1 STAFF REPORT
DATE: July 15, 2025
TO: Justin Hess, City Manager
FROM: Patrick Prescott, Community Development Director VIA: David Kriske, Assistant Community Development Director, Transportation BY: Karen Pan, Transportation Services Manager
SUBJECT: Adoption of a Resolution Approving the 202 5 Title VI Program Triennial Update for BurbankBus per the United States Department of Transportation (DOT) / Federal Transit Administration (FTA) Title VI Requirements and Guidelines for Federally Funded Subrecipients
RECOMMENDATION
Adopt A RESOLUTION OF THE COUNCIL OF THE CITY OF BURBANK APPROVING THE 2025 TITLE VI PROGRAM TRIENNIAL UPDATE FOR BURBANKBUS PER THE
UNITED STATES DEPARTMENT OF TRANSPORTATION (DOT) / FEDERAL TRANSIT
ADMINISTRATION (FTA) TITLE VI REQUIREMENTS AND GUIDELINES FOR FEDERALLY FUNDED SUBRECIPIENTS (Attachment 1).
BACKGROUND
Title VI of the Civil Rights Act of 1964 is a federal law that prohibits recipients and subrecipients of federal financial assistance from discriminating on the basis of race, color, or national origin in their programs or activities, and obligates federal ly funded agencies to enforce compliance. The federal government, through the Federal Transit Administration (FTA), provides financial assistance to develop new transit systems and improve, maintain, and operate existing systems. The City of Burbank receives federal transit funds through the Los Angeles County Metropolitan Transportation Authority (Metro) in the form of transit capital grants used to purchase transit buses. Since the City receives this federal transit funding, it is required to implement its transit program in compliance with Title VI. This means the City must ensure that its transit programs are available and accessible to all, regardless of race, color, or national origin, and must prepare and update a Title VI Program at least once every three years that documents
COMMUNITY
DEVELOPMENT
2 the City’s efforts to ensure this accessibility. The City completed its most recent BurbankBus Title VI Program Triennial Update on September 13, 2022 and is in compliance.
DISCUSSION
To meet FTA requirements, staff has prepared an updated Title VI Program. The City’s 2025 BurbankBus Title VI Program Triennial Update (Attachment 2) adheres to the mandates provided in FTA Circular 4702.1B (Attachment 3) regarding Title VI Program requirements. As such, the City’s BurbankBus Title VI Program Triennial Update is required to address the following program elements:
1. A system for notifying the public of their Title VI rights;
2. Instructions to the public regarding how to file a Title VI complaint;
3. A log of Title VI investigations, complaints, or lawsuits;
4. A Public Participation Plan;
5. A Language Assistance Plan to better encourage the participation of Limited English Proficient (LEP) persons
1;
6. Racial demographics of transit-related policy boards or committees;
7. A copy of the City Council resolution affirming that the City Council reviewed and approved the Title VI Program;
8. System- wide standards and policies for BurbankBus; and
9. Service policies for BurbankBus.
The City’s 2025 BurbankBus Title VI Program Triennial Update documents how the City meets the requirements listed above, including:
• Documenting service change hearings and other outreach activities that occurred during the previous plan period (such as the May 16, 2022 Transportation Commission Meeting for the proposed Service Change for BurbankBus Green Route);
• Confirming that Burbank’s LEP persons predominately speak Spanish and Armenian;
• Documenting that the City did not receive any Title VI -related complaints in the previous three-year cycle;
• Confirming that the City will continue to provide transit schedules, written communications, and outreach in the two native languages of Burbank’s LEP populations (Spanish and Armenian);
• Showing the relationship between BurbankBus service and low -income and minority census tracts; and
1 Individuals who have a limited ability to read, write, speak or understand English are Limited English Proficient or “LEP” as defined in the FTA Title VI regulations.
3 • Identifying the racial composition of the Transportation Commission as BurbankBus’s policy commission ( seven Caucasian members , including one Armenian and one Hispanic).
Recommendations for the Title VI Program Triennial Update The 2025 BurbankBus Title VI Program Triennial Update continues the policies, programs, and procedures from the City’s originally adopted 2014 Title VI Program. In updating the Title VI Program for 2025 , staff analyzed U nited States Census data to determine if there were any changes to the LEP population that is served by BurbankBus, to ensure that the Program’s public language assistance plan adequately serves its current LEP population.
Based on the most recent demographic data provided in the U.S. Census Bureau’s 2023 American Community Survey Five-Year Estimates, Spanish and Armenian speaking LEP individuals continue to be the only two populations in the C ity for whom BurbankBus are required to prepare a public language assistance plan, per the FTA’s thresholds. 2 Recent data also reveals that there are other LEP individuals noted to be just below the FTA’s threshold that requires inclusion of these populations in the Program’s public language assistance plan. This includes Tagalog (including Filipino); Russian, Polish, or other Slavic; Chinese (including Mandarin, Cantonese) ; Other Asian and Pacific Island ; Arabic; and Korean . Based on the BurbankBus Customer Service Call Center call logs that track the frequency of contact between BurbankBus staff in conjunction wi th discussion with BurbankBus bus operators, there is no record of requests from individuals from these LEP populations for language assistance. In the past year, the BurbankBus Call Center has only received calls for Spanish translation services.
Based on the review of available data, staff is recommending that the City continue to translate vital transportation documents and Title VI related public hearing notices in Spanish and Armenian. Verbal translation services shall be made available on an as - needed basis to these populations. The City has its own resources and translation services when other languages are needed.
Transportation Commission Input
To obtain input from the City’s LEP population for the City of Burbank’s Title VI Program Triennial Update for BurbankBus, t he Transportation Commission received a
2 The FTA Title VI guidance refers to the US Department of Justice Safe Harbor Provision, which has been adopted by USDOT. The Safe Harbor Provision stipulates that “if a recipient provides written translation of vital documents for each eligible LEP language group that constitutes five percent or 1,000 persons, whichever is less, of the total population of persons eligible to be served or likely to be affected or encountered, then such action will be considered strong evidence of compliance with the recipient’s written translation obligations.” Under this provision, BurbankBus would be viewed as in compliance with LEP requirements if it provides translations of its vital transit documents into Spanish and Armenian.
4 presentation on the 2025 BurbankBus Title VI Program Triennial Update at the June 2 5, 2025 regular meeting. Notices for this meeting were prepared and published in English, Spanish, and Armenian newspapers, provided on the City’s website and social media platforms, and were provided on-board the BurbankBus fixed-route buses.
Upon staff’s presentation of the draft 2025 BurbankBus Title VI Program Triennial Update, the Transportation Commission was supportive of the updated Title VI Program and recommended that the City Council approve the BurbankBus Title VI Program Triennial Update.
ENVIRONMENTAL REVIEW
Approval of this Resolution has no potential for resulting in a direct or reasonably foreseeable indirect physical change to the environment and as such, falls outside the definition of a “project” under the California Environmental Quality Act (CEQA) and is therefore not subject to CEQA pursuant to CEQA Guidelines § 15378. This approval does not alter or make any physical changes to existing operations and solely relates to program services.
FISCAL IMPACT
Ongoing costs for implementing the programs in the proposed Title VI Program Update, including maintaining printed material, the BurbankBus website, and translation services, are part of the BurbankBus annual budget. Thus, there is no fiscal impact to adopting the proposed Title VI Program update. Failing to adopt the program could cause the City to become ineligible for federal transit funds in the future.
CONCLUSION
In order for the City of Burbank to meet the requirements of the FTA and ensure that the City continues its ability to receive future federal funds, staff recommends the City Council adopt the proposed 2025 Title VI Program Triennial Update. With this proposed update, staff believes the City’s Title VI Program meets the requirements of Metro and FTA and is in compliance with Title VI requirements. The Title VI Program demonstrates how the City does not discriminate in the way it provides transit services, encourages public participation in how the City operates transit services, and provides language assistance to the City’s LEP populations. Should the City Council elect not to adopt the Title VI Program, this action would jeopardize the City’s ability to receive future federal funds for transit services and vehicle purchases. Therefore, staff recommends that the City Council adopt a Resolution approving the City of Burbank’s 2025 Title VI Program Triennial Update for BurbankBus per the DOT /FTA Title VI requirements and guidelines for federally funded subrecipients.
ATTACHMENTS
Attachment 1 – Resolution
5 Attachment 2 – City of Burbank Title VI Program Triennial Update Attachment 3 – FTA Circular 4702.1B