HomeMy WebLinkAboutE-6 Staff Report - Title VI Program UpdateCONSENT ITEM
E-6
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: SERGIO GONZALEZ, CITY MANAGER
FROM: MIKI CARPENTER, COMMUNITY RESOURCES DIRECTOR
DATE: NOVEMBER 2, 2020
SUBJECT: RESOLUTION TO APPROVE THE UPDATED CITY OF AZUSA TITLE VI
PROGRAM
BACKGROUND:
As a sub-recipient of grant funds from the Federal Transit Administration (FTA) for the intermodal
transit facility and the purchase of new Transit buses, the City of Azusa Community Resources
Department, responsible for the planning and operations of the Dial-A-Ride and Gold-Line Shuttle, is
required to comply with Title VI of the Civil Rights Act of 1964 which provides that “no person in the
United States shall, on the grounds of race, color, or national origin, be excluded from participation in,
be denied the benefits of, or be subjected to discrimination under any program or activity receiving
federal financial assistance.” The City of Azusa adopted a Title VI Program on September 2, 2014,
which was subsequently approved by Caltrans on October 1, 2014. Subsequently, the City of Azusa
adopted an updated Title VI Program on February 5, 2018 for the triennial cycle of September 2, 2017
through September 2, 2020, which was approved on March 12, 2018. The Title VI Program must be
updated and approved every three years, by the City Council and Los Angeles County Metropolitan
Transit Authority (LACMTA) on behalf of Caltrans.
RECOMMENDATION:
Staff recommends that City Council take the following actions:
1)Adopt Resolution No. 2020-C67 approving the updated City of Azusa Title VI Program, a
requirement to comply with the Civil Rights Act of 1964 for all agencies receiving Federal
Transit Administration grant funds.
ANALYSIS:
Triggered by FTA grant funding utilized in the construction of the intermodal transit facility and the
purchase of Transit buses, the City of Azusa Dial-A-Ride program is required to adopt a Title VI
Program. A Title VI Program provides that no person shall be discriminated against on the basis of race,
color, and national origin.
APPROVED
CITY COUNCIL
11/02/2020
Title VI Program Update
November 2, 2020
Page 2
The City of Azusa complied with FTA Circular 4702.1B – Title Guidelines for FTA Recipients, and
approved and submitted their original Title VI Program on September 2, 2014. LACMTA requested
some minor modifications to the Program, which were approved in an amendment on April 20, 2015. A
triennial update covering September 2, 2017 through September 2, 2020 was approved by City Council
on February 5, 2018. Due to COVID, the deadline for the current required triennial approval was
extended to November 2020.
The Title VI Program includes documents that will be posted and/or available at the Community
Resources webpage and on all transit vehicles operated by the City of Azusa. These documents include,
but are not limited to: A Title VI Notice to Beneficiaries, Title VI Complaint Procedures, and, a Title VI
Complaint Form. In addition, the Title VI Plan includes a Limited English Proficiency (LEP) Plan and
Public Participation Plan.
For purposes of determining the number of LEP persons eligible to be served by Transit Division
services, an analysis was conducted that focused on those who speak English “less than very well,” in
accordance with the formal definition of LEP persons from the FTA. The analysis results showed that
of the various languages spoken in Azusa, the Spanish language has an estimate of 8, 433 speakers who
could speak English “less than very well,” thus falling under the FTA’s “Safe Harbor Provision”
threshold (over 1,000). Based on these results, notifications and forms must also be provided in
Spanish. No other language spoken in Azusa meets the threshold for these requirements.
This updated Title VI Plan has minor modifications, which primarily include updated names of
individuals who hold legislative offices and updated charts based on recent survey results.
FISCAL IMPACT:
There is minimal fiscal impact associated with this action. Any costs incurred with language translation
services would be paid for with Prop A/Prop C Funds through the Transit Division budget. If necessary,
a budget amendment will be prepared for these costs.
Prepared by: Reviewed and Approved:
Nikki Rosales Miki Carpenter
Senior Management Analyst Director of Community Resources
Reviewed and Approved:
Sergio Gonzalez
City Manager
Attachment:
1) Title VI Program
2) Resolution No. 2020-C67
CITY OF AZUSA
AZUSA DIAL-A-RIDE & GOLD LINE SHUTTLE
2020 Title VI Program
Draft Report
Developed October 2020
Adopted by the City of Azusa City Council
November 2, 2020
Point of Contact
Ms. Nikki Rosales
Senior Management Analyst
City of Azusa
213 E. Foothill Boulevard
Azusa, CA 91702
(626) 812-5261
nrosales@AzusaCA.gov
Prepared by
Moore & Associates, Inc.
25852 McBean Pkwy, Suite 187
Valencia, CA 91355
888.743.5977
Attachment 1
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Azusa Transit (Azusa Dial-A-Ride and Gold Line Shuttle) is a public transit program which serves residents
and visitors within the city limits of Azusa, in Los Angeles County, California.
This document was prepared by Moore & Associates, Inc., on behalf of the City of Azusa. It has been
adopted by the City of Azusa City Council to comply with Title VI of the Civil Rights Act of 1964, including
recent provisions detailed in U.S. Department of Transportation’s FTA Circular 4702.1B, “Title VI
Requirements and Guidelines for Federal Transit Administration Recipients.”
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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TABLE OF CONTENTS
Section 1 | Introduction .......................................................................................................................... 1
The City of Azusa: Transit Division’s Pledge to Fair and Equal Access .................................................... 1
Section 2 | Title VI Notice to the Public and Locations Where Displayed .................................................. 3
Title VI Notice to the Public (English) ................................................................................................... 3
Title VI Notice to the Public (Spanish) .................................................................................................. 4
Section 3 | Title VI Complaint Procedures and Form ................................................................................ 6
Title VI Complaint Procedure and Form (English) ................................................................................. 6
Title VI Complaint Procedure and Form (Spanish) .............................................................................. 10
Section 4 | List of Transit-Related Title VI Investigations, Complaints, and Lawsuits ............................... 14
Section 5 | Public Participation Plan ...................................................................................................... 15
About the City of Azusa ..................................................................................................................... 15
Purpose of this Plan ........................................................................................................................... 15
Approach to Public Participation ........................................................................................................ 15
Section 6 | Summary of Outreach Efforts .............................................................................................. 19
Section 7 | Language Assistance Plan and Four-Factor Analysis ............................................................. 20
Purpose of the Language Assistance Plan ........................................................................................... 20
Service Overview ............................................................................................................................... 20
Four-Factor Analysis .......................................................................................................................... 22
Language Assistance Plan .................................................................................................................. 29
Implementation Plan ......................................................................................................................... 31
Section 8 | Minority Representation on Planning and Advisory Bodies .................................................. 33
Section 9 | Subrecipient Monitoring and Schedule of Subrecipient Title VI Program Submissions .......... 34
Section 10 | Title VI Equity Analysis ....................................................................................................... 35
Section 11 | City Council Adoption of Title VI Program Update .............................................................. 36
Section 12 | Appendix ........................................................................................................................... 38
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Section 1 | Introduction
The City of Azusa: Transit Division’s Pledge to Fair and Equal Access
The City of Azusa is deeply committed to protecting the rights of its residents. Per Title VI of the Civil Rights
Act of 1964, the City has reexamined its Transit Division to ensure that no citizen eligible for Dial-A-Ride
or Gold Line Shuttle service (collectively known as Azusa Transit) is excluded from its services due to race,
color, or national origin.
Since its inception, the primary goal of Azusa Transit has been to provide the highest level of service. This
manual has been prepared with that same level of service in mind. The rights afforded to all residents of
the City of Azusa – regardless of race, color, or national origin – are outlined in this manual, as are the
legal actions that may be pursued to protect residents from said discrimination.
This manual allows the Transit Division and its customers to work together to maintain and build a better
Division. The City of Azusa regards this issue and others pertaining to customer service very highly and is
dedicated to working to improve and maintain exceptional service. Thus, the City, along with the Transit
Division, encourages residents to read through this manual and utilize any and all tools and resources
provided to them.
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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The City of Azusa, in accordance with the Civil Rights Act of 1964, and as a federally funded entity, of
Federal Transit Administration (FTA) of the U.S. Department of Transportation (US DOT), is obligated to
offer its residents the following:
• The benefits of services are shared equitably throughout the City.
• The quality of services is adequate to provide equal access to all patrons.
• No one is excluded from contributing to Azusa Transit’s planning and development
process.
• Process and procedures are implemented which prohibit discrimination of any kind, both
intentional and unintentional.
The Azusa Transit Division worked to compile this manual which best reflects the City, its residents, and
the Dial-A-Ride and Gold Line Shuttle services. The program has been redesigned and updated to meet
federal regulations and provide the utmost in customer service.
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Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Section 2 | Title VI Notice to the Public and Locations Where Displayed
The City of Azusa’s Title VI Notice to the Public is currently posted at the following locations:
Exhibit 2.1 List of Locations Where Title VI Notice Is Posted
Location Address
City Hall 213 E. Foothill Boulevard, Azusa, CA 91702
Onboard transit vehicles -----
City website https://www.ci.azusa.ca.us/329/Azusa-Transit
The Azusa Transit Title VI Complaint Form and program information are provided on the City of Azusa’s
transit website at:
https://www.ci.azusa.ca.us/329/Azusa-Transit
Title VI Notice to the Public (English)
Per Title VI of the Civil Rights Act of 1964, the residents of the City of Azusa cannot be denied access to
programs and services based on race, color, or national origin. The City of Azusa pledges to protect these
rights and has taken the necessary precautions. Residents are assured the following:
• Equal access to transit services,
• Proper notification on modifications pertaining to the services,
• Encouraged public participation regarding issues pertaining to transit services,
• Easy access to information regarding transit services, and
• Ability to easily file a complaint with the City of Azusa should an incident occur pertaining
to Title VI Rights.
Residents are encouraged to utilize the resources afforded to them by Title VI Rights. Should a patron or
resident have issues or concerns regarding these or any other rights, they should contact the Transit
Division at 626-812-5206 or City Hall at 626-812-5229.
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Title VI Notice to the Public (Spanish)
Según el Título VI de la Ley de Derechos Civiles de 1964, no se puede negar a los residentes de la Ciudad
de Azusa el acceso a programas y servicios basados en la raza, el color o el país de origen. La Ciudad de
Azusa se compromete a proteger estos derechos y ha tomado las precauciones necesarias. Los residentes
tienen la seguridad de lo siguiente:
• Igual acceso a los servicios de servicios de tránsito,
• Notificación adecuada sobre las modificaciones relacionadas con los servicios,
• Fomentó la participación del público en relación con cuestiones relacionadas con servicios
de tránsito,
• Fácil acceso a la información sobre servicios de tránsito, y
• Posibilidad de presentar una queja fácilmente ante la Ciudad de Azusa en caso de que
ocurra un incidente relacionado con los Derechos del Título VI.
Se alienta a los residentes a utilizar los recursos que se les otorgan mediante los Derechos del Título VI. Si
un usuario o residente tiene problemas o inquietudes con respecto a estos u otros derechos, debe
comunicarse con la División de Tránsito al 626-812-5206 o al Ayuntamiento al 626-812-5229.
Exhibit 2.2 Title VI Notice Posted on Azusa Transit Vehicles
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Exhibit 2.3 Title VI Notice Posted in City Hall
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Section 3 | Title VI Complaint Procedures and Form
Title VI Complaint Procedure and Form (English)
Title VI Complaint Procedure
As a recipient of federal dollars, the City of Azusa is required to comply with Title VI of the Civil Rights Act
of 1964 and ensure that services and benefits are provided on a non- discriminatory basis. The City of
Azusa has in place a Title VI Complaint Procedure, which outlines a process for local disposition of Title VI
complaints and is consistent with guidelines found in the Federal Transit Administration Circular 4702.1B,
dated October 1, 2012.
Any person who believes she or he has been discriminated against on the basis of race, color, or national
origin by the City of Azusa may file a Title VI complaint by completing and submitting the agency’s Title VI
Complaint Form. The City of Azusa investigates complaints received no more than 180 days after the
alleged incident. The City of Azusa will only process complaints that are complete.
Within 10 business days of receiving the complaint, the City of Azusa will review it to determine if our
office has jurisdiction. The complainant will receive an acknowledgement letter informing her/him
whether the complaint will be investigated by our office. The City of Azusa has 30 days to investigate the
complaint. The complainant will be notified in writing of the cause to any planned extension to the 30-
day rule.
If more information is needed to resolve the case, the City of Azusa may contact the complainant. The
complainant has 10 business days from the date of the letter to send requested information to the
investigator assigned to the case. If the investigator is not contacted by the complainant or does not
receive the additional information within 10 business days the City of Azusa can administratively close the
case.
A case can be administratively closed also if the complainant no longer wishes to pursue their case. After
the investigator reviews the complaint, she/he will issue one of two letters to the complainant: a closure
letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was
not a Title VI violation and that the case will be closed. An LOF summarizes the allegations and the
interviews regarding the alleged incident, and explains whether any disciplinary action, additional training
of the staff member, or other action will occur. If the complainant wishes to appeal the decision, she/he
has 10 business days after the date of the letter or the LOF to do so.
A person may also file a complaint directly with the Federal Transit Administration, at FTA Office of Civil
Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.
Below is a general outline of our process and procedures:
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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ReceiveComplaint is received
by the Transit Division
ReviewCity reviews for
determination of
jurisdiction and sends
acknowledgement
letter within 10
business days
InvestigateCity has 30 days to
investigate and
determine if a violation
took place
DeterminationIf determined no Title
VI violation took place,
a closure letter will be
issued
If a Title VI violation did
take place, a Letter of
Finding will be sent out
summarizing the
allegations and the
interviews regarding
the alleged incident,
and explaining whether
any disciplinary action,
additional training of
the staff member, or
other action will occur AppealComplainant has 10
days to appeal the
decision
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Exhibit 3.1 Title VI Complaint Form (English)
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Title VI Complaint Procedure and Form (Spanish)
Procedimientos de Quejas del Título VI
Como receptora de dólares federales, la Ciudad de Azusa debe cumplir con el Título VI de la Ley de
Derechos Civiles de 1964 y garantizar que los servicios y beneficios se brinden de manera no
discriminatoria. La Ciudad de Azusa cuenta con un Procedimiento de Quejas del Título VI, que describe un
proceso para la disposición local de las quejas del Título VI y es consistente con las pautas que se
encuentran en la Circular 4702.1B de la Administración Federal de Tránsito, con fecha del 1 de octu bre,
2012.
Cualquier persona que crea que ha sido discriminada por motivos de raza, color o nacionalidad por parte
de la Ciudad de Azusa puede presentar una queja del Título VI completando y enviando el Formulario de
Queja del Título VI de la agencia. La Ciudad de Azusa investiga las denuncias recibidas no más de 180 días
después del presunto incidente. La Ciudad de Azusa solo procesará las quejas que estén completas.
Dentro de los 10 días hábiles posteriores a la recepción de la queja, la Ciudad de Azu sa la revisará para
determinar si nuestra oficina tiene jurisdicción. El demandante recibirá una carta de reconocimiento
informándole si la queja será investigada por nuestra oficina. La Ciudad de Azusa tiene 30 días para
investigar la denuncia. El denunciante será notificado por escrito de la causa de cualquier extensión
planificada de la regla de 30 días.
Si se necesita más información para resolver el caso, la Ciudad de Azusa puede comunicarse con el
demandante. El denunciante tiene 10 días hábiles a partir de la fecha de la carta para enviar la información
solicitada al investigador asignado al caso. Si el investigador no es contactado por el denunciante o no
recibe la información adicional dentro de los 10 días hábiles, la Ciudad de Azusa puede cerrar
administrativamente el caso.
Un caso puede también cerrarse administrativamente si el demandante ya no desea continuar con su
caso. Después de que el investigador revise la queja, enviará una de dos cartas al denunciante: una carta
de cierre o una carta de conclusión (LOF, por sus siglas en inglés). Una carta de cierre resume las
acusaciones y establece que no hubo una violación del Título VI y que el caso se cerrará. Una LOF resume
las acusaciones y las entrevistas con respecto al presunto incidente y explica si se llevará a cabo alguna
acción disciplinaria, capacitación adicional del miembro del personal u otra acción. Si el demandante
desea apelar la decisión, tiene 10 días hábiles después de la fecha de la carta o la LOF para hacerlo.
Una persona también puede presentar una queja directamente ante la Administración Federal de
Tránsito, en la Oficina de Derechos Civiles de la AFT, 1200 New Jersey Avenue SE, Washington, DC 20590.
A continuación se muestra un esquema general de nuestro proceso y procedimientos:
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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RecibirLa queja es recibida por la
División de Tránsito.RevisiónLa Ciudad revisa la
determinación de
jurisdicción y envía una
carta de reconocimiento
dentro de los 10 días
hábiles.InvestigarLa Ciudad tiene 30 días
para investigar y
determinar si ocurrió una
infracción.DeterminaciónSi se determina que no
hubo violación del Título
VI, se emitirá una carta de
cierre.
Si se produjo una
infracción del Título VI, se
enviará una carta de
determinación
resumiendo las
acusaciones y las
entrevistas con respecto al
presunto incidente, y
explicando si se llevará a
cabo alguna acción
disciplinaria, capacitación
adicional del miembro del
personal u otra acción.ApelaciónEl demandante tiene 10
días para apelar la
decisión.
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Exhibit 3.2 Title VI Complaint Form (Spanish)
2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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2020 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
October 2020
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Section 4 | List of Transit-Related Title VI Investigations, Complaints,
and Lawsuits
Per FTA Circular 4702.1B, “all recipients are required to prepare and maintain a list of any of the following
that allege discrimination on the basis of race, color, or national origin”:
• Active investigations conducted by FTA and entities other than FTA;
• Lawsuits; and
• Complaints naming the recipient (i.e., City of Azusa and/or Azusa Transit, Azusa Dial -A-
Ride, or Azusa Gold Line Shuttle).
To date, neither Azusa Transit nor the City of Azusa has been subject to any Title VI investigations, Title VI
complaints, or Title VI lawsuits. Below is a matrix which will be utilized by City staff to internally track and
report any and all future incidents:
Exhibit 4.1 Title VI Investigations, Lawsuits, and Complaints Summary Table
Case/Reference
Number Date Summary (including basis
of complaint) Current Status Action(s) Taken
Active Investigations
XXX
XXX
Lawsuits
XXX
XXX
Complaints
XXX
XXX
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Section 5 | Public Participation Plan
About the City of Azusa
The City of Azusa was founded in 1887 and incorporated as a general law city on December 29, 1898. The
City is located in the County of Los Angeles, situated 27 miles northeast of the City of Los Angeles, and
nestled against the San Gabriel Mountain foothills. The City of Azusa encompasses 9.13 square miles and
has a population of approximately 46,361. Educational facilities provided through the Azusa Unified
School District include nine public elementary schools, three public middle schools, one public K-8 school,
three public high schools, an Adult School and Alternative Education school. Also located within Azusa are
three private schools and one private university. In the California State Legislature, Azusa is located in the
22nd Senate District, represented by Democrat Susan Rubio, and in the 48th Assembly District, represented
by Democrat Blanca Rubio. Federally, Azusa is located in California's 32nd congressional district, and is
represented by Democrat Grace Napolitano.
Purpose of this Plan
Public participation is the process through which stakeholders can partake directly in agency decision -
making, and express their concerns, desires, and values. It is the mission of this agency to "improve the
lives of people with disabilities by creating opportunities to maximize their independence." At every
opportunity through prescribed methods the agency will solicit input from stakeholders in order to best
support persons served without creating disproportionately high and adverse human health or
environmental effects on minority and/or low-income populations.
Approach to Public Participation
The public participation process will be considered at the earliest stages of any Azusa Transit project or
service enhancement which may impact the surrounding communities, existing riders, and potential
riders. As transit-related services and projects vary in scope and goals, the public participation process will
be tailored to most effectively assist each. The following process outlines tools and strategies to ensure
that public input is invited and all foreseeable impacts to the service area communities are consider ed.
The City has developed three prioritized categories of projects which guided the development of minimum
public participation requirements. During the initial planning phase of each transit-related project or
major service revisions, City of Azusa staff will identify into which level the project falls and develop a
tailored participation plan accordingly. At any time during a project’s development and/or
implementation process, the project may be reclassified to a higher level, if City of Azusa staff deems
appropriate. The levels of public participation are presented below.
• Baseline – Routine service, schedule, and system enhancements and revisions. Also
includes short- (less than one year) term projects where potential impacts to Azusa
Transit and its customers should be considered during planning phases.
Examples include minor schedule revisions and impacts to service due to routine
maintenance or construction, as well as updates to service branding, fare media, and
collateral.
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• Moderate – Projects involving a year or longer of development and/or implementation
where impacts to existing and future riders must be considered.
Examples include development and implementation of new/expanded services, any
elimination of service (whether through elimination of service to a particular area or a
decrease in the level of service), development of Short-Range Transit Plans, Marketing
Plans, and facility/storage construction projects, etc. Any project within this level to be
conducted by a third-party (i.e., consultant or contractor) will include public participation
requirements and criteria as part of the RFP process.
• High – Projects involving multiple years of development and/or implementation where
impacts to existing and future riders must be considered.
Examples include Comprehensive Operational Analyses, development and construction
of transit center/facilities, transit system redesign (complete overhaul of existing system
and operations), transition of administration of services, etc. Any project within this level
to be conducted by a third-party (i.e., consultant or contractor) will include public
participation requirements and criteria as part of the RFP process.
Outreach Requirements and Activities
The following activities are intended to serve as guidelines for each level of outreach to ensure existing
and future riders of Azusa Transit services are provided with equal access and opportunity to participate
in transit and transportation planning.
Baseline Level – Minimum Outreach
• Notice for public events may include car-cards, posters, email blasts, notices posted to
City website, media releases to local papers, or radio announcements (as funding allows).
• Any notice will be posted no less than one week prior to the public event.
• Notices may be posted at the same locations used for posting of Title VI notifications.
• Whenever possible, information regarding public participation opportunities will also be
posted on the City of Azusa transit website at least two weeks prior to the event.
• Comments will be accepted at public outreach events and via email, mail, and phone to
ensure that all populations have the opportunity to participate. The comment period will
open no less than one week prior to the first outreach event and close no less than one
week following the last outreach event.
• When feasible, the City will provide notification two weeks in advance of any change to
the service.1
• All meeting/outreach locations will be ADA accessible.
Moderate Level – Minimum Outreach
• All applicable Baseline Level elements are included within Moderate Level projects.
• Unique notices/fliers will be developed and posted a minimum of two weeks in advance
for the following outreach activities (as deemed appropriate for each project):
1 Two weeks’ notice may not always be achievable, such as in cases where service is disrupted due to construction. In such cases,
the City will provide notice as soon as is feasible.
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o Focus group participation,
o Stakeholder discussions,
o Community surveying efforts, and
o Customer survey efforts.
• Where more than one workshop or meeting open to the public is planned, the workshops
shall be scheduled throughout all day-parts (i.e., mornings, afternoons, and evenings) as
funding and resources allow to maximize opportunity for participation.
• Public participation events shall be held in central locations within walking distance of
fixed-routes stops whenever feasible.
• Materials may be developed specifically for public participation including FAQ sheets,
presentation slides, newsletters, and media releases.
High Level – Minimum Outreach
• All applicable Baseline and Moderate Level elements are included within High Level
projects.
• The City shall conduct expanded outreach to community stakeholders and its partners.
• The City shall investigate the formation of a transit-oriented committee to guide the
development and implementation of the project and public participation.
• The City shall expand regional entity participation, including but not limited to Los
Angeles County Metropolitan Transportation Authority (LACMTA); Los Angeles County;
cities of Baldwin Park, Covina, Duarte, and Glendora; and other nearby transit operators
by seeking comments and participation in project meetings and planning activities.
Currently, Spanish is the most frequently spoken language by persons who speak English less than “very
well.” Comprising 18.7 percent of the City’s total population, this LEP population is large enough to qualify
under the Safe Harbor provision. The City of Azusa will continue assessing the language needs of citizens
in its service area through its Language Assistance Plan. Should any population with limited English
proficiency reach or surpass population levels as defined by the FTA Title VI Circular (five percent of the
total service area population or 1,000 persons, whichever is less), the City will reassess this element of its
Title VI program and the strategies presented below.
Outreach Methods for Engaging Limited English Proficient Populations
Baseline Level – Minimum LEP Outreach
• The City will make event information available to community groups and agencies that
work with LEP populations, if such contacts exist.
• When it is deemed appropriate or necessary, the City will ensure non-English
interpretation in additional languages is made available.
Moderate Level – Minimum LEP Outreach
• All applicable Baseline Level elements are included within Moderate Level projects.
• The City will continue cultivating relationships with community agencies that serve LEP
populations.
• Public outreach events may include attending already existing community meetings and
gatherings, such as school meetings, farmers markets, faith-based events, and other
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community activities, in order to invite participation from LEP populations who may not
attend City-hosted public events.
High Level – Minimum LEP Outreach
• All applicable Baseline and Moderate Level elements are included within High Level
projects.
• The City will ensure that non-English language interpretation will be available at any
public meeting or workshop associated with a High Level project as deemed appropriate
and necessary.
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Section 6 | Summary of Outreach Efforts
The following is a summary of outreach efforts conducted by the City of Azusa as they relate to Title VI
requirements under the Public Participation Plan. Many of our activities are conducted in partnership or
ad hoc outreach with other service organizations and non-profit agencies within the community. This is in
no way a complete list but rather documents the agency's outreach efforts as they relate specifically to
minority and low-income populations.
City Council and Commission Meetings - Open to the Public
City Council and Advisory Commission meetings are open to the public and announced on the agency's
website. When public meetings are held they take place in ADA-accessible buildings. Meetings to discuss
changes or additions to the transportation program are publicized by posting the agenda at the City Clerk’s
office, the Police Department, the Library, in front of the Auditorium, Light & Water, and on the City’s
webpage.
Los Angeles County Office of Emergency Services
The City of Azusa previously worked in conjunction with the Los Angeles County Office of Emergency
Services in the development of the Los Angeles County Evacuation Plan. This plan specifically addresses
the needs of populations at risk including disabled, minority, and low-income. This partnership also
includes a coordinated plan in which this agency will provide vehicles, transportation, and shelter during
evacuation emergencies.
Food, Clothing, and Toy Drives
Annually, the City of Azusa conducts food, clothing, and toy drives to connect with and benefit low-income
populations. These events are publicized through press releases to various media outlets and flyers.
City of Azusa Website
Currently, the City of Azusa posts notices and announcement on the agency's website. Additional public
input can be obtained by the Title VI Complaint Form, which is available as a download in English and
Spanish.
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Section 7 | Language Assistance Plan and Four-Factor Analysis
Purpose of the Language Assistance Plan
This Language Assistance Plan and Four-Factor Analysis was developed concurrently with the City’s Title
VI Program to ensure its services are accessible to Limited English-Proficient (LEP) individuals. Title VI of
the 1964 Civil Right Act is one of two federal mandates that guarantee the provision of meaningful access
to federally funded transit services for LEP individuals:
• Title VI of the 1964 Civil Right Act prohibits discrimination on the basis of race, color, and
national origin in programs and activities receiving federal financial assistance. One
critical concern addressed by Title VI is the language barrier that Limited English
Proficiency (LEP) persons face with respect to accessing information about and using
transit service. Transit operators must ensure that this group has adequate access to the
agency’s programs and activities, including public participation opportunities.
• President’s Executive Order 13166, “Improving Access to Services for Persons with
Limited English Proficiency” (August 11, 2000): forbids funding recipients from “restricting
an individual in any way in the enjoyment of any advantage or privilege enjoyed by others
receiving any service, financial aid, or other benefit under the program,” or from
“utilize[ing] criteria or methods of administration which have the effect of subjecting
individuals to discrimination because of their race, color, or national origin, or hav e the
effect of defeating or substantially impairing accomplishment of the objectives of the
program as respects to individuals of a particular race, color, or national origin.”
The United States Department of Transportation (DOT) published guidance that directed its recipients to
ensure meaningful access to the benefits, services, information, and other important portions of their
programs and activities for LEP customers. FTA Circular 4702.1B was developed by the Federal Transit
Administration (FTA) and details the administrative and reporting requirements for recipients of FTA
financial assistance to comply with Title VI and related executive orders including on LEP. The City of
Azusa’s language assistance plan (LAP) includes a four-factor analysis and implementation plan that
complies with the requirements of DOT LEP guidance.
Service Overview
Azusa Transit consists of two demand-response services: Azusa Dial-A-Ride and the Gold Line Shuttle.
Azusa Dial-A-Ride provides service within the city of Azusa to residents who are age 55 and older or have
a disability. The service operates from 5:00 a.m. to 6:00 p.m. Monday through Friday. Non-medical
appointments are limited to within Azusa city limits, while service for medical and social services
appointments extends to neighboring communities. The fare for a one-way trip within Azusa is 50 cents,
or 25 cents for the nutrition program at the Senior Center. Fares outside of Azusa range from 50 cents to
$1.50 depending on destination.
The reservation-based Azusa Gold Line Shuttle is open to all residents of Azusa and offers service between
designated pick-up and drop-off locations and the Metro Gold Line Station. The fare for each one-way trip
is 50 cents.
Fixed-route and ADA complementary paratransit services in Azusa are provided by Foothill Transit and
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Access Services, Inc. These services are not represented by this Title VI Program. Separate Title VI
Programs for these services can be found at http://foothilltransit.org/about/organization/title-vi/
(Foothill Transit) and https://accessla.org/about_us/title_vi.html (Access Services).
The City of Azusa’s current Title VI Program was prepared in October 2020 in accordance with FTA Circular
4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, October 1,
2012.
The City’s Title VI Program Administrator is:
Ms. Nikki Rosales
Senior Management Analyst
City of Azusa
213 E. Foothill Boulevard
Azusa, CA 91702
Phone: (626) 812-5261
Email: nrosales@AzusaCA.gov
Additional information regarding the Title VI Program is available at:
https://www.ci.azusa.ca.us/329/Azusa-Transit
Language Assistance Plan Goals
One of the overarching goals of the City of Azusa’s Title VI Program is to ensure meaningful access for LEP
customers to transit services, information, and materials through the development of a Language
Assistance Plan and by regular evaluation of the developed methods and strategies. The first step toward
this is the development of a Four-Factor Analysis as outlined by the U.S. Department of Transportation
(USDOT). The Four-Factor Analysis includes:
• Factor 1: The number or proportion of LEP persons in the service area who may be served
or are likely to encounter Azusa Transit.
• Factor 2: The frequency with which LEP persons come in contact with Azusa Transit.
• Factor 3: The nature and importance of services provided by Azusa Transit to the LEP
population.
• Factor 4: The resources available to the City of Azusa and overall cost to provide LEP
assistance.
Following the Four-Factor Analysis, the Language Assistance Plan includes methodologies for identifying
LEP individuals, providing services, establishing policies, and monitoring the LAP, as well as an
implementation plan.
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Four-Factor Analysis
Factor 1: The number or proportion of LEP persons eligible to be served or likely to be encountered by the
program or recipient.
Estimating the number or proportion of LEP individuals that may be encountered by Azusa Transit will
help identify the populations covered by the USDOT’s Safe Harbor Provision. This provision stipulates that
if an LEP group speaking a non-English language constitutes five percent or 1,000 persons, whichever is
less, of the total population of persons likely to be encountered by transit services, then the service
provider must make the following materials and services available to speakers of that language:
• Documents critical for accessing recipient’s services or benefits,
• Letters requiring response from customer,
• Materials informing customers of free language assistance,
• Complaint forms, and
• Notification of rights.
Service Area Demographics
The service area demographic analysis describes potential Title VI -protected populations residing within
Azusa Transit’s service area, including their approximate size and geographic distribution. Title VI-
protected populations within the service area include LEP persons. Specific groups considered include:
1. Potential LEP Language Groups
• Spanish
• Chinese
The American Community Survey (ACS) provides information at various levels on multiple topics. For the
purposes of this Title VI program, our assessment utilized the population estimates provided in the City
of Azusa geographic boundaries.
Exhibit 7.1 Racial Breakdown of Total Population of Service Area
The American Community Survey data presents language spoken at home for persons five years of age
Estimate Percent of
Total Estimate Percent of
Total Estimate Percent of
Total
Race
White 23,721 47.9%5,186,859 51.4%23,529,068 60.1%
Black or African American 1,647 3.3%823,987 8.2%2,267,875 5.8%
Asian 6,227 12.6%1,469,968 14.6%5,604,339 14.3%
Native Hawaiian/Pacific Islander 80 0.2%27,929 0.3%153,366 0.4%
American Indian/Alaska Native 564 1.1%70,527 0.7%296,475 0.8%
Some other race alone 14,510 29.3%2,121,102 21.0%5,415,410 13.8%
Two or more races 2,795 5.6%397,680 3.9%1,882,227 4.8%
Total 49,544 100.0%10,098,052 100.0%39,148,760 100.0%
Ethnicity
Hispanic or Latino (of any race)31,530 63.6%4,893,603 48.5%15,221,577 38.9%
Azusa Los Angeles County California
Race or Ethnicity
American Community Survey 2014 - 2018 five-year estimates
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and older. ACS 2015 (the most recent data available at this level of detail) estimates revealed 42.8 percent
of the Azusa Transit service area residents spoke only English at home, while approximately 47.5 percent
spoke Spanish, making it the most commonly spoken language other than English found within the service
area. The next most cited language spoken at home was Chinese with 1.95 percent.
While many residents of Azusa speak another language at home, many of them speak English “very well.”
In fact, 77.9 percent of Azusa residents fall within this category. Given the large population of Spanish
speakers, it is not surprising to find Spanish speakers who speak English less than “very well” comprise
18.7 percent of the total population. By contrast, Chinese speakers who speak English less than “very
well” comprise just one percent of the total population.
Exhibit 7.2 Languages Spoken at Home By Community
Based on the Safe Harbor provision cited above, only Spanish falls into the category of 1,000 individuals or
five percent of the population, whichever is less. Consequently, the City of Azusa is required to provide
vital information and communications in Spanish. While the City is not required to provide these materials
in other languages based on the Safe Harbor provision, it may elect to do so depending on how frequently
Estimate Percent of
Total Estimate Percent of
Total Estimate Percent of
Total
Total Population 45,078 100.0%9,396,753 100.0%35,909,688 100.0%
Total Speak only English 19,287 42.8%4,062,062 43.2%20,142,054 56.1%
Total Speak language other than English 25,791 57.2%5,334,691 56.8%15,767,634 43.9%
Total Speak English "very well"35,123 77.9%7,299,928 77.7%30,456,010 84.8%
Total Speak English less than "very well"9,955 22.1%245,600 2.6%6,620,218 18.4%
Speak Spanish 8,433 18.7%1,627,354 17.3%4,430,740 12.3%
Speak Chinese 435 1.0%219,912 2.3%633,043 1.8%
Speak Tagalog/Filipino 406 0.90%73,397 0.78%266,692 0.74%
Speak Other Pacific Island Languages 163 0.36%9,563 0.10%43,739 0.12%
Speak Korean 138 0.31%110,976 1.2%215,449 0.60%
Speak Vietnamese 68 0.15%48,582 0.52%319,841 0.89%
Speak Persian/Farsi 54 0.12%30,929 0.33%75,896 0.21%
Speak Arabic 49 0.11%17,109 0.18%65,444 0.18%
Speak African Languages 35 0.08%5,668 0.06%22,522 0.06%
Speak Greek 32 0.07%1,545 0.02%5,089 0.01%
Speak German 30 0.07%2,538 0.03%13,419 0.04%
Speak Thai 25 0.06%13,569 0.14%27,666 0.08%
Speak Japanese 18 0.04%25,857 0.28%64,728 0.18%
Speak Other Indic Languages 14 0.03%11,227 0.12%80,630 0.22%
Speak Other Asian Languages 13 0.03%10,113 0.11%50,717 0.14%
Speak Portuguese 8 0.02%3,160 0.03%23,946 0.07%
Speak Hmong 8 0.02%343 0.00%33,689 0.09%
Speak French 7 0.02%6,384 0.07%19,048 0.05%
Speak Serbo-Croatian 7 0.02%1,520 0.02%5,778 0.02%
Speak Other West Germanic Languages 7 0.02%785 0.01%3,182 0.01%
Speak Russian 5 0.01%25,344 0.27%72,109 0.20%
American Community Survey 2011 - 2015 five-year estimates (most recent data available)
Speak English less than "very well" - breakdown
Language Spoken at Home
Azusa Los Angeles County California
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LEP speakers of other languages come into contact with the transit program. This is assessed under Factor
2.
City of Azusa English Learner Data
In addition to census data collected via the American Community Survey (ACS), we also reviewed English
Learner (EL) statistics for students within the Azusa Unified School District. Public schools within the
California Department of Education (CDE) must report on their students who are English Learners –
students whose native tongue is a language other than English – as well as which language is their mother
tongue each year, which provides more current data than the ACS. This data is available online via CDE’s
DataQuest website, dq.cde.ca.gov/dataquest/.
The City accessed the available EL data for the 2019/20 school year to complete its comprehensive
assessment of the populations it provides service to, including what LEP populations exists and where these
groups may be concentrated. Periodically reviewing this data will enable the City to monitor which non -
English languages are growing in order to provide appropriate language assistance services.
Consistent with data from the 2015 American Community Survey, the highest concentration of EL students
within Azusa speak Spanish, followed distantly by Chinese and Tagalog. This helps to confirm the older data
contained within the ACS is still accurate. Detailed counts and relative percentages are presented in the
table below.
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Exhibit 7.3 School English Learner (EL) Population
Language Name Kindergarten Grade 1 Grade 2 Grade 3 Grade 4 Grade 5 Grade 6 Grade 7 Grade 8 Grade 9 Grade 10 Grade 11 Grade 12 Total Percent of
Total
Spanish 158 197 210 160 123 176 147 122 145 87 108 91 102 1,826 97.13%
Chinese 0 1 1 1 0 3 1 1 1 1 0 0 1 11 0.60%
Filipino (Pilipino or Tagalog)0 1 0 0 0 1 0 0 1 2 0 1 2 8 0.43%
Vietnamese 1 1 0 1 0 2 0 0 0 0 0 0 0 5 0.27%
Arabic 0 1 2 0 0 0 0 0 0 0 0 0 0 3 0.16%
Armenian 1 0 0 0 0 1 0 0 0 0 0 0 0 2 0.11%
Indonesian 0 0 0 0 0 0 0 0 1 0 0 0 0 1 0.05%
Japanese 0 0 0 0 0 0 0 0 0 1 0 0 0 1 0.05%
Punjabi 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0.05%
Tamil 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0.05%
Other non-English languages 1 1 2 0 0 2 3 1 2 1 2 6 0 21 1.12%
Total 162 202 215 162 123 185 151 124 150 92 110 99 105 1,880 100.00%
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Factor 2: The frequency with which LEP persons come into contact with the program.
In order to estimate how often LEP populations come into contact with the City’s transit services, surveys
were conducted of both riders and City staff.
Customer Survey
A survey of Azusa Dial-A-Ride and Gold Line Shuttle customers was conducted in September and October
2020. Surveys were mailed to a random selection of 424 Dial-A-Ride customers (an additional 76 surveys
were returned undeliverable) and distributed onboard both Dial-A-Ride and Gold Line Shuttle vehicles. A
total of 55 responses was received. The survey was available in English and Spanish.
The majority of surveys (80 percent) were completed in English. Seventy-six percent of surveys were from
Azusa Dial-A-Ride and 24 percent from the Gold Line Shuttle.
The primary languages spoken by respondents at home were generally English (69.1 percent) or Spanish
(20.0 percent). Two additional languages were specified: Five respondents indicated Tagalog/Filipino
while one specified Italian. Forty-six respondents (83.6 percent) said they were a native English speaker
or spoke English “very well,” while the remainder spoke English less than “very well” (14.6 percent) or not
at all (1.8 percent). No riders indicated being aware of any difficulties using the City’s transit programs
due to a language barrier.
More than 60 percent of respondents indicated a minority race or ethnicity, either alone or combined
with another race/ethnicity. The most frequently cited minority ethnicity was Hispanic/Latino (20
responses, or 36.4 percent of respondents), followed by Asian (12 responses, or 21.8 percent of
respondents).
Staff Survey
City staff and drivers were also surveyed regarding their customer interactions. As drivers and customer
service staff are typically on the “front lines” and most frequently come into contact with transit patrons,
their observations and insights provide an informative picture of how many LEP persons use Azusa Transit.
Data from the 11 completed City staff/driver surveys generally corroborate the findings described in the
Service Area Demographics section. Specific highlights from the driver survey are detailed below.
• At least 64 percent of the City’s transit staff speak Spanish. Of the 11 individuals surveyed,
only two cited speaking only English. Two did not respond to the question. One indicated
only a basic knowledge of Spanish.
• All staff reported encountering Spanish-speaking customers. Forty-five percent cited
encountering Tagalog, while 27 percent each said Chinese and Korean. Two respondents
said they encountered Japanese, while one respondent each cited encountering
Persian/Farsi, Arabic, and Vietnamese.
• Seventy-eight percent of drivers said they encounter at least five unique individuals each
week who do not speak English or who do not speak English very well. Forty-four percent
said they encounter more than 10 such customers each week.
• Despite the high frequency of contact with LEP individuals, 73 percent of staff indicated
they had no issues or problems with communication. This is likely due to the significant
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number of bilingual Spanish individuals on staff. Twenty-seven percent said they
experience occasional problems, but no one reported frequent issues.
• Nearly all staff indicated that their personal language capabilities improve their ability to
communicate with transit riders.
• When asked what materials/services would be of most benefit to riders who do not speak
English or do not speak English well, 64 percent said a translated service brochure, 55
percent each said posting onboard notices in other languages and providing translated
materials online, 36 percent said making translation available through dispatch, and 27
percent cited language cards with commonly used phrases. One driver suggested
providing drivers with a laminated map so that LEP customers could point to where they
need to travel.
• The most common area/topic indicated by all City staff to have language/communication
barriers was how to use Azusa Transit (82 percent), followed by basic directions (45
percent) and how to pay the fare (36 percent).
A copy of the staff survey instrument is provided in the Appendix.
Factor 3: The nature and importance of the program, activity, or service provided by the program to
people’s lives.
Transit services operated by the City of Azusa play a vital role in the lives of many residents of the servi ce
area. City transit services include connections to the Los Angeles regional transit network via Metro Gold
Line, Metro bus lines, and Foothill Transit bus lines. These services reach most major job centers in
Southern California. In addition, seniors rely on transit services for trips to shopping areas, doctor
appointments, and many other destinations in the City.
To better understand Azusa Transit’s role among LEP populations, 19 local stakeholders (comprised of
social service agencies, senior centers, faith-based organizations, and educational institutions) were
contacted regarding the nature of the populations they serve. These stakeholders were selected because
they were deemed likely to act as representatives for, or come into frequent contact with, LEP populations
in Azusa. Of the stakeholders contacted, 12 completed our stakeholder survey (survey instrument is
provided in the Appendix). Together, these stakeholders provided important insight into the City’s public
transit service area’s key LEP groups. As representatives who serve as leaders for these communities, they
are attuned to the needs and potential language barriers members of these communities may face when
using Azusa Transit.
• Nine stakeholders indicated representing individuals who speak Spanish, while six
indicated Chinese and five indicated Tagalog/Filipino. Japanese, German, Korean, Thai,
and Arabic were each specified by three stakeholders. Vietnamese, Farsi/Persian, French,
Italian, Russian, Armenian, and Hebrew were each indicated by one stakeholder. Azusa
Pacific University noted it has over 40 countries represented on campus.
• When stakeholders come into contact with non-native English-speakers, most non-native
English-speakers speak English either “somewhat well” or “very well” (eight
respondents). Three characterize the ability of non-native English speakers to speak
English as “not well,” while one said they did not know. When asked how well non-native
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English-speakers read English, seven stakeholders indicated non-native English-speakers
were able to read English either “somewhat well” or “very well,” while four said “not well”
and one said they did not know.
• Stakeholders were also asked about usage of Azusa Transit services by their members or
clients. Four stakeholders indicated its members/clients use the City’s transit services.
However, seven stakeholders said they were unaware as to whether their
members/clients use the City’s transit services.
• Of the four stakeholders who cited use of Azusa Transit services, one indicated non-native
English speakers comprised fewer than 25 percent of transit riders, while another said
more than 75 percent are transit riders. The other two respondents fell in between.
• Two stakeholders indicated language being a barrier to the use of the City’s transit
services. Specific languages cited by one stakeholder included Spanish, Chinese, Tagalog,
and Arabic. Specific barriers included a lack of knowledge of available services and
difficulty accessing service information, including online. One stakeholder said often non-
English-speaking individuals are hesitant to call the City for information because they do
not know if the person who answers will speak their language.
Factor 4: The resources available to the recipient for LEP outreach, as well as the costs associated with
that outreach.
The City of Azusa currently provides resources to each LEP group while maintaining cost efficiency for
taxpayers. Resources may include, but are not limited to:
1. Bilingual or multilingual staff members (the City’s Transit Division currently has staff members who
are fluent in Spanish).
2. Professional translation services (can be implemented quickly with minimal cost).
3. On-call translation services (can be implemented quickly).
4. Input by various community organizations that regularly interact with LEP populations (ongoing
basis).
5. Printing services for vital documents, brochures, and other media. Essential documents such as Title
VI forms, Dial-a-Ride applications, proposed service/fare changes, and certain scheduling
information will be made available in the identified languages per the LEP analysis. The City will
attempt to use universal symbols such as pictures, maps, and diagrams when feasible to streamline
communication among all language groups.
6. Documents, brochures, and other media of less-essential importance shall be translated into the
identified languages per the LEP analysis upon request.
7. Multilingual services and resources offered and utilized by other City departments (available upon
request).
Conclusions
The Four-Factor Analysis showed a significant portion of the population within the Azusa Transit service
area (more than 22 percent) speaks English less than very well. Spanish is the most commonly used
language other than English, comprising 18.7 percent of the population. Spanish was determined to be the
only language that fell within the Safe Harbor guidance.
The employee survey found Spanish to be the most frequently encountered language by the transit
program, and more than three-quarters of employees said they encountered at least five unique LEP
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individuals each week. However, due to the high frequency of bilingual Spanish drivers and dispatch ers,
employees indicated only occasional issues with communication.
The customer and stakeholder surveys also reinforced Spanish as the most frequently encountered
language. While there are numerous other languages present in the service area, they are e ncountered
infrequently and populations are relatively small.
While the City is not required under Title VI to provide documents and information in any language other
than Spanish, the feedback from the stakeholders indicates there are likely some residents who do not use
Azusa Transit’s services due to a language barrier. Strategies to address this, as well as other
recommendations, are identified within the Language Assistance Implementation Plan.
Language Assistance Plan
Language measures currently used or planned to be used by the City of Azusa to address the needs of LEP
persons include the following:
• Vital documents including the Civil Rights Notice, Title VI Complaint Form, and Title VI Complaint
Procedures translated into the identified LEP languages;
• Translating marketing materials into Spanish;
• If needed, arranging for availability of oral translators depending on availability;
• Interactive meeting materials to engage LEP individuals in the planning process; and
• Posting notices in appropriate languages informing LEP persons of available transit services,
routes, and amenities; as well as opportunities for LEP persons to provide input on transit-related
projects.
The City will continue to seek ways to add notices to the City website to inform LEP populations of
opportunities for input.
Online Resources
While the Title VI Program is posted on the City’s website, the transit website contains no information
translated in Spanish. The website includes basic transit information (Dial-A-Ride and Gold Line Shuttle),
information about the City’s Foothill Transit Bus Pass Program, Title VI, and Reasonable Modifications.
While a Google Translate widget allows individuals to select another language for the webpages, it does
not translate any .pdf attachments. As such, the City should, at a minimum, provide its Title VI Program
and the flyer regarding the Gold Line Shuttle in Spanish, as translation of those attachments is not
provided through the translation widget. In addition, any time a link to a Spanish-language document is
included on an otherwise English webpage, the link should be in Spanish. Therefore, rather than reading
“Title VI Program Complaint Form (Spanish),” it should read “Formulario de Quejas del Título VI (Español).”
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Telephonic Interpretation Service
In order to eliminate barriers due to language, the City should consider moving forward with establishing
an account with a telephonic interpretation service such as TeleLanguage or Language Line. The
telephonic interpretation service could be made available to all persons interacting with the City (not just
related to transit), and will also allow for real -time assistance to customers who call into the customer
service phone number. Initial contact is made with a City employee who then determines if language
assistance is required. When an employee receives a call in another language, they ask what language,
and can prompt the caller using the most frequently encountered languages if necessary. The City
employee dials the service, enters the appropriate PIN or code, and can reach a live translator for over
200 languages. As it is an on-demand service, the City would only pay for the minutes it actually uses.
In order for the telephonic interpretation service to effectively mitigate barriers due to language, use of
the service must be effectively communicated to the general public. A media release may be used to
notify the community at-large, while other information can be posted on the City’s transit website. This
notification will be most effective if the phrase, “For information in [name of language], call 626 -812-
5206” is translated into the languages most frequently encountered by City staff and cited by stakeholders
and riders. These include Chinese, Tagalog/Filipino, Japanese, German, Korean, Thai, Arabic, Vietnamese,
Farsi/Persian, Italian, Russian, Armenian, and Hebrew. This would be a one-time cost, or could be
translated for free using Google Translate.
Bilingual Staff Incentives
Some of Azusa Transit Dial-a-Ride customers have very limited English literacy skills and are unable to read
or write in English. The City of Azusa has a bilingual incentive program, where it certifies then provides
additional compensation to staff that can adequately read, write, and communicate in Spanish. Azusa
Transit has bilingual dispatchers and drivers that can assist its native Spanish-speaking population with
minor translation services.
Staff Training
To ensure effective implementation of this plan, the City of Azusa will schedule traini ng at orientations for
new City staff and relevant employees on an annual basis to review:
• The City’s Language Assistance Plan,
• Demographic data about the local LEP populations,
• Printed materials available to LEP individuals,
• Other resources available to assist LEP individuals,
• How to provide assistance to customers with Limited English Proficiency,
• Which staff members are key resources for various languages,
• How to use an on-demand telephone interpretation service (if implemented),
• How and when to document interactions with LEP customers, and
• How to identify and respond to civil rights complaints.
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Notice to LEP Persons about Available Language Assistance
The City of Azusa is working toward being able to notify LEP persons in their own language about the
language assistance available to them without cost by using the following methods:
• Webpage notices,
• Information at local events, City Hall, Community Center, and Azusa Public Library ,
• Flyers and brochures, and
• Sending information to local organizations.
Monitoring, Evaluating, and Updating Plan
The Language Assistance Plan has been updated as part of this Title VI Program Update. On an ongoing
basis, monitoring activities may identify changes that should be made to the Language Assistance Plan.
The following reoccurring reporting and evaluation measures will be used to update the Language
Assistance Plan.
The City of Azusa will regularly assess the effectiveness of how it communicates with LEP individuals by:
• Including questions about language assistance and information needs on any customer or
community surveys;
• Conversations with stakeholders, organizations, and entities which work with LEPs; and
• As-needed outreach with LEP groups.
The City will monitor its language assistance efforts, including:
• Recording and reporting on customer service interactions with LEP individuals,
• Incorporating discussion of Title VI into staff meetings and training, and
• Updating the Language Assistance Plan based on feedback received.
Implementation Plan
The matrix below presents an Implementation Plan for ensuring the Language Assistance Plan is quickly
and efficiently implemented.
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Exhibit 7.4 LAP Implementation Plan
Goal Task Anticipated
Completion
Assess LEP population in the
Azusa Transit service area
Four Factor Analysis October 2020
Stakeholder Survey October 2020
Driver/Staff Survey October 2020
Customer Survey October 2020
Demographics Analysis October 2020
Develop Language Assistance
Procedures
Update website to include .pdf attachments
translated into Spanish FY 2021
Implement telephonic interpretation
program FY 2021
Staff Training
Train City transit staff regarding in-house
language resources and materials available
to LEP individuals
FY 2021
Train City staff regarding use of on-demand
telephone interpretation service (if
applicable)
FY 2021
Train City staff regarding how and when to
document interactions with LEP customers FY 2021
Train City Staff how to respond to civil rights
complaints FY 2021
Notification of Title VI Rights
and Materials
Post Title VI notices in specified public
locations
Prior to October
2020
Monitor and Update Language
Assistance Plan
Regularly review ACS and census
demographic data FY 2023
Incorporate discussion of Title VI into regular
staff meetings and trainings FY 2021; ongoing
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Section 8 | Minority Representation on Planning and Advisory Bodies
The City of Azusa has not established a non-elected committee or council to assist with the transit
program.
Should a non-elected committee or council be established in the future, a summary of the committee
members identified by race and a description of efforts made to encourage the participation of minorities
on said committee will be provided in this section utilizing the table below.
Exhibit 8.1 Non-Elected Committee Membership Table
Race/Ethnicity Service Area Population
(Percentage)
Commission
(Percentage)
Caucasian XXX% XXX%
Hispanic/Latino XXX% XXX%
Black/African American XXX% XXX%
Asian XXX% XXX%
American Indian/Alaska Native XXX% XXX%
Native Hawaiian/Pacific Islander XXX% XXX%
Member participation and selection will be monitored by the City’s Title VI Program Administrator.
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Section 9 | Subrecipient Monitoring and Schedule of Subrecipient Title
VI Program Submissions
The City does not have any subrecipients of federal funding at this time and does not anticipate expanding
to include subrecipients.
If in the future the City elects to expand the Azusa Transit services provided and begins contracting with
subrecipients, the City will ensure compliance with Title VI regulations by updating this element of its Title
VI Program to include the monitoring methodology and reporting schedules for all subrecipients. The City
will also ensure Appendix E of the Title VI Assurances (US DOT Orde r 1050.2A) is incorporated into all
subrecipient contracts.
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Section 10 | Title VI Equity Analysis
Title VI regulations require the completion of an Equity Analysis whenever a recipient or subrecipient
begins planning the location and construction of a new transit facility (not including bus shelters, transit
stations, power substations, or other facilities already evaluated through NEPA).
The City of Azusa has not undertaken any construction projects for facilities at a new location within the
past several years. Therefore, no Equity Analysis is required at this time.
If in the future the City of Azusa begins planning for the development and construction of a new transit
facility, the City will conduct an equity analysis prior to the selection of a construction site inclusive of the
Title VI requirements below:
a. The City of Azusa shall complete a Title VI equity analysis during the planning stage with regard to
where a project is located or sited to ensure the location is selected without regard to race, color,
or national origin. The City shall engage in outreach to persons potentially impacted by the siting
of facilities. The Title VI equity analysis shall compare the equity impacts of various siting
alternatives, and the analysis shall occur before the selection of the preferred site.
b. When evaluating locations of facilities, the City shall give attention to other facilities with similar
impacts in the area to determine if any cumulative adverse impacts might result. Analysis shall be
done at the Census tract or block group where appropriate to ensure that proper perspective is
given to localized impacts.
c. If the City determines that the location of the project will result in a disparate impact on the basis
of race, color, or national origin, the City may only locate the project in that location if there is a
substantial legitimate justification for locating the project there, and where there are no
alternative locations that would have a less disparate impact on the basis of race, col or, or
national origin. The City shall show how both tests are met; it is important to understand that in
order to make this showing, the City must consider and analyze alternatives to determine whether
those alternatives would have less of a disparate impact on the basis of race, color, or national
origin, and then implement the least discriminatory alternative.
The equity analysis shall be completed and submitted as part of the City of Azusa’s next Title VI Program
update.
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Section 11 | City Council Adoption of Title VI Program Update
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Section 12 | Appendix
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Exhibit A.1 Customer Survey Instrument
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Exhibit A.2 Employee Survey Instrument
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Exhibit A.3 Stakeholder Survey Instrument
RESOLUTION NO. 2020-C67
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF AZUSA
ADOPTING THE UPDATED TITILE VI PROGRAM
WHEREAS, the City of Azusa desires to comply with Title VI of the Civil
Rights Act of 1964, including new provisions detailed in U.S. Department of
Transportation’s FTA Circular 4702.1B, “Title VI Requirement and Guidelines for
Federal Transit Administration Recipients,” and
WHEREAS, the City of Azusa adopted a Title VI Program on September 2,
2014, which was approved by Caltrans on October 1, 2014, and
WHEREAS, the Title VI Program requires updating every three (3) years, and
WHEREAS, the Title VI Program was updated and approved for the triennial
cycle of September 2, 2017 to September 2, 2020, and
WHEREAS, the City Council wishes to approve the updated compliance plan
developed to comply with the necessary provisions of the Civil Rights Act.
NOW, THEREFORE BE IT RESOLVED, by the City Council as follows:
1.The City Manager is authorized to implement any components of the updated
plan in order to meet Federal requirements.
2.The City Manager is authorized to implement policies that may be necessary
to comply with subsequent revisions or interpretations to the Civil Rights Act.
PASSED, APPROVED and ADOPTED this 2nd day of November, 2020.
Robert Gonzales
Mayor
ATTEST:
Jeffrey Lawrence Cornejo, Jr.
City Clerk
Attachment 2
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss.
CITY OF AZUSA )
I HEREBY CERTIFY that the foregoing Resolution No. 2020-C67 was duly
adopted by the City Council of the City of Azusa at a regular meeting thereof, held on the
2nd day of November, 2020, by the following vote of Council:
AYES: COUNCILMEMBERS
NOES: COUNCILMEMBERS
ABSENT: COUNCILMEMBERS
Jeffrey Lawrence Cornejo, Jr.
City Clerk
APPROVED AS TO FORM:
Best Best & Krieger, LLP
City Attorney