## **TITLE VI COMPLIANCE ASSESSMENT**

#### **OF THE**

####  

**UTAH TRANSIT AUTHORITY**

**(UTA)**

**SALT LAKE CITY, UTAH**

## Final Report

## January 2004

##### Prepared For

U.S. DEPARTMENT OF TRANSPORTATION

FEDERAL TRANSIT ADMINISTRATION

OFFICE OF CIVIL RIGHTS

## 

## 

## **Prepared By**

## MILLIGAN & Company, LLC

###### Table of Contents

####### GENERAL INFORMATION.......................................................3

I.  JURISDICTION AND
    AUTHORITIES.......................................\...4

II. PURPOSE AND
    OBJECTIVES..................................................5

III. BACKGROUND
     INFORMATION.................................\...\...\...\........6

IV. SUMMARY OF FARE
    INCREASES............................................8

V.  SCOPE AND
    METHODOLOGY..............................................\...9

VI. RESULTS AND RECOMMENDATIONS....................................12

VII. SUMMARY OF RESULTS AND RECOMMENDATIONS...............16

VIII. ATTENDEES.......................................................................17

I. **[GENERAL INFORMATION]{.underline}**

Grant Recipient: Utah Transit Authority

> 3600 S. 700 West
>
> P.O. Box 30810
>
> Salt Lake City, UT 84130

City/State: Salt Lake City, Utah

Grantee No: 8001

Executive Official: John English, General Manager

Utah Transit Authority

3600 S. 700 West

> P.O. Box 30810

Salt Lake City, Utah 84130

Report Prepared By: MILLIGAN & Company, LLC

Mulberry Atrium North

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

Philadelphia, PA 19103

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

Compliance Review

Team Members: Sandra Swiacki

Lead Reviewer

Milligan & Company, LLC

Anne Marie Byrnes

Reviewer

Milligan & Company, LLC

Joseph Herzog

Reviewer

Milligan & Company, LLC

**II. [JURISDICTION AND AUTHORITIES]{.underline}**

The Federal Transit Administration (FTA) Office of Civil Rights is
authorized by the Secretary of the U.S. Department 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 Utah Transit Authority (UTA) 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.

On February 11, 1994, Executive Order 12898, entitled "Federal Actions
to Address Environmental Justice in Minority Populations and Low--Income
Populations," was signed into law. The order requires federal agencies
to identify and address disproportionately high and adverse human health
or environmental effects, including interrelated social and economic
effects, on minority and low-income populations. In April of 1997, the
Department of Transportation issued its own Environmental Justice Order
affirming that it will monitor its programs, policies and activities to
ensure that disproportionately high and adverse effects on minority and
low-income populations are avoided, minimized or mitigated.

The Title VI Program requirements as specified in the FTA Circular
4702.1, Title VI Program Guidelines for Federal Transit Administration
Recipients, and the Department of Transportation Order to Address
Environmental Justice in Minority Populations and Low-Income
Populations, define the components that should be addressed by UTA and
were the basis for the selection of elements reviewed and summarized in
this document.

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

**Purpose**

The Federal Transit Administration (FTA) Office of Civil Rights has
engaged Milligan & Company, LLC to develop guidance for conducting Title
VI Assessments in four areas -- Multilingual Communications, Fare
Increases, Service Changes, and Equitable Allocation of Resources. To
evaluate the procedures in the newly developed guidance, the Office of
Civil Rights authorized Milligan & Company, LLC to conduct pilot reviews
in each of the four areas.

For the pilot assessment for Fare Increases, the FTA's Office of Civil
Rights selected the Utah Transit Authority. The purpose of the
assessment was to determine the extent to which UTA has met its Title VI
Program requirements relative to fare increases, as specified in the FTA
Circular 4702.1, Program Guidelines for Federal Transit Administration
Recipients, and the U. S. Department of Transportation (DOT) Order to
Address Environmental Justice in Minority Populations and Low-Income
Populations, and to solicit their input on the guidance.

**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;

-   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;

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

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

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

**IV. [BACKGROUND INFORMATION]{.underline}**

The Utah Transit Authority was organized under the Utah Transit District
Act of 1970. UTA provides public transportation to the residents of Box
Elder, Weber, Davis, Salt Lake, Tooele and Utah counties; an area of
approximately 1,400 square miles with a resident population of more than
1.7 million people.

UTA operates fixed route bus service, a light rail service called TRAX,
ride share and car pool services, and specialized paratransit services
known as Flextrans. UTA also contracts with several providers for
paratransit service including the United Way in Utah County; Handi-Trans
service in Weber and Davis Counties, Brigham City, Williard and Perry;
and Aging Services in Tooele County. UTA operates a fleet of more than
490 buses over 136 routes and carries an average of 75,767 weekday bus
passengers. Its TRAX operation carries an average of 30,451 weekly
passengers. Its workforce is comprised of approximately 1,689 employees.

A Board of Trustees comprised of fifteen (15) appointed members
representing the six (6) counties served governs UTA. Board members are
generally appointed to serve two (2) consecutive three-year terms by the
respective County Commissioners and City Councils.

General demographic characteristics for the UTA, obtained from the 2000
census, are summarized below.

+----------------+--------+--------+--------+--------+--------+--------+
| **Ra           | **Salt | *      | **D    | **Box  | **To   | **Utah |
| ce/Ethnicity** | Lake   | *Weber | avis** | E      | oele** | Co     |
|                | Co     | Co     |        | lder** |        | unty** |
|                | unty** | unty** | **Co   |        | **Co   |        |
|                |        |        | unty** | **Co   | unty** |        |
|                |        |        |        | unty** |        |        |
+----------------+--------+--------+--------+--------+--------+--------+
| **White**      | 7      | 1      | 2      | 39,699 | 36,330 | 3      |
|                | 75,666 | 72,339 | 20,486 |        |        | 40,388 |
|                |        |        |        | (93%)  | (89%)  |        |
|                | (86%)  | (88%)  | (92%)  |        |        | (92%)  |
+----------------+--------+--------+--------+--------+--------+--------+
| **African      | 9,495  | 2,748  | 2,615  | 71     | 521    | 1,096  |
| American**     |        |        |        |        |        |        |
|                | (1%)   | (1%)   | (1%)   | (\<1%) | (1%)   | (\<1%) |
+----------------+--------+--------+--------+--------+--------+--------+
| **American     | 7,892  | 1,510  | 1,379  | 375    | 694    | 2,206  |
| Indian/        |        |        |        |        |        |        |
| Alaskan        | (\<1%) | (\<1%) | (\<1%) | (\<1%) | (2%)   | (\<1%) |
| Native**       |        |        |        |        |        |        |
+----------------+--------+--------+--------+--------+--------+--------+
| # **Asian/Paci | 34,066 | 2,827  | 4,304  | 443    | 316    | 6,039  |
| fic Islander** |        |        |        |        |        |        |
|                | (4%)   | (1%)   | (2%)   | (1%)   | (\<1%) | (2%)   |
+----------------+--------+--------+--------+--------+--------+--------+
| **Hispanic\*** | 1      | 24,858 | 12,955 | 2,791  | 4,214  | 25,791 |
|                | 06,787 |        |        |        |        |        |
|                |        | (13%)  | (5%)   | (6%)   | (10%)  | (7%)   |
|                | (12%)  |        |        |        |        |        |
+----------------+--------+--------+--------+--------+--------+--------+
| ##             | 8      | 1      | 2      | 42,745 | 40,735 | 3      |
|                | 98,387 | 96,533 | 38,994 |        |        | 68,536 |
| ## **Tota      |        |        |        |        |        |        |
| l Population** |        |        |        |        |        |        |
+----------------+--------+--------+--------+--------+--------+--------+

\*Hispanics may be of any race, so also are included in applicable race
categories.

**Persons Below Poverty Level in the State of Utah**\*

  -------------------------- --------------------------- ----------------
  **County**                 **Number**                  **Percent %**

  **Salt Lake**              70,714                      47%

  **Weber**                  18,022                      12%

  **Davis**                  11,984                      8%

  **Box Elder**              3,011                       2%

  **Tooele**                 2,615                       2%

  **Utah**                   43,270                      29%

  **Total**                  149,616                     100%
  -------------------------- --------------------------- ----------------

**\***Data as of 1999 taken from the 2000 census

**V. SUMMARY OF FARE INCREASES**

During the past three (3) years, the following fare increases were
proposed by UTA. The first proposal occurred in January of 2001 and only
involved paratransit. The proposed changes included an increase in the
cash fare from \$1.00 to \$2.00 and the elimination of UTA passes for
paratransit services. Approximately seven (7) public hearings were held
but no further action was taken by UTA to implement the proposal.

In August of 2001, UTA announced a significant change in transit fares.
The proposed changes affected all fare types and passes with incremental
increases over a three (3) year period. The reasons for the increase
included rising costs of fuel, utilities, and labor, and an attempt to
keep fares consistent with the annual growth in costs of all goods and
services. Subsequent to the public hearings, the UTA Board of Trustees
approved a resolution to implement the new fare structure effective
January 1, 2002, continuing with increases annually through 2004 for
some fare types. UTA staff was also directed to take steps with members
of the disabled community, including the Committee on Accessible
Transportation, to identify non-Authority sources of revenue that are
available to reduce the paratransit fare increase scheduled for 2003 and
2004, and to report the availability of such revenues to the Board on a
periodic basis.

A summary of the increase by fare type and pass type for the three (3)
year period is provided below:

  ----------------- -------------- -------------- -------------- --------------
  **Fare Type**     **Initial      **2002**       **2003**       **2004**
                    Rate**                                       

  **Adult**         **\$1.00**     **\$1.25**     **\$1.25**     **\$1.25**

  **Senior**        **.35**        **.50**        **.60**        **.60**

  **Disabled**      **.35**        **.50**        **.60**        **.60**

  **Premium Ex**    **2.00**       **2.25**       **2.50**       **2.50**

  **Paratransit**   **1.00**       **1.50**       **2.00**       **2.50**

  **Ski**           **1.75**       **2.00**       **2.50**       **2.50**

  **Ski Shuttle**   **1.00**       **1.25**       **1.25**       **1.25**

  **Day Pass**      **2.00**       **2.50**       **2.50**       **2.50**

  **Ski Day Pass**  **3.50**       **4.00**       **5.00**       **5.00**
  ----------------- -------------- -------------- -------------- --------------

  ----------------- ------------------- -------------- -------------- --------------
  **Pass Type**     **Initial Rate**    **2002**       **2003**       **2004**

  **Adult**         **\$32.00**         **\$40.00**    **\$45.00**    **\$45.00**

  **Senior**        **11.00**           **18.00**      **22.00**      **22.00**

  **Disabled**      **11.00**           **18.00**      **22.00**      **22.00**

  **Premium Ex**    **70.00**           **81.00**      **90.00**      **90.00**

  **Paratransit**   **32.00**           **48.00**      **68.00**      **90.00**

  **Paratransit     **\-\-\-\-\-\--**   **14.00**      **18.00**      **23.00**
  Trip**                                                              

  **Summer Youth**  **25.00**           **30.00**      **40.00**      **40.00**

  **S.Y. Buddy**    **20.00**           **25.00**      **35.00**      **35.00**

  **Minor**         **20.00**           **28.00**      **33.00**      **33.00**

  **Student**       **20.00**           **28.00**      **33.00**      **33.00**
  ----------------- ------------------- -------------- -------------- --------------

In May of 2003, UTA announced a series of public hearings to discuss a
further increase in the adult cash fare from \$1.25 to \$1.50. The basis
for the increase was to make up for higher diesel costs and a decrease
in sales tax revenue, a major source of UTA funding. No fares or passes
were affected by the proposal other than the adult cash fare.

**VI. [SCOPE AND METHODOLOGY]{.underline}**

######## Scope

The Title VI Compliance Assessment of UTA for Fare Increases focused on
the following areas, as specified in the FTA Circular 4702.1, Title VI
Program Guidelines for Federal Transit Administration Recipients:

> 1\. [Assessment of Compliance by Grantees]{.underline} -- Transit
> systems are required to establish procedures for developing and
> maintaining local standards for compliance with Title VI. Systemwide
> service changes and proposed improvements should be evaluated at the
> planning and programming stages to determine whether the overall
> benefits and costs of such changes or improvements are distributed
> equally and are not discriminatory.
>
> 2\. [Information Dissemination]{.underline} -- Transit systems are
> required to provide a description of the methods used to inform
> minority communities of service changes (e.g. public notices, public
> hearings, other formal or informal public discussions, presentations,
> meetings, etc.) relating to transit service and improvements.
>
> 3\. [Changes in Service Features]{.underline} - Transit systems are
> required to provide a description of the type of service changes
> proposed by the transit authority over the next three (3) years, and a
> statement of the effect of these changes on minority transit users. In
> particular, the transit system should describe significant service
> changes relating to hours or days of operation, headways and fares,
> and should provide the schedule reflecting such changes.

In addition, the review focused on the recipient's obligations under
Executive Order 12898 as specified in the Department of Transportation
Order to Address Environmental Justice in Minority Populations and
Low-Income Populations. These obligations are stated as follows:

1.  Identify and evaluate environmental, public health, and interrelated
    social and economic effects of programs, policies and activities.

2.  Propose measures to avoid, minimize and or mitigate
    disproportionately high and adverse environmental, public health,
    and interrelated social and economic effects.

3.  Consider alternatives to proposed programs, policies, and
    activities, where such alternatives would result in avoiding and or
    minimizing disproportionately high and adverse impacts.

4.  Elicit public involvement and input from affected minority and
    low-income populations in considering alternatives.

######## Methodology

This section describes the process Milligan & Company, LLC followed to
initiate contact with the grantee, collect data, and conduct the site
visit.

[Initial Contact and Data Collection]{.underline}

At the beginning of the pilot review, a telephone interview was
conducted with Rebecca Tanrath, Regional Civil Rights Officer, about
specific Title VI issues and concerns regarding UTA. Following the
interview, a detailed letter was sent to John English, General Manager
of UTA, advising him of the site visit, its purpose, issues to be
discussed, and information that would be needed for the pilot review. In
the letter, UTA was asked to provide the following background
information:

-   Details on recent fare increases, to include:

    -   Timeline of fare change (e.g. from financial planning to public
        hearings to initiation date(s) of increases)

    -   Modes of service affected

    -   Fare Instruments affected (e.g. base fares, transfers,
        paratransit fares and discounted sales)

-   Any analysis on the impact of the fare increase on protected groups

-   UTA's public participation process for fare increases and service
    changes

-   Details on public meetings held (dates, location, and meeting
    summaries)

-   Documentation of all methods used to disseminate information about
    the fare increase to protected groups

-   Complaints or lawsuits regarding the proposed or enacted fare
    increases

-   Average percent of protected group populations within the service
    area

-   Contact information for community groups that provided comment on
    the fare increase.

In follow-up telephone conversations with Jerri Ashurst, Programs
Administrator, additional information was requested and provided to the
review team. This included UTA's Title VI Program approved by the FTA on
June 27, 2001, Board Resolutions that established a systemwide fare
policy, copies of a slide presentation about the fare increase, the UTA
Benchmark Study, and Proposed Fare Change Scenarios.

The review team also met with Ms. Tanrath on May 5, 2003, at which time
she provided several newspaper articles and various correspondence,
letters and complaints forwarded to the FTA regarding UTA's public
participation process and fare increase proposal.

[Site Visit]{.underline}

The site visit at UTA was conducted on May 6 to May 8, 2003. The
individuals participating in the review are listed in Section IX of this
report. At the entrance conference, the purpose of the pilot review, the
proposed schedule for conducting the review, and the review process were
discussed. The agenda included interviews with appropriate staff
representatives to verify the methodology for the fare increase, the
effect on fare instruments, the impact on modes of service, the impact
analyses on protected groups, and the communication and dissemination of
information to the public. Interviews were also conducted with community
representatives to determine the efforts taken by the grantee to
communicate information on the proposed fare increase to protected
groups.

During the site visit, the following documents were requested and
provided to the review team:

-   UTA's 2002 Report of Paratransit Fare Assistance and Funding Sources

-   Meeting minutes from the Committee on Accessible Transportation
    (CAT) dated November 27, 2000 and January 22, 2001

-   Equity Analysis dated August 14, 2001

-   Minutes of the Three Hundred and Thirty Eighth, Three Hundred and
    Thirty Ninth, Three Hundred and Fortieth, Three Hundred and Forty
    First, Three Hundred and Forty Second, and Three Hundred and Forty
    Third Meetings of the UTA Board of Trustees

-   Executive summary of financial facts for UTA as of December 31,2000

-   Slide presentation of the History of Paratransit Service at UTA

-   Letter dated April 9, 2001 to Dr. Walter Talbot, Chairperson of
    UTA's Board of Trustees, from the Committee on Accessible
    Transportation

-   UTA's main media list for television, news print and radio and trade
    media list

-   Copies of various press releases, media advisories, and newspaper
    articles regarding the fare increase covering the period January
    2001 through May 2003.

[Exit Conference and Next Steps]{.underline}

At the exit conference, the review team and UTA management discussed the
results of the pilot review, recommendations and suggestions, and the
next steps.

**VII. [RESULTS AND RECOMMENDATIONS]{.underline}**

The Title VI Compliance Assessment for Fare Increases focused on UTA's
compliance with the Title VI Program requirements as specified in the
FTA Circular 4702.1, Title VI Program Guidelines for Federal Transit
Administration Recipients and the U. S. Department of Transportation
(DOT) Order to Address Environmental Justice in Minority Populations and
Low-Income Populations. This section describes the areas examined, the
results of the review, and recommendations.

**1. [Development of Equitable Method for the Fare
Increase]{.underline}**

The recipient is required to demonstrate that its method for determining
the actual or proposed fare increase took equity into consideration and
was not discriminatory.

> **Results of Review:** Evidence indicates that the method utilized by
> UTA for the fare increase was primarily predicated on three (3)
> factors. These included a fare structure proportionate to the cost of
> the service, a declining fare box recovery ratio, and an increase in
> operating costs. As such, the fare proposal was based on a 25%
> increase to the fixed route service in an effort to achieve their goal
> of a 20% farebox recovery ratio. The increase was applicable to both
> bus and rail service. However, with respect to paratransit, the fare
> was proposed at twice the fixed-route base fare due to the high cost
> of providing the service and its low farebox recovery ratio. Based on
> information provided and analyzed showing that the fare increase
> affected minority and non-minority customers equally, and that the
> increase for senior, disabled and paratransit fares was within legally
> permissible levels, UTA's demonstrated that its method for determining
> the fare increase took equity into consideration and was not
> discriminatory.

**2.** **[Impact Analysis and Consideration of
Alternatives]{.underline}**

> The recipient is required to evaluate systemwide service changes at
> the planning and programming stages to determine whether the overall
> benefits and costs of such changes are distributed equally and are not
> discriminatory. The recipient is also required to consider the impact
> of the of the service changes on each major protected group in the
> service area. Where an impact is identified, the recipient should also
> demonstrate that it considered and evaluated alternatives that would
> either avoid or substantially reduce the impact of the decision on
> protected groups.
>
> **Results of Review:** No documentation was provided to demonstrate
> that UTA conducted an analysis during the planning and programming
> stages to evaluate the impact of the fare increase on each protected
> group in the service area. The only such analysis appears to be a
> survey that was initiated and conducted by the Committee on Accessible
> Transportation (CAT), a citizen advisory group for disability issues,
> to determine the economic impact of the fare increase on paratransit
> customers.
>
> However, after the results of the survey were presented, evidence
> indicated that UTA considered and evaluated alternatives to avoid and
> substantially reduce the impact of the decision on paratransit users.
> One of the alternatives included the development of a coupon book that
> provides ten (10) trips at a discounted price for infrequent
> paratransit riders who could not afford a monthly pass. Another
> alternative was the implementation of The Freedom Access Pass Program
> that provides paratransit customers with free transportation on the
> fixed route system, along with training to assist with and encourage
> their transition from paratransit to regular service. While the
> program was initiated as a pilot for a three (3) month period, it was
> later extended on a yearly basis due to its success. Lastly, evidence
> indicates that UTA investigated other funding sources to potentially
> offset either UTA's paratransit operating costs or the paratransit
> rider's fare obligation. Few viable sources have been identified to
> date.
>
> **Recommendations:** UTA should develop a procedure to ensure that
> when planning a fare increase, the impact on all protected groups in
> the service area is evaluated at the planning and programming stages
> to ensure that the overall costs of such changes are distributed
> equally and are not discriminatory. The analysis, including
> consideration of alternatives, should be documented. It was also
> recommended that UTA continue to seek out and consider other
> alternatives to minimize or avoid the impact of the projected fare
> increase on the paratransit community.

**3. [Solicitation and Considering of Public Comments]{.underline}**

> The recipient is required to develop a process for soliciting and
> considering public comment prior to raising fares.
>
> **Results of Review:** UTA has a developed process for soliciting and
> considering public comment prior to raising fares. The written process
> requires that public hearings be held for all fare increases. It
> further specifies various steps to be taken in preparation for public
> hearings, including appropriate notification, solicitation, and
> documentation.
>
> According to the written process, public notices are required for
> publication in general circulation newspapers in affected areas a
> minimum of 15 days before the scheduled hearing. Notification efforts
> should also include direct mailings, placement of flyers on buses,
> press releases and news articles about the fares. At the hearing, the
> process calls for the collection of sign-in cards and comment sheets
> and the recording of all written and verbal comments. Public comments
> are also accepted after the completion of the hearings.
>
> With respect to documentation, an official public hearing record
> should be compiled in accordance with the process. This includes a
> summary report of the hearing(s) prepared by the hearing examiner,
> public hearing notices, proofs of publication from the newspaper,
> transcribed minutes of the hearing(s), all comments received, and
> copies of the presentation, handouts and newspaper articles.
>
> **Recommendation:** During the compliance assessment, UTA indicated
> that it was currently developing new guidelines for its public
> participation process. It was suggested that UTA describe the process
> for conducting the meetings and considering public comment in the
> newly drafted guidelines.

**4. [Adherence to Developed Process ]{.underline}**

> The recipient should indicate whether it followed its process in
> implementing the fare increase.
>
> **Results of Review**: UTA conducted a total of seventeen (17) public
> hearings in 2001 regarding the proposed fare increase -- seven (7) on
> the original and ten (10) on the revised proposal. In accordance with
> UTA's developed process, information regarding the public hearings was
> advertised in various newspapers and distributed by way of mailings,
> flyers, press releases and news articles. Each meeting commenced with
> an opening presentation by UTA staff that provided the basis or
> rationale for the fare increase, the purpose of the hearing, and the
> process for soliciting and considering public comments.
>
> Documentation was also provided that showed that sign-in cards,
> letters, emails, and comments cards were collected. All verbal and
> written comments were recorded and a summary report of the hearings
> was prepared. The documentation contained in the public record and
> interviews with UTA staff and community representatives, demonstrated
> that UTA followed its public participation process prior to
> implementing the fare increase.

**5. [Dissemination of Fare Increase Information]{.underline}**

> The recipient is required to inform protected groups of changes
> related to transit service and improvements.
>
> **Results of Review:** Evidence was provided to substantiate that UTA
> notified protected groups of the fare increase prior to its
> implementation. Notices regarding the seventeen (17) public hearings
> were published in newspapers of general circulation covering the
> entire UTA service area. Flyers were placed on all regular service
> buses and paratransit service buses, and were posted at TRAX stations.
> The notice was also mailed to more than 1300 city and county
> officials, community councils, interested citizens, social service
> agencies, including those that serve disabled and disadvantaged
> populations, senior citizen centers, libraries and private
> transportation providers. Ethnic media on the mailing list included
> several radio stations as well as newspapers targeted to the Hispanic
> and Asian communities, such as the LaPrensa, the La Semana, the Mundo
> Hispano, and the Utah Nippo. However, during the interviews, it was
> learned that UTA mails the notices to these newspapers and does not
> cover the cost for their advertisement as with the major general
> circulation newspapers. Furthermore, it appears that based on a list
> of minority-focused media and associations found on UTA's website and
> through interviews with staff and community representatives,
> additional sources were available through which UTA could have
> broadened their outreach to protected groups.
>
> Lastly, the review team confirmed that the rooms selected for the
> public hearing were fully accessible to the disabled community.
> Accommodations for sign language interpreters and printed materials in
> alternate formats were also provided to ensure full participation at
> the hearings. It was noted, however, that the information disseminated
> about the fare increase was provided only in English.
>
> **Recommendation:** It is suggested that in the future UTA should
> cover the advertising cost for the placement of public notices
> relating to transit service and improvements, including fare
> increases, in those ethnic newspapers with the widest distribution to
> protected groups, as it does for major general circulation newspapers.
> UTA should also update their mailing and media lists for disseminating
> information to include all television, radio, and community
> organizations that would expand their outreach to protected groups.
> Lastly, It is recommended that UTA evaluate their ridership to
> determine whether there is a need for providing information in a
> language other than English in accordance with the U.S. Department of
> Transportation (DOT) Guidance to Recipients on Special Language
> Services to Limited English Proficient (LEP) Beneficiaries.

**6. [Consideration of Protected Groups' Concerns]{.underline} -** The
recipient is required to ensure that due consideration is given to the
comments made by protected groups regarding the fare increase.

> **Results of Review:** The vast majority of comments received
> regarding the fare increase emanated from the disabled and senior
> citizens who believed the proposed paratransit fares were too high
> relative to their low and fixed incomes. In response to their concerns
> raised at the first public hearing, UTA delayed the increase. UTA also
> revised their original proposal by increasing fares on a gradual basis
> to reduce the economic impact on this community. Lastly, as suggested,
> the fare increase was later extended to all other modes of service and
> not just paratransit. The above actions and others previously
> mentioned, such as the coupon book and the Freedom Access Pass,
> demonstrated that UTA gave due consideration to comments made by
> protected groups.

**VIII. [SUMMARY OF RESULTS AND RECOMMENDATIONS]{.underline}**

  ----------------------- ----------------------- -----------------------
  **Areas Examined**      **Results of Review**   **Recommendations**

  **1. Development of     Information provided to 
  Equitable Method for    demonstrate that fare   
  Fare Increase**         increase methods were   
                          equitable and           
                          non-discriminatory.     

  **2. Impact Analysis/   Impact analysis not     In the future, analyze
  Consideration of        conducted; alternatives the impact of proposed
  Alternatives**          considered.             fare increases on all
                                                  protected groups.
                                                  Document analysis and
                                                  consideration of
                                                  alternatives for impact
                                                  reduction. Continue
                                                  efforts to seek out
                                                  alternatives for the
                                                  paratransit community.

  **3. Solicitation/      Adequate process        Describe process for
  Consideration of Public utilized and documented conducting meetings and
  Comments**              for soliciting and      considering public
                          considering public      comment in the newly
                          comment.                drafted guidelines.

  **4. Adherence to       Documentation was       
  Developed Process**     provided to demonstrate 
                          that developed process  
                          was followed.           

  **5. Dissemination of   Documentation was       Cover advertisement
  Information**           provided to demonstrate costs for public
                          that protected groups   notices in those ethnic
                          were informed of fare   newspapers with widest
                          increases. Improvements distribution to
                          could be made.          protected groups.
                                                  Update mailing and
                                                  media lists for
                                                  disseminating
                                                  information. Determine
                                                  if there is a need to
                                                  consider LEP when
                                                  disseminating
                                                  information.

  **6. Consideration of   Adequate consideration  
  Protected Group         given to concerns of    
  Concerns**              protected groups.       
  ----------------------- ----------------------- -----------------------

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

+----------------+---------------------+----------+--------------------+
| **NAME**       | **T                 | *        | **EMAIL**          |
|                | ITLE/ORGANIZATION** | *PHONE** |                    |
+----------------+---------------------+----------+--------------------+
| Rebecca Ubando | Regional Civil      | \(303\)  | <Rebecca.Ta        |
| Tanrath        | Rights Officer/     | 844-3221 | nrath@fta.dot.gov> |
|                | Federal Transit     |          |                    |
|                | Administration      |          |                    |
+----------------+---------------------+----------+--------------------+
| Gary Kitchen   | Economist/UTA       | \(801\)  | <gkitc             |
|                |                     | 262-5626 | hen@uta.cog.ut.us> |
|                |                     | x2425    |                    |
+----------------+---------------------+----------+--------------------+
| Jeffrey L.     | Deputy Chief Asset  | \(801\)  | <jhar              |
| Harris         | Management/UTA      | 287-2337 | ris@uta.cog.ut.us> |
+----------------+---------------------+----------+--------------------+
| Toby Alires    | Manager, Civil      | \(801\)  | <tali              |
|                | Rights              | 262-5626 | res@uta.cog.ut.us> |
|                | Compliance/UTA      |          |                    |
+----------------+---------------------+----------+--------------------+
| Desiree Peri   | Associate Corporate | \(801\)  | <dp                |
|                | Counsel/UTA         | 287-4684 | eri@uta.cog.ut.us> |
+----------------+---------------------+----------+--------------------+
| Jerri Ashurst  | Programs            | \(801\)  | <jashu             |
|                | Administrator/UTA   | 262-5626 | rst@uta.cog.ut.us> |
|                |                     | x2352    |                    |
+----------------+---------------------+----------+--------------------+
| Sherry         | ADA Compliance      | \(801\)  | <srepsc            |
| Repscher       | Officer/UTA         | 262-5626 | her@uta.cog.ut.us> |
|                |                     | x3536    |                    |
+----------------+---------------------+----------+--------------------+
| Cherryl        | Operations          | \(801\)  | cbever             |
| Beveridge      | Manager/UTA         | 262-5626 | idge@uta.cog.ut.us |
|                |                     | x5350    |                    |
+----------------+---------------------+----------+--------------------+
| Mike Hansen    | Planner/UTA         | \(801\)  | mha                |
|                |                     | 262 5626 | nsen@uta.cog.ut.us |
|                |                     | x2364    |                    |
+----------------+---------------------+----------+--------------------+
| Kris McBride   | Spokesperson/UTA    | \(801\)  | kmcb               |
|                |                     | 244-1942 | ride@uta.cog.ut.us |
+----------------+---------------------+----------+--------------------+
| Marti Money    | Public Relations    | \(801\)  | <mmo               |
|                | Specialist/UTA      | 287-2290 | ney@uta.cog.ut.us> |
+----------------+---------------------+----------+--------------------+
| Irene Huntsman | Corporate Office    | \(801\)  | ihunt              |
|                | Coordinator/UTA     | 287-2214 | sman@uta.cog.ut.us |
+----------------+---------------------+----------+--------------------+
| Barbara Toomer | Corporate           | \(801\)  | <dra               |
|                | Secretary/Disabled  | 685-8214 | cale@peoplepc.com> |
|                | Rights Action       |          |                    |
|                | Committee (DRAC)    |          |                    |
+----------------+---------------------+----------+--------------------+
| Kenneth        | Ch                  | \(801\)  | <ki                |
| Robertson      | airperson/Committee | 466      | ckoutkr@yahoo.com> |
|                | on Accessible       | -5565    |                    |
|                | Transportation      |          |                    |
|                | (CAT)               |          |                    |
+----------------+---------------------+----------+--------------------+
| Robert         | Administrator       | \(801\)  | llarchie.ar        |
| Archuleta      | Minority            | 535-7734 | chuleta@slcgov.com |
|                | Affairs/Office of   |          |                    |
|                | the Mayor           |          |                    |
+----------------+---------------------+----------+--------------------+
| Sandra Swiacki | Lead                | \(215\)  | sswiacki48@aol.com |
|                | Reviewer/Milligan & | 496-9100 |                    |
|                | Company, LLC        | x120     |                    |
+----------------+---------------------+----------+--------------------+
| Anne Marie     | Reviewer/Milligan & | \(215\)  | <abyrne            |
| Byrnes         | Company, LLC        | 4        | s@milligancpa.com> |
|                |                     | 96-9100, |                    |
|                |                     | x151     |                    |
+----------------+---------------------+----------+--------------------+
| #########      | Reviewer/Milligan & | \(215\)  | <jherzo            |
| Joseph Herzog  | Company, LLC        | 496-9100 | g@milligancpa.com> |
+----------------+---------------------+----------+--------------------+