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39 Table 1. plaints were resolved by explaining to patrons why the Transit Agencies Having a Title VI Policy Ap- service changes were occurring and that most riders plicable to Reduction in Service or Increases would experience only minor inconvenience. In addi- in Fares tion, the agency used an appeals process to consider complaints with special circumstances, a method that Transit Agencies Having a Ti- 32 resulted in approximately 10 percent of proposed bus tle VI Policy stop consolidations being reinstated. Transit Agencies Not Having 32 Another agency described its practice in the han- a Title VI Policy dling of specific complaints regarding service reductions and fare increases. First, the agency's service planning For agencies having a policy, some of the transit group used statistical analyses and documentation to agencies' responses were: demonstrate that none of the allegations could be sub- stantiated. Second, an analysis by the agency's revenue The agency's "policy/procedures regarding fare in- department demonstrated that complaints regarding creases and service changes and the public review of fare increases also could not be substantiated. such proposals is part of the Agency's policy and proce- In neither of the two agencies' situations described dure manual which does not differentiate between Title above were complaints filed with the FTA. VI or ADA complaints." In sum, many agencies having a policy referred to The agency has a written policy but it is not "spe- their Title VI investigation and complaint process. As cific to reductions in service or increases in fares." discussed below, when asked specifically about consid- The agency "regularly includes information on [its] eration of low-income populations or outreach to LEP policy and complaint process in monthly brochures to persons, a much higher number of transit agencies re- our passengers." ported having a policy of evaluating the effect of a re- duction in service or an increase in fares on low-income Several agencies referred to their formal Title VI in- populations and having implemented methods to com- vestigation and complaint process. For example, one municate with and involve LEP persons with respect to agency in describing its practice stated that any com- such changes. plaints are logged and forwarded to the appropriate officer, an internal investigation is conducted with the assistance of counsel, and the results are conveyed in a B. Low-Income Populations letter to the complainant. Fifty-nine transit agencies said that when reducing A more detailed description provided by one agency transit service and/or increasing fares they take into was that: account the effect of the change on low-income popula- tions as a factor in the agency's decision-making. Three It has established procedures and developed "local agencies stated that they do not. standards" for compliance with Title VI. It has established internal guidelines for making Table 2. determinations of Title VI compliance as part of the Transit Agencies That Consider the Effect of a local decision-making processes and "continuing project Reduction in Service or an Increase in Fare on management responsibilities." Low-Income Populations It evaluates system-wide changes in service and proposed improvements at the planning stage to deter- Transit Agencies That 59 mine whether the benefits and costs of the changes are Consider the Effect on Low- distributed equally and are not discriminatory. Income Populations It conducts compliance assessments of transit ser- Transit Agencies That Do 3 vices and benefits to assure that service levels are equi- Not Consider the Effect on table and to ensure consistency in the quality of service Low-Income Populations among different user groups and to ensure responsive- Transit Agencies Not Re- 2 ness to the needs of minorities. sponding It takes action on the findings and recommenda- tions made by officials reviewing the agencies' policies In describing their practices, the agencies stated, for and actions. example, that: In the resolution of complaints on an informal basis, The agency collects and analyzes demographic and the practices of some agencies are of interest. One service data showing the extent to which members of agency stated that in one instance when there were minority and low-income populations within the complaints regarding a service reduction, the com-