and
interviews with GRTC's staff and community representatives.

The GRTC bus garage and maintenance facility was toured. Several bus
routes were toured, including Routes 10, 16, and 37. On the third day of
the site visit, the review team also examined the assignment and
condition of vehicles from the bus garage.

Interviews were conducted with GRTC staff and community representatives
to provide information on the extent to which GRTC incorporates Title VI
requirements in the planning and implementation of service. The
interviews also focused on GRTC efforts to make communications and
information available in non-English formats for minority groups, as
required. In addition, the interviews with community representatives
focused on perceptions of the level and quality of bus service and
amenities in minority communities and the availability of information on
proposed changes in service.

The African-American community representatives spoke favorably of
GRTC\'s efforts to inform the Black population of GRTC\'s activities as
they particularly affected that population group.  Community
representatives noted that GRTC made significant efforts to utilize the
local African-American newspapers to inform them about bus route changes
due to construction as well as about the recent fare increase.  These
community representatives feel that GRTC has been very accommodating to
the general public and that there is a good working relationship between
them.

 

The Spanish-speaking community leaders indicated that there is over
crowding on the buses because buses are not running frequently enough
for this group of riders.  There is also a language barrier between the
riders and the bus drivers; so riders have difficulty getting around the
system.  The new Spanish language maps published by GRTC help, but are
so new that their impact is difficult to assess.  According to the
Hispanic community representatives, GRTC has made some favorable efforts
within the last year to reach out to the Hispanic population by
developing maps in Spanish, having GRTC booths at Hispanic events,
hosting workshops on how to use the bus, and producing fare change
notices to the Spanish language media.

 

Community representatives are eager to develop a stronger relationship
with GRTC and recommend that GRTC do the following:

 

1)  Hire more bilingual staff

2)  Increase marketing efforts to the Spanish-speaking community

3)  Partner with employers who hire Spanish speaking workers

4)  Provide more demos on how to ride the bus (in English & Spanish)

5)  Enhance relationships with minority community leaders who serve the
    bus riding population (Black and Hispanic)

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V.  []{#__RefHeading___Toc485799038 .anchor}FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on GRTC\'s compliance with both
the General Reporting Requirements and the Program-Specific
Requirements. This section describes the requirements and findings at
the time of the Compliance Review site visit. In summary, deficiencies
were identified in three of the twelve areas examined. It does appear
that GRTC actively considers Title VI issues in most of its transit
planning and operations activities. GTRC had developed three of the five
required service standards and collects relevant data with respect to
the written standards as required by the Circular. However, at the time
of the site visit, GRTC did not have written standards for vehicle
assignment and transit amenities, and did not monitor service or conduct
assessments in accordance with FTA requirements.

####  

#### Findings of the General Reporting Requirements

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

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

**Finding:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for List of Active
Complaints and Lawsuits. In its most recent Title VI submittal, made in
2002, GRTC reported that it did not have any active Title VI complaints
or lawsuits.

At the time of the site visit, GRTC indicated that there were two Title
VI complaints filed against them since its 2002 submission, both of
which were resolved. One complaint was filed by a passenger who stated
that a bus operator refused to give a white male passenger a transfer.
The second complaint was filed by a passenger who stated that he was not
able to use the seats reserved for elderly/disabled, since the seats
were occupied by young black males. GRTC investigated the validity of
each complaint, performed recommended actions to resolve issues, and
closed each complaint in accordance with its established procedures.

While GRTC categorized these as Title VI complaints, in fact, neither of
the complainants are protected classes under the Title VI law.

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

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

**Finding:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for Pending Applications
for Financial Assistance. In information provided at the site visit,
GRTC did report on its pending applications for financial assistance by
other Federal agencies, in conformance with FTA Circular 4702.1. In its
most recent submittal, and at the time of the site visit, GRTC did not
have any pending applications for Federal funds from any agency other
than FTA. In its most recent Title VI submittal, made in 2002, GRTC
reported on its FTA-funded grants. GRTC was advised to report on all
pending applications for financial assistance, and all financial
assistance currently provided by *other* Federal agencies in future
submittals.

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

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

**Finding:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for Summary of Civil
Rights Compliance Reviews. In March 2002, FTA conducted a Disadvantaged
Business Enterprise Compliance Review of GRTC. This Review identified
several deficiencies that are being addressed outside of the scope of
this Title VI Compliance Review. The most recent FTA Triennial Review
conducted in February 2004 examined Civil Rights requirements and no
deficiencies were identified with the FTA requirements for Title VI.

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

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

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

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

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

**Finding:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for DOT Title VI
Assurance. At the site visit and in its most recent Title VI submittal,
made in 2002, GRTC reported that it had properly executed its "one-time"
DOT Title VI Assurance in 2001.

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

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

**Finding:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for Fixed-Facility/
Environmental Justice Impact Analysis. At the site visit, GRTC indicated
that it was in the early planning stages of either relocating or
renovating its existing facilities, including its administrative offices
and bus facility, which may lead to construction activities. In 2002,
GRTC conducted a feasibility study of a streetcar system in downtown
Richmond. GRTC also indicated it was contemplating the construction of a
downtown transit center. It was noted that none of the proposed projects
were developed to the point where fixed facility analyses were
warranted. GRTC was advised that it must conduct fixed
facility/environmental justice impact analyses for all construction
projects and report on the impacts in its Title VI submittal.

#### 

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

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

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

**Findings:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for Demographic and
Service Profile Maps, Overlays and Charts. During the site visit, GRTC
provided Base Maps and Overlays as required by the Circular. The Base
Maps identified each census tract by number, major streets and highways,
the fixed transit facilities and identified the major activity centers
and transit trip generators.

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

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

(1) Vehicle Load or Load Factor

(2) Vehicle Assignment

(3) Distribution of Transit Amenities

(4) Vehicle Headway

(5) Transit Access

**Findings:** During this Title VI Compliance Review of GRTC,
deficiencies were found with FTA requirements for Service Standards and
Policies. At the time of the site visit, the most recent document
containing service standards was GRTC's *FY 2004-2008 Transit
Development Plan* (TDP) that has service standards for three of the five
required factors. GRTC also included standards in its 2002 Title VI
submittal. The GRTC service standards required for Title VI are
summarized in the following table:

+-------------------+--------------------------------------------------+
| **FTA Service     | **GRTC Policy**                                  |
| Standard**        |                                                  |
+===================+==================================================+
| **Vehicle         | Vehicle loads for Local and Shuttle service is   |
| Load** - A ratio  | 1.20 peak, and 1.00 off-peak. Vehicle loads for  |
| of the number of  | Express is 1.0 peak (off-peak is not             |
| passengers on a   | applicable).                                     |
| vehicle to the    |                                                  |
| number of seats   |                                                  |
+-------------------+--------------------------------------------------+
| **Vehicle         | Maximum peak headway is 20 minutes (except on    |
| Headway** -       | low ridership routes); and maximum off-peak      |
|                   | headway is 60 minutes.                           |
| The time interval |                                                  |
| between two       |   ------------- ---------------- --------------- |
| vehicles          |   ***Service    ***Headway***                    |
| traveling in the  |   Type***                                        |
| same direction on |                                                  |
| the same route    |                 Peak             Off-peak        |
|                   |                                                  |
|                   |   Weekday       15 to 20 minutes 30 to 60        |
|                   |                                  minutes         |
|                   |                                                  |
|                   |   Saturday      \--              60 minutes      |
|                   |                                                  |
|                   |   Sunday        Service provided                 |
|                   |                 based on local                   |
|                   |                 policy                           |
|                   |                                                  |
|                   |   Express       Demand driven                    |
|                   |   ------------- ---------------- --------------- |
+-------------------+--------------------------------------------------+
| **Transit         | Access to the transit system is measured by      |
| Access** - The    | distance to the closest transit line as well as  |
| distance a person | by proximity of transit lines to major activity  |
| must travel to    | centers.                                         |
| gain access to    |                                                  |
| transit service   |   ---------------------- ----------------------  |
|                   |   **Accessibility to the                         |
|                   |   transit System by                              |
|                   |   Residential Density**                          |
|                   |                                                  |
|                   |   *Persons/Acre*         *Max Distance to        |
|                   |                          Transit Line*           |
|                   |                                                  |
|                   |   Over 6.0               ¼ mile                  |
|                   |                                                  |
|                   |   3.0-6.0                ½ mile                  |
|                   |                                                  |
|                   |   1.5-3.0                1 mile                  |
|                   |   ---------------------- ----------------------  |
|                   |                                                  |
|                   |   ---------------------- ----------------------  |
|                   |   **Accessibility to the                         |
|                   |   Transit System from                            |
|                   |   Activity Centers**                             |
|                   |                                                  |
|                   |   *Number of Employees*  *Max Distance to        |
|                   |                          Transit Line*           |
|                   |                                                  |
|                   |   Over 100               ¼ mile                  |
|                   |                                                  |
|                   |   50-100                 ½ mile                  |
|                   |                                                  |
|                   |   25-50                  1 mile                  |
|                   |   ---------------------- ----------------------  |
+-------------------+--------------------------------------------------+

+-------------+---------------------------+---------------------------+
| **FTA       | **GRTC Policy**           | **Comment**               |
| Service     |                           |                           |
| Standard**  |                           |                           |
|             |                           |                           |
| **(c        |                           |                           |
| ontinued)** |                           |                           |
+-------------+---------------------------+---------------------------+
| **Vehicle   | > GRCT does not have a    | > GRTC must have a        |
| A           | > written standard for    | > written quantifiable    |
| ssignment** | > vehicle assignment.     | > service standard to     |
| -           | >                         | > determine equitable     |
|             | > During the site visit,  | > distribution of         |
| The process | > GRTC verbally indicated | > vehicles consistent     |
| by which    | > that they assigned      | > with Title VI           |
| vehicles    | > vehicles in relation to | > requirements.           |
| are         | > loads; i.e. higher      |                           |
| assigned to | > capacity buses were     |                           |
| routes      | > assigned to routes with |                           |
| throughout  | > higher loads.           |                           |
| the system  | >                         |                           |
| due to      | > []{.mark}               |                           |
| variations  |                           |                           |
| among       |                           |                           |
| vehicles    |                           |                           |
| (age, size, |                           |                           |
| amenities,  |                           |                           |
| etc.).      |                           |                           |
+-------------+---------------------------+---------------------------+
| **D         | > GRTC has the following  | > GRTC's service standard |
| istribution | > policy for amenities:   | > for shelters is not     |
| of Transit  | >                         | > quantifiable and may    |
| Amenities** | > *Benches*: When funding | > not provide for the     |
| -           | > is available, benches   | > equitable distribution  |
|             | > are provided at stops   | > of shelters as required |
| Criteria    | > that do not have        | > by the Circular. In     |
| for         | > passenger shelters and  | > addition, GRTC does not |
| i           | > serve 100 or more       | > have a written service  |
| nstallation | > boarding passengers.    | > standard for trash      |
| of items of | >                         | > cans, another bus stop  |
| comfort and | > *Shelters:* Shelters    | > amenity.                |
| convenience | > are provided at all     | >                         |
| available   | > Park-n-Rides and where  | > GRTC does not appear to |
| to the      | > private businesses      | > have a disparity in the |
| general     | > agree to finance        | > distribution of transit |
| public      | > shelter construction    | > amenities. GRTC also    |
|             | > and maintenance.        | > provided documentation  |
|             |                           | > of its planned          |
|             |                           | > amenities, which seemed |
|             |                           | > to be distributed       |
|             |                           | > equitably as well.      |
+-------------+---------------------------+---------------------------+

Subsequent to the site visit, GRTC provided revised service standards
for shelters and trash cans that meet the requirements of the Circular.
The revised service standards are as follows:

+-------------------+--------------------------------------------------+
| **FTA Service     | **GRTC Policy**                                  |
| Standard**        |                                                  |
+===================+==================================================+
| **Distribution of | GRTC has the following policy for shelters and   |
| Transit           | trash cans:                                      |
| Amenities** -     |                                                  |
|                   | *Shelters:* Given physical considerations, GRTC  |
| Shelters and      | will endeavor to provide shelters for stops with |
| Trash Cans        | ≥400 weekly boardings. Stops with fewer weekly   |
|                   | boardings (101-499) will be evaluated on a       |
|                   | case-by-case basis. The type of shelter will be  |
|                   | evaluated on a case-by-case basis.               |
|                   |                                                  |
|                   | *Trash Cans:* Given physical considerations,     |
|                   | GRTC will endeavor to provide trash cans for     |
|                   | stops with ≥100 weekly boardings or alightings.  |
|                   | Stops with fewer weekly boardings and alightings |
|                   | (0-100) will be evaluated on a case-by-case      |
|                   | basis.                                           |
+-------------------+--------------------------------------------------+

**Corrective Actions and Schedules:** Within 90 days, GRTC must submit
to the FTA Region III Civil Rights Officer a quantifiable service
standard for vehicle assignment. The standard must take into
consideration the age and type of equipment to ensure that vehicles are
deployed in an equitable manner along minority and non-minority routes.

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

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

**Finding:** During this Title VI Compliance Review of GRTC,
deficiencies were found with FTA requirements for Assessment of
Compliance by Grantees. During the site visit, GRTC provided
documentation of its assessment of compliance with Title VI
requirements. However, GRTC did not analyze the resultant data to
determine compliance with the Circular or explain or correct deviations
from service standards where indicated. For example, GRTC's assessment
of transit access indicated areas of substandard access in minority
areas. At the time of the site visit, GRTC did not give explanations or
take corrective actions for the identified substandard areas.

In addition, GRTC's assessment of vehicle loads and headways indicated
that a minority route had a crush load of 159 percent and its only
non-minority route had a maximum load factor of 49 percent. Thus, it
would appear that GRTC should increase the service on the minority route
to comply with its service standard for load factor of 120 percent. GRTC
indicated that the assessment data was derived from one day and may not
be sufficient for assessing its compliance with its established service
standards. This type of data should have triggered further study and a
determination of the "one-time" nature of the load factor or the need
for added service to resolve the apparent disparity.

GRTC did identify its minority and non-minority routes in its 2002 Title
VI submittal in accordance with the definition of the Circular.

[]{.mark}

During the site visit, the review team conducted limited on-site checks
to determine if the quality and quantity of service provided to the
minority community and the non-minority community complied with Title VI
objectives. The review team checked vehicle loads, vehicle assignments
and transit amenities. No disparities were apparent from the limited on
site assessment. However, GRTC does not follow all of the assessment
procedures outlined in FTA Circular 4702.1. These procedures were
discussed during the site visit.

Subsequent to the site visit, GRTC provided documentation that it had
performed an analysis of its substandard areas with respect to transit
access. In its analysis, GRTC identified the areas with substandard
service and provided reasonable explanations for the substandard
results, such as, topographical constraints, nonresidential areas or
areas with no people needing service, and funding limitations when
service was proposed for substandard areas.

**Corrective Actions and Schedules:** Within 90 days, GRTC must submit
to the FTA Region III Civil Rights Officer documentation that it has
conducted an assessment of compliance for the four standards of vehicle
load, vehicle assignment, vehicle headway and transit amenities and has
addressed substandard results and/or taken corrective action in the
appropriate area. []{#__RefHeading___Toc485799048 .anchor}

10. 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 GRTC, no
deficiencies were found with FTA requirements for Changes in Service
Features. In its 2002 Title VI submittal and its *Transit Development
Plan*, GRTC did identify and consider the impacts on minorities prior to
making decisions on fare increases and service changes.

######## 

######## Information Dissemination

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

> **Finding:** During this Title VI Compliance Review of GRTC, no
> deficiencies were found with FTA requirements for Information
> Dissemination. GRTC makes efforts to inform the minority communities
> of transit service changes or improvements. In 2004, GRTC raised its
> fare for the first time in eleven years. In an effort to inform the
> minority communities, GRTC advertised the fare increase in many local
> minority newspapers and issued flyer notices in Spanish. GRTC has
> changed its bus route service over the last several years due to
> cutbacks or construction. GRTC also developed a new Ride Guide in
> English and Spanish, held public hearings, and posted information on
> its website. GRTC also issued internal memorandum informing staff of
> the service changes so that they may effectively communicate the
> changes to riders.

######## 

######## 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 GRTC, no
deficiencies were found with FTA requirements for Minority
Representation on Decision-Making Bodies. The GRTC Board is comprised of
six members who are appointed by the City Council of Richmond and
Chesterfield County Board of Supervisors. The City of Richmond and
Chesterfield County each select three members on an annual basis. At the
time of the site visit, the Board was comprised of two Blacks and four
Whites, which amounts to a minority representation of 33 percent. This
representation is below the service area minority population of 52
percent, and the City and County may consider appointing at least one
additional minority to the Board at the next opportunity.

Other noted advisory committees include the Richmond Area MPO, Technical
Advisory Committee, Citizens Transportation Advisory Committee, and the
Elderly and Disabled Advisory Committee, each of which have some
minority representation. On the Richmond MPO, 14 percent of its voting
members are minorities, on the Technical Advisory Committee, six percent
of its voting members are minorities, on the Citizens Transportation
Advisory Committee, 14 percent of its voting members are minorities, and
on the Elderly and Disabled Advisory Committee, 50 percent of its voting
members are minorities.

While there are no deficiencies in this area, since GRTC does make an
effort to include minorities in its decision making bodies, this should
be an area of continued focus to assure that minorities are represented
in an equitable manner.

######## 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 GRTC, no
deficiencies were found with FTA requirements for Multilingual
Facilities. GRTC's second largest minority group is its Hispanic
population. GRTC documented that it has signage and materials available
in Spanish, including its new Ride Guide and notices of its recent fare
increase. GRTC's Planning and Schedules Department is constantly seeking
and creating relationships with members of the non-English speaking
communities in an effort to improve communication regarding transit
service with non-English speaking communities.

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

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

**Findings:** During this Title VI Compliance Review of GRTC,
deficiencies were found with FTA requirements for Internal Monitoring
Procedures. At the time of the site visit, GRTC had not implemented the
required "level of service" and "quality of service" monitoring
procedures. GRTC provided documentation of transit route analysis used
to evaluate transit services, including farebox return, passenger trips
per mile and per hour of service, and operating costs per trip. These
procedures are used by GRTC to monitor the efficiency and effectiveness
of transit service. However, these are not the monitoring methodologies
required by the Title VI Circular to monitor the level and quality of
its transit service.

[]{.mark}

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

[]{#__RefHeading___Toc485799050 .anchor}

12. Title VI Complaints

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

**Finding:** During this Title VI Compliance Review of GRTC, no
deficiencies were found with FTA requirements for Title VI Complaints.
At the site visit, GRTC provided a document called *Title VI Monitoring
and Enforcement, Lawsuits and Complaints, GRTC Procedures and
Record-Keeping*. The document describes the process for receiving,
documenting and handling Title VI complaints from GRTC customers. The
document describes a multi-step process of receiving and logging the
complaint into a database, sending the complaint to the Title VI Officer
for investigation and resolution, writing a report on the findings and
recommendations for corrective action, if warranted, obtaining approval
by the Chief Operating Officer on the disposition of the complaint,
notifying the alleging party on disposition within 30 days, and
maintaining a document trail of complaint processing activity. The
procedures also allow the alleging party to request reconsideration of a
complaint within 30 days from the date of the notice of disposition. At
the site visit, GRTC indicated that there were no outstanding Title VI
complaints against it.

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

+--------------+------+-----------+-------------------+-------+------+
| **Title VI   | **   | **De      | **Corrective      | **Res | **   |
| Requirements | Site | scription | Action(s)**       | ponse | Date |
| For Transit  | Re   | of        |                   | D     | Clos |
| Providers**  | view | Defic     |                   | ays/D | ed** |
|              | F    | iencies** |                   | ate** |      |
|              | indi |           |                   |       |      |
|              | ng** |           |                   |       |      |
+==============+======+===========+===================+=======+======+
| 1\. List of  | ND   |           |                   |       |      |
| Active       |      |           |                   |       |      |
| Complaints   |      |           |                   |       |      |
| and Lawsuits |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 2\. List of  | ND   |           |                   |       |      |
| Pending      |      |           |                   |       |      |
| Grant        |      |           |                   |       |      |
| Applications |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 3\. Summary  | ND   |           |                   |       |      |
| of           |      |           |                   |       |      |
| Compliance   |      |           |                   |       |      |
| Reviews      |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 4\. Signed   | ND   |           |                   |       |      |
| Civil Rights |      |           |                   |       |      |
| Assurance    |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 5.  Signed   | ND   |           |                   |       |      |
|     DOT      |      |           |                   |       |      |
|     Title VI |      |           |                   |       |      |
|              |      |           |                   |       |      |
|    Assurance |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 6\.          | ND   |           |                   |       |      |
| Fi           |      |           |                   |       |      |
| xed-Facility |      |           |                   |       |      |
| Impact       |      |           |                   |       |      |
| Analysis     |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 7\.          | ND   |           |                   |       |      |
| Demographic  |      |           |                   |       |      |
| and Service  |      |           |                   |       |      |
| Maps,        |      |           |                   |       |      |
| Overlays and |      |           |                   |       |      |
| Charts       |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 8\. Service  | D    | > Service | > GRTC must       | 90    |      |
| Standards    |      | >         | > submit to the   | Days  |      |
| and Policies |      | Standards | > FTA Region III  |       |      |
|              |      | > Not     | > Civil Rights    |       |      |
|              |      | >         | > Officer a       |       |      |
|              |      |  Adequate | > quantifiable    |       |      |
|              |      |           | > service         |       |      |
|              |      |           | > standard for    |       |      |
|              |      |           | > vehicle         |       |      |
|              |      |           | > assignment. The |       |      |
|              |      |           | > standard must   |       |      |
|              |      |           | > take into       |       |      |
|              |      |           | > consideration   |       |      |
|              |      |           | > the age and     |       |      |
|              |      |           | > type of         |       |      |
|              |      |           | > equipment to    |       |      |
|              |      |           | > ensure that     |       |      |
|              |      |           | > vehicles are    |       |      |
|              |      |           | > deployed in an  |       |      |
|              |      |           | > equitable       |       |      |
|              |      |           | > manner along    |       |      |
|              |      |           | > minority and    |       |      |
|              |      |           | > non-minority    |       |      |
|              |      |           | > routes.         |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 9\.          | D    | > No      | > GRTC must       | 90    |      |
| Assessment   |      | > C       | > submit          | Days  |      |
| of           |      | ompliance | > documentation   |       |      |
| Compliance   |      | > A       | > to the FTA      |       |      |
| by Grantee   |      | ssessment | > Region III      |       |      |
|              |      | >         | > Civil Rights    |       |      |
|              |      | Conducted | > Officer that it |       |      |
|              |      |           | > has conducted   |       |      |
|              |      |           | > an assessment   |       |      |
|              |      |           | > of compliance   |       |      |
|              |      |           | > in accordance   |       |      |
|              |      |           | > with FTA        |       |      |
|              |      |           | > requirements    |       |      |
|              |      |           | > and that it has |       |      |
|              |      |           | > established a   |       |      |
|              |      |           | > process to      |       |      |
|              |      |           | > conduct the     |       |      |
|              |      |           | > assessments on  |       |      |
|              |      |           | > a periodic      |       |      |
|              |      |           | > basis.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 10\. Other   | ND   |           |                   |       |      |
| Areas of     |      |           |                   |       |      |
| Title VI     |      |           |                   |       |      |
| Co           |      |           |                   |       |      |
| nsiderations |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 11\.         | D    | > No      | > GRTC must       | 90    |      |
| Monitoring   |      | > M       | > submit to the   | Days  |      |
| Procedures   |      | onitoring | > FTA Region III  |       |      |
|              |      | > P       | > Civil Rights    |       |      |
|              |      | rocedures | > Officer         |       |      |
|              |      |           | > documentation   |       |      |
|              |      |           | > of procedures   |       |      |
|              |      |           | > to implement an |       |      |
|              |      |           | > internal        |       |      |
|              |      |           | > monitoring      |       |      |
|              |      |           | > process.        |       |      |
|              |      |           | > Further, GRTC   |       |      |
|              |      |           | > must provide    |       |      |
|              |      |           | > documentation   |       |      |
|              |      |           | > that it has     |       |      |
|              |      |           | > initiated the   |       |      |
|              |      |           | > internal        |       |      |
|              |      |           | > monitoring      |       |      |
|              |      |           | > process and has |       |      |
|              |      |           | > a schedule of   |       |      |
|              |      |           | > dates for       |       |      |
|              |      |           | > periodic        |       |      |
|              |      |           | > monitoring of   |       |      |
|              |      |           | > bus services    |       |      |
|              |      |           | > and transit     |       |      |
|              |      |           | > amenities for   |       |      |
|              |      |           | > the next three  |       |      |
|              |      |           | > years.          |       |      |
+--------------+------+-----------+-------------------+-------+------+
| 12\. Title   | ND   |           |                   |       |      |
| VI           |      |           |                   |       |      |
| Complaints   |      |           |                   |       |      |
+--------------+------+-----------+-------------------+-------+------+

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

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

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

  -------------------------------------------------------------------------------------------------------------------------------------
  **NAME**    **TITLE/ORGANIZATION**   **PHONE**      **FAX**        **E-MAIL**
  ----------- ------------------------ -------------- -------------- ------------------------------------------------------------------
  Rollo Axton Chief Executive Officer  804 358-3871   804 342-1933   <raxton@ridegrtc.com>

  Elridge     Chief Operating Officer  804 358-3871   804 342-1933   <ecoles@ridegrtc.com>
  Coles                                                              

  Robert      Director of Planning &   804 358-3871   804 342-1933   <rhodder@ridegrtc.com>
  Hodder      Scheduling                                             

  Scott Clark Transit Analyst          804 358-3871   804 342-1933   <sclark@ridegrtc.com>

  Michelle    Intern                   804 358-3871   804 342-1933   <mnoche@ridegrtc.com>
  Noch                                                               

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

  Donald      Reviewer, DMP Group      202-726-2630   202-726-1830   [donald.lucas@thedmpgroup.com](mailto:royaleiii@thedmpgroup.com)
  Lucas                                                              

  Dana P.     Reviewer, DMP Group      202-726-2630   202-726-1830   [dana.lucas@thedmpgroup.com](mailto:royaleiii@thedmpgroup.com)
  Lucas                                                              
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[^1]: Census 2000, Data Summary #3, Planning Section, Metropolitan
    Planning Commission, October 2002

[^2]: GRTC Transit System, Department of Planning and Schedules