CITY OF MANTECA
MANTECA TRANSIT
2024 Title VI Program
(Fiscal Years 2024/25 to 2026/27)
Draft Report
April 2024
Adopted by the Manteca City Council
June 2024
Prepared by
Moore & Associates, Inc.
25852 McBean Pkwy, Suite 187
Valencia, CA 91355
888.743.5977
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Manteca Transit operates fixed route and Dial-a-Ride bus service throughout Manteca with stops at key locations throughout the city.
This document was prepared by Moore & Associates, Inc., on behalf of the City of Manteca. It has been adopted by the City of Manteca City Council to comply with Title VI of the Civil Rights Act of 1964, including recent provisions detailed in U.S. Department of Transportation’s FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients.” ATTACHMENT 2
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TABLE OF CONTENTS
Section 1 | Introduction ..........................................................................................................................5 The City of Manteca: Manteca Transit Policy Statement ......................................................................5 Environmental Justice Requirements...................................................................................................5 Section 2 | Title VI Notice to the Public and Locations Where Displayed..................................................7 Title VI Notice to the Public .................................................................................................................8 Section 3 | Title VI Complaint Procedures and Forms............................................................................. 11 Title VI Complaint Procedure and Form ............................................................................................. 11 Internal Complaint Procedures.......................................................................................................... 20 Section 4 | List of Transit-Related Title VI Investigations, Complaints, and Lawsuits............................... 22 Section 5 | Public Participation Plan ...................................................................................................... 23 Introduction ...................................................................................................................................... 23 Goals and Objectives ......................................................................................................................... 23 Stakeholders and Public Groups......................................................................................................... 24 Information Access............................................................................................................................ 25 Outreach Techniques......................................................................................................................... 25 Action Items for Use of Public Participation Plan................................................................................ 25 Public Meetings................................................................................................................................. 26 General Awareness Surveys............................................................................................................... 26 Bilingual Outreach ............................................................................................................................. 26 Input Mechanisms............................................................................................................................. 27 Schedule............................................................................................................................................ 27 Evaluation ......................................................................................................................................... 28 Section 6 | Summary of Outreach Efforts .............................................................................................. 29 Section 7 | Language Assistance Plan and Four-Factor Analysis ............................................................. 30 Purpose of the Language Assistance Plan........................................................................................... 30 Language Assistance Plan Goals......................................................................................................... 30 Four-Factor Analysis.......................................................................................................................... 31 Language Assistance Plan .................................................................................................................. 39 Implementation Plan ......................................................................................................................... 42 Section 8 | Minority Representation on Planning and Advisory Bodies .................................................. 43 ATTACHMENT 2
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Section 9 | Subrecipient Monitoring and Schedule of Subrecipient Title VI Program Submissions.......... 44 Section 10 | Title VI Equity Analysis....................................................................................................... 45 Section 11 | System-wide Standards and Policies .................................................................................. 46 Vehicle Load...................................................................................................................................... 46 Vehicle Headway ............................................................................................................................... 46 On-time Performance........................................................................................................................ 47 Service Availability............................................................................................................................. 47 Distribution of Transit Amenities....................................................................................................... 47 Vehicle Assignment ........................................................................................................................... 48 Section 12 | City Council Approval of Title VI Program Update............................................................... 49 Section 13 | Appendix ........................................................................................................................... 50 ATTACHMENT 2
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Section 1 | Introduction
The City of Manteca: Manteca Transit Policy Statement
The City of Manteca is committed to ensuring that no person is excluded from participation in or denied the benefits of its services on the basis of race, color, or national origin, as provided by Title VI of the Civil Rights Act of 1964, as amended.
The purpose of this Title VI Program is to establish guidelines to effectively monitor and ensure that the City’s transit services, commonly known to the public as Manteca Transit, are in compliance with FTA Title VI requirements.
Title VI states 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 FTA is required to ensure federally supported transit services and related benefits are provided consistent with Title VI. The Title VI Report requires an update every three years.
The City (Manteca Transit) will ensure that its programs, policies, and activities comply with Department of Transportation’s (DOT) Title VI Regulations (49 CFR Part 21) and with Limited English Proficient (LEP) Persons requirements (70 FR 74087, December 14, 2005). The City is committed to creating and maintaining a public transportation system that is free of all forms of discrimination. The City will take necessary preventive corrective and disciplinary actions to stem behavior that violates this policy or the rights and privileges it is designed to protect. FTA requires recipients to documents compliance with DOT Title VI regulations by submitting a Title VI Program once every three years.
Environmental Justice Requirements
City of Manteca shall integrate an environmental justice analysis into its National Environmental Protection Act (NEPA) documentation of construction projects. For projects where NEPA documentation is not required, the City of Manteca will prepare an environmental assessment (EA) or environmental impact statement (EIS) assessing potential disparate impact and disproportionate burden when performing construction projects. The EA or EIS will integrate into its documents the following components:
• A description of the low-income and minority population within the study area affected by the project, and a discussion of the method used to identify this population (e.g., analysis of Census data, direct observation, or a public involvement process); • A discussion of all adverse effects of the project both during and after construction that would affect the identified minority and low-income populations; • A discussion of all positive effects of the project that would affect the identified minority and lowincome populations, such as improvements in transit service, mobility, or accessibility; • A description of all mitigation and environmental enhancement actions incorporated into the project to address the adverse effects, including, but not limited to, any special features of the ATTACHMENT 2
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relocation program that go beyond the requirements of the Uniform Relocation Act and address adverse community effects such as separation or cohesion issues; and the replacement of the community resources destroyed by the project;
• A discussion of the remaining effects, if any, and why further mitigation is not proposed; and • For projects that traverse predominantly minority and low-income and predominantly nonminority and non-low-income areas, a comparison of mitigation and environmental enhancement actions that affect predominantly low-income and minority areas with mitigation implemented in predominantly non-minority or non-low-income areas.
In addition, the State of California, through the California Environmental Quality Act (CEQA), requires state and local agencies to identify the significant environmental impacts of their actions and to avoid or mitigate those impacts, if feasible. When NEPA documents are prepared, the City will also comply with CEQA regulations.
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Section 2 | Title VI Notice to the Public and Locations Where Displayed The City of Manteca’s Title VI Notice to the Public is currently posted at the locations listed in Exhibit 2.1.
Exhibit 2.1 List of Locations Where Title VI Notice Is Posted Location Address
Manteca Transit buses ----
Manteca Transit Center 220 Moffat Boulevard, Manteca
Manteca Transit Rider’s Guide ----
City of Manteca Website www.mantecatransit.com
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Title VI Notice to the Public
Exhibit 2.2 Title VI Notice to the Public
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Exhibit 2.3 Title VI Notice to the Public (Online)
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Exhibit 2.4 Title VI Complaint Forms (Online)
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Section 3 | Title VI Complaint Procedures and Forms
Title VI Complaint Procedure and Form
The City of Manteca details its complaint procedures and provides Civil Rights Complaint forms in both English and Spanish. These documents are provided in Exhibits 3.1 through 3.4.
The Manteca Transit Title VI Complaint Form and program information are provided on the City of Manteca’s transit website at:
https://www.manteca.gov/departments/development-services/manteca-transit/ manteca-transit-title-vi-program
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Exhibit 3.1 Title VI Complaint Procedures (English)
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Exhibit 3.2 Title VI Complaint Form (English)
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Exhibit 3.3 Title VI Complaint Procedures (Spanish)
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Exhibit 3.4 Title VI Complaint Form (Spanish)
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Internal Complaint Procedures
When a civil rights complaint (including a Title VI complaint) is received by the City of Manteca, it is processed in the following manner.
Verification
Civil rights complaints should be filed as soon as possible, but must be received no more than 180 days after the alleged incident. The City will only process complaints that are complete and signed by the complainant or their representative.
Follow-Up
In instances where additional information is needed for assessment or investigation of the complaint, the City will contact the complainant in writing within fifteen (15) working days of receipt of the complaint.
Failure of the complainant to provide the requested information within thirty (30) business days may result in the administrative closure of the complaint. A case can also be administratively closed if the complainant no longer wishes to pursue their case.
Review
Once all information regarding the complaint is received, it will be referred to the City of Manteca Director of Human Resources and Risk Management for review to determine if the City has jurisdiction. The City will respond within ten (10) working days with an acknowledgement letter informing the complainant whether their complaint will be investigated by the City’s Director of Human Resources and Risk Management.
Investigation
If the complaint will be investigated by the City’s Risk Management and Human Resource Director, such investigation must be completed within ninety (90) calendar days of receipt of the complaint.
Decision
The Director of Human Resources and Risk Management will notify the complainant in writing of the final decision reached, including the disposition of the matter. One of two letters will be issued to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed. An LOF summarizes the allegations and the interviews regarding the alleged incident and explains whether any disciplinary action, additional training of the staff person, or other action will occur.
Appeal
The complainant will also be advised of their right to appeal the decision to federal and state authorities as appropriate. If the complainant wishes to appeal the City’s decision, they have ten (10) days after the date of the letter or the LOF to do so. The City’s Transit Manager will also provide a copy of the City’s decision and summary of findings to the Federal Transit Administration upon completion of the investigation.
Note: If a Title VI complaint is filed simultaneously with an external entity, any other Federal or State agencies or courts, the external complaint will supersede the City’s complaint and the City’s complaint procedures will be suspended pending the external entity’s findings.
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Exhibit 3.5 Internal Complaint Procedure
Verification
Has the complaint
been filed within
180 days of the
alleged incident?
Is the complaint
complete and
signed?
Has all information
needed to
investigate the
complaint been
provided?
Follow
-Up
If additional
information is
needed, the City
will contact the
complainant within
15 working days.
The complainant
has 30 business
days to provide the
requested
information.
Failure by the
complainant to
provide additional
requested
information may
result in
administrative
closure of the
complaint.
Review
The complaint will
be reviewed by the
City's Director of
Human Resources
and Risk
Management to
determine if it has
jurisdiction.
The City will
respond with an
acknowledgement
letter within 10
working days
informing the
complainant
whether the
complaint will be
investigated by the
Director of Human
Resources and Risk
Management.
Investigation
Investigation by
the City's
Director of
Human
Resources and
Risk
Management
will be
completed
within 90
calendar days
from its receipt
of the complaint.
Decision
Upon completion
of the
investigation, the
Director of Human
Resources and Risk
Management will
issue a closure
letter (which closes
the case without a
finding of a Title VI
violation) or a
letter of finding
(which addresses
the Title VI
violation, including
disciplinary actions
taken or
retraining).
Appeal
Following receipt of
the Closure Letter
or Letter of Finding,
the complainant
has the right to
appeal the decision
within 10 days.
The City's Transit
Supervisor will
provide a copy of
the City's decision
and summary of
findings to the
Federal Transit
Administration.
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Section 4 | List of Transit-Related Title VI Investigations, Complaints, and Lawsuits
As a recipient of Federal funds, the City of Manteca is required to prepare and maintain a list of investigations, complaints, or lawsuits that pertain to allegations of discrimination on the basis of race, color, and/or national origin in transit-related activities and programs and that pertain to the entity submitting the report, not necessarily the larger agency or department of which the entity is a part. In accordance with FTA Title VI Regulations, this list must include details regarding:
• Active investigations conducted by FTA and entities other than FTA; • Lawsuits; and
• Complaints naming the City of Manteca.
The City of Manteca has not been involved in any transit-related Title VI investigations, complaints or lawsuits during the period covered by the prior Title VI Program (FY 2022 – FY 2024). The City’s Transit Manager will continue to maintain a list of any Title VI investigations, complaints, and lawsuits and include a summary and description of actions taken by the City, as required by the Title VI regulations. The list will include the date that the investigation, lawsuit, or complaint was filed; a summary of the allegations(s); the status of the investigation; lawsuit, or complaint; and actions taken in response, or final findings related to the investigation, lawsuit, or complaint. The list (shown in Exhibit 4.1) will be included in the City’s Title VI submittal every three years.
Exhibit 4.1 Title VI Investigations, Lawsuits, and Complaints Summary Table Record of Title VI Complaints, Investigations and Lawsuits Date Summary Status Actions Taken
Investigations
1. None
2. 3.
Lawsuits
1. None
2. 3.
Complaints
1. None
2. 3.
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Section 5 | Public Participation Plan
Introduction
Located in California's Central Valley, Manteca is an attractive city of 83,897 residents (American Community Survey 2022 Five-Year Estimates) in a productive area of San Joaquin County. The city, which comprises 20.57 square miles, is surrounded on all sides by scenic agricultural land and open spaces.
Manteca boasts a low crime rate, an award-winning school district, quality residential homes, and a quaint downtown; and continues to foster its goal of maintaining a vibrant and diversified community. The City's mission statement is exemplified through its aggressive policies adopted to preserve a family atmosphere and high quality of life.
Manteca is geographically located on State Route 120 between the San Francisco Bay Area and the historic Mother Lode leading to Yosemite National Park. It is 25 minutes from Stockton and Modesto; Manteca offers a central location with direct access to all modes of transportation. As part of the transportation planning process, citizen input on the work, projects, and products proposed and created by the City is desired and requested.
Manteca Transit is operated under contract with MTM Transit. The present servicesinclude a local dial-aride service within the City limits and four fixed routes that operate within city limits. The Dial-A-Ride service and four fixed routes operate Monday through Friday; and three fixed routes and Dial-A-Ride service operate on Saturdays. The City also operates a peak-hour shuttle between the Manteca Transit Center and the Lathrop/Manteca ACE Station.
The City recognizes the importance and necessity of the public participation process. The Manteca City Council sets the overall policy for the transit system. There are five City Council members. The Council meets on the first and third Tuesday of each month at 6:00 p.m. at Manteca City Hall (1001 W. Center Street, Manteca).
All meetings of the Manteca City Council are open to the public. Members of the public may request time on the agenda of the Manteca City Council to comment on specific subjects of interest to the councilmembers. A minimum of three weeks advance notice should be given for requested agenda time.
Additional subcommittees and working groups may be appointed at any time by the Mayor to address specific transportation-related topics or areas of interest to the City.
Goals and Objectives
The public participation process required by 23 CFR 450 should “provide complete information, timely public notice, full public access to key decisions, and support early and continuing participation of the public in developing plans and Transportation Improvement Programs.…” The City is committed to the availability of timely, complete information; to the notification of and public accessto the decision-making process; and to ongoing public participation throughout the transportation planning process including, but not limited to, the development of a Short Range Transit Plan; the Transportation Improvement Program; review of transit services, fares, and operating parameters; ATTACHMENT 2
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Federal Transit Administration civil rights issues such as Title VI, Disadvantaged Business Enterprise (DBE), Equal Opportunity Program (EEO), and Americans With Disabilities Act (ADA); Unmet Transit Needs process; and the Public Participation process. Through this Public Participation Process, the City aims to identify methods for obtaining public input for and encouraging public participation in the transportation planning process.
The City’s Public Participation Plan is based on the following principles:
• Flexibility. The engagement process will accommodate participation in a variety of ways and be adjusted as needed.
• Inclusiveness. The City will proactively reach out to and engage low-income, minority, and Limited English Proficient (LEP) populations.
• Respect. All feedback will be given careful and respectful consideration. • Proactive and Timeliness. Participation methods will allow for early involvement and be ongoing.
• Clear, Focused, and Understandable. Participation methods will have a clear purpose and use for the input and will be described in language that is easy to understand. • Honest and Transparent. Information provided will be accurate, trustworthy, and complete. • Responsiveness. The City will respond and incorporate appropriate public comments into transportation decisions.
• Accessibility. Meetings will be held in locations which are fully accessible and welcoming to all area residents, including, but not limited to, low-income and minority members of the public and in locations relevant to the topics being presented and discussed.
Stakeholders and Public Groups
The City has identified the following groups and individuals as those having potential interest in public input and participation opportunities:
• Neighborhood organizations;
• Homeowner associations;
• Chamber of Commerce and other business groups;
• Groups representing travel modes (transit, bicycle, pedestrian, freight); • Advocacy groups for disadvantaged and/or minority groups; • Media (print, television, radio);
• Governmental agencies;
• Educational Institutions (school districts, community colleges, private schools, State universities;
• Organizations or individuals who have been notified of public hearings for major projects, or organizations and individuals who have submitted written comments relating to public hearings for major projects, service changes and plans(these individuals and organizations would remain on the mailing list as long as the major project is under development).
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Information Access
All planning and programming information for the City's transit system (Manteca Transit) is available for public review. The information can be viewed at the Manteca Transit Center, 220 Moffat Boulevard, Manteca, CA 95336. Additional information is posted online at www.mantecatransit.com.
Outreach Techniques
Information about all City meetings is added to the existing Public Meeting Calendar that is produced weekly and distributed to local newspapers (Manteca Bulletin, Modesto Bee, The Record) as well as local radio stations in Modesto and Manteca and placed on the City's website. In addition, the agenda for the meetings is posted at Manteca City Hall, in the Manteca Transit Center, and on the City’s website, www.ci.manteca.ca.us, a minimum of seventy-two hours prior to the meetings.
Meeting information, when needed, is included on the website and City social media sites. Regular meetings, as well as special activities related to transit planning, Title VI, and project development are included. Press releases to area newspapers, television stations, and radio stations are used to notify citizens of upcoming activities of the City.
The City maintains an active participation in the local government access cable channel. Programs describing the activities of the City are included in the programming.
The City's transit website, www.mantecatransit.com, is used to provide information about transportationrelated activities including information about the development of the Short-Range Transit Plan, the Transportation Improvement Program, TDA Article 8 “Unmet Transit Needs” hearings, and Federal Transit Administration civil rights documents such as Title VI and others. The City’s representatives are listed along with contact information.
Formal notices for public input meetings are published in the Manteca Bulletin.
The City posts transit schedules and rider information on its website in English and Spanish. The City also provides easy access to bilingual (English and Spanish) administrative staff and bus operators during operating hours to answer questions for Manteca Transit LEP customers. MTM Transit also provides access to Language Line telephonic interpretation for customer service calls.
Action Items for Use of Public Participation Plan
The City will use its public participation plan when considering fare changes, modifications to routes and schedules, and other transit planning projects when:
• A fare increase or significant change in the method of fare payment is being considered; • A new route is established;
• An existing route is proposed for elimination;
• Considering the total discontinuance of service on any line or group of lines on any given day when service is currently offered;
• Any system-wide change in service hours that exceeds (plus or minus) 10 percent of current total service hours;
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• Recommending changes to routing on any given route that affects more than 25 percent of the riders using the affected route;
• Schedules are changed on any given route that reduce the total number of one-way bus trips by more than 25 percent of the current number of bus trips; and • Developing the FTA Program of Projects in conjunction with the San Joaquin Council of Governments (SJCOG) for projects that benefit the Manteca Urbanized Area, including City projects.
For minor schedule and service changes, the City will post service change notices 30 days in advance on the City’s website, on buses, at bus stops, and at the Manteca Transit Center.
Public Meetings
The City reaches out to the community directly through meetings with agency and community staff and their clients, as needed. Information regarding the City’s transit services is disseminated at these meetings. Information is also made available at various locations throughout the community, including Manteca City Hall, Manteca Library, Community Centers, Manteca Transit Center, on buses, and on the City’s website at www.mantecatransit.com.
The City Transit Manager participates in monthly meetings with the San Joaquin Council of Governments (SJCOG) Interagency Transit Committee (ITC), Social Services TransportationAdvisory Committee (SSTAC), andTechnicalAdvisoryCommitteetodiscusstransit planning activities and coordination. The City Manager participates in the Transit Ad hoc Committee as part of the SJCOG Management and Finance Committee.
When transit issues are discussed, the City schedules transit workshops to invite the public to provide feedbackontransit-relatedissuesandalsousestheCity Council,which setsthe policy forthe transitsystem, as an opportunity to gather public feedback before acting on a decision.
The City Transit Manager also participatesin the development of the SJCOG’s Public Involvement Plan and the San Joaquin County Coordinated Public Transit and Human Services Transportation Plan. The plan was last updated by San Joaquin Regional Transit District (RTD) in 2021. When the plan was developed, meetings were conducted countywide with participantsfrom throughout the county. Recommendations to maximize community involvement are reflected in these plans and adopted by the RTD.
General Awareness Surveys
The City from time to time conducts on-board rider and general awareness surveys in conjunction with various service planning-related projects. These one-on-one and online surveys allow customers to convey any concerns or comments they have regarding Manteca Transit services. The most recent fixedroute customer survey was conducted in March 2024 in conjunction with this Title VI Program update.
Bilingual Outreach
Manteca Transit provides Spanish-speaking customerswith bilingual information onpublic transit services.
Staff assistance is utilized in outreach programs and offered for programs andpublicmeetings. Inaddition, if any transit-related information is needed in an alternative language, customers can contact the City’s Transit Manager or call the transit customer line (which has access to a telephonic interpretation service).
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Input Mechanisms
The City accepts input and comments from the public through a variety of channels:
a. Online through the City's website at www.mantecatransit.com. b. By mail to 220 Moffat Boulevard, Manteca, CA 95336.
c. By emailing [email protected].
d. By faxing a request or letter to 209.923.8998.
Comment forms can be directly downloaded from the Manteca Transit website at https://www.manteca.gov/home/showpublisheddocument/152/637907946938800000 or obtained by calling 209.456.8775 to have one mailed, emailing a request to [email protected], or faxing a request to 209.923.8998.
The public may also submit comments to individual Manteca City Council members or directly to the City Council itself. In addition, comments on the City's transit services, plans, reports, and programs may be made at public input meetings. The City ensures all public input meeting locations are accessible in accordance with the Americans with Disabilities Act (ADA).
Members of the public, or a representative of a group, with expressed comments on a particular topic may make a request to the Mayor an appointment to serve as a citizen representative on an appropriate subcommittee, if one is activated.
Interested members of the public are able to offerinputto the committees during a public forum element of each agenda.
The City does consider and respond to all public input received during planning and program development processes. If significant written or oral comments are receivedontransitservices, FTAcivilrights programs, or plans, a summary, analysis, and report on the disposition of the comments is made a part of the conclusion of the public participation process.
Schedule
Notification and announcement of all upcoming public meetings are made approximately 30 days in advance of the scheduled meeting through the methods described in the Outreach Techniques section of this plan. Legal notice of a scheduled public input meeting is published in the Manteca Bulletin approximately seven to ten days prior to the meeting.
Public meetings may be scheduled regularly or may occur on an as-needed basis depending upon the specific subject matter such as the development of the Short-Range Transit Plan; the Transportation Improvement Program; review of transit services, fares, and operating parameters; Unmet Transit Needs Hearings; and Federal Transit Administration civil rights issues such as Title VI, Disadvantaged Business Enterprise, Equal Opportunity Program and the Americans With Disabilities Act (ADA). Other public input meetings are held throughout the year, as necessary.
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Updates and revisions to the City's Public Participation Plan require a 10-day public comment period. The City Council will approve this plan following the completion of the public comment period, if revisions are needed after the initial adoption of the plan.
Evaluation
The City will review this Public Participation Plan periodically in order to monitor the effectiveness of the procedures outlined in this document. Following evaluation of the outputs and outcomes of the Public Participation Plan, the City may revise these methods to incorporate new and innovative ways to involve the public in the transportation decision-making process.
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Section 6 | Summary of Outreach Efforts
A summary of outreach activities taking place during FY 2022 – FY 2024 is provided in Exhibit 6.1. It should be noted that this time period was in the wake of the COVID-19 pandemic, which impacted many inperson outreach activities.
Exhibit 6.1 Outreach Activities, FY 2022 – FY 2024
Event Name Information
Manteca Pumpkin Fair Community event held the first full weekend in October Manteca Watermelon Street Faire Community event held in June Stuff the Bus Annual transit event held in November
Eskaton Manteca Manor Event for seniors
Wide Horizons Event for individuals with autism and neurodiverse abilities Manteca High School Event for youth
In addition to the outreach activities listed above, the City also conducted social media marketing and advertising (Facebook and Instagram), posted information on the transit website, created displays at the transit center, conducted outreach to schools, and posted notices and information onboard transit vehicles.
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Section 7 | Language Assistance Plan and Four-Factor Analysis Purpose of the Language Assistance Plan
This Limited English Proficiency (LEP) Plan has been prepared to address the City’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The Plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, Federal Transit Administration Circular 4702.1A dated May 13, 2007, which state that no person shall be subjected to discrimination on the basis of race, color, or national origin.
Executive Order 13166, titled Improving Access to Services for Persons with Limited English Proficiency, indicates that differing treatment based upon a person’s inability to speak, read, write, or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure thatsuch discrimination does nottake place. This order applies to all State and local agencies which receive federal funds, including City departments receiving federal grant funds.
Service Overview
The City administers Manteca Transit services under a contract with MTM Transit for fixed-route and demand-response services. The Manteca City Council is the policy-making body for the transit system.
Manteca Transit services consist of four fixed routes, the ACE Shuttle, and the demand-response (Dial-ARide) service. Manteca Transit operates generally Monday through Friday from 6:00 a.m. to 7:00 p.m. and Saturday from 9:00 a.m. to 4:00 p.m.
The City has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access services provided by Manteca Transit. As defined by Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write, or understand English.
Language Assistance Plan Goals
One of the overarching goals of the City of Manteca’s Title VI Program is to ensure meaningful access for LEP customers to transit services, information, and materials through the development of a Language Assistance Plan and by regular evaluation of the developed methods and strategies.
This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, and how to notify LEP persons that assistance is available. The first step toward this is the development of a Four-Factor Analysis as outlined by the U.S. Department of Transportation (USDOT). The Four-Factor Analysis includes:
1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter Manteca Transit activities or services.
2. The frequency with which LEP persons come in contact with Manteca Transit activities or services.
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3. The nature and importance of programs, activities, or services provided by the Manteca Transit to the LEP population.
4. The resources available to Manteca Transit customers and overall cost to provide LEP assistance.
Following the Four-Factor Analysis, the Language Assistance Plan (LAP) includes methodologies for identifying LEP individuals, providing services, establishing policies, and monitoring the LAP, as well as an implementation plan.
Four-Factor Analysis
Factor 1: The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient.
Estimating the number or proportion of LEP individuals that may be encountered by Manteca Transit will help identify the populations covered by the USDOT’s Safe Harbor Provision. This provision stipulates that if an LEP group speaking a non-English language constitutes five percent or 1,000 persons, whichever is less, of the total population of persons likely to be encountered by transit services, then the service provider must make the following materials and services available to speakers of that language:
• Documents critical for accessing recipient’s services or benefits, • Letters requiring response from customer,
• Materials informing customers of free language assistance, • Complaint forms, and
• Notification of rights.
Service Area Demographics
The service area demographic analysis describes potential Title VI-protected populations residing within Manteca Transit’s service area, including their approximate size and geographic distribution. Title VIprotected populations within the service area include LEP persons. Specific groups considered include:
1. Potential LEP Language Groups
• Spanish
• Tagalog
• Other Indo-European languages
The American Community Survey (ACS) provides information at various levels on multiple topics. For the purposes of this Title VI program, our assessment utilized the population estimates provided in the City of Manteca geographic boundaries.
An analysis of the racial composition of Manteca reveals slightly more than half of residents self-identify as White (50.8 percent), while 40 percent identify as Hispanic or Latino. Persons identifying as two or more races comprise 17.8 percent of residents, while 14.4 percent identify as Asian. This is a slightly higher White population than San Joaquin County and the state as a whole. The percentage of Hispanic/Latino residents of Manteca is slightly lower than that of San Joaquin County and nearly equal to that of California.
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Exhibit 7.1 Racial Breakdown of Total Population of Service Area The American Community Survey (ACS) data details the language spoken at home for persons five years of age and older. ACS 2022 five-year estimates (the most recent data available at this level of detail) revealed 67.2 percent of Manteca residents spoke only English at home, while 19.7 percent spoke Spanish, making it the most commonly spoken language other than English found within the service area. The next most cited language spoken at home was “Other Indo-European languages” 1 with 6.0 percent, followed
by Tagalog with 2.8 percent.
While nearly one-third of Manteca residents speak another language at home, many of them speak English “very well.” In fact, 20.6 percent of Manteca residents age five and older, and 62.8 of those who speak a language other than English at home, fall within this category. Given the large population of Spanish speakers, it is not surprising to find Spanish speakers who speak English less than “very well” comprise 6.8 percent of the total population. By contrast, “Other Indo-European language” speakers who speak English less than “very well” comprise just 2.4 percent of the total population, while LEP Tagalog speakers comprise 1.3 percent of the total.
Based on data provided for English Learners in Manteca (discussed below), the most likely “Other IndoEuropean languages” spoken in Manteca include Punjabi and Persian/Farsi.
When compared to both San Joaquin County and the state of California, Manteca features a larger percentage of residents who speak only English and a lower incidence of LEP individuals (12.2 percent of Manteca residents compared to 17.1 percent each of San Joaquin County and California residents). The population of LEP Spanish-speakers in Manteca (6.8 percent) is significantly lower than that of San Joaquin County (10.7 percent) and California (10.8 percent).
1 Per the U.S. Census Bureau, the “Other Indo-European languages” category in the American Community Survey includes languages such as Italian, Portuguese, Greek, Serbo-Croatian, Armenian, Persian (including Farsi, Dari), Gujarati, Hindi, Urdu, Punjabi, Bengali, Nepali, Marathi, Konkani, other Indic languages, Albanian, Lithuanian, Pashto, Romanian, Swedish, Telugu, Tamil, Malayalam, Kannada, and other Dravidian languages. The distribution of individual languages within the language group is not provided.
Estimate
Percent of
Total Estimate
Percent of
Total Estimate
Percent of
Total
Race
Total 83,897 100.0% 779,445 100.0% 39,356,104 100.0%
White alone 42,635 50.8% 328,081 42.1% 18,943,660 48.1% Black or African American alone 2,816 3.4% 54,792 7.0% 2,202,587 5.6% American Indian or Alaska Native alone 744 0.9% 7,932 1.0% 394,188 1.0% Asian alone 12,115 14.4% 133,870 17.2% 5,949,136 15.1%
Native Hawaiian or Pacific Islander alone 1,322 1.6% 4,778 0.6% 150,531 0.4% Some other race alone 9,306 11.1% 106,602 13.7% 6,388,999 16.2% Two or more races 14,959 17.8% 143,390 18.4% 5,327,003 13.5% Ethnicity
Hispanic or Latino (of any race) 33,522 40.0% 331,382 42.5% 15,617,930 39.7% Manteca San Joaquin County California
Source: American Community Survey 2022 5-Year Estimates.
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Exhibit 7.2 Languages Spoken at Home By Community
Based on the Safe Harbor provision cited above, Spanish and Tagalog both fall into the category of “1,000 individuals or five percent of the population, whichever is less.” While the City is not required to provide these materials in other languages based on the Safe Harbor provision, it may elect to do so depending on how frequently LEP speakers of other languages come into contact with the transit program. This is assessed under Factor 2.
City of Manteca English Learner Data
In addition to census data collected via the American Community Survey (ACS), the City also reviewed English Learner (EL) statistics for students within the Manteca Unified School District. Public schools within the California Department of Education (CDE) must report on their students who are English Learners – students whose native tongue is a language other than English – as well as which language is their mother tongue each year, which provides more current data than the ACS. This data is available online via CDE’s DataQuest website, dq.cde.ca.gov/dataquest/.
The City accessed the available EL data for the 2022/23 school year to complete its comprehensive assessment of the populations it provides service to, including what LEP populations exists and where these groups may be concentrated. Periodically reviewing this data will enable the City to monitor which nonEnglish languages are growing in order to provide appropriate language assistance services.
The highest concentration of EL students within Manteca speak Spanish, followed distantly by Punjabi and Filipino/Tagalog. Given Punjabi is included within the U.S. Census Bureau category of “Other Indo-European languages,” this is consistent with the ACS, where Spanish, “Other Indo-European languages,” and Tagalog are the top three responses. This helps to confirm the older data contained within the ACS is still accurate.
Detailed counts and relative percentages are presented in Exhibit 7.3.
Estimate
Percent
of Total Estimate
Percent
of Total Estimate
Percent
of Total
Total Population (age 5 and up) 78,178 100.0% 727,476 100.0% 37,097,796 100.0% Total Speak only English 52,522 67.2% 426,402 58.6% 20,809,671 56.1% Total Speak language other than English 25,656 32.8% 301,074 41.4% 16,288,125 43.9% Total Speak English "very well" 16,125 20.6% 176,351 24.2% 9,929,983 26.8% Total Speak English less than "very well" 9,531 12.2% 124,723 17.1% 6,358,142 17.1% Spanish 5,333 6.8% 77,765 10.7% 4,017,360 10.8%
Russian, Polish, or other Slavic lang. 8 0.0% 419 0.1% 99,385 0.3% Other Indo-European languages 1,869 2.4% 16,323 2.2% 377,204 1.0% Korean 7 0.0% 380 0.1% 195,175 0.5%
Chinese (incl. Mandarin & Cantonese) 293 0.4% 4,701 0.6% 669,536 1.8% Vietnamese 55 0.1% 4,094 0.6% 330,882 0.9%
Tagalog (incl. Filipino) 1,020 1.3% 8,530 1.2% 248,922 0.7% Other Asian & Pacific Island lang. 842 1.1% 10,524 1.4% 257,526 0.7% Arabic 77 0.1% 1,074 0.1% 71,666 0.2%
Other & unspecified languages 27 0.03% 778 0.11% 60,655 0.2% San Joaquin County California
Speak English less than "very well" - breakdown
Source: American Community Survey 2022 5-Year Estimates.
Manteca
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Exhibit 7.3 School English Learner (EL) Population
Language K 1 2 3 4 5 6 7 8 9 10 11 12 Total Percent of
Total
Spanish 400 387 330 317 373 352 321 295 278 305 273 263 230 4,124 75.8% Punjabi 120 107 74 67 56 50 36 30 17 20 26 23 12 638 11.7% Filipino (Pilipino or
Tagalog) 7 6 8 9 10 10 9 4 7 12 8 11 11 112 2.1%
Arabic 8 10 3 3 9 6 7 6 3 3 4 4 8 74 1.4%
Farsi (Persian) 12 10 6 5 9 5 5 2 3 5 6 2 3 73 1.3%
Hindi 7 11 5 4 8 6 9 6 1 2 0 2 3 64 1.2%
Other non-English
languages 9 5 11 8 8 6 1 4 4 0 2 3 1 62 1.1%
Vietnamese 6 7 9 4 7 2 5 3 8 2 4 2 3 62 1.1%
Pashto 3 3 4 3 1 4 1 4 2 2 0 4 0 31 0.6%
Hmong 0 3 1 5 3 3 1 3 2 6 2 1 1 31 0.6%
Khmer
(Cambodian) 2 3 2 5 4 1 1 1 3 1 1 4 2 30 0.6%
Telugu 7 5 3 1 3 4 2 0 0 0 0 0 0 25 0.5%
Urdu 5 2 1 1 3 0 2 0 1 0 1 1 1 18 0.3%
Ilocano 2 1 0 2 1 0 4 2 1 1 1 1 1 17 0.3%
Portuguese 1 2 1 2 0 0 0 1 0 0 1 1 2 11 0.2%
Mandarin
(Putonghua) 1 3 0 1 0 0 0 0 0 0 1 1 2 9 0.2%
Tamil 3 0 1 1 0 1 1 0 1 0 1 0 0 9 0.2%
Lao 0 0 0 0 1 0 1 0 0 1 1 1 1 6 0.1%
Cantonese 0 0 0 0 2 1 2 0 0 0 0 0 0 5 0.1%
Tongan 0 0 1 0 0 0 0 0 0 0 2 1 0 4 0.1%
Korean 0 2 0 1 0 0 0 0 0 0 0 0 0 3 0.1%
French 0 1 0 0 0 1 0 1 0 0 0 0 0 3 0.1%
Gujarati 0 0 0 0 1 0 0 0 0 1 0 0 0 2 0.0%
Indonesian 0 1 0 1 0 0 0 0 0 0 0 0 0 2 0.0%
Japanese 1 0 0 1 0 0 0 0 0 0 0 0 0 2 0.0%
Kannada 0 1 1 0 0 0 0 0 0 0 0 0 0 2 0.0%
Bengali 1 0 1 0 0 0 0 0 0 0 0 0 0 2 0.0%
Burmese 0 1 0 0 0 1 0 0 0 0 0 0 0 2 0.0%
Kurdish (Kurdi,
Kurmanji) 1 0 0 0 0 0 0 0 1 0 0 0 0 2 0.0%
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Language K 1 2 3 4 5 6 7 8 9 10 11 12 Total Percent of
Total
Russian 0 0 1 0 0 1 0 0 0 0 0 0 0 2 0.0%
Samoan 1 0 0 0 0 1 0 0 0 0 0 0 0 2 0.0%
Tigrinya 0 1 0 0 0 0 0 0 0 1 0 0 0 2 0.0%
Toishanese 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0.0%
Turkish 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0.0%
Thai 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0.0%
Marathi 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0.0%
Assyrian 0 0 0 0 0 0 0 1 0 0 0 0 0 1 0.0%
Cebuano (Visayan) 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0.0%
Amharic 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0.0%
Khmu 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0.0%
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Factor 2: The frequency with which LEP persons come into contact with the program.
In order to estimate how often LEP populations come into contact with the City’s transit services, surveys were conducted of both riders and City staff.
Customer Survey
A survey of Manteca Transit customers was conducted in March and April 2024 as part of this Title VI update. Fixed-route surveys were collected via driver distribution, intercept, and online methodologies.
Three valid responses were received. Consequently, the results cited herein are anecdotal rather than representative. The survey was provided in both English and Spanish.
Two of the three valid responses utilized the Spanish survey instrument. Three additional surveys were invalidated given they were largely blank. Survey findings are shown below. • Two respondents indicated paying the regular one-way fare, while one used a regular monthly pass.
• One respondent indicated use of the Vamos Mobility mobile app. • The three respondents use Manteca Transit to travel to work, shopping, or for social or recreational purposes.
• Two respondents indicated a primary language of Spanish, the third Tagalog/Filipino. • Two respondent indicated having limited English proficiency (both Spanish-speakers). • Two respondents indicated their race as white, the other as “Mexican/Latino.” • Two respondents identified as Hispanic/Latino.
• The three respondents were in three different age ranges: 19-24, 25-44, and 45-64. • Two respondents indicated a household income, which was $25,000 to $29,999 and $50,000 to $74,999.
• One respondent indicated living in a two-person household, and the other two indicated living in a three-person household.
A copy of the customer survey instrument is provided in the Appendix.
Staff Survey
City staff and drivers were also surveyed regarding their customer interactions. As drivers and customer service staff are typically on the “front lines” and most frequently come into contact with transit patrons, their observations and insights provide an informative picture of how many LEP persons use Manteca Transit.
Data from the 22 completed City staff/driver surveys generally corroborate the findings described in the Service Area Demographics section. Specific highlights from the driver survey are detailed below. • Approximately 14 percent of the City’s transit staff speak Spanish. Of the 22 individuals surveyed, three cited speaking Spanish.
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• More than 77 percent of respondents reported encountering Spanish-speaking customers. Nine percent (two responses) cited encountering Arabic, while Chinese, Korean, Tagalog, Hindu, and Malayalam were each cited once. • Nearly 78 percent of drivers said they encounter fewer than five unique individuals each week who do not speak English or who do not speak English very well. Of those, 16.7 percent said they encounter none. Only four (22.2 percent) cited encountering between five and ten such customers each week.
• Nearly 87 percent of customer service representatives/dispatchers said they encounter fewer than five unique individuals each week who do not speak English or who do not speak English very well. Of those, 13.3 percent said they encounter none. Only two (13.3 percent) cited encountering between five and ten such customers each week. • Despite the regular frequency of contact with LEP individuals, 95.5 percent of staff reported no or occasional issues. Only one individual reported frequent issues. • Only one staff member said their personal language capabilities hinder their ability to interact with Manteca Transit riders.
• When asked what materials/services would be of most benefit to riders who do not speak English or do not speak English well, nearly two-thirds said translated route brochures, while more than one-third said onboard notices in other languages. • The most common topics impacted by a language barrier were basic directions/instructions (cited by 59.1 percent) and how to use Manteca Transit (cited by
54.5 percent.
A copy of the staff survey instrument is provided in the Appendix.
Factor 3: The nature and importance of the program, activity, or service provided by the program to people’s lives.
Transit services operated by the City of Manteca play a vital role in the lives of many residents of the service area. To better understand Manteca Transit’s role among LEP populations, 18 local stakeholders (comprised of social service agencies, senior centers, faith-based organizations, and educational institutions) were contacted regarding the nature of the populations they serve. These stakeholders were selected because they were deemed likely to act as representatives for, or come into frequent contact with, LEP populations in Manteca. Of the stakeholders contacted, five individuals representing two organizations completed a stakeholder survey (survey instrument is provided in the Appendix). Together, these stakeholders provided important insight into the City’s public transit service area’s key LEP groups.
As representatives who serve as leaders for these communities, they are attuned to the needs and potential language barriers members of these communities may face when using Manteca Transit.
Four separate surveys were received from community health workers at Golden Valley Health Centers, and one was received from the Manteca Unified School District. • All five stakeholders indicated Spanish as one of the languages they encounter. Other languages cited were Punjabi (4), Hindi (3), Persian/Farsi (2), Hmong (2), Pashto (1), and Tagalog (1).
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• Most of the non-native English speakers four of the five stakeholders encounter speak and read English somewhat well. One stakeholder indicated they did not speak or read English well.
• Only two stakeholders indicated the populations they served use Manteca Transit. Three indicated language as being a barrier to using transit. The languages for which there was a barrier were Spanish and possibly Punjabi.
• Some of the biggest barriers cited were non-native English speakers not knowing where to start to find information. One stakeholder suggested posting Manteca Transit information at schools where parents can find it easily. Many of these individuals are new to Manteca. Others struggle with reading signs and communicating with drivers.
Factor 4: The resources available to the recipient for LEP outreach, as well as the costs associated with that outreach.
The City of Manteca currently provides resources to each LEP group while maintaining cost efficiency for taxpayers. Resources may include, but are not limited to:
1. Bilingual or multilingual staff members (the City’s Transit Division currently has staff members who are fluent in Spanish).
2. Professional translation services (can be implemented quickly).
3. On-call translation services (Transit recently implemented a Language Line account via its operations contractor).
4. Input by various community organizations that regularly interact with LEP populations (ongoing basis).
5. Printing services for vital documents, brochures, and other media. Essential documents such as Title VI forms, Dial-a-Ride applications, proposed service/fare changes, and certain scheduling information will be made available in the identified languages per the LEP analysis. The City will attempt to use universal symbols such as pictures, maps, and diagrams when feasible to streamline communication among all language groups.
6. Documents, brochures, and other media of less-essential importance shall be translated into the identified languages per the LEP analysis upon request.
7. Multilingual services and resources offered and utilized by other City departments(available upon request).
Conclusions
The Four-Factor Analysis showed a significant portion of the population within the Manteca Transit service area (12.2 percent) speaks English less than very well. Spanish is the most commonly used language other than English, comprising 19.7 percent of the population. Spanish and Tagalog were determined to be the only languages that fell within the Safe Harbor guidance based on demographic analysis.
The employee survey found Spanish to be the most frequently encountered language by the transit program, though few employees said they encountered five or more unique LEP individuals each week.
Employees indicated only occasional issues with communication.
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are numerous other languages present in the service area, they are encountered infrequently and populations are relatively small.
While Tagalog nominally meets the threshold under Safe Harbor guidelines, there does not appear to be evidence of a significant LEP Tagalog-speaking population that comes into contact with Manteca Transit or does not use transit due to a language barrier. Therefore, the four-factor analysis finds that Tagalog is not required to be translated under Title VI.
While the City is not required under Title VI to provide documents and information in any language other than Spanish, there may still be some residents who do not use Manteca Transit’s services due to a language barrier. Strategies to address this, as well as other recommendations, are identified within the Language Assistance Implementation Plan.
Language Assistance Plan
Language measures currently used or planned to be used by the City of Manteca to address the needs of LEP persons include the following:
• Translating vital documents including the Civil Rights Notice, Title VI Complaint Form, and Title VI Complaint Procedures into Spanish;
• Ensuring the Civil Rights Notice is posted in Spanish; • Translating marketing materials into Spanish;
• Promoting awareness of the transit contractor’s Language Line in target languages (Spanish, Tagalog/Filipino, Punjabi, Arabic, and Farsi/Persian); • Incorporating a translation tool into the City’s website, which can provide translation into, at a minimum, Spanish and Tagalog/Filipino, but ideally also Punjabi, Arabic, and Farsi/Persian.
• On the English version of the City’s website, ensuring links for materials provided in Spanish (such as the Title VI Complaint Procedure, Civil Rights Complaint Form, and Rider’s Guide) have the clickable links translated into Spanish. • If needed, arranging for availability of oral translators depending on availability; • Providing interactive meeting materials to engage LEP individuals in the planning process; and
• Posting notices in appropriate languages informing LEP persons of available transit services, routes, and amenities; as well as opportunities for LEP persons to provide input on transit-related projects.
The City will continue to seek ways to add notices to the City website to inform LEP populations of opportunities for input.
Online Resources
While the Title VI Program is posted on the City’s website, the transit website contains very little content translated in Spanish. The City is working toward adding more Spanish transit information and/or a Google Translate tool which can provide translation into, at a minimum, Spanish and Tagalog/Filipino, but ideally also Punjabi, Arabic, and Farsi/Persian. The page does include a .pdf of the Rider’s Guide which ATTACHMENT 2
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includes service information in Spanish. However, the links to Spanish-language materials (such as the Title VI Complaint Procedure, Civil Rights Complaint Form, and Rider’s Guide) are only provided in English.
Providing the links in Spanish (e.g., Formulario de Queja de Derechos Civiles instead of Civil Rights Complaint Form – Spanish) will make this information easier to find for LEP Spanish speakers. Use of a translation tool would also accomplish this – it will translate the names of the links even though it will not translate the attachments.
Telephonic Interpretation Service
In order to eliminate barriers due to language, the transit operations contractor has established an account with the telephonic interpretation service Language Line. The telephonic interpretation service allows for real-time assistance to customers who call into the customer service phone number. Initial contact is made with a Transit employee who then determines if language assistance is required. When an employee receives a call in another language, they ask what language, and can prompt the caller using the most frequently encountered languages if necessary. The employee dials the service, enters the appropriate PIN or code, and can reach a live translator for over 200 languages.
In order for the telephonic interpretation service to effectively mitigate barriers due to language, use of the service must be effectively communicated to the general public. A media release may be used to notify the community at-large, while other information can be posted on the Manteca Transit website.
This notification will be most effective if the phrase, “For information in [name of language], call (209) 456-8888” is translated into the languages most frequently encountered by Transit staff, cited by stakeholders and riders, and represented by LEP demographics. These include Spanish, Tagalog/Filipino, Punjabi, Arabic, and Persian/Farsi, though any number of languages could be included. There would be a one-time cost for professional translation (recommended), or could be translated for free using Google Translate.
Bilingual Staff
Some Manteca Transit customers have limited English literacy skills and are unable to read or write in English. Manteca Transit has bilingual drivers, as well as a bilingual Transit Manager, that can assist its native Spanish-speaking population with minor translation services. The Transit Manager also attends all Transit public meetings and provides Spanish interpretation when needed.
Staff Training
MTM Transit uses Percipio for quarterly compliance courses that include topics on diversity and inclusion.
City staff attend National Transit Institute courses and utilize training resources provided by the FTA and CalACT.
To ensure effective implementation of this plan, Manteca Transit will schedule training at orientations for new staff and relevant employees on an annual basis to review:
• Manteca Transit’s Language Assistance Plan,
• Demographic data about the local LEP populations,
• Printed materials available to LEP individuals,
• Other resources available to assist LEP individuals,
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• How to provide assistance to customers with Limited English Proficiency, • Which staff members are key resources for various languages, • How to use Language Line on-demand telephone interpretation, • How and when to document interactions with LEP customers, and • How to identify and respond to civil rights complaints.
Notice to LEP Persons about Available Language Assistance Manteca Transit is working toward being able to notify LEP persons in their own language about the language assistance available to them without cost by using the following methods:
• Notices on the Manteca Transit webpage,
• Providing information at local events, and
• Including this information on service collateral (e.g., brochures).
The Notice to the Public is provided in Spanish in the Rider Guide, which is available online. The English Notice to the Public includes statements in English and Spanish regarding how to obtain information in another language. In the future, the City will post the Notice to the Public in Spanish in its facilities, as well as including a statement about the availability of language assistance.
Monitoring, Evaluating, and Updating Plan
The Language Assistance Plan has been updated as part of this Title VI Program Update. On an ongoing basis, monitoring activities may identify changes that should be made to the Language Assistance Plan.
The following reoccurring reporting and evaluation measures will be used to update the Language Assistance Plan.
The City of Manteca will regularly assess the effectiveness of how it communicates with LEP individuals by:
• Including questions about language assistance and information needs on any customer or community surveys;
• Conversations with stakeholders, organizations, and entities which work with LEPs; and • As-needed outreach with LEP groups.
The City will monitor its language assistance efforts, including:
• Recording and reporting on customer service interactions with LEP individuals, • Incorporating discussion of Title VI into staff meetings and training, and • Updating the Language Assistance Plan based on feedback received.
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Implementation Plan
The matrix below presents an Implementation Plan for ensuring the Language Assistance Plan is quickly and efficiently implemented.
Exhibit 7.4 LAP Implementation Plan
Goal Task Anticipated
Completion
Assess LEP population in the
Manteca Transit service area
Four Factor Analysis April 2024
Stakeholder Survey April 2024
Driver/Staff Survey April 2024
Customer Survey April 2024
Demographics Analysis April 2024
Develop Language Assistance
Procedures
Update website to include translation tool FY 2025
Promote telephonic interpretation program
(Language Line) in non-English languages FY 2025
Staff Training
Train City transit staff regarding in-house
language resources and materials available
to LEP individuals
FY 2025
Train contractor staff regarding use of
Language Line telephone interpretation
service
February 2024
Train City staff regarding how and when to
document interactions with LEP customers FY 2025
Train City Staff how to respond to civil rights
complaints FY 2025
Notification of Title VI Rights
and Materials Post Title VI notice in Spanish FY 2024
Monitor and Update Language
Assistance Plan
Regularly review ACS and census
demographic data FY 2027
Incorporate discussion of Title VI into regular
staff meetings and trainings Ongoing
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 43
Section 8 | Minority Representation on Planning and Advisory Bodies The FTA requires the City to document efforts to encourage participation of minorities on non-elected committees, board, councils, or other bodies. The City must provide in its Title VI Program a table of transit-related, non-elected planning boards, advisory councils or committees, or similar bodies, the membership of which is selected by the City of Manteca City Council, and must indicate the racial breakdown of the membership of such committees or councils.
The City of Manteca has not established any non-elected transit-related committees or councils.
Should a non-elected committee or council specific to transit be established in the future, a summary of the committee members identified by race and a description of efforts made to encourage the participation of minorities on said committee will be provided in this section utilizing the table below.
Exhibit 8.1 Non-Elected Committee Membership Table
Race/Ethnicity Service Area Population
(Percentage)
Commission
(Percentage)
Caucasian XXX% XXX%
Hispanic/Latino XXX% XXX%
Black/African American XXX% XXX%
Asian XXX% XXX%
American Indian/Alaska Native XXX% XXX%
Native Hawaiian/Pacific Islander XXX% XXX%
Member participation and selection will be monitored by the City’s Title VI Program Administrator.
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 44
Section 9 | Subrecipient Monitoring and Schedule of Subrecipient Title VI Program Submissions
The City currently contracts its federally funded transit operations to MTM Transit, Inc. Third-party contractors are not required to develop their own Title VI Programs, but must comply with the Title VI Program of the recipient with which they are contracting. Therefore, it is up to the City of Manteca to monitor its operations contractor to ensure it remains in compliance with the City’s Title VI Program.
Currently, the City monitors Title VI compliance by ensuring the Notice to the Public is displayed on all transit vehicles, reviewing monthly reports, performing quality control checks, and holding meetings with contractor management. If recommended by the FTA, the City will also ensure Appendix E of the Title VI Assurances (US DOT Order 1050.2A) is incorporated into contracts with its third-party contractor. This document identifies the civil rights legislation with which all contractors must remain compliant.
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 45
Section 10 | Title VI Equity Analysis
Title VI regulations require the completion of an Equity Analysis whenever a recipient or subrecipient begins planning the location and construction of a new transit facility (not including bus shelters, transit stations, power substations, or other facilities already evaluated through NEPA).
The City of Manteca has not undertaken any construction projects for facilities at a new location within the past several years. Therefore, no Equity Analysis is required at this time.
If in the future the City of Manteca begins planning for the development and construction of a new transit facility, the City will conduct an equity analysis prior to the selection of a construction site inclusive of the Title VI requirements below:
a. The City of Manteca shall complete a Title VI equity analysis during the planning stage with regard to where a project is located or sited to ensure the location is selected without regard to race, color, or national origin. The City shall engage in outreach to persons potentially impacted by the siting of facilities. The Title VI equity analysis shall compare the equity impacts of various siting alternatives, and the analysis shall occur before the selection of the preferred site. b. When evaluating locations of facilities, the City shall give attention to other facilities with similar impacts in the area to determine if any cumulative adverse impacts might result. Analysis shall be done at the Census tract or block group where appropriate to ensure that proper perspective is given to localized impacts.
c. If the City determines that the location of the project will result in a disparate impact on the basis of race, color, or national origin, the City may only locate the project in that location if there is a substantial legitimate justification for locating the project there, and where there are no alternative locations that would have a less disparate impact on the basis of race, color, or national origin. The City shall show how both tests are met; it is important to understand that in order to make this showing, the City must consider and analyze alternatives to determine whether those alternatives would have less of a disparate impact on the basis of race, color, or national origin, and then implement the least discriminatory alternative.
The equity analysis shall be completed and submitted as part of the City of Manteca’s next Title VI Program update.
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 46
Section 11 | System-wide Standards and Policies
The FTA requires all fixed-route transit providers to develop quantitative service standards and policies for their fixed-route service. Individual public transportation providers may set standards that best reflect their local environment. Since the City operates fixed-route bus service, system-wide standards and policies are discussed below.
Vehicle Load
Measure: Provides service levels to prevent overcrowding and standees.
The City’s transit fleet consists of eight cutaway vehicles. All are wheelchair accessible in compliance with the Americans with Disabilities Act and all are equipped with bike racks. Manteca Transit rarely turns customers away due to capacity issues.
The City system-wide goal is to have an average maximum load factor for fixed-route service not to exceed
1.0 (i.e., 19 passengers for 19 seats and no standees). The chart below identifies the make and model of the vehicles used to provide transitservice and their maximum load factor. The 26-foot cutaways and 35- foot Gillig are regularly assigned to the fixed-route service, though one of the smaller vehicles may be used as a spare if needed.
Vehicle Type
Average Passenger Capacities
Vehicle
Length
Seating
Capacity
Standing
Capacity* Total Maximum Load Factor
Champion LF270FP 26 ft 19 0 19 1.0
Champion LF270FP 24 ft 13 0 13 1.0
Champion LF270FP 23 ft 13 0 13 1.0
Gillig Low-Floor 35 ft 31 0 31 1.0
*For safety reasons, Manteca Transit does not allow standees on any of its vehicles.
Vehicle Headway
Measure: Provides adequate service frequency based on the corridor of operation and ridership demand.
Manteca Transit operates four fixed routes, Monday through Friday from 6:00 a.m. to 7:00 p.m. and three fixed routes on Saturday from 9:00 a.m. to 4:00 p.m. Each route consists of a one-way loop of approximately 13 miles and 25 stops.
Manteca Transit’s vehicle headway is 60 minutes on all fixed routes and does not have peak and off-peak hours. Therefore, vehicle frequency per route during weekdays is one vehicle per hour on all routes.
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 47
Manteca Transit also operates a shuttle to the ACE station which is designed to connect with ACE rail service, Monday through Friday. Morning service consists of two trips operating 43 minutes apart, while afternoon service consists of three trips operating on a 60-minute frequency.
On-time Performance
Measure: Provides accessible and reliable transit services to Manteca.
On-time performance is tracked manually in a daily log by the bus operators while on route. In addition, bus operators are required to call in to dispatch when running late. Below are the City of Manteca’s ontime performance standards for fixed-route service.
On-Time Departures
It is the goal of the City that fixed-route buses shall depart no more than five (5) minutes late from any scheduled time point. In addition, Manteca Transit strives to ensure a minimum of 95 percent of all departures meet this criterion.
Operating Ahead of Schedule
No bus shall depart a designated time point prior to its scheduled departure time.
Missed Trips
Manteca Transit shall, at a minimum, complete 100 percent of all scheduled trips. Any fixed route trip operating 20 minutes or more behind the scheduled time shall be considered a “missed trip.” Service Availability
Measure: Provides accessible and reliable transit services to Manteca.
It is Manteca Transit’s goal is to provide affordable, reliable, efficient and user-friendly transit service that effectively meets the local mobility needs of those who have limited mobility options and those who choose Manteca Transit for environmental or lifestyle reasons.
Transit service is provided to major destinations and activity centers within Manteca. This goal includes major employers, shopping centers, healthcare and educational facilities, and other large trip generators.
The availability of routes is based on the ridership demand balanced with available resources.
Service Policies
Distribution of Transit Amenities
Transit amenities refer to items of comfort, convenience, and safety that are available to the general riding public. Fixed-route transit providers must set a policy to ensure equitable distribution of transit amenities across the system. This requirement applies after a transit provider has decided to fund an amenity.
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 48
Transit amenities may include: seating (benches, seats at stops/stations); bus shelters; printed information (signs, system maps, schedules); and waste receptacles.
The City of Manteca determines equitable locations of all transit amenities placed throughout the City to serve the fixed-route system. There are currently 76 bus stop locations in the fixed-route system. Bus stop improvements will be given priority at locations that receive higher numbers of boardings and alightings and will be made throughout the City during implementation of each improvement cycle.
Vehicle Assignment
Vehicle assignment refers to the process by which transit vehicles are placed into service on routes throughout the transit provider’s system. The eight cutaway vehicles within the Manteca Transit fleet are ramp-equipped, have bicycle racks, and have heat/air conditioning. There is very little difference within the fleet with respect to customer amenities or capacity. Three of the eight cutaways are designed for dial-a-ride service.
While it is possible the vehicles may be shared between modes, six are generally dedicated for fixed-route use. The five cutaways assigned to the fixed-route service are so assigned given they are larger vehicles (capacity of 19 passengers, versus 13 passengers for the vehicles assigned for dial-a-ride use). The 35-foot Gillig Low-Floor bus is also assigned to the fixed-route service. All cutaway vehicles are the same age and general condition. Assignment of fixed-route vehicles on individual routes is based primarily on accruing mileage equally across the fleet. Route assignments rotate equally among the six vehicles. At present, with the exception of the 35-foot Gillig (which is newer), all of the vehicles have similar mileage as others assigned to the same mode. An additional two (2) 29-foot Gilligs are currently on order, and will be added to the fixed-route fleet, along with an electric van to service Dial-A-Ride.
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 49
Section 12 | City Council Approval of Title VI Program Update [PENDING]
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 50
Section 13 | Appendix
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 51
Exhibit A.1 Employee Survey Instrument
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 52
Exhibit A.2 Stakeholder Survey Instrument
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 53
Exhibit A.3 Rider Survey Instrument (English)
ATTACHMENT 2
CITY OF MANTECA
2024 MANTECA TRANSIT TITLE VI PROGRAM
Draft Report
April 2024
MOORE & ASSOCIATES, INC. PAGE 54
Exhibit A.4 Rider Survey Instrument (Spanish)
ATTACHMENT 2