HomeMy WebLinkAboutE-9 Staff Report - Title VI Update 2023CONSENT ITEM
E-9
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: SERGIO GONZALEZ, CITY MANAGER
FROM: MIKI CARPENTER, DIRECTOR OF COMMUNITY RESOURCES
DATE: DECEMBER 4, 2023
SUBJECT: RESOLUTION TO APPROVE THE UDPATED CITY OF AZUSA TITLE VI
PROGRAM
BACKGROUND:
As a sub-recipent 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 of 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 approved by Caltrans on October 1, 2014. Subsequently, the City of Azusa adopted an
updated Title VI Program on February 5, 2018, and November 2, 2020, covering the two triennial
cycles. 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. This action
approves the update for the triennial period beginning September 1, 2023 through August 31, 2026.
RECOMMENDATION:
Staff recommends that City Council take the following actions:
1)Adopt Resolution No. 2023-C72 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
Approved
City Council
December 4, 2023
Title VI Update
December 4, 2023
Page 2
Program. A Title VI Program provides that no person shall be discriminated against on the basis of race,
color, and national origin.
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.
Two triennial updates have been approved by City Council; one in February of 2018 and another in
November of 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 8,620 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 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
Fiscal Review by: Reviewed and Approved by:
Talika M. Johnson Sergio Gonzalez
Director of Administrative Services City Manager
Attachment:
1) Title VI Program
2) Resolution No. 2023-C72
CITY OF AZUSA
AZUSA DIAL-A-RIDE & GOLD LINE SHUTTLE
2023 Title VI Program
Draft Report
Developed October 2023
To be adopted by the City of Azusa City Council
December 4, 2023
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
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE ii
Azusa Transit (inclusive of Azusa Dial-A-Ride and Gold Line Shuttle) is a public transit program which serves
residents of, visitors to, and persons employed 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.”
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE iii
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 | Sub-recipient Monitoring and Schedule of Sub-recipient 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 ........................................................................................................................... 37
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 1
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 examined its Transit Division to ensure no citizen eligible for Dial-A-Ride or Gold
Line Shuttle service (known collectively 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. The
rights afforded to all residents of the City of Azusa – regardless of race, color, or national origin – are
outlined herein, as are the legal actions that may be pursued to protect residents from potential
discrimination.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 2
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 (USDOT), 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 the City’s transit planning and development
process.
• Process and procedures are in effect prohibiting discrimination of any kind, both
intentional and unintentional.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 3
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 regarding
the City’s public transit services and the rights afforded under federal Title VI.
Residents are encouraged to utilize the resources afforded under Title VI of the 1964 Civil Rights Act.
Should an Azusa resident or other person using the City’s public transit service have issues or concerns
regarding these or any other rights afforded under Title VI, they are encouraged to contact the City’s
Transit Division at (626) 812-5206 or City Hall at (626) 812-5229.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 4
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
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 5
Exhibit 2.3 Title VI Notice Posted in City Hall
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 6
Section 3 | Title VI Complaint Procedures and Form
Title VI Complaint Procedure and Form (English)
Title VI Complaint Procedure
As a recipient of federal transportation funding, 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. This process 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 ten business days of receiving the complaint, the City of Azusa will review it to determine if the
City has jurisdiction. The complainant will receive an acknowledgement letter informing her/him whether
the complaint will be investigated by the City’s designated representative. 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.
Should additional information be required to resolve the case, the City of Azusa may contact the
complainant. The complainant will have ten 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 requested additional information within ten 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 the 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 there was not a
Title VI violation and that the case will be closed. A LOF summarizes the allegations and the interviews
regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff
involved, or other action will occur. If the complainant wishes to appeal the decision, she/he has ten
business days after the date of the closure letter or the letter of finding 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 the City of Azusa’s process and procedures:
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 7
Re
c
e
i
v
e
Complaint is received
by the Transit Division
Re
v
i
e
w
City reviews for
determination of
jurisdiction and sends
acknowledgement
letter within 10
business days
In
v
e
s
t
i
g
a
t
e
City has 30 days to
investigate and
determine if a violation
took place
De
t
e
r
m
i
n
a
t
i
o
n
If 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
Ap
p
e
a
l
Complainant has 10
days to appeal the
decision
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 8
Exhibit 3.1 Title VI Complaint Form (English)
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 9
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 10
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 octubre,
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 Azusa 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:
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 11
Re
c
i
b
i
r
La queja es recibida por la
División de Tránsito.
Re
v
i
s
i
ó
n
La Ciudad revisa la
determinación de
jurisdicción y envía una
carta de reconocimiento
dentro de los 10 días
hábiles.
In
v
e
s
t
i
g
a
r
La Ciudad tiene 30 días
para investigar y
determinar si ocurrió una
infracción.
De
t
e
r
m
i
n
a
c
i
ó
n
Si 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.
Ap
e
l
a
c
i
ó
n
El demandante tiene 10
días para apelar la
decisión.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 12
Exhibit 3.2 Title VI Complaint Form (Spanish)
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 13
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 14
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
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 15
Section 5 | Public Participation Plan
About the City of Azusa
Nestled in the foothills of the San Gabriel Mountains, the City of Azusa was founded in 1887 and
incorporated as a general law city on December 29, 1898. Azusa lies within the County of Los Angeles,
approximately 27 miles northeast of the city of Los Angeles.
The city of Azusa encompasses 9.13 square miles and has a population of approximately 48,824 (July
2022). Educational facilities provided through the Azusa Unified School District include eight public
elementary schools, one public middle school, two public high schools, and 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 community stakeholders can partake directly in agency
decision-making, and express their concerns, desires, and values. It is the mission of the City of Azusa’s
Transit Division to "improve the lives of people with disabilities by creating opportunities to maximize
their independence." At every opportunity through prescribed methods the Transit Division 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 considered.
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 revision, City of Azusa staff will identify into which category the project falls and develop an
appropriate participation plan. 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:
• Baseline – Routine service, schedule, and system enhancements and revisions. Also
includes short-term (less than one year) projects where potential impacts to Azusa Transit
and its customers should be considered during planning phases.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 16
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.
• 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.
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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 17
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):
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 multiple 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 14.2 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 percen t 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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 18
• 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
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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 19
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 examples of the City'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, Police Department, 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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 20
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 orig in, or have 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 (October 1, 2012) 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 locations 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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 21
Fixed-route and ADA complementary paratransit services in Azusa are provided by Foothill Transit and
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 2023 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 (LAP) includes methodologies for
identifying LEP individuals, providing services, establishing policies, and monitoring the LAP, as well as an
implementation plan.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 22
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
and older. ACS 2021 (the most recent data available at this level of detail) estimates revealed 46.5 percent
Estimate Percent of
Total Estimate Percent of
Total Estimate Percent of
Total
Race
White 22,751 46.0%4,382,079 43.7%20,553,732 52.1%
Black or African American 1,569 3.2%795,213 7.9%2,233,258 5.7%
Asian 7,431 15.0%1,478,561 14.8%5,887,396 14.9%
Native Hawaiian/Pacific Islander 51 0.1%24,383 0.2%148,278 0.4%
American Indian/Alaska Native 540 1.1%99,324 1.0%360,607 0.9%
Some other race alone 9,805 19.8%2,201,939 22.0%6,036,865 15.3%
Two or more races 7,310 14.8%1,038,136 10.4%4,235,217 10.7%
Total 49,457 100.0%10,019,635 100.0%39,455,353 100.0%
Ethnicity
Hispanic or Latino (of any race)31,270 63.2%4,878,619 48.7%15,593,787 39.5%
Azusa Los Angeles County California
Race or Ethnicity
American Community Survey 2021 five-year estimates
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 23
of the Azusa Transit service area residents spoke only English at home, while approximately 41.7 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 4.1 percent.
While many residents of Azusa speak another language at home, many of them speak English “very well.”
In fact, 34.9 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
14.2 percent of the City’s total population. By contrast, Chinese speakers who speak English less than
“very well” comprise just two percent of the City’s 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
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/.
Estimate Percent of
Total Estimate Percent of
Total Estimate Percent of
Total
Total Population 46,451 100.0%9,449,268 100.0%37,105,018 100.0%
Total Speak only English 21,598 46.5%4,172,934 44.2%20,833,290 56.1%
Total Speak language other than English 24,853 53.5%5,276,334 55.8%16,271,728 43.9%
Total Speak English "very well"16,233 34.9%3,111,296 32.9%9,894,273 26.7%
Total Speak English less than "very well"8,620 18.6%2,165,038 22.9%6,627,434 17.9%
Speak Spanish 6,606 14.2%1,447,908 15.3%4,049,098 10.9%
Speak French, Haitian, or Cajun 37 0.1%6,230 0.1%17,622 0.0%
Speak German or other West Germanic languages 10 0.02%2,817 0.03%12,315 0.03%
Speak Russian, Polish, or other Slavic languages 3 0.01%27,630 0.29%94,771 0.26%
Speak Other Indo-European languages 151 0.33%140,858 1.5%373,332 1.01%
Speak Korean 181 0.39%95,811 1.01%193,854 0.52%
Speak Chinese (incl. Mandarin, Cantonese)978 2.11%222,496 2.35%672,186 1.81%
Speak Vietnamese 65 0.14%49,416 0.52%328,522 0.89%
Speak Tagalog (incl. Filipino)396 0.85%69,719 0.74%249,979 0.67%
Speak Other Asian and Pacific Island languages 134 0.29%71,015 0.75%706,179 1.90%
Speak Arabic 46 0.10%16,563 0.18%72,025 0.19%
Speak Other and unspecified languages 13 0.03%14,575 0.15%58,825 0.16%
American Community Survey 2021 five-year estimates (most recent data available)
Speak English less than "very well" - breakdown
Language Spoken at Home
Azusa Los Angeles County California
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 24
The City accessed the available EL data for the 2022/23 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 2021 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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 25
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 215 140 142 123 153 156 139 98 111 110 98 110 90 1,685 96.45%
Other non-English languages 1 1 1 0 2 1 1 0 2 2 0 0 0 11 0.63%
Cantonese 2 1 0 1 0 2 0 0 1 0 1 1 0 9 0.52%
Mandarin (Putonghua)2 3 0 1 0 1 0 0 1 0 0 0 1 9 0.52%
Vietnamese 1 1 0 1 2 0 1 0 1 0 0 0 0 7 0.40%
Mayan Languages 4 0 0 0 0 0 0 0 0 0 0 1 1 6 0.34%
Arabic 0 1 1 2 0 2 0 0 0 0 0 0 0 6 0.34%
Filipino (Pilipino or Tagalog)2 0 0 1 1 0 0 0 1 0 0 0 0 5 0.29%
Korean 0 0 0 0 1 1 0 0 0 0 0 0 0 2 0.11%
Indonesian 1 0 0 0 0 0 0 0 0 0 0 1 0 2 0.11%
Khmer (Cambodian)0 0 2 0 0 0 0 0 0 0 0 0 0 2 0.11%
Japanese 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0.06%
Toishanese 0 0 0 0 0 0 0 0 1 0 0 0 0 1 0.06%
Armenian 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0.06%
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 26
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
2023. Surveys were mailed to a random selection of 150 Dial-A-Ride customers and distributed onboard
both Dial-A-Ride and Gold Line Shuttle vehicles. A total of 37 responses was received. The survey was
available in English and Spanish. A copy of the survey instrument is provided in the Appendix.
The majority of surveys (75.7 percent) were completed in English. Seventy percent of surveys were from
Azusa Dial-A-Ride and 10.8 percent from the Gold Line Shuttle. Seven respondents did not indicate which
service they used.
The primary languages spoken by respondents at home were generally English (59.5 percent) or Spanish
(29.7 percent). Two additional languages were specified: Three respondents indicated Chinese while one
specified Tagalog/Filipino. Twenty-one respondents (56.8 percent) said they were a native English
speaker or spoke English “very well,” while the remainder spoke English less than “very well” (35.1
percent) or not at all (8.1 percent). No riders indicated being aware of any difficulties using the City’s
transit programs due to a language barrier.
More than 70 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 (16
responses, or 43.2 percent of respondents), followed by Asian (seven responses, or 18.9 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 10 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.
• Half of the staff surveyed speak Spanish. The others did not indicate speaking any other
languages besides English.
• Half of the staff surveyed indicated encountering more than 10 unique riders per week
that do not speak English or do not speak English very well. Another 30 percent indicated
encountering five to 10 such individuals. Most of these individuals speak Spanish, though
two staff cited Tagalog and one Chinese as languages they encounter.
• LEP riders often board at the El Super on Pasadena, between First St and Gladstone on
the east side, and at the Gold Line station. Many are traveling to the senior center, Gold
Line station, doctor’s offices, and grocery stores.
• Only one staff member indicated having frequent communication problems with LEP
riders, while two others indicated having occasional problems (none of these individuals
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 27
indicated speaking Spanish). All other staff members (70 percent) said they had no issues
or problems.
• 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, 70 percent said posting onboard notices in other
languages; 60 percent said a translated service brochure; 50 percent said making
translation available through dispatch; and 20 percent said providing translated materials
online. One staff member noted that riders are sometimes confused by the Dial-A-Ride
courtesy call and transit voicemail prompt, which are both only in English.
• The most common areas/topics indicated by City staff to have language/communication
barriers were how to use Azusa Transit and basic directions/instructions (60 percent
each), followed by how to pay the fare (30 percent). One staffer said barriers also involved
Dial-A-Ride pick-up times and hours of operation.
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 service
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, 24 local stakeholders (comprised of
social service agencies, senior centers, faith-based organizations, and educational institutions) were
contacted regarding transportation barriers for 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, nine completed a 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.
• Seven stakeholders indicated representing individuals who speak Spanish, while three
indicated Tagalog/Filipino, two indicated Chinese, and two indicated Korean. Vietnamese,
Farsi/Persian, Armenian, Arabic, and Bangla 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 “somewhat well” (five respondents). One characterizes
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 English-speakers read English, two
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 28
stakeholders indicated non-native English-speakers were able to read English either
“somewhat well,” while three said “not well” and two 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, four 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 between 25 percent and 50 percent of transit riders, while
another said between 51 percent and 75 percent are transit riders. The other two
respondents did not respond.
• No stakeholders indicated language being a barrier to the use of the City’s transit services.
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 (18.6 percent) speaks English less than very well. Spanish is the most commonly used language other
than English, comprising 14.2 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 80 percent of employees said they encountered at least five unique LEP individuals each
week. However, due to the high frequency of bilingual Spanish drivers and dispatchers, the majority of
employees indicated no or only occasional issues with communication.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 29
The customer and stakeholder surveys also reinforced Spanish as the most frequently encountered LEP
language. While there are numerous other LEP languages present in the service area, they are encountered
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 include notices on 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, Reasonable Modifications , and the
City’s rideshare efforts. 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 title of the link should be in Spanish.
For example, rather than reading “Title VI Program Complaint Form (Spanish),” it should read “Formulario
de Quejas del Título VI (Español).”
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 lang uage
assistance is required. When an employee receives a call in another language, they ask what language,
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 30
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, Korean, Bangla, Arabic, Vietnamese, Farsi/Persian,
and, Armenian This would be a one-time cost, or could be translated for free using Google Translate.
Bilingual Staff Incentives
Some 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 training 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.
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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 31
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;
• Determining whether Dial-A-Ride call-out messages should also be provided in Spanish;
• Holding conversations with stakeholders, organizations, and entities which work with LEPs; and
• Conducting 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.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 32
Exhibit 7.4 LAP Implementation Plan
Goal Task Anticipated
Completion
Assess LEP population in the
Azusa Transit service area
Four Factor Analysis October 2023
Stakeholder Survey October 2023
Driver/Staff Survey October 2023
Customer Survey October 2023
Demographics Analysis October 2023
Develop Language Assistance
Procedures
Update website to include .pdf attachments
translated into Spanish FY 2024
Implement telephonic interpretation
program FY 2024
Staff Training
Train City transit staff regarding in-house
language resources and materials available
to LEP individuals
FY 2024
Train City staff regarding use of on-demand
telephone interpretation service (if
applicable)
FY 2024
Train City staff regarding how and when to
document interactions with LEP customers FY 2024
Train City Staff how to respond to civil rights
complaints FY 2024
Notification of Title VI Rights
and Materials
Post Title VI notices in specified public
locations
Verified August
2023
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 2024; ongoing
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 33
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 its public 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 XX% XX%
Hispanic/Latino XX% XX%
Black/African American XX% XX%
Asian XX% XX%
American Indian/Alaska Native XX% XX%
Native Hawaiian/Pacific Islander XX% XX%
Member participation and selection will be monitored by the City’s Title VI Program Administrator.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 34
Section 9 | Sub-recipient Monitoring and Schedule of Sub-recipient
Title VI Program Submissions
The City does not have any sub-recipients of federal funding at this time and does not anticipate expanding
to include sub-recipients.
If in the future the City elects to expand the Azusa Transit services provided and begins contracting with
sub-recipients, 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 sub -recipients.
The City will also ensure Appendix E of the Title VI Assurances (US DOT Order 1050.2A) is incorporated
into all sub-recipient contracts.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 35
Section 10 | Title VI Equity Analysis
Title VI regulations require the completion of an Equity Analysis whenever a recipient or sub -recipient
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 three 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, color, 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 for the siting of any future new transit facility would be completed and submitted as
part of the City of Azusa’s next Title VI Program update.
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 36
Section 11 | City Council Adoption of Title VI Program Update
[pending adoption]
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 37
Section 12 | Appendix
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 38
Exhibit A.1 Customer Survey Instrument
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 39
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 40
Exhibit A.2 Employee Survey Instrument
2023 City of Azusa Title VI Program
Azusa Dial-A-Ride and Gold Line Shuttle
November 2023
MOORE & ASSOCIATES, INC. PAGE 41
Exhibit A.3 Stakeholder Survey Instrument
Attachment 2
RESOLUTION NO. 2023-C72
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 Title VI Program was updated and approved for the triennial cycle
of October 1, 2020 to September 30, 2023, 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 4th day of December, 2023.
Robert Gonzales
Mayor
ATTEST:
Jeffrey Lawrence Cornejo, Jr.
City Clerk
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss.
CITY OF AZUSA )
I HEREBY CERTIFY that the foregoing Resolution No. 23-XXX was duly
adopted by the City Council of the City of Azusa at a regular meeting thereof, held on the
4th day of December, 2023, 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