TABLE OF CONTENTS
I. OVERVIEW ................................................................................... 1 A. Purpose .................................................................................... 1 B. Service Area Description ........................................................... 2 C. Culver CityBus Service Description ............................................ 3 D. Culver City Commitment to Environmental Justice .................... 7 II. GENERAL REPORTING REQUIREMENTS ..................................... 11 A. Public Notification of Culver CityBus Title VI Protections ........ 11 B. Culver CityBus Title VI Complaint Investigation Procedures .. 12 C. List of Active Lawsuits ............................................................ 12 D. Compliance Review Activities ................................................. 12 E. Signed Assurances .................................................................. 12 F. Construction Impact Analysis .................................................. 12 G. Information Dissemination ..................................................... 13 H. Limited English Proficiency Implementation Plan ................... 14 I. Public Participation Plan .......................................................... 14 J. Minority Representation on Decision Making Bodies ................ 15 III. PROGRAM SPECIFIC REQUIREMENTS ...................................... 15 A. Service Standards and Policies ............................................... 15 B. Service Standards ................................................................... 15 Vehicle Load .............................................................................. 16 Vehicle Headway ....................................................................... 16 On-Time Performance................................................................ 16 Service Availability .................................................................... 16 C. Service Policies ....................................................................... 17 Distribution of Transit Amenities ............................................... 17 Vehicle Assignment ................................................................... 17 IV. CONCLUSION ........................................................................... 18
APPENDICES
APPENDIX A: Culver CityBus FTA Title VI Certifications and Assurances
APPENDIX B: Culver CityBus Title VI Complaint Investigation Procedures
APPENDIX C: Methodology to Analyze Service and Fare Changes
APPENDIX D: Limited English Proficiency Assessment and Implementation Plan for Culver CityBus
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
1 I. OVERVIEW
A. Purpose
The Culver City Transportation Department operates a transit system that receives federal financial assistance, and as such, is required to ensure:
• The level and quality of public transportation service is provided in a non-discriminatory manner;
• Full and fair participation in public transportation decision -making is provided without regard to race, color or national origin; and, • Meaningful access to transit -related programs and activities by persons with limited English proficiency.
These requirements are implemented under the authority of Title VI of the Civil Rights Act of 1964 and applicable federal transit laws contained in Title 49, United States Code, Chapter 53. Additionally, the U.S. Department of Transportation has issued Order 5610.2 (a), “Actions to Address Environmental Justice in Minority Populations and Low-Income Populations” and accompanying guidance which describes the process that the Federal Transit Administration (FTA) and other modal agencies will use to incorporate environmental principles into programs, policies and activities.
Title VI regulations are paired with environmental justice (EJ) guidance as both d irectives require considerations in transportation programs and decision-making to protect minority populations from disproportionate and significant adverse impacts. The EJ principles additionally incorporate low- income populations, without regard to race, color, national origin or limited English proficiency, into these considerations and commit mitigation strategies where disproportionately high and adverse effects are determined.
In addition to the general reporting requirements, this year’s update wi ll voluntarily consider FTA procedures for equity analyses for major service changes, fare changes, and public engagement, using the guidance mandated for transit providers that operate 50 or more fixed route transit vehicles in peak service and located in urbanized populations of 200,000 or more people.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
2 B. Service Area Description
Culver CityBus was one of eight municipal transit systems in the Los Angeles region originally eligible to apply for federal grants under the Urban Mass Transportation Act of 1964. Its designation as a federal funding recipient enabled access to subsequent state and countywide transit funds that supported the system’s development over the past 90 years. The legacy for transportation innovation started by Culver City leaders in the early 20th century continued into a new millennium with the opening of a state-of-the-art transportation facility and transition to more sustainable fuel sources. Culver CityBus has been a regional leader in advancing new fare technology and was one of the earliest transit systems to use cashless fare collection technology.
In the last decade, Culver CityBus introduced its first Bus Rapid Transit (BRT) line on Sepulveda Blvd. and expanded its service eastward to interface with Metro’s E Line (formerly Expo) Light Rail Transit (LRT) Culver City Station. These service improvements are the foundation for the next decade of transit enhancements that are being developed to achieve its vision of:
• Rethinking Mobility - building on the success of our fixed route and paratransit services, expanding on other public service transportation options to reduce the demand for automobile ownership, reduce traffic and improve air quality.
• Connecting Communities - improving options for mobility within the core Culver City community and extending mobility options to surrounding communities within its service area.
• Enhancing Quality of Life - developing public transportation services that enhance life satisfactions including physical health, family, education, safety, economic and environmental elements.
The diversity of transportation solutions that define Culver City’s service delivery and enhancements strategy reflects the diversity of the community it serves. The Title VI General Reporting Requirements presented in the following ch apters demonstrate how the transit system will continue to comply with provisions that ensure equity in accordance with regulatory and environmental justice policy guidance.
The Culver CityBus total service area encompasses 33 square miles with census tracts overlapping this area totaling 529,532 people. The racial and ethnic breakdown of this population is shown below in Table 1. On the following page, Figure B.1 shows the percentage of minority population by Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
3 census tract.
Culver City Table 1. Bus Service Area Population Percentage by Race and Ethnicity
White Hispanic or
Latino
African Am
Asian Am Indian
and Alaska
Native
47.4% 23.7% 8% 14.3% 0.2%
Native
Hawaiian and
Other Pacific
Islander
Other Race Two or More
Races
Total
Minority
Total Non‐
Minority
0.2% 0.9% 5.4% 52.6% 47.4%
Source: U.S. 2020 Decennial Census
C. Culver CityBus Service Description
Fixed-Route Service
Culver CityBus operates seven fixed -route local bus routes and one Bus Rapid Transit line. Culver CityBus’ service area encompasses Culver City and the Los Angeles communities of Century City, Marina del Rey, Mar Vista, Palms, Playa Vista, Rancho Park, Ven ice, West Los Angeles, Westchester, and Westwood.
Service runs from the University of California at Los Angeles (UCLA) to the north, to the Metro Green Line Station to the south, and from West L.A. Transit Center to the east, to Venice Beach to the west . Culver CityBus service also connects with the E Line (formerly Expo Light Rail Line ) at La Cienega, Culver City, Sepulveda, and Westwood stations.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
4 In FY 2020, the Department’s total fleet was comprised of 54 New Flyer 40 ‐ foot low‐floor compressed natural gas (CNG) buses with an average fleet age
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
5 of 9.3 years. Culver CityBus coordinates its service schedules with surrounding transit providers including the Los Angeles County Metropolitan Transportation Authority (Metro), Santa Monica’s Big Blue Bus, and the City of Los Angeles Department of Transportation (LADOT) in a joint effort to develop a functional regional transportation plan and provide riders with an easy commute throughout the west side of Los Angeles and to a variety of surrounding locations. In FY 2020, Culver CityBus operate d 44 peak hour buses and provided public transportation for 3.4 million unlinked passenger trips annually. Culver CityBus accrued about 12.2 million annual passenger miles and 1.6 million annual vehicle revenue miles. Table 2 provides the peak frequencies of service by day for all Culver CityBus routes.
Table 2: Service Days and Operating Frequencies by Route Route Description Peak Frequency (in minutes)
Weekday Saturday Sunday
1 Washington Blvd:
West Los Angeles Transit
Center to Venice
15 15
20 2
Inglewood Blvd:
Slauson/Sepulveda to Venice
High School
60 3
Crosstown:
Mesmer/Centinela to Century
City
20‐25
30 30
4 Jefferson Blvd:
West Los Angeles Transit
Center to Westfield Culver
City Transit Center
40‐45
45 5
Braddock Dr:
School Tripper to Venice HS
60 (Operates three
times per day with
limited stops/school
days only)
6 Sepulveda Blvd:
UCLA to Metro Green Line 18 20 20
6 Rapid Sepulveda Blvd:
UCLA to Metro Green Line
30 (Midday peak
only)
7 Culver Blvd:
Robertson/Venice to
Fisherman's Village
40‐45
Source: Culver City Bus Schedules (2020)
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
6 The Impacts of COVID-19 on System Performance
Consistent with regional and national trends, the pandemic has significantly impacted Culver CityBus system’s ridership and overall system performance.
Fixed route ridership experienced a major decline with the outbreak of the COVID-19 global pandemic in March 2020. System ridership dropped drastically in the first two month of the pandemic, with April 2020 systemwide ridership being 23% of its pre-COVID level. Ridership retuned at a slow pace by summer of 2020 and then dipped with another surge in COVID cases towards the end of the year . Since January 2021, the system observed another growth period that peaked in October 2021 but decreased again during 2021 holiday season with impacts from widespread COVID variants.
Since June 2021, system ridership has fluctuated at approximately 48% of its pre-COVID level. Staff anticipates the ridership will continue to recover slowly in the next several years.
Paratransit Services
The Culver City Transportation Department oversees operation of the City's Paratransit Program that provides transportation services for senior and disabled residents. The paratransit program consists of a Dial‐a‐Ride service and a taxi coupon program. These services are not funded by Federal funds, but by revenues from other local funding sources issued to the City of Culver City.
Dial‐a‐Ride service operates within the City of Culver City as well as the Kaiser‐ Permanente medical facilities located at 6041 Cadillac Ave. and 5620 Mesmer Ave. The service operates Monday thru Friday 8:30 a.m. ‐ 4:15 p.m.; donation fares are accepted. The Dial‐a‐Ride service is operated with three City vehicles and has two City employees assigned as drivers.
The taxi coupon program supplements the Dial‐a‐Ride program for approved participants. By working with local taxicab companies, the program allows participants to book trips at a subsidized rate, allowing for lower costs and more flexibility. Participants can travel on trips originating or ending in Culver City, or in the nearby unincorporated communities of View Park, Windsor Hills, or Ladera Heights. Participants purchase coupons for use on taxicab trips.
Each coupon is worth $1.00, and taxi drivers are required to accept a maximum of $10.00 in taxi coupons per trip. If the fare exceeds the $10.00 coupon limit, the participant must pay the balance of the fare.
In addition to these services, Access Services provides feder ally‐mandated complementary paratransit services within and around the Culver CityBus service area.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
7 D. Culver City Commitment to Environmental Justice
The guiding principles of environmental justice (EJ) pursuant to FTA guidance are:
• To avoid, minimize, or mitigate disproportionately high and adverse human health and environmental effects, including social and economic effects, on minority populations and low -income populations.
• To ensure the full and fair participation by all potentially affect ed communities in the transportation decision-making process. • To prevent the denial of, reduction in, or significant delay in the receipt of benefits by minority and low-income populations.
Culver City General Plan 2045
To demonstrate its commitment to th ese EJ goals, Culver City reiterated its commitment to equitable planning for future generations in its vision and guiding principles for its General Plan 2045 Update. The core values th at define Culver City’s culture and provide a sense of direction for General Plan implementation are:
• Equity and Inclusion
• Sustainability
• Innovation and Creativity
• Compassion and Community
The Plan’s guiding principles for mo bility are to build more active and shared modes of getting to, from, and through Culver City by providing more reliable, safe, affordable, clean, and connected transportation a nd mobility options for people of all ages and abilities. It intersects with other social equity principles that include health equity, climate action, and urban ecology. These principles also foster advancement of racial, demographic, and socioeconomic diversity by supporting a range of housing types for different income levels, household compositions, stages of life, and marginalized populations.
Culver CityBus Short Range Transit Plan
In March 2020, the transit system’s Short Range Transit Plan, which connects its organizational vision to actionable programs and projects was approved. It defines major efforts to improve overall services categorized to include:
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
8 Comprehensive Mobility Services Plan , which includes the following analyses and evaluations:
• A Comprehensive Service Analysis – A complete analysis of the fixed - route and paratransit, which was postponed due to the pandemic, is scheduled to begin in FY2023.
• Potential impacts from current and future influencers, such as:
o Developments in Culver City – With the opening of the Metro E Line, Culver City has been evolving rapidly into a significant hub of employment, bringing in companies associated with
technology, media production and biotech industries. Culver CityBus is working with the development community to plan convenient mobility services a nd better transportation demand management to help mitigat e impacts on the overall
transportation infrastructure.
o Major destinations within the service area, such as West Los Angeles College, Hayden Tract Business District, UCLA, and Playa Vista Master Development.
o Metro’s NextGen Plan
o Purple Line Extension, Cr enshaw Line Extension, LAX Automated People Mover, Sepulveda Transit Corridor Project, and other major transportation projects
o Metro Micro Program
o 2028 Summer Olympics
o Other future influencers that may create impacts on the Culver CityBus service, such as Metro’s Traffic Reduction Study, High - Occupancy Toll Express Lanes.
Bus-Only Lane s – Through the MOVE Culver City initiative, Culver City implemented pilot bus and bike lanes in its downtown corridor on Culver Boulevard and Washington Boulevard that enable d buses to move efficiently through this corridor that connects downtown Culver City with E Line, Culver City Station and Arts District. In FY2023, Culver City will start the conceptual design of bus and bike lanes on Sepulveda and Jefferson Boulevards . These corridors include some of the largest trip generators and destinations/ influencers in the system network.
Mobility Services - All relevant mobility options, such as micromobility, microtransit and other innovative programs to create a system of mob ility services to respond to the community’s needs.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
9 Transportation Demand Management – to help inform and leverage mobility services to support City’s TDM Program and measures to incentivize active and mass/shared transportation modes and support and inf luence public mobility options.
Vehicle Electrification – In FY 2022, Culver City Council approved a policy for Culver CityBus to implement a 100% zero -emission fleet by 2028 to meet Culver City’s commitment to the Transportation Electrification Partnership (TEP) and to comply with the Innovative Clean Transit regulation en acted by the California Air Resources Board. The policy is to ensure the implementation of an electric fleet that balances environmental, financial and reliability goals.
The implementation strategy addresses transit revenue vehicle s, general service vehicles, and facility and infrastructure design components.
Transportation Technology and Infrastructure Enhancements – Culver CityBus has developed a technology roadmap to improve internal business processes and customer focused service performance with the FY 2021 completion of its Intelligent Transportation System which provides real -time tracking system and traffic signal prioritization and real-time customer information offered on multiple web -based applications including Interactive Voice Response, internet, text, email and bus stop LED signs.
The commitment to environmental justice extends throughout the service area, including areas identified on the following map as low -income populations (Figure D.1). Many of the census tracts identified as containin g higher concentrations of low -income populations are within or adjacent to transit priority areas or activities that will continue to benefit from the service enhancements being implemented by the system.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
10 Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
11 II. GENERAL REPORTING REQUIREMENTS
There were no sub‐recipients for this reporting period that received Federal financial assistance from the FTA through Culver CityBus.
A. Public Notification of Culver CityBus Title VI Protections
It is Culver CityBus’ Title VI responsibility to inform the public of its obligations through a public notice that details their Title VI complaint procedures. The Culver CityBus published notification is shown below.
The bilingual notification has been available to the public since 2011 and is annually updated. It is also posted in in every Culver CityBus revenue vehicle, at the service counter of the Transportation Department, in the lobby of City Hall and on the Culver CityBus website.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
12 The Culver CityBus Title VI complaint form and procedures are linked to the notification on the website and available in hard copy format at the Culver CityBus facility location. The form may be submitted either by mail or delivered in person at the following address: Attention Title VI Coordinator, 4343 Duquesne Avenue, Culver City, CA 90232. The notification is also linked to the system’s full Title VI Report and Limited English Proficiency Plan.
B. Culver CityBus Complaint Investigation Procedures
Please refer to Appendix B for a full copy of the Culver CityBus Title VI complaint forms in English and Spanish, and the Culver CityBus Title VI Complaint Investigation procedures.
C. List of Active Lawsuits
There are currently no active lawsuits or complaints against Culver CityBus alleging discrimination on the basis of race, color or national origin arising from the service provided.
D. Compliance Review Activities
No local, state or federal agency (other than the FTA during the triennial review process) has conducted a civil rights review on Culver CityBus in the last 3 years.
E. Signed Assurances
The signed FTA assurances (Appendix A) were submitted through the FTA’s web‐based grants administration system, TRAMS, on February 24, 2021, and in compliance with current reporting requirements.
F. Construction Impact Analysis
Culver CityBus has operated from its original yard facility since 1934. When the facility underwent a major renovation in the mid -1990s, an Environ mental Impact Report was prepared resulting in a Finding of No Significant Impact from construction of a new administration and maintenance building on the existing site. In FY 2022, there are plans to improve the existing facility to incorporate the elect rification infrastructure necessary to support its fleet conversion to electric vehicles. There are currently no plans to relocate any facility functions that would require preparation of a Title VI Equity Analysis.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
13 G. Information Dissemination
All announcements for public hearings are given wide distribution through the use of updated mailing and e ‐mail address listings inclusive of community groups and concerned individuals. In addition, these notices are posted on the website and as “take ‐ones” in all Culver CityBus buses and at City Hall. The public can also dial the city’s telephone number or access the city’s website to get updated information regarding city business affairs.
Culver CityBus also submits a service change proposal to the Los Angeles County Metropolitan Transportation Authority (Metro) for review if the change (1) involves in excess of 25% of the revenue service provided on a bus route; (2) duplicates in excess of 2% of another operator’s service; or (3) will be funded with Proposition A or C Local Return funds.
As stated above, when Culver CityBus proposes any major service changes, the system must meet formal notification and public hearing requirements. To briefly summarize the requirements, Culver CityBus must provide formal notification of what changes are proposed to each jurisdiction affected by service changes and allow each respective authority 90 days to respond. A public hearing must also be held to provide public input and feedback on the proposed service changes.
These and further requirements are contained in:
The Los Angeles County Metropolitan Transportation Authority “Service Notification Policy – Measures and Public Sharing Procedures for Major Service or Fare Changes”
U.S. Department of Transportation, Federal Transit
Administration, Circular C 9030.1B Urbanized Area Formula program: Grant Application Chapter 5.5 (O), “Public comment of Fare and Service Changes”
U.S. Department of Transportation, Federal Transit
Administration Triennial Review Guidelines “Public Comment on Fare and Service Changes.” Washington, DC, 1997
During this dissemination period, Culver CityBus staff are confident that all the system riders, including minorities, senior citizens, the disabled, and limited English proficiency populations, will be thoroughly apprised of any proposed service changes and will have opportunities to influence service‐ planning decisions as they arise.
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
14 Under the new Title VI guidance, transit providers with 50 or fewer peak period service buses are not required to conduct a fare equity or service change analysis. However, any impacts of these types of changes to persons of minority or low ‐income status as defined by the FTA are considered. Culv er CityBus provides opportunity for public comment and this feedback is considered prior to the implementation of any fare or service changes as detailed in their future fare and service change methodology (see Appendix C).
H. Limited English Proficiency Implementation Plan
Culver CityBus’ updated Limited English Proficiency Assessment and Implementation (LEP) Plan , which continues its assurance of meaningful access to transit services and programs for persons with limited English proficiency, is located in Appendix D. The plan was previously updated in May 2017.
I. Public Participation Plan
Culver CityBus recognizes the importance of involving the public in the planning and implementation of transit services and programs. The goals of the Culver CityBus public involvement plan are to ensure that:
• Residents are given the opportunity to fully participate in the transportation planning activities.
• The issues and concerns of residents are given consideration in the transportation investment decision making.
• Potential adverse impacts from transportation projects or programs are identified and mitigated to the extent possible, without regard to race, ethnicity or income level.
Public Participation Principles
The following principles are used to develop the Public Participation Plan for Culver CityBus projects and programs:
• Public meetings and formal hearings will be advertised in the community through printed materials onboard buses (e.g., interior cards, flyers, and/or comment cards) describing the proposed changes, as well as at major transit stops, on the Culver CityBus website and social media platforms, local print media, and at local community centers throughout the service area.
• Culver CityBus will provide notifications of meetings, particularly forums Culver City Transportation - Title VI Report
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15 for public input, in both English and Spanish and offer language assistance services for other LEP populations as described in its LEP Plan.
• Public meetings will be held in locations that are accessible to transit riders and people with disabilities, and will be scheduled at times that are convenient for members of the public, including LEP communities.
J. Minority Representation on Decision Making Bodies
Culver City does not have an exclusive commission or policy board to se t policies for Culver CityBus operations, other than the City Council . The Transportation Department meets regularly with the standing Mobility, Traffic and Parking Subcommittee of the City Council to review and obtain feedback on developing mobility plans and programs in preparation for consideration by the full Council.
City Council and Mobility, Traffic and Parking Subcommittee meetings both provide a public venue for comments and feedback regarding fare, service and other policies related to transit delivery. City Council meetings are held twice per month and create a venue for riders and members of the public to have an opportunity to comment publicly regarding Culver CityBus services. The City Council is an elected body representing, reflecting and accountable to the diverse community it services.
III. PROGRAM SPECIFIC REQUIREMENTS
Culver CityBus operated 44 peak hour fixed route buses during the reporting period and as a result is mandated by FTA Circular (FTA C 4702.1B) to only detail the system‐wide service standards and policies as part of Section III of the report.
A. Service Standards and Policies
Culver CityBus has adopted quantitative system‐wide service standards for its fixed route services. These standards, which are summarized below, were developed and implemented to help Culver CityBus better achieve equity for all its transit customers in service design and operations decisions. There have been no changes to Culver CityBus service standards during the past three years. These standards were reviewed with the most recent transit system Line‐by‐Line Analysis completed in 2015.
B. Service Standards
Culver City Transportation - Title VI Report
And Limited English Proficiency Plan Update Report Update - March 2022
16 Vehicle Load
Vehicle load is the ratio of passengers on the vehicle to the number of seats on the bus. Culver CityBus measures the vehicle load at the maximum load point on each route during peak and off‐peak periods. The Culver CityBus policy is to maintain vehicle load factors at or below 125%. To prevent the load factors from being exceeded, Culver CityBus has created three trippers to ease any overcrowding on their busiest lines.
Vehicle Headway
Vehicle headway is the measurement of time between buses on a line. Culver CityBus operates fixed‐route service with vehicle headways between 15‐60 minutes during weekday peak periods, during weekday off‐peak periods and on weekends.
On-Time Performance
Culver CityBus defines on‐time performance for fixed route bus trips as those trips that arrive at a time point location no earlier than 1 minute before the time listed on printed schedules, and arrives at the time point no later than 5 minutes from the scheduled time. Culver CityBus identified their on ‐time performance standard in the 2015 Line‐by‐Line Analysis. To enhance customer experience and improve perceived on -time performance, Culver CityBus upgraded bus technology and installed a real time arrival information system in 2020. The agency also recently implemented a tactical dedicated bus -bike lane in Downtown Culver City to maximize transit benefits and improve travel time and on-time performance. In addition, Culver CityBus is implementing a bus signal priority system at all signalized intersections within Culver City limits, with a projected completion date set for late 2022.
Service Availability
Service availability corresponds to the provision of transit service on major traffic corridors in the service area and access to high population centers and trip generators in urbanized areas. Culver CityBus provides fixed‐route service primarily to people who reside within one‐half to one‐quarter mile of the stops along the routes. Due to the large and varied number of municipal operators that include Santa Monica’s Big Blue Bus, LADOT, and the Los Angeles County Metropolitan Transportation Authority (Metro), who also provide services at or near many Culver CityBus bus stops, patrons have many options to access public transportation and Culver CityBus. The many operators in the region also coordinate regularly to reduce unnecessary duplication of routes and increase a more even distribution of transit services. Culver CityBus provides Culver City Transportation - Title VI Report
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17 riders with many opportunities to access the more regional transit systems and hubs for a seamless transit experience. With the implementation of the completed Metro Exposition Line in the service area , Culver C ityBus has procured additional buses to broaden feeder bus service to the new stations.
Additionally, Culver CityBus has altered its service availability due to expanded and new developments in its service area. The Playa Vista mixed use development, Metro E Line Phase 2 extension, West Los Angeles College expansion, and Los Angeles International Airport expansion, all affect service demand, local traffic generation, and scheduling, and service has been altered in response.
C. Service Policies
Culver CityBus has adopted quantitative system ‐wide service policies for its fixed‐route services. These policies, which are summarized below, were developed and implemented to help Culver CityBus better achieve equity for all its transit customers in service design and operations decisions. There have been no changes to Culver CityBus service policies during the past three years.
Distribution of Transit Amenities
Transit amenities such as bus benches are provided as a convenience to passengers. The placement of transit amenities is guided by the Culver CityBus Standards for New and Existing Bus Stops (February 2005). These standards govern the spacing, location, design and operational aspects of bus stops and bus furniture placed at Culver CityBus stop locations. Generally, bus stops are placed no more than 1,000 feet apart (stops may be closer in commercial and downtown Culver City areas). Benches are placed at high‐volume bus stops within the Culver CityBus service area as well as bus stops where there is less frequent service and identified high levels of usage by senior and disabled patrons. At bus stops outside the city of Culver City, the local jurisdictions determine the placement of transit amenities. The older stop furniture is in the process of being replaced along with roadway and sidewalk improvements. Partial funding has been acquired for this effort and along with ongoing efforts the remaining funds will be secured.
Vehicle Assignment
With regards to vehicle assignment, Culver CityBus assigns vehicles on an “available” basis with no specifically assigned vehicles to specific routes. The exception is the thirteen (13) buses designated for Line 6 Rapid services; these buses are identified with a specific paint scheme/ branding to indicate they are providing service to that line only. This ensures that no geographic location is preferred over another.
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And Limited English Proficiency Plan Update Report Update - March 2022
18 Culver CityBus strives to supply its customer base with well‐maintained, clean burning CNG vehicles that are ADA compliant by intending to replace all buses after their 12‐year life span. This ensures that riders are supplied with newer vehicles for the near future. Characteristics of the Culver CityBus fleet beginning in June 2020 are listed in Table 3. Culver City is in the process of replacing all CNG buses with battery -electric buses 2028. All new buses will be ADA compliant.
Table 3: Fleet Characteristics
Culver City Municipal Bus Lines Fleet Inventory ‐ June 2020
Year Built
Manufacturer
Seats
Length
Total
Vehicles
2001 New Flyer 36 40' 4
2009 New Flyer 36 40' 6
2012 New Flyer 36 40' 20
2014 New Flyer 40 40’ 6
2017 New Flyer 40 40’ 18
Totals 54
Source: National Transit Database, FY2020
IV. CONCLUSION
This report fulfills the compliance reporting requirements for Title VI as detailed in FTA Circular 4702.1B. The report detailed the Culver CityBus services, long -range planning efforts and general reporting requirements mentioned in the circular. The program specific requirements were addressed with a profile of their service standards and policies along with a description of the Culver CityBus fleet. The results demonstrate that Culver CityBus serves a diverse population and supplies public transportation equitably to all classified races, ethnicities, and income levels.
APPENDIX A:
CULVER CITYBUS FTA
TITLE VI
CERTIFICATIONS AND
ASSURANCES
APPENDIX B:
CULVER CITYBUS TITLE VI
COMPLAINT INVESTIGATION
PROCEDURES
Culver CityBus
Title VI Complaint Process
Culver CityBus grants all citizens equal access to all its transportation services.
It is further the intent of Culver CityBus that all citizens are aware of their rights to such access. This information is designed for members of the public, including employees of the Transportation Department , so that they may understand their protections under Title VI of the Civil Rights Act of 1964, to access to Culver CityBus programs and services.
What is Title VI
Title VI is a section of the Civil Rights Act of 1964 requiring 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.”
Who are Limited English Proficient Persons?
Persons who do not speak English as their primary language and who have limited ability to read, speak, write, or understand English can be limited English proficient, or “LEP.” These individuals may be entitled to language assistance with respect to a particular type of service, benefit, or encounter.
Different treatment based on a person’s inability to speak, read, write, or understand English may be a type of national origin discrimination.
How do I file a complaint?
If you believe that you have received discriminatory treatment by the Culver CityBus on the basis of your race, color or national origin, you have the right to file a complaint with the Culver CityBus Title VI Coordinator (Senior Management Analyst). The complaint must be filed no later than 180 calendar days of the alleged discriminatory incident.
Methods of Filing a Complaint
The preferred method is to file your complaint in writing using the Title VI Complaint Form, and sending it to:
Title VI Coordinator
Culver CityBus
4343 Duquesne Avenue
Culver City, California 90232
Verbal complaints will be accepted and transcribed by the Title VI Coordinator.
To make a verbal complaint, call (310) 253‐6500 and ask for the Title VI Coordinator. Complaints may also be filed with external entities such as the Equal Employment Opportunity Commission (EEOC); Federal Transit Administration (FTA); or Department of Fair Employment and Housing (DFEH).
Please review information on the respective agency websites for details on filing Title VI complaints.
Should a complaint be filed with Culver CityBus and an external entity simultaneously, the external complaint shall supersede the Culver CityBus complaint and the Culver CityBus complaint procedures will be suspended pending the external entity’s findings.
Investigations
Within 10 working days of receipt of the formal complaint, the Title VI Coordinator will notify the complainant and begin an investigation (unless the complaint is filed with an external entity first or simultaneously).
The investigation may include discussion(s) of the complaint with all affected parties to determine the problem. The complainant may be represented by an attorney or other representative of his/her own choosing and may bring witnesses and present testimony and evidence in the course of the investigation.
The investigation will be conducted and completed within 90 days of the receipt of the formal complaint.
Based upon all the information received, an investigation report will be written by the Title VI Coordinator for submittal to the Chief Transportation Officer.
The complainant will receive a letter stating that final decision by the end of the 90‐day time limit.
The complainant shall be notified of his/her right to appeal the decision.
Appeals may be made to the Federal Transit Administration (FTA).
If the complainant is dissatisfied with the determination and/or resolution set forth by Culver CityBus, the same complaint may be submitted to the FTA for investigation. The complainant will be advised to contact the Federal Transit
Administration, Office of Civil Rights, 201 Mission Street Suite 1650 San Francisco, CA 94105‐1839.
A copy of the complaint and Culver CityBus’ investigation report/letter of finding and final remedial action plan, if appropriate, will be issued to FTA within 120 days of the receipt of the complaint.
A summary of the complaint and its resolution will be included as part of the Title VI updates to the FTA.
APPENDIX C:
ASSESSMENT OF SERVICE AND
FARE CHANGES ON MINORITY
AND LOW INCOME POPULATIONS
Assessment of Impacts on Minority and Low‐Income Riders of Future Fare and Major Service Changes
Title VI requires transit agencies with more than 50 peak hour service vehicles to conduct an equity analysis when considering major service and fare changes. While Culver CityBus does not meet the minimum size standard, its commitment to social and environmental justice is supported by the following methodologies
Fare Change
When considering any fare increase, Culver CityBus will engage its public notification process in both English and Spanish. Notices of the proposed fare changes and dates for public comments will be posted on all buses, sent to customer email distributions on social media and the Culver CityBus website.
Public notices will encourage input , including comments from persons with limited English proficiency and those who may consider the proposed fare an excessive economic impact. To assist low‐income riders, the agency provides information and promotes the availability of subsidy program for low‐ income riders, such as the Low Income Fare is Easy (LIFE) regional program, to help minimize the impacts of the fare change.
Service Change
Any service change that affects 25% of an individual route, in terms of route length, service hours or service miles or 25% of the system’s mileage, overall, will be considered a major service change. Notices of proposed major service changes and dates for public comments will be posted on all buses, sent to customer email distributions on social media and the Culver CityBus website.
An analysis of disparate impacts on low income households will be performed by examining where proposed changes to route alignments and service frequencies impact low income areas at the census tract level. Additionally, Culver CityBus will consider public comments on social and economic issues related to proposed service changes as part of the decision making process.
APPENDIX D:
LIMITED ENGLISH PROFICIENCY
ASSESSMENT AND IMPLEMENTATION
PLAN FOR CULVER CITY
TRANSPORTATION DEPARTMENT
LIMITED ENGLISH PROFICIENCY ASSESSMENT AND
IMPLEMENTATION PLAN
CULVER CITY TRANSPORTATION
Introduction
This Limited English Proficiency (LEP) Assessment and Implementation Plan has been prepared to address Culver City Transportation’s (Culver CityBus) responsibilities as a recipient of federal financial assistance to provide meaningful access to limited-English proficient persons. While consistent with Title VI requirements for non -discrimination on the basis of race, color, or national origin, obligations to LEP compliance are enacted by Executive Order 13166, which requires Federal agencies to provide guidance to recipients of federal financial assistance on ways to provide meaningful access to LEP individuals. The Department of Transportation (DOT) guidance is provided through 70 FR 74090, Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient Persons , which frames the criteria used by DOT in evaluating compliance with Title VI regulations.
Limited English proficient (LEP) persons are individuals for whom English is not their primary language and who have limited ability to read, write, speak or understand English. Within the Culver CityBus service area, 40% of the population speaks at least one other language other than English. Slightly less than 12% of the service area population meets the definition of an LEP person.
Assessment of Limited English Proficient Population
In order to determine the extent of its obligation to provide LEP services, Culver CityBus assessed the LEP environm ent using the U.S. Department of Transportation’s four‐factor LEP analysis which considers the following factors:
1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a Culver CityBus program, activity or service.
2. The frequency with which LEP persons come in contact with Culver CityBus programs, activities or services.
3. The nature and importance of programs, activities or services provided by Culver CityBus to the LEP population.
4. The resources available to Culver CityBus and overall cost to provide LEP assistance.
The assessment examined census tract -level information derived from the 2019 American Community Survey for Language Spoken at Home for Population 5 Years and Older. Based on this data, the following summary of the four-factor analysis is presented in the following section.
Four-Factor Analysis
1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a Culver CityBus program, activity or service.
Census tracts that are within 3/4 mile of a Culver CityBus route comprise the Culver CityBus service area. Figure 1 shows the areas where the LEP populations reside in relation to transit service within this radius.
Data derived from the U.S. Census 2019 American Community Survey (ACS) shows the total service area has a population of 485,938 that are five years of age or older. Of those persons, 56,695 (11.7%) speak English “less than very well” More than one -half of the LEP population (31,056) speak Spanish as their primary language. A chart showing a breakdown of languages spoken at home is presented in Table A.1.
The category, “Other Indo European” populations comprised approximately 8,100 persons or 1.7% of the service area population. As the 2019 ACS data combined certain languages that were included in Culver City’s last LEP Update, the analysis also considered 2015 ACS information to discern more detailed information on specific LEP populations. In the 2015 data, Persian, Armenian, Portuguese, Italian and Hindi were separate categories that have since been combined into the broader 2019 category. Of these languages, Persian speakers represent ed 1% of the LEP population, with the remaining languages representing less than 0.1%, each.
Mandarin and Cantonese are spoken as first languages by over 5,200 persons (1.1%) within the service area. “Other Asian and Pacific Islander” languages are spoken as the primary language for 3,898 (0.8%) persons. This category includes Japanese, Khmer /Cambodian, M iao/Hmong, Laotian and Thai languages in the 2019 ACS. Approximately one -third of the service area’s Korean population (2,140) speak English “less than very well”, which represents 0.4% of the total service area population.
Figure A.2 shows the dispersion of the total LEP population across the Culver CityBus service area. While higher concentrations of LEP residents are reflected on the eastern and southern perimeters of the service boundary, the map shows that Culver CityBus
serves a diverse population with limited English proficiency, of which more than one- half speak Spanish. Figures A.3 through A.7 show the distribution of these LEP populations by language category.
Table A.1
Culver City Service Area LEP Speakers
Department of Justice Safe Harbor Analysis
American Community Survey 2015 American Community Surevy 2019 Total Population 5 Years and Older 344,701 485,938
Language Group
Total in
Group
Percent of
Total
Population
Speak English "less
than very well" Group
Total in
Group
Percent of
Total
Population
Speak English "less
than very well" Group
Percent Number Percent Percent Number Percent
English 206,760 60.0% 291,452 60.0%
0.0%
Spanish 64,387 18.7% 19,202 5.6% 98,154 20.2% 31,056 6.4% Indo-European 31,957 9.3% 7,699 2.2%
French/ Haitian/ or Cajun 4,488 1.3% 730 0.2% 6,783 1.4% 1,038 0.2% French/ Creole 212 0.1% - 0.0%
Italian 1,414 0.4% 179 0.1%
Portuguese 1,296 0.4% 295 0.1%
German/ other West Germanic 2,083 0.6% 108 0.0% 3,267 0.7% 274 0.1% Yiddish 190 0.1% 5 0.0%
West Germanic 474 0.1% 35 0.0% Scandanavian 742 0.2% 25 0.0% Greek 486 0.1% 60 0.0%
Russian/ Polish/ Other Slavic 2,889 0.8% 980 0.3% 5,593 1.2% 1,476 0.3% Polish 391 0.1% 95 0.0%
Serbo-Croatian 365 0.1% 31 0.0% Slavic 342 0.1% 28 0.0%
Armenian 962 0.3% 226 0.1%
Persian 9,383 2.7% 3,439 1.0%
Gujarathi 743 0.2% 123 0.0%
Hindi 2,524 0.7% 285 0.1%
Urdu 1,154 0.3% 350 0.1%
Other Indic 1,228 0.4% 470 0.1%
Other Indo European 591 0.2% 235 0.1% 30,388 6.3% 8,096 1.7% Asian/ Pacific Islander 34,643 10.1% 12,585 3.7%
0.0%
Mandarin/ Cantonese 6,797 2.0% 2,633 0.8% 15,410 3.2% 5,207 1.1% Cantonese 6,479 1.9% 2,510 0.7%
Japanese 5,012 1.5% 2,366 0.7%
Korean 5,851 1.7% 2,222 0.6% 6,506 1.3% 2,140 0.4% Khmer, Cambodian 348 0.1% 203 0.1% Miao Hmong 79 0.0% - 0.0%
Thai 801 0.2% 478 0.1%
Laotian 61 0.0% 35 0.0%
Vietnamese 1,881 0.5% 383 0.1% 2,138 0.4% 530 0.1% Other Asian 2,088 0.6% 490 0.1%
Tagalog 4,217 1.2% 953 0.3% 4,854 1.0% 999 0.2% Other Asian and Pacific Islander 1,029 0.3% 312 0.1% 11,813 2.4% 3,898 0.8% All Other Languages 6,954 2.0% 2,060 0.6% Navajo - 0.0% - 0.0%
Other Native American - 0.0% - 0.0% Hungarian 383 0.1% 96 0.0%
Arabic 3,310 1.0% 1,381 0.4% 3,176 0.7% 970 0.2% Hebrew 1,479 0.4% 263 0.1%
African 1,550 0.4% 250 0.1%
Other Unspecified 232 0.1% 70 0.0% 6,404 1.3% 1,011 0.2% Total 63,890 18.5% 485,938 100.0% 56,695 11.7%
2. The frequency with which LEP persons come in contact with Culver CityBus programs, activities or services.
Culver CityBus routinely monitors the frequency with which staff and drivers have, or could have, contact with LEP persons. This includes reviewing phone inquiries and surveying bus operators. In addition to serving a diverse residential population, Culver CityBus services Los Angeles International Airport which connects international visitors to local transit service at the LAX Transit Center. Culver CityBus serves major tourism attractions, su ch as Venice Beach and provides connections to other major educational, commercial and tourist destinations across Los Angeles County via direct service to destinations within the area’s vibrant westside communities and connections to the regional Metro light rail network.
Since the onset of the COVID -19, the transit system has deferred all external surveying activities; however, the most recent survey taken found that 34% bus operators have daily interaction with limited English-speaking passengers.
The predominant language encountered by bus operators is Spanish, with bus operators reporting some interaction with passengers speaking other languages including Korean, Japanese and Chinese dialects. While all public notices placed on transit vehicles are published in both English and Spanish, 90% of motor coach operators had not received requests for translated materials in other languages.
3. The nature and importance of programs, activities or serv ices provided by Culver CityBus to the LEP population.
Public transportation is an essential service which Culver CityBus provides without regard to race, color, or national origin. Staff training provided to all personnel who come into contact with the public clearly indicates that every effort is to be made to ensure that a passenger’s rights to access the service are protected and that service is not to be denied based on a customer’s inability to speak English well.
When plans and programs to improve public transportation services are being developed, the opportunity for persons with limited English proficiency to provide input and fully engage in the planning process is also important.
4. The resources available to Culver CityBus and overall cost to provide LEP assistance.
Culver CityBus operates fewer than 50 vehicles, yet its commitment to social
and environmental equity in demonstrated in its voluntary inclusion of Title VI components required of transit providers that operate larger transit systems, including:
• A demographic analysis and map of the transit provider’s service area, • A description of the public engagement process for setting “major service change policy.”
Although there is not financial capacity to incorporate written translations for every language spoken within the diverse LEP community, a language assistance implementation plan has been developed that commits resources needed to support full access to services, plans and programs to LEP persons.
Language Assistance Implementation Plan
Culver CityBus will make every effort to provide oral interpretation, written translation and other language assistance services to LEP individuals . The foundation of this support will be provided through:
• Identification and training of in-house, multi- lingual staff • Voluntary translators available through community -based social and cultural organizations throughout the service area, and • Commercial translation, electronic and telephonic interpretation/ translation services.
• Continued analysis of the frequency with which LEP i ndividuals come in contact with Culver CityBus services and programs.
• Posting the availability of language assistance services at meetings, online and in telephone messaging systems for incoming customer service calls.
• Provide Census Bureau Language Identification Flashcards (“I Speak Cards”) to bus operators, customer service staff and at registration tables set up for Culver CityBus public meetings and events.
• Network with local community service centers, such as the Culver City Senior Center, that provide services to LEP individuals and seek opportunities to provide information on transit services. • Vehicle operators and other front ‐line staff, including bus operators, supervisors, customer service representatives, clerical staff and dispatchers will be informally surveyed periodically on their experience concerning any contacts with LEP persons during the previous year. • Monitor LEP participation as part of the Culver CityBus Consolidated Service Analysis that will be conducted in FY 2023 to foster LEP participation in the planning process and to incorporate survey tools that
will allow the process to produce relevant information on LEP customer accessibility to mobility programs and services.
• Incorporate the use of a computerized translation tools on the Culver CityBus website.
• Provide written translation of any Culver CityBus policy, upon request of an LEP person.
Safe Harbor Stipulation
The Department of Transportation has adopted the Department of Justice’s Safe Harbor provision that presumes strong evidence of compliance with a recipient’s written translation obligations under Title VI if written translation of vital documents is provided for each LEP group that constitutes five percent (5%) of the total service area population or 1,000 persons, whichever is less.
In the Culver CityBus service area, only Spanish speakers with limited English proficiency exceed 5% of the total population . A number of language groups exceed the 1,000 person threshold for which written translations of vital documents could be provided under the safe harbor standard. The language groups that exceed 1,000 persons include: Other Indo-European Languages (8,096); Mandarin/ Cantonese (5,207); Other Asian and Pacific Islander Languages (3,898); Korean (2,140); Russian/Polish/ Slavic Languages (1,476); French/ Haitian/ or Cajun (1,038); and Other Unspecified Languages (1,011). Table D.1 shows the LEP population analyz ed pursuant to this provision.
The inability to provide written translations of all transit policies for each language group that meets the safe harbor criteria does not mean there is noncompliance. However, this analysis will serve as a guide in better understanding the need for interpretation/ translation services within the Culver CityBus service area.
While, Culver CityBus will continue to translate vital documents such as the Title VI Complaint Forms, the Title VI reporting process, the LEP Plan and public notices of changes to transit service into the Spanish, it will monitor and evaluate the need for future translation of materials into the other languages listed above. Culver CityBus staff will utilize features such as Google Translate and multilingual staff from the City of Culver City to translate vital documents for eligible LEP language groups upon request. Culver CityBus will also proceed with oral interpretation options for compliance with LEP regulations.
Dissemination of the Culver CityBus LEP Plan
The following training information will be distributed to Culver CityBus staff:
• Information on the Title VI Policy and LEP responsibilities. • Description of language assistance services offered to the public. • Use of the Language Identification Flashcards.
• Information on how to document language assistance requests. • How to handle a potential Title VI/LEP complaint.
• Bus operator training incorporating FTA’s Title VI training video. • Information on how City personnel may qualify to become a paid language assistance translator.
Members of the public will be able to access the Title VI Update report and LEP Plan from the City of Culver City website where both documents will be available in a downloadable .PDF format. Copies may also be obtained upon request via telephone, fax, mail, or in person, and shall be provided at no cost. LEP individuals may request copies of the plan in translation which Culver CityBus will provide, if feasible.
Questions or comments regarding the LEP Plan may be submitted to:
Title VI Coordinator
City of Culver City Transportation
4343 Duquesne Avenue
Culver City, CA 90232
(310) 253‐6500.
Monitoring and Updating the LEP Plan
Culver CityBus will continue to monitor , assess and update the LEP Plan as required by the FTA. The next update of this plan will be completed by April 1 2023.