CONSENT ITEM
E-22
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: SERGIO GONZALEZ, CITY MANAGER
FROM: MIKI CARPENTER, DIRECTOR OF COMMUNITY RESOURCES
DATE: SEPTEMBER 21, 2026
SUBJECT: CONSIDERATION OF ADOPTION OF RESOLUTION APPROVING 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 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 in February of 2018, November of 2020, and December of 2023, covering the three 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 October 1, 2026, through September 30, 2029.
RECOMMENDATION:
Staff recommends the City Council take the following action:
1) Adopt Resolution No. 2026-C62 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 Title VI Plan Update
September 21, 2026
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.
Three triennial updates have been approved by City Council; one in February of 2018, another in November of 2020, and another in December of 2023.
The Title VI Program includes documents that will be posted and/or available on the Community Resources webpage and on all transit vehicles operated by the City of Azusa. These documents include but are not limited to: 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 estimated 15% of the population who can speak English “less than very well,” thus falling under the FTA’s “Safe Harbor Provision” threshold. 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 no significant fiscal impact associated with adoption of the updated Title VI Program. Any costs associated with implementation of the Program, including required language translation services, will be funded with available Proposition A and/or Proposition C funds within the Transit Division's approved FY 2026/27 budget under accounts 15-25-521-480-6399 and 17-25-521-120-6399. No additional General Fund appropriation is required as a result of this action.
Prepared by: Reviewed and Approved:
Nikki Rosales Miki Carpenter
Senior Management Analyst Director of Community Resources Reviewed and Approved by:
Sergio Gonzalez
City Manager
Title VI Plan Update
September 21, 2026
Attachments:
1) Title VI Program
2) Resolution No. 2026-C62
Attachment 2
RESOLUTION NO. 2026-C62
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 Title VI Program was updated and approved for the triennial cycle of October 1, 2023, to September 30, 2026; 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 21st day of September, 2026.
Eddie Alvarez
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. 2026-C62 was duly adopted by the City Council of the City of Azusa at a regular meeting thereof, held on the 21st day of September, 2026, by the following vote of Council:
AYES: COUNCILMEMBERS
NOES: COUNCILMEMBERS
ABSENT: COUNCILMEMBERS
Jeffrey Lawrence Cornejo, Jr.
City Clerk
APPROVED AS TO FORM:
Burke, Williams, & Sorensen, LLP
City Attorney
CITY OF AZUSA
AZUSA TRANSIT
2026 Title VI Program
Final Report
Developed July 2026
Adopted by the City of Azusa City Council
September 21, 2026
Point of Contact
Ms. Nikki Rosales
Senior Management Analyst
City of Azusa
213 E. Foothill Boulevard
Azusa, CA 91702
(626) 812-5261
[email protected]
Prepared by
Moore & Associates, Inc.
25852 McBean Pkwy, Suite 187
Valencia, CA 91355
(888) 743.5977
Attachment 1
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The City of Azusa's Azusa Transit system, composed of Azusa Dial-A-Ride and the Gold Line Shuttle, provides public transportation services to residents, visitors, and individuals employed within the City of Azusa, located in Los Angeles County, California.
This Title VI Program was prepared by Moore & Associates, Inc., on behalf of the City of Azusa and has been adopted by the Azusa City Council. The document was developed to demonstrate the City's compliance with Title VI of the Civil Rights Act of 1964, as amended, and the implementing guidance contained in the Federal Transit Administration (FTA) Circular 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients. The program outlines the policies, procedures, and practices the City has established to ensure transit services are provided in a fair, equitable, and nondiscriminatory manner, regardless of race, color, or national origin. 2026 City of Azusa Title VI Program
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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 ....................................................2 Title VI Notice to the Public (English)........................................................................................................2 Title VI Notice to the Public (Spanish).......................................................................................................3 Section 3 | Title VI Complaint Procedures and Form ...................................................................................5 Title VI Complaint Procedure and Form (English).....................................................................................5 Title VI Complaint Procedure and Form (Spanish)..................................................................................10 Section 4 | List of Transit-Related Title VI Investigations, Complaints, and Lawsuits................................15 Section 5 | Public Participation Plan...........................................................................................................16 About the City of Azusa...........................................................................................................................16 Purpose of this Public Participation Plan................................................................................................16 Public Participation Philosophy ..............................................................................................................16 Public Participation Levels......................................................................................................................17 Outreach Requirements..........................................................................................................................17 Outreach to Limited English Proficient (LEP) Populations......................................................................18 LEP Outreach Requirements...................................................................................................................18 Public Participation Process....................................................................................................................19 Section 6 | Summary of Outreach Efforts...................................................................................................20 Public Participation Activities .................................................................................................................20 Section 7 | Language Assistance Plan and Four-Factor Analysis................................................................22 Purpose of the Language Assistance Plan...............................................................................................22 Service Overview.....................................................................................................................................22 Language Assistance Plan Goals .............................................................................................................24 Four-Factor Analysis................................................................................................................................24 Language Assistance Plan .......................................................................................................................36 Monitoring, Evaluation, and Plan Updates.............................................................................................39 Implementation Plan ..............................................................................................................................39 Section 8 | Minority Representation on Planning and Advisory Bodies.....................................................40 2026 City of Azusa Title VI Program
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Section 9 | Sub-recipient Monitoring and Schedule of Sub-recipient Title VI Program Submissions........41 Section 10 | Title VI Equity Analysis............................................................................................................42 Section 11 | City Council Adoption of Title VI Program Update.................................................................43 Section 12 | Appendix.................................................................................................................................44 2026 City of Azusa Title VI Program
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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 committed to ensuring all individuals have equal access to public transportation services and to protecting the civil rights of residents, visitors, and transit users. In accordance with Title VI of the Civil Rights Act of 1964, the City has evaluated its public transit services—including Azusa Dial-ARide and the Gold Line Shuttle (collectively referred to as Azusa Transit)—to ensure no person is excluded from participation in, denied the benefits of, or otherwise subjected to discrimination on the basis of race, color, or national origin.
Since its inception, Azusa Transit has been dedicated to providing safe, reliable, and accessible transportation services which meet the mobility needs of the community. This Title VI Program outlines the rights and protections afforded to all transit users under federal law, the City's policies and procedures for ensuring compliance with Title VI, and the process for filing a complaint if an individual believes they have been subjected to discrimination. Through this program, the City reaffirms its commitment to providing equitable, nondiscriminatory transit services for all members of the community. • As a recipient of federal transportation funding, the City of Azusa is committed to complying with Title VI of the Civil Rights Act of 1964 and all applicable federal nondiscrimination requirements.
In accordance with these obligations, the City strives to ensure that:
• The benefits of public transit services are distributed equitably throughout the community. • Transit services are provided in a fair, accessible, and nondiscriminatory manner, ensuring equal access for all riders.
• All individuals have meaningful opportunities to participate in the planning, development, and decision-making processes related to the City's public transportation services. • Policies, procedures, and practices are in place to prevent discrimination based on race, color, or national origin, whether intentional or unintentional, in the administration of transit programs and services.
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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.azusaca.gov/329/Transportation-Division The City of Azusa makes its Azusa Transit Title VI Program, Title VI complaint procedures, and bilingual complaint forms are available online to ensure the public has easy access to information regarding their rights and the complaint process. These materials can be found on the City's transit website at:
https://www.azusaca.gov/329/Transportation-Division
Title VI Notice to the Public (English)
In accordance with Title VI of the Civil Rights Act of 1964, no person shall be excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under the City of Azusa's public transit programs or activities on the basis of race, color, or national origin. The City of Azusa is committed to protecting these civil rights and has established policies and procedures to ensure compliance with all applicable federal nondiscrimination requirements.
Transit riders and members of the public are assured the following:
• Equal and nondiscriminatory access to Azusa Transit services. • Timely notification of significant service changes and modifications affecting transit services. • Meaningful opportunities for public participation in the planning and development of transit services.
• Accessible information regarding transit services, programs, policies, and Title VI protections. • A fair and accessible process for filing a Title VI complaint if an individual believes they have experienced discrimination in connection with the City's public transit services.
The City encourages all transit riders and members of the public to become familiar with the rights and protections afforded under Title VI of the Civil Rights Act of 1964. Individuals who have questions, concerns, or believe they have been subjected to discrimination on the basis of race, color, or national origin in connection with Azusa Transit services are encouraged to contact the City of Azusa Community Resources Department – Transit Division at (626) 812-5206 or Azusa City Hall at (626) 812-5229 for assistance.
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Title VI Notice to the Public (Spanish)
De conformidad con el Título VI de la Ley de Derechos Civiles de 1964, ninguna persona será excluida de participar en, se le negarán los beneficios de, o será objeto de discriminación en los programas o actividades de transporte público de la Ciudad de Azusa por motivos de raza, color u origen nacional. La Ciudad de Azusa está comprometida con la protección de estos derechos civiles y ha establecido políticas y procedimientos para garantizar el cumplimiento de todos los requisitos federales aplicables en materia de no discriminación.
Los usuarios de Azusa Transit y los miembros del público tienen garantizados los siguientes derechos:
• Acceso equitativo y libre de discriminación a los servicios de Azusa Transit. • Notificación oportuna sobre cambios significativos en el servicio y modificaciones que afecten los servicios de transporte público.
• Oportunidades significativas de participación pública en la planificación y el desarrollo de los servicios de transporte público.
• Acceso a información sobre los servicios de transporte público, programas, políticas y las protecciones establecidas por el Título VI.
• Un proceso justo y accesible para presentar una queja bajo el Título VI si una persona considera que ha sido objeto de discriminación en relación con los servicios de transporte público de la Ciudad.
La Ciudad de Azusa alienta a todos los usuarios del transporte público y a los miembros del público a familiarizarse con los derechos y protecciones que otorga el Título VI de la Ley de Derechos Civiles de 1964. Las personas que tengan preguntas, inquietudes o crean haber sido objeto de discriminación por motivos de raza, color u origen nacional en relación con los servicios de Azusa Transit pueden comunicarse con el Departamento de Recursos Comunitarios – División de Transporte de la Ciudad de Azusa al (626) 812-5206 o con el Ayuntamiento de la Ciudad de Azusa al (626) 812-5229 para obtener asistencia. 2026 City of Azusa Title VI Program
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Exhibit 2.2 Title VI Notice Posted on Azusa Transit Vehicles and in City Hall 2026 City of Azusa Title VI Program
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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 transportation funding, the City of Azusa is required to comply with Title VI of the Civil Rights Act of 1964 and ensure no person is excluded from participation in, denied the benefits of, or subjected to discrimination on the basis of race, color, or national origin in the provision of its public transit services.
To fulfill this obligation, the City has established a Title VI Complaint Procedure provides a fair and accessible process for the local investigation and resolution of Title VI complaints. This procedure is consistent with the guidance contained in Federal Transit Administration (FTA) Circular 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients (March 6, 2025).
Any individual who believes they have been subjected to discrimination on the basis of race, color, or national origin by the City of Azusa in connection with its public transit services may file a Title VI complaint by completing and submitting the City's Title VI Complaint Form. Complaints must be filed within 180 calendar days of the alleged discriminatory act or incident. The City will investigate only those complaints which are complete and fall within its jurisdiction.
Within ten (10) business days of receiving a complaint, the City will review it to determine whether it has jurisdiction and whether sufficient information has been provided to proceed with an investigation. The complainant will receive written acknowledgment indicating whether the complaint has been accepted for investigation.
The City will make every reasonable effort to complete its investigation within thirty (30) calendar days of accepting the complaint. If additional time is required, the complainant will be notified in writing of the reason for the extension and the anticipated completion date.
If additional information is needed to investigate the complaint, the City may request supplemental documentation or clarification from the complainant. The complainant will have ten (10) business days from the date of the request to provide the requested information. Failure to respond within the specified timeframe may result in the complaint being administratively closed.
A complaint may also be administratively closed if the complainant voluntarily withdraws the complaint or otherwise indicates they no longer wish to pursue the matter.
Upon completion of the investigation, the City will issue one of the following written determinations:
• Closure Letter – Issued when the investigation determines there is insufficient evidence to substantiate a violation of Title VI. The letter summarizes the allegations, explains the findings, and notifies the complainant the case has been closed.
• Letter of Finding (LOF) – Issued when the investigation is completed and summarizes the 2026 City of Azusa Title VI Program
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allegations, investigative findings, and conclusions. If appropriate, the letter will also describe any corrective actions to be taken, including policy changes, staff training, disciplinary action, or other measures implemented to address the findings.
If the complainant disagrees with the City's determination, they may submit a written appeal within ten (10) business days of receiving the Closure Letter or Letter of Finding.
A complainant also has the right to file a Title VI complaint directly with the Federal Transit Administration:
Federal Transit Administration
Office of Civil Rights
1200 New Jersey Avenue, SE
Washington, DC 20590
The following exhibit provides an overview of the City of Azusa's Title VI complaint process and procedures.
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Exhibit 3.1 Title VI Procedures (English)
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Exhibit 3.2 Title VI Complaint Form, Page 1 (English)
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Exhibit 3.3 Title VI Complaint Form, Page 2 (English)
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Title VI Complaint Procedure and Form (Spanish)
Procedimientos de Quejas del Título VI
Como beneficiaria de fondos federales para el transporte, la Ciudad de Azusa está obligada a cumplir con el Título VI de la Ley de Derechos Civiles de 1964 y a garantizar que ninguna persona sea excluida de participar en, se le nieguen los beneficios de, o sea objeto de discriminación por motivos de raza, color u origen nacional en la prestación de sus servicios de transporte público.
Para cumplir con esta obligación, la Ciudad ha establecido un Procedimiento para la Presentación de Quejas del Título VI, el cual proporciona un proceso justo y accesible para la investigación y resolución local de las quejas presentadas bajo el Título VI. Este procedimiento es consistente con las directrices establecidas en la Circular 4702.1B de la Administración Federal de Tránsito (FTA), Title VI Requirements and Guidelines for Federal Transit Administration Recipients (6 de marzo de 2025).
Toda persona que considere haber sido objeto de discriminación por motivos de raza, color u origen nacional por parte de la Ciudad de Azusa, en relación con sus servicios de transporte público, puede presentar una queja del Título VI completando y enviando el Formulario de Queja del Título VI de la Ciudad. Las quejas deberán presentarse dentro de los 180 días calendario posteriores al presunto acto o incidente discriminatorio. La Ciudad investigará únicamente aquellas quejas que estén completas y que se encuentren dentro de su jurisdicción.
Dentro de los diez (10) días hábiles siguientes a la recepción de una queja, la Ciudad la revisará para determinar si tiene jurisdicción y si se ha proporcionado información suficiente para iniciar una investigación. El denunciante recibirá una notificación por escrito indicando si la queja ha sido aceptada para investigación.
La Ciudad hará todos los esfuerzos razonables para completar la investigación dentro de los treinta (30) días calendario siguientes a la aceptación de la queja. Si se requiere tiempo adicional, el denunciante será notificado por escrito sobre el motivo de la prórroga y la fecha estimada de conclusión.
Si durante la investigación se requiere información adicional, la Ciudad podrá solicitar al denunciante documentación complementaria o aclaraciones. El denunciante dispondrá de diez (10) días hábiles a partir de la fecha de la solicitud para proporcionar la información requerida. Si no responde dentro del plazo establecido, la Ciudad podrá cerrar administrativamente la queja.
Una queja también podrá cerrarse administrativamente si el denunciante retira voluntariamente la queja o indica de alguna otra manera que ya no desea continuar con el proceso.
Al concluir la investigación, la Ciudad emitirá una de las siguientes determinaciones por escrito:
• Carta de Cierre (Closure Letter): Se emite cuando la investigación determina que no existe evidencia suficiente para sustentar una violación del Título VI. La carta resume las alegaciones, explica las conclusiones de la investigación e informa al denunciante que el caso ha sido cerrado. • Carta de Determinación (Letter of Finding – LOF): Se emite una vez concluida la investigación y resume las alegaciones, los hallazgos de la investigación y las conclusiones. Cuando corresponda, 2026 City of Azusa Title VI Program
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la carta también describirá las medidas correctivas que se adoptarán, las cuales pueden incluir cambios en las políticas, capacitación del personal, medidas disciplinarias u otras acciones implementadas para atender los hallazgos.
Si el denunciante no está de acuerdo con la determinación de la Ciudad, podrá presentar una apelación por escrito dentro de los diez (10) días hábiles siguientes a la recepción de la Carta de Cierre o de la Carta de Determinación.
El denunciante también tiene derecho a presentar una queja del Título VI directamente ante la Administración Federal de Tránsito (FTA) en la siguiente dirección:
Federal Transit Administration
Office of Civil Rights
1200 New Jersey Avenue, SE
Washington, DC 20590
El siguiente diagrama proporciona una visión general del proceso y los procedimientos de la Ciudad de Azusa para la presentación y resolución de quejas conforme al Título VI. 2026 City of Azusa Title VI Program
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Exhibit 3.4 Title VI Procedures (Spanish)
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Exhibit 3.5 Title VI Complaint Form, Page 1 (Spanish)
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Exhibit 3.6 Title VI Complaint Form, Page 2 (Spanish)
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Section 4 | List of Transit-Related Title VI Investigations, Complaints, and Lawsuits
In accordance with Federal Transit Administration (FTA) Circular 4702.1B, all recipients of federal transit funding are required to prepare and maintain a record of any investigations, lawsuits, or complaints alleging discrimination on the basis of race, color, or national origin. Specifically, recipients must maintain a list of:
• Active investigations conducted by the FTA or other entities; • Lawsuits alleging discrimination on the basis of race, color, or national origin; and • Title VI complaints naming the recipient (i.e., the City of Azusa and/or Azusa Transit, including Azusa Dial-A-Ride and the Gold Line Shuttle).
To date, the City of Azusa and Azusa Transit have not been the subject of any Title VI investigations, Title VI complaints, or Title VI lawsuits. The table below has been established to document and track any future Title VI investigations, complaints, or lawsuits in accordance with FTA reporting requirements.
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
Nestled at the base of the San Gabriel Mountains, the City of Azusa was founded in 1887 and incorporated as a general law city on December 29, 1898. Located in Los Angeles County, Azusa is situated approximately 27 miles northeast of downtown Los Angeles.
The City encompasses approximately 9.13 square miles and has an estimated population of 49,000 residents (2025). Public education opportunities within the community include eight elementary schools, one middle school, two high schools, and one Adult Education Center.
For state legislative representation, Azusa is located within California's 22nd Senate District and 48th Assembly District. At the federal level, the City is represented within California's 31st Congressional District.
Purpose of this Public Participation Plan
Public participation is an essential component of the transportation planning process. It provides residents, transit riders, businesses, community organizations, public agencies, and other stakeholders with meaningful opportunities to participate in decisions which affect public transportation services.
The purpose of this Public Participation Plan is to establish a consistent framework for engaging the public throughout the planning, development, implementation, and evaluation of Azusa Transit services and projects. Through proactive outreach and community engagement, the City seeks to ensure transportation decisions reflect community needs while complying with the public participation requirements of Title VI of the Civil Rights Act of 1964, Executive Order 12898 (Environmental Justice), and applicable Federal Transit Administration (FTA) guidance.
The City of Azusa is committed to engaging all segments of the community—including minority, lowincome, senior, disabled, and Limited English Proficient (LEP) populations—to ensure equitable access to public transportation planning and decision-making.
Public Participation Philosophy
The City recognizes transit projects vary considerably in size, complexity, duration, and community impact.
Accordingly, the level of public participation should be proportional to the significance of each project.
Public participation will begin at the earliest practical stage of project development and continue throughout implementation, as appropriate. Whenever feasible, outreach will occur before decisions are finalized so public input can meaningfully influence project outcomes.
City staff will evaluate each transit-related project during the initial planning phase and assign one of three levels of public participation:
• Level 1 – Baseline
• Level 2 – Moderate
• Level 3 – High
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If project scope, public interest, or potential impacts increase during project development, the City may elevate the project to a higher participation level.
Public Participation Levels
Level Typical Project
Duration Example Projects
Level 1 –
Baseline Less than one year
Minor schedule adjustments, temporary service changes, bus stop relocations, service branding updates, website updates, fare media revisions
Level 2 –
Moderate
Approximately one
year or longer
New or expanded services, fare policy changes, Short Range Transit Plans, Marketing Plans, transit facility improvements Level 3 –
High Multiple years
Comprehensive Operational Analyses, transit system redesigns, transit centers, major capital projects, transition of transit operations
Outreach Requirements
The City will tailor outreach activities to the anticipated level of community interest and project impact.
At a minimum, the following outreach activities will be implemented.
Level 1 – Baseline Outreach
Projects requiring Baseline outreach will generally include:
• Public notices distributed through one or more communication methods, including:
o City website
o Social media
o Email notifications
o Onboard notices
o Posters and car cards
o News releases
• Public notice provided at least one week prior to any outreach event. • Public comments accepted through meetings, email, mail, telephone, and online methods. • Public comment period extending at least one week following the final outreach activity. • ADA-accessible meeting locations.
• Advance notice of significant service changes whenever practical.
Level 2 – Moderate Outreach
In addition to all Baseline outreach activities, Moderate projects may include:
• Public meetings or workshops.
• Rider and community surveys.
• Stakeholder meetings.
• Focus groups.
• Project-specific fact sheets and Frequently Asked Questions. • Presentations to community organizations.
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• Meetings scheduled during varying times of day to maximize participation. • Meetings held at locations conveniently served by public transit whenever feasible.
Level 3 – High Outreach
In addition to all Baseline and Moderate outreach activities, High-Level projects may include:
• Multiple public meetings throughout project development. • Project advisory committees or stakeholder working groups. • Open houses.
• Expanded online engagement opportunities.
• Coordination with regional transportation agencies and neighboring jurisdictions. • Targeted outreach to historically underserved populations. • Ongoing public updates throughout project implementation.
Projects conducted by consultants or contractors shall include appropriate public participation requirements within the Request for Proposals (RFP) and contractual scope of work.
Outreach to Limited English Proficient (LEP) Populations Consistent with the City's Language Assistance Plan, Azusa Transit is committed to ensuring meaningful access for individuals with Limited English Proficiency.
Current demographic data indicates Spanish is the most frequently spoken language among persons who speak English less than "very well" and qualifies under the FTA Safe Harbor Provision. Accordingly, vital Title VI information is provided in both English and Spanish.
The City will continue to evaluate demographic changes and language needs throughout its service area.
Should another language meet or exceed the Safe Harbor threshold established by the FTA, the City will update its Language Assistance Plan and expand language assistance services accordingly.
LEP Outreach Requirements
Participation
Level Minimum LEP Outreach
Level 1 –
Baseline
Provide Title VI information in English and Spanish; notify community organizations serving LEP populations; provide interpretation services when appropriate.
Level 2 –
Moderate
All Baseline activities plus outreach through schools, faith-based organizations, community groups, farmers markets, neighborhood events, and multilingual outreach materials.
Level 3 – High
All Baseline and Moderate activities plus professional interpretation services at public meetings, translation of additional project materials, culturally appropriate outreach strategies, and targeted engagement of underserved populations. 2026 City of Azusa Title VI Program
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Public Participation Process
The City's public participation process generally follows the steps below:
1. Identify the proposed project or service change.
2. Determine the appropriate level of public participation.
3. Develop a project-specific outreach plan.
4. Conduct public outreach and engagement activities.
5. Collect and document public comments.
6. Evaluate community feedback.
7. Incorporate appropriate recommendations into the final project.
8. Communicate final decisions and project outcomes to the public. 2026 City of Azusa Title VI Program
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Section 6 | Summary of Outreach Efforts
Public Participation Activities
The City of Azusa is committed to engaging residents, transit riders, community organizations, businesses, and other stakeholders in the planning and delivery of its public transportation services. Consistent with the City's Public Participation Plan and the requirements of Title VI of the Civil Rights Act of 1964, the City conducts a variety of outreach activities designed to encourage meaningful public participation and ensure minority, low-income, and Limited English Proficient (LEP) populations have opportunities to provide input on transit-related programs and services.
Many of these outreach efforts are conducted in collaboration with local government agencies, nonprofit organizations, schools, and community partners. The activities described below are representative examples of the City's ongoing public participation efforts and are not intended to be an exhaustive list.
City Council and Advisory Commission Meetings
City Council and Advisory Commission meetings are open to the public and provide opportunities for residents and stakeholders to participate in local decision-making, including matters related to Azusa Transit. Meeting agendas, staff reports, and supporting materials are posted on the City's website in advance of each meeting.
When transit-related service changes, policies, or projects are considered, public meeting notices and agendas are also posted at designated public locations, including:
• City Clerk's Office
• Police Department
• Azusa Library
• Azusa Auditorium
• Azusa Light & Water
• City of Azusa website
All public meetings are held in facilities which comply with the Americans with Disabilities Act (ADA) and are accessible to individuals with disabilities.
Los Angeles County Office of Emergency Management
The City of Azusa partners with the Los Angeles County Office of Emergency Management to support regional emergency preparedness and evacuation planning. As part of this collaboration, Azusa Transit participates in coordinated emergency response efforts by providing vehicles, transportation services, and evacuation assistance when needed.
These planning efforts consider the mobility needs of vulnerable populations, including older adults, individuals with disabilities, minority populations, and low-income residents.
Community Assistance Programs
The City annually sponsors or participates in community assistance programs, including food, clothing, and toy drives, which serve residents experiencing economic hardship. These events provide 2026 City of Azusa Title VI Program
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opportunities to engage directly with low-income populations while sharing information about City programs and transit services.
Community assistance events are promoted through a variety of communication methods, including:
• City website
• Social media
• News releases
• Flyers and community notices
City of Azusa Website
The City of Azusa website serves as an important public information resource by providing current information regarding Azusa Transit services, public meetings, service announcements, and community engagement opportunities.
The website also provides access to Title VI resources, including:
• Title VI Program
• Title VI Notice to the Public
• Title VI Complaint Procedures
• Title VI Complaint Form (available in both English and Spanish) These online resources help ensure members of the public have convenient access to information regarding their civil rights and opportunities to participate in the City's transportation planning process.
Community Surveys and Public Outreach
The City periodically conducts rider surveys, stakeholder surveys, public meetings, and other outreach activities to obtain community feedback regarding transit services, service improvements, customer satisfaction, and future transportation needs. Survey opportunities may be offered both in person and online to maximize participation by riders and the general public. 2026 City of Azusa Title VI Program
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Section 7 | Language Assistance Plan and Four-Factor Analysis Purpose of the Language Assistance Plan
The City of Azusa is committed to ensuring all individuals have meaningful access to its transit services, regardless of their ability to speak, read, write, or understand English. This Language Assistance Plan (LAP) was developed as part of the City's Title VI Program to identify and address the communication needs of individuals with Limited English Proficiency (LEP) and to ensure compliance with applicable federal civil rights requirements.
Title VI of the Civil Rights Act of 1964 and subsequent federal guidance prohibit discrimination on the basis of race, color, or national origin in programs and activities receiving federal financial assistance. Given language can be closely associated with national origin, recipients of federal funding must take reasonable steps to ensure meaningful access to their programs and services for LEP individuals.
The City's Language Assistance Plan is guided by the following federal requirements:
• Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in any program or activity receiving federal financial assistance. A key component of Title VI compliance is ensuring individuals with limited English proficiency are able to obtain information about and access public transportation services and participate in public involvement activities.
• Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency" (August 11, 2000), requires federal agencies and recipients of federal financial assistance to take reasonable steps to ensure meaningful access to programs and services for LEP individuals. The Executive Order prohibits funding recipients from using policies or practices which have the effect of denying meaningful access due to national origin or limited English proficiency.
The U.S. Department of Transportation (USDOT) has issued guidance requiring recipients of federal transportation funding to evaluate the language needs of their communities and provide appropriate language assistance. The Federal Transit Administration (FTA) established these requirements through FTA Circular 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients (October 1, 2012).
Consistent with this guidance, the City of Azusa has prepared a Four-Factor Analysis and Language Assistance Plan to evaluate the language assistance needs of its service area, identify existing resources, establish policies and procedures for providing language assistance, and ensure ongoing compliance with Title VI requirements.
Service Overview
The City of Azusa provides two locally operated transit services:
Azusa Dial-A-Ride
Azusa Dial-A-Ride is a reservation-based shared-ride service available to:
• Residents age 55 and older; and
• Individuals with disabilities, regardless of age.
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The service operates Monday through Friday from 5:00 a.m. to 6:00 p.m.
Dial-A-Ride provides transportation for trips within the City of Azusa. Medical and certain social service trips are also available to designated destinations in neighboring communities.
One-way fares are:
• $0.50 for trips within Azusa;
• $0.25 for transportation to the Senior Center nutrition program; and • $0.50 to $1.50 for trips outside the city limits, depending on destination.
Azusa Gold Line Shuttle
The Azusa Gold Line Shuttle is a reservation-based service available to all Azusa residents. The shuttle provides transportation between designated pick-up and drop-off locations and the Metro Gold Line Station.
The fare for each one-way trip is $0.50.
Fixed-route bus service and complementary ADA paratransit service within Azusa are provided by Foothill Transit and Access Services, Inc., respectively. These services are administered independently and are not covered by this Title VI Program.
Additional information regarding these agencies' Title VI Programs is available at:
• Foothill Transit: https://www.foothilltransit.org/your-rights • Access Services: https://accessla.org/about_us/title_vi.html The City of Azusa's current Title VI Program was prepared in March 2026 in accordance with FTA Circular 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients.
Title VI Program Administrator
Ms. Nikki Rosales
Senior Management Analyst
City of Azusa
213 E. Foothill Boulevard
Azusa, CA 91702
Phone: (626) 812-5261
Email: [email protected]
Additional information regarding the City's Title VI Program is available at:
https://www.azusaca.gov/329/Transportation-Division
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Language Assistance Plan Goals
The primary goal of the City of Azusa's Language Assistance Plan is to ensure individuals with limited English proficiency have meaningful access to transit services, information, programs, and public participation opportunities.
To accomplish this goal, the City periodically evaluates the language needs of its service area, identifies appropriate language assistance measures, and updates its policies and practices as community demographics and service needs evolve.
As recommended by the U.S. Department of Transportation and required by FTA Circular 4702.1B, the City first conducts a Four-Factor Analysis to evaluate the language assistance needs of the community.
The analysis considers:
• Factor 1: The number and proportion of LEP persons eligible to be served or likely to encounter Azusa Transit services.
• Factor 2: The frequency with which LEP individuals come into contact with Azusa Transit programs, services, staff, and information.
• Factor 3: The nature and importance of the programs, services, and activities provided by Azusa Transit to the LEP population.
• Factor 4: The resources available to the City and the costs associated with providing various language assistance measures.
The results of the Four-Factor Analysis provide the framework for the City's Language Assistance Plan. The plan identifies reasonable and appropriate methods for communicating with LEP individuals, outlines procedures for providing language assistance, establishes staff responsibilities, describes training and monitoring activities, and identifies strategies for evaluating the effectiveness of language assistance efforts over time.
The City reviews its Language Assistance Plan as part of each Title VI Program update and revises its language assistance strategies as necessary to reflect changes in community demographics, service delivery, and customer needs.
Four-Factor Analysis
Factor 1: The number and proportion of LEP persons eligible to be served or likely to encounter Azusa Transit services.
The first factor of the Four-Factor Analysis examines the number and proportion of Limited English Proficient (LEP) individuals within the Azusa Transit service area who may use or come into contact with the City's transit services. Understanding the size and distribution of LEP populations enables the City to identify language assistance needs and determine the extent of language services necessary to provide meaningful access to transit information and services.
A key component of this analysis is the U.S. Department of Transportation's Safe Harbor Provision. Under this provision, if an LEP language group constitutes 5 percent of the population or 1,000 persons, whichever is less, within the service area eligible to be served or likely to encounter the transit system, 2026 City of Azusa Title VI Program
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the transit provider should translate vital documents into that language.
Vital documents generally include materials which are necessary for obtaining services or understanding an individual's rights and responsibilities, including:
• Documents required to obtain services or benefits;
• Letters or notices requiring a response from customers; • Information notifying customers of the availability of free language assistance; • Title VI complaint forms and complaint procedures; and • Notices describing an individual's civil rights under Title VI.
Service Area Demographics
To identify LEP populations within the service area, the City evaluated demographic information from the 2024 American Community Survey (ACS) 5-Year Estimates, the most current detailed demographic information available at the community level. The analysis focuses on residents living within the City of Azusa, which defines the primary service area for Azusa Transit.
For purposes of the Safe Harbor analysis, particular attention was given to the following non-English language groups:
• Spanish
• Chinese
Exhibit 7.1 presents the racial and ethnic composition of the City's service area.
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.
Estimate
Percent of
Total Estimate
Percent of
Total Estimate
Percent of
Total
White 10,876 22.2% 3,025,998 30.9% 15,604,753 39.7%
Black or African American 1414 2.9% 751,615 7.6% 2,134,516 5.4% Asian 7,517 15.3% 1,486,983 15.1% 6,100,560 15.5%
Native Hawaiian/Pacific Islander 76 0.2% 22,609 0.2% 148,310 0.4% American Indian/Alaska Native 576 1.2% 141,639 1.4% 498,657 1.3% Some other race alone 14686 30.0% 2,428,851 24.7% 7,263,783 18.5% Two or more races 13,886 28.3% 1,950,972 19.8% 7,536,798 19.2% Total 49,031 100.0% 9,808,667 99.6% 39,287,377 100.0%
Hispanic or Latino 32,067 65.4% 4,752,274 48.3% 15,778,963 40.2% Race or Ethnicity
Azusa Los Angeles County California
American Community Survey 2024 five-year estimates
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Languages Spoken at Home
The American Community Survey also provides information regarding languages spoken at home by residents five years of age and older.
According to the 2024 ACS, 44 percent of Azusa residents indicated speaking Spanish, making it by far the most common language spoken other than English within the service area. The next most common language is Chinese, spoken by three percent of residents.
Although many residents speak a language other than English at home, a substantial percentage report they speak English "very well." Approximately 35.5 percent of Azusa residents fall into this category, indicating bilingual households do not necessarily represent individuals with limited English proficiency.
However, Spanish-speaking residents who speak English less than "very well" comprise approximately
15.4 percent of the City's total population, significantly exceeding the Safe Harbor threshold established by the U.S. Department of Transportation. In comparison, Chinese speakers who speak English less than "very well" represent approximately three percent of the City's population.
Exhibit 7.2 summarizes the languages spoken at home within the service area and the relative concentrations of residents with limited English proficiency.
Exhibit 7.2 Languages Spoken at Home By Community
Estimate
Percent of
Total Estimate
Percent of
Total Estimate Percent of Total
Total Population 46,128 100.0% 9,307,645 100.0% 37,121,454 100.0% Total Speak only English 20,106 43.6% 4,182,166 44.9% 20,642,638 55.6% Total Speak language other than English 26,022 56.4% 5,125,479 55.1% 16,478,816 44.4% Total Speak English "very well" 16,370 35.5% 2,951,029 31.7% 9,979,561 26.9% Total Speak English less than "very well" 9,652 20.9% 2,174,450 23.4% 6,499,255 17.5% Speak Spanish 7,116 15.4% 1,458,491 15.7% 4,107,223 11.1% Speak French, Haitian, or Cajun 24 0.1% 5,418 0.1% 17,518 0.0% Speak German or other West Germanic languages 0 0.0% 2,345 0.0% 12,418 0.0% Speak Russian, Polish, or other Slavic languages 14 0.0% 31,095 0.3% 108,427 0.3% Speak Other Indo-European languages 183 0.4% 143,407 1.5% 401,868 1.1% Speak Korean 68 0.1% 92,322 1.0% 191,282 0.5%
Speak Chinese (incl. Manadarin, Cantonese) 1448 3.1% 222,958 2.4% 672,864 1.8% Speak Vietnamese 88 0.2% 49,036 0.5% 333,873 0.9%
Speak Tagalog (incl. Filipino) 321 0.7% 68,983 0.7% 253,929 0.7% Speak Asian and Pacific Island languages 125 0.3% 68,673 0.7% 264,548 0.7% Speak Arabic 116 0.3% 15,651 0.2% 74,874 0.2%
Speak Other and unspecified languages 149 0.3% 16,071 0.2% 60,431 0.2% American Community Survey 2024 five-year estimates
Language Spoken at Home
Azusa Los Angeles County California
Speak English less than "very well" - breakdown
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Safe Harbor Determination
Based on the demographic analysis, Spanish is the only language group which exceeds the Safe Harbor threshold of 5 percent or 1,000 persons, whichever is less.
Accordingly, the City of Azusa is required to translate vital Title VI documents and other critical transit information into Spanish. These materials include, but are not limited to, Title VI notices, complaint procedures, complaint forms, service information, and documents necessary for accessing transit services.
Although other language groups do not meet the Safe Harbor threshold, the City may elect to provide additional language assistance when warranted based on community needs, customer interactions, or other factors identified through the remaining components of the Four-Factor Analysis. The frequency with which individuals speaking these languages interact with Azusa Transit is evaluated under Factor 2.
City of Azusa English Learner Data
In addition to U.S. Census Bureau data, the City reviewed English Learner (EL) enrollment statistics reported by the California Department of Education (CDE) for students attending schools within the Azusa Unified School District.
California public schools annually identify students who are classified as English Learners and report each student's primary language through the CDE's DataQuest reporting system (https://dq.cde.ca.gov/dataquest/). Given these data are collected annually, they provide a valuable supplement to the American Community Survey by offering a more current snapshot of languages spoken within the community.
As part of the 2026 Title VI Program update, the City reviewed English Learner data for the 2024-2025 school year to better understand current language trends and identify emerging LEP populations which may require additional outreach or language assistance in the future.
Consistent with the American Community Survey findings, the overwhelming majority of English Learner students identify Spanish as their primary language. Chinese represents the second most common language among English Learners, followed by Tagalog, although each accounts for a comparatively small share of the total English Learner population.
The consistency between the American Community Survey and California Department of Education data provides confidence that Spanish remains the primary language requiring translation and language assistance services within the Azusa Transit service area.
Exhibit 7.3 presents detailed English Learner enrollment by primary language for the Azusa Unified School District.
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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; Castilian 129 161 140 124 137 104 101 97 74 53 70 63 67 1,320 94.90% Mandarin (Putonghua, Guoyu) 4 0 2 1 1 2 1 0 1 0 2 0 2 16 1.15% Mayan languages 1 3 2 0 0 0 1 0 0 0 0 1 1 9 0.65%
Philippine languages 0 2 1 1 1 1 1 0 0 0 0 0 1 8 0.58%
Cantonese 0 1 1 1 0 1 0 2 0 0 1 0 1 8 0.58%
Uncoded languages (Other non-English languages) 0 0 0 1 1 0 1 0 1 0 2 0 0 6 0.43% Vietnamese 0 1 1 0 0 0 1 0 1 0 0 1 0 5 0.36%
Korean 0 0 0 0 1 0 1 1 0 0 0 0 0 3 0.22%
Arabic 1 0 0 0 1 1 0 0 0 0 0 0 0 3 0.22%
Indonesian 0 1 0 0 2 0 0 0 0 0 0 0 0 3 0.22%
Japanese 0 0 1 1 0 0 0 0 0 0 0 0 0 2 0.14%
Amharic 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0.07%
Italian 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0.07%
Armenian 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0.07%
Chinese (Other Chinese languages) 0 0 0 0 1 0 0 0 0 0 0 0 0 1 0.07% Filipino; Pilipino 0 0 0 0 0 0 1 0 0 0 0 0 0 1 0.07%
Panjabi; Punjabi 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0.07%
Undetermined 0 0 1 0 0 0 0 0 0 0 0 0 0 1 0.07%
Thai 0 0 0 0 1 0 0 0 0 0 0 0 0 1 0.07%
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Summary
The demographic analysis confirms Spanish-speaking residents represent the City's largest Limited English Proficient population and clearly exceed the Safe Harbor threshold established by the U.S. Department of Transportation. Consequently, Spanish-language translation of vital documents remains a critical component of the City's Language Assistance Plan.
While Chinese and other language groups do not currently meet the Safe Harbor threshold, the City will continue monitoring demographic trends, school enrollment data, customer interactions, and community feedback to determine whether additional language assistance measures become appropriate in future Title VI Program updates.
Factor 2: The frequency with which LEP individuals come into contact with Azusa Transit programs, services, staff, and information.
The second factor of the Four-Factor Analysis evaluates how frequently Limited English Proficient (LEP) individuals interact with Azusa Transit. Understanding the frequency of these encounters helps the City determine the level of language assistance which is reasonable and appropriate.
To assess customer interactions with LEP individuals, the City collected information from two primary sources:
• A survey of Azusa Transit customers; and
• A survey of City transit staff, including drivers, dispatchers, customer service representatives, and supervisory personnel.
Together, these surveys provide insight into the languages spoken by transit users, the extent to which customers experience language barriers, and the types of language assistance which would most benefit riders.
Customer Survey
A customer survey was conducted during May 2026 to better understand rider demographics, travel behavior, and language assistance needs.
Survey questionnaires were mailed to a random sample of 200 recent Azusa Dial-A-Ride customers and distributed onboard the Azusa Gold Line Shuttle. Surveys were available in both English and Spanish, and a copy of the survey instrument is included in the Appendix.
A total of 34 valid surveys was received.
Approximately 74 percent of respondents completed the survey in English, while the remaining surveys were completed in Spanish. Of the completed surveys:
• 25 were from Dial-A-Ride customers;
• Six were from Gold Line Shuttle riders; and
• Three respondents did not indicate which service they used. 2026 City of Azusa Title VI Program
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Languages Spoken at Home
Respondents identified English (54 percent) and Spanish (34 percent) as the primary languages spoken in their households.
Four additional languages were identified by individual respondents:
• Bangla
• Farsi
• Italian
• Tagalog
Although these languages were represented by only one respondent each, they demonstrate the linguistic diversity present within the community.
English Proficiency
Participants were asked to rate their English-speaking ability.
Among respondents:
• 53 percent reported speaking English "very well";
• 24 percent indicated speaking English less than "very well"; and • 25 percent reported speaking little or no English.
Despite the number of respondents with limited English proficiency, none of the 27 respondents who answered the question identified language as a barrier to using Azusa Transit services.
This finding suggests existing communication methods, bilingual staff, or informal assistance from family members or companions have generally been effective in supporting LEP riders.
Race and Ethnicity
Survey respondents self-identified as:
• Hispanic or Latino (41 percent)
• White (38 percent)
• Asian (18 percent)
• Other (3 percent)
For comparison, the 2024 American Community Survey estimates the City's overall population to be approximately:
• 65 percent Hispanic or Latino;
• 22 percent White; and
• 15 percent Asian.
Household Size and Income
Approximately two-thirds of respondents reported living in households consisting of one or two individuals, considerably smaller than the City's average household size of 3.13 persons.
Survey respondents also reported relatively modest household incomes. Nearly 60 percent indicated annual household incomes below $40,000, while 38 percent reported annual incomes of $15,000 or less. 2026 City of Azusa Title VI Program
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For comparison:
• The 2026 Federal Poverty Guideline for a one-person household was $15,960. • The City's estimated per capita income was approximately $39,000. • Average household income was approximately $91,000.
These findings reinforce the importance of Azusa Transit in providing affordable transportation for lowerincome residents and individuals with limited transportation alternatives.
Transit Staff Survey
Transit employees interact with riders on a daily basis and provide valuable firsthand observations regarding language assistance needs within the community.
To better understand these interactions, the City surveyed 13 transit staff members, including drivers, customer service representatives, dispatch personnel, and supervisors.
Overall, staff responses closely corroborated the demographic findings identified through the American Community Survey and customer survey.
Key findings include:
• More than three-quarters of surveyed staff reported being bilingual in English and Spanish. One driver also indicated proficiency in Italian.
• Most employees reported encountering customers with limited English proficiency on a regular basis. Staff estimated interacting with up to ten unique LEP customers during a typical service week.
• Spanish was overwhelmingly identified as the most common non-English language encountered, followed by Chinese, Tagalog, and Korean.
• Staff reported LEP riders are most frequently picked up or dropped off at the Senior Center, supermarkets, the Department of Motor Vehicles (DMV), and the Social Security office. • Three staff members indicated experiencing occasional communication challenges when assisting LEP customers.
• Nearly all respondents agreed having bilingual staff significantly improves communication with customers and enhances customer service.
When asked which language assistance resources would be most beneficial, staff identified the following priorities:
1. A translated rider guide and service brochure (70 percent);
2. Bilingual onboard notices and informational signage;
3. Translation assistance available through dispatch;
4. Common transit phrase cards for operators; and
5. Additional translated materials available on the City's website.
Staff also identified the most common communication challenges experienced by LEP riders. These generally involve:
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• Understanding how to use Azusa Transit services, including eligibility, reservations, and operating procedures; and
• Understanding fare payment procedures.
A copy of the staff survey instrument is included in the Appendix.
Summary
The customer and staff surveys indicate Azusa Transit regularly serves individuals with limited English proficiency, particularly Spanish-speaking riders. Although relatively few customers reported language as a barrier to using transit services, staff consistently reported interacting with LEP customers throughout the week and identified opportunities to improve communication through additional translated materials and bilingual resources.
Taken together, the survey findings confirm Spanish-language assistance remains the City's highest priority, while also supporting continued monitoring of other language groups identified within the service area. These findings are incorporated into the implementation strategies described later in this Language Assistance Plan.
Factor 3: The nature and importance of the programs, services, and activities provided by Azusa Transit to the LEP population.
The third factor of the Four-Factor Analysis considers the nature and importance of Azusa Transit’s programs and services to individuals with limited English proficiency (LEP). The more essential a service is to an individual’s daily life, the greater the importance of ensuring meaningful access to information about that service.
Azusa Transit provides mobility that supports access to healthcare, shopping, social services, recreation, employment, education, and other daily activities. For many riders—particularly older adults, individuals with disabilities, and residents without access to a personal vehicle—Azusa Transit provides an important, and in some cases primary, means of transportation.
The City’s transit services also provide connections to the regional transportation network, including Metro A Line (formerly Gold Line) rail service, Metro bus routes, and Foothill Transit routes. These connections extend the reach of Azusa Transit by enabling riders to access destinations throughout Los Angeles County and the surrounding region.
Azusa Dial-A-Ride is particularly important for older adults and individuals with disabilities, providing transportation to medical appointments, pharmacies, grocery stores, community facilities, and other destinations that support independent living and quality of life. Findings from the customer survey further demonstrate the importance of these services and the degree to which many riders depend on them.
Customer Survey Trip Purpose
Respondents were asked to identify the primary purpose or purposes of the trip they were making when surveyed. Because respondents could select more than one trip purpose, percentages total more than 100 percent.
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The most frequently reported trip purposes were:
• Healthcare, including dialysis (41 percent)
• Shopping (32 percent)
• Entertainment and recreation, including the Senior Center (29 percent) • Personal business (26 percent)
Employment and education represented a relatively small share of surveyed trips. Three respondents reported traveling to work, while two identified school as a trip purpose.
These findings demonstrate that Azusa Transit plays an important role in connecting riders to healthcare, shopping, and other activities that support their health, independence, and quality of life. This is particularly significant when considering the older adults and individuals with disabilities served by the City’s Dial-A-Ride program.
Customer Survey Transit Dependency
Customer survey findings also demonstrate that many riders have limited transportation alternatives and rely on Azusa Transit to meet their mobility needs.
When asked how they would have made their surveyed trip if Azusa Transit had not been available:
• 26 percent stated they would not have made the trip at all; • 26 percent reported they would have walked or bicycled; and • Fewer than 10 percent indicated they would have driven themselves.
Most notably, more than one-quarter of respondents indicated they would not have made their trip without Azusa Transit. When considered alongside the prevalence of healthcare and shopping trips, this finding underscores the importance of the service in providing access to essential destinations. The relatively small percentage of respondents who would have driven themselves also suggests that access to a personal vehicle is limited among many Azusa Transit riders.
Community Stakeholder Survey
To supplement the customer survey findings and better understand the transportation needs of LEP populations, the City conducted a survey of community organizations serving Azusa residents. The survey was intended to identify languages encountered by local organizations, understand how the populations they serve use Azusa Transit, and identify potential language-related barriers to accessing transit services and information.
A total of 17 community organizations were invited to participate, representing sectors that frequently interact with LEP populations, including social services, education, senior services, faith-based organizations, and business and community organizations.
These organizations were selected because they serve as trusted community resources and can provide insight into the needs of individuals who may rely on public transportation or encounter language barriers when accessing public services.
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Five organizations completed the survey:
1. Independent Community Resources
2. Azusa Chamber of Commerce
3. Azusa Unified School District
4. Neighborhood Homework House
5. Center for Integrated Family and Health Services
While the number of responses was limited, the participating organizations represented several sectors of the community and provided useful qualitative information regarding language needs and potential barriers to accessing transit. A copy of the stakeholder survey instrument is included in the Appendix.
Stakeholder Survey Findings
Key findings from the stakeholder survey included:
• Responding organizations represented the mental health, social service, education, and business sectors and collectively serve a broad cross-section of the Azusa community. • All five organizations reported regularly serving individuals who speak Spanish, reinforcing findings from the demographic analysis, customer survey, and staff survey. • Respondents also identified Arabic and Vietnamese among the languages or communication needs encountered within the populations they serve.
• Each responding organization reported serving more than 50 individuals, indicating the participating organizations collectively interact with a substantial number of community members. • Stakeholders generally indicated that the non-native English speakers they serve communicate in English either “very well” or “somewhat well.” While this suggests many individuals have some degree of English proficiency, language assistance may still be important when communicating detailed or unfamiliar transit information.
• Three of the five organizations reported that their clients or members regularly use Azusa Transit.
The remaining two were unsure whether the populations they serve use City transit services. • Among stakeholders identifying language-related barriers to transit use, the most frequently cited challenges were understanding transit schedules and service information and making Dial-A-Ride reservations.
These findings are particularly relevant given the importance of Dial-A-Ride and other Azusa Transit services to older adults, individuals with disabilities, and riders traveling to healthcare and other essential destinations. Difficulty understanding service information or arranging a Dial-A-Ride trip could therefore create a meaningful barrier to mobility for an LEP individual.
Factor 3 Conclusion
The customer and stakeholder survey findings demonstrate that Azusa Transit provides important mobility for community members who may have limited transportation alternatives. Healthcare and shopping are among the most common trip purposes, and more than one-quarter of surveyed riders indicated they would not have made their trip if Azusa Transit had not been available. These findings underscore the importance of ensuring that LEP individuals can understand how to access and use the City’s transit services.
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The stakeholder survey further indicates that Spanish remains the principal language for which language assistance is likely to be needed, consistent with the findings of Factors 1 and 2. While other languages and communication needs were identified, Spanish was the only non-English language reported by every responding organization. Stakeholders also identified specific areas where language barriers may affect transit access, particularly understanding route and schedule information and making Dial-A-Ride reservations.
Taken together, the Factor 3 findings support the continued provision of Spanish-language assistance for vital transit information and customer communications, as well as continued availability of bilingual or interpretation resources where appropriate. They also support ongoing coordination with community organizations to identify changing language needs and help ensure LEP individuals have meaningful and equitable access to Azusa Transit services.
Factor 4: The resources available to the City and the costs associated with providing various language assistance measures.
The fourth factor of the Four-Factor Analysis considers the resources available to the City of Azusa and the costs associated with providing language assistance to individuals with Limited English Proficiency (LEP).
While Title VI requires recipients of federal financial assistance to provide meaningful access to LEP individuals, the U.S. Department of Transportation recognizes language assistance measures should be reasonable and appropriate based on available resources and the costs of implementation.
The City has identified several existing and potential resources which allow it to provide effective language assistance while remaining fiscally responsible. These resources include:
1. Bilingual Staff. The City's Transit Division currently employs bilingual staff who are fluent in English and Spanish and are available to assist customers with limited English proficiency.
2. Professional Translation Services. The City has access to professional translation services which can be used to translate vital documents and customer information into Spanish and other languages when appropriate.
3. Telephonic Interpretation Services. On-demand telephone interpretation services can be implemented quickly and provide access to interpreters in more than 200 languages, allowing staff to communicate with LEP individuals in real time.
4. Community Partnerships. The City maintains relationships with community organizations who regularly serve LEP populations and can provide valuable feedback regarding communication needs and outreach strategies.
5. Printed Materials. Vital documents, applications, brochures, notices, and customer information can be translated into the languages identified through the Four-Factor Analysis. Whenever possible, materials should also incorporate universal symbols, graphics, maps, and diagrams to improve comprehension regardless of language proficiency.
6. Translation of Additional Materials. Documents which are not considered vital may be translated upon request or when deemed appropriate based on customer demand and available resources.
7. Citywide Language Resources. The Transit Division may utilize multilingual resources, interpretation services, and translated materials available through other City departments to maximize efficiency and reduce duplication of effort.
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Conclusions
The Four-Factor Analysis demonstrates a significant portion of the Azusa Transit service area consists of residents with limited English proficiency. Approximately 21 percent of residents report speaking English less than "very well," with Spanish representing the predominant non-English language spoken within the community.
Based on the U.S. Department of Transportation's Safe Harbor guidance, Spanish is the only language which exceeds the Safe Harbor threshold, requiring the translation of vital documents.
The employee survey further confirmed Spanish is the language most frequently encountered by transit staff.
Approximately 80 percent of surveyed employees reported interacting with at least five unique LEP individuals during a typical week. Given most drivers and dispatch personnel are bilingual (i.e., English and Spanish), staff generally reported few communication challenges.
Customer and stakeholder surveys similarly identified Spanish as the primary language spoken by LEP transit users. Although numerous other languages—including Chinese, Tagalog, Korean, Arabic, Bangla, Farsi, Vietnamese, and American Sign Language—are present within the community, they are encountered relatively infrequently and currently represent much smaller populations.
While Title VI does not require the City to translate vital documents into languages other than Spanish, stakeholder feedback indicates language barriers remain a potential obstacle for some residents.
Accordingly, the City will continue monitoring demographic trends, evaluating customer interactions, and implementing practical measures to improve communication with LEP populations.
The following Language Assistance Plan outlines the measures the City will employ to provide meaningful access to transit services while balancing available resources and operational needs.
Language Assistance Plan
Based on the findings of the Four-Factor Analysis, the City of Azusa will continue implementing and expanding language assistance measures to ensure individuals with limited English proficiency have meaningful access to transit services and information.
The City's Language Assistance Plan includes the following components.
Translation of Vital Documents
The City will continue translating vital transit documents into Spanish, including, but not limited to:
• Title VI Notice of Rights;
• Title VI Complaint Form;
• Title VI Complaint Procedures;
• Dial-A-Ride applications;
• Public notices regarding proposed fare or service changes; • Other documents necessary to obtain or access transit services. 2026 City of Azusa Title VI Program
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Additional documents may be translated into other languages when warranted by community needs or customer requests.
Customer Information and Outreach
To improve communication with LEP individuals, the City will continue to:
• Translate key marketing and outreach materials into Spanish; • Develop multilingual outreach materials as appropriate; • Utilize graphics, maps, photographs, and universal symbols whenever feasible; • Develop bilingual public meeting materials and outreach tools to encourage participation by LEP populations; and
• Post notices informing customers of available language assistance services.
The City will also continue expanding opportunities for LEP individuals to participate in public meetings, surveys, and other community engagement activities.
Online Resources
The City's website currently provides general information regarding Azusa Transit, including Dial-A-Ride, Gold Line Shuttle, Foothill Transit Bus Passes, Title VI, Reasonable Modifications, and rideshare programs.
Although the website includes a Google Translate feature, PDF attachments are not translated through this tool.
To improve accessibility, the City should:
• Provide Spanish-language versions of the Title VI Program and other vital PDF documents; • Translate the Gold Line Shuttle informational flyer into Spanish; • Continue expanding translated online materials as resources permit; and • Display hyperlinks to translated documents in the language in which the document is written. For example, instead of "Title VI Complaint Form (Spanish)," the website should display "Formulario de Quejas del Título VI (Español)."
Telephonic Interpretation Services
The City utilizes Voiance Language Services, LLC to provide telephonic interpretation assistance for individuals with limited English proficiency. The service provides access to on-demand interpretation, enabling City staff to communicate with callers who speak a wide range of languages. Interpretation services are available to all City departments, including transit customer service, and provide a convenient resource for assisting customers when bilingual staff are not readily available.
To ensure customers are aware that language assistance is available at no cost to them, the City should actively promote the availability of interpretation services through:
• Notices on the City and transit websites;
• Transit brochures, schedules, and other printed materials; • Press releases and public information materials;
• Community meetings, outreach events, and other public engagement activities; and • Notices translated into the languages most frequently encountered within the transit service area. 2026 City of Azusa Title VI Program
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Promoting the availability of these services through multiple communication channels will help ensure individuals with limited English proficiency are aware that language assistance is available and can meaningfully access transit information, programs, and services.
Bilingual Staff
The City currently maintains a bilingual pay incentive program for employees who demonstrate proficiency in speaking, reading, and writing Spanish.
This program has enabled Azusa Transit to employ bilingual dispatchers and drivers who provide day-today assistance to Spanish-speaking customers and significantly reduce communication barriers.
The City will continue supporting bilingual staffing whenever practical and encourage employees to utilize these language skills when assisting customers.
Staff Training
To ensure consistent implementation of this Language Assistance Plan, newly hired employees and appropriate City staff will receive periodic training regarding:
• The City's Language Assistance Plan;
• Local LEP demographics;
• Available translated materials and language resources; • Procedures for assisting LEP customers;
• Staff members available to provide bilingual assistance; • Use of telephonic interpretation services;
• Documentation of LEP customer interactions; and
• Identification and processing of Title VI complaints.
Training will occur during employee orientation and periodically thereafter.
Notification of Available Language Assistance
The City will continue expanding efforts to notify LEP individuals of the availability of free language assistance. Notification methods include:
• Information posted on the City's website;
• Brochures and informational flyers;
• Community events and outreach activities;
• Notices at City Hall, the Community Center, the public library, and transit facilities; and • Distribution of information through community organizations serving LEP populations. 2026 City of Azusa Title VI Program
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Monitoring, Evaluation, and Plan Updates
The Language Assistance Plan will be reviewed and updated as part of each Title VI Program update and whenever significant demographic or service changes occur.
To evaluate the effectiveness of language assistance efforts, the City will:
• Include questions regarding language assistance needs on future rider and community surveys; • Evaluate whether Dial-A-Ride automated telephone messages should also be available in Spanish; • Maintain ongoing communication with community organizations serving LEP populations; • Conduct targeted outreach when emerging language needs are identified; • Monitor customer service interactions involving LEP individuals; • Incorporate Title VI discussions into regular staff meetings and training sessions; and • Update language assistance strategies based on customer feedback, demographic changes, and operational experience.
Implementation Plan
The matrix below summarizes the major activities associated with implementing and maintaining the City's Language Assistance Plan.
Exhibit 7.4 LAP Implementation Schedule
Goal Task Anticipated
Completion
Assess LEP population in the
Azusa Transit service area
Four Factor Analysis June 2026
Stakeholder Survey June 2026
Driver/Staff Survey June 2026
Customer Survey June 2026
Demographic Analysis June 2026
Develop Language Assistance
Procedures
Update website to include .pdf attachments
translated into Spanish Ongoing
Implement telephonic interpretation
program
As needed
Staff Training
Train City transit staff regarding in-house
language resources and materials available
to LEP individuals
Ongoing
Train City staff regarding use of on-demand
telephone interpretation service (if
applicable)
Ongoing
Train City staff regarding how and when to
document interactions with LEP customers Ongoing
Train City Staff how to respond to civil rights
complaints As needed
Public Notification of Title VI
Rights and Materials
Post Title VI notices in specified public
locations Verified May 2026
Monitor and Update Language
Assistance Plan
Regularly review ACS and census
demographic data May 2026
Incorporate discussion of Title VI into regular
staff meetings and trainings Ongoing
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Section 8 | Minority Representation on Planning and Advisory Bodies FTA Circular 4702.1B requires recipients with non-elected planning boards, advisory councils, committees, or similar bodies to provide a description of the membership of those bodies by race and a discussion of efforts undertaken to encourage participation by minority populations.
At this time, the City of Azusa does not maintain any non-elected planning boards, advisory councils, committees, or similar bodies that provide recommendations or guidance regarding the City's public transit program. Consequently, there are no committee membership demographics to report.
Should the City establish a non-elected committee or advisory body related to transit planning or operations in the future, this section will be updated to include:
• The racial and ethnic composition of the committee members; • A comparison of committee membership to the demographics of the transit service area; and • A description of the outreach efforts undertaken to encourage participation by minority populations and ensure committee membership reflects the diversity of the community served.
Exhibit 8.1 provides the format that will be used to report this information in future Title VI Program updates, if applicable.
Exhibit 8.1 Non-Elected Committee Membership Table
Race/Ethnicity Service Area Population
(Percentage)
Commission Membership
(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%
Responsibility for monitoring compliance with this requirement and updating this section, if applicable, rests with the City's Title VI Program Administrator.
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Section 9 | Sub-recipient Monitoring and Schedule of Sub-recipient Title VI Program Submissions
FTA Circular 4702.1B requires primary recipients of federal financial assistance to monitor the Title VI compliance of any subrecipients that receive federal transit funds through the agency.
At this time, the City of Azusa does not have any subrecipients of Federal Transit Administration (FTA) funding associated with its transit program. Accordingly, no subrecipient monitoring activities or Title VI Program submission schedules are required.
Should the City establish agreements with subrecipients in the future, this section will be updated to describe the City's subrecipient monitoring procedures, including the methodology used to evaluate Title VI compliance and the schedule for reviewing and receiving subrecipient Title VI Program submissions.
In addition, the City will ensure all applicable agreements with subrecipients incorporate the required Title VI Assurances contained in Appendix E of U.S. DOT Order 1050.2A, as well as any other federal civil rights provisions required by the Federal Transit Administration.
The City's Title VI Program Administrator will be responsible for implementing and overseeing all subrecipient monitoring activities and ensuring continued compliance with applicable Title VI requirements.
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Section 10 | Title VI Equity Analysis
FTA Circular 4702.1B requires recipients and subrecipients of Federal Transit Administration (FTA) funding to conduct a Title VI Equity Analysis whenever they plan to construct a new transit facility or relocate an existing facility. This requirement applies to facilities such as maintenance facilities, operations centers, administrative offices, and transit centers, but does not apply to bus shelters, bus stops, transit stations, power substations, or facilities that have already been evaluated through the National Environmental Policy Act (NEPA) process.
The purpose of the Title VI Equity Analysis is to ensure that decisions regarding the location of transit facilities are made without regard to race, color, or national origin and that the selected location does not result in disproportionately adverse impacts on minority populations.
The City of Azusa has not planned or constructed any new transit facilities during the past three years.
Therefore, no Title VI Equity Analysis is required at this time.
Should the City propose the construction or relocation of a transit facility in the future, a Title VI Equity Analysis will be completed during the planning process and prior to the selection of a preferred site. At a minimum, the analysis will include the following:
a. Site Selection Analysis
The City will conduct a Title VI Equity Analysis during the planning phase to evaluate potential facility locations and ensure site selection decisions are made without regard to race, color, or national origin.
The analysis will compare the potential equity impacts of all reasonable site alternatives and will include meaningful public outreach to individuals and communities that may be affected by the proposed facility. b. Evaluation of Cumulative Impacts
When evaluating potential facility locations, the City will consider the presence of other facilities with similar environmental or community impacts to determine whether cumulative adverse effects may occur. Where appropriate, the analysis will be conducted at the Census tract or Census block group level to ensure localized impacts are properly evaluated.
c. Evaluation of Disparate Impacts
If the analysis determines that a proposed facility location would result in a disparate impact based on race, color, or national origin, the City may proceed with that location only if:
• There is a substantial legitimate justification for selecting the proposed site; and • No practicable alternative location exists that would result in a less disparate impact.
To satisfy these requirements, the City will document its evaluation of all reasonable alternatives, demonstrate why the preferred location is necessary, and implement the least discriminatory alternative consistent with project objectives.
If required, the completed Title VI Equity Analysis for any future transit facility project will be incorporated into the City's next Title VI Program update or submitted to the Federal Transit Administration in accordance with applicable federal requirements.
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Section 11 | City Council Adoption of Title VI Program Update 2026 City of Azusa Title VI Program
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Section 12 | Appendix
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Exhibit A.1 Customer Survey Instrument (English)
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Exhibit A.2 Customer Survey Instrument (Spanish)
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Exhibit A.3 Employee Survey Instrument
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Exhibit A.4 Stakeholder Survey Instrument