City Council Memorandum
TO: HONORABLE MAYOR AND CITY COUNCIL DATE: AUGUST 15, 2023 FROM: PARKS, RECREATION AND COMMUNITY WARDS: ALL
SERVICES DEPARTMENT
SUBJECT: THE 2024–2026 SPECIAL TRANSPORTATION TITLE VI PROGRAM; REQUIREMENT UNDER THE FEDERAL TRANSIT ADMINISTRATION CIRCULAR 4702.B1 ISSUES:
Approve the 2024-2026 Special Transportation Title VI Program as required under the Federal Transit Administration Circular 4702.B1.
RECOMMENDATIONS:
That the City Council:
Approve the Special Transportation Title VI Program as required by the Federal Transit Administration (FTA) as part of their requirements; and Authorize the City Manager, or designee, to execute all necessary documents to implement the approval of these documents, including making minor and non-substantive changes.
BACKGROUND:
The Civil Rights Act of 1964 is a landmark piece of civil rights legislation in the United States that outlawed discrimination based on race, color, religion, sex, or national origin. It ended unequal application of voter registration requirements and racial segregation in schools, workplaces, and facilities that serve the general public.
On February 11, 1994, Executive Order (EO) 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,” was enacted by President Clinton. The Presidential memorandum accompanying EO 12898 identified Title VI of the Civil Rights Act of 1964 as one of several federal laws that should be applied “to prevent minority communities and low-income communities from being subject to disproportionately high and adverse environmental effects.” Title VI prohibits discrimination by recipients of federal financial assistance on the basis of race, color, and national origin, including the denial of meaningful access for limited English Proficient Persons.
In 2012, the Federal Transit Administration modified the requirements for all FTA funded recipients related to Title VI Civil Rights Act of 1964, requiring all recipients to document their compliance with DOT’s Title VI regulations by submitting a comprehensive Title VI Program to their FTA regional civil rights officer once every three years or as otherwise directed by the FTA. Additionally, the Title VI Program required approval by the submitting agency’s governing entity prior to submission.
Special Transportation’s 2021-2024 Title VI Program was approved by the City Council on July 20, 2021.
DISCUSSION:
The City of Riverside’s Title VI Program includes the processes and procedures in place by Special Transportation under the Parks, Recreation and Community Services Department as well as the Title VI plan implemented for the City by the General Services Department in 2017. This includes the General Services Department’s designation of a Title VI Coordinator, a Title VI brochure outlining the City’s policy on Title VI, and complaint forms in English and Spanish, all of which are posted on the City’s website. These important steps taken by the City not only ensure adherence to the FTA’s Title VI Program, but also create an environment of inclusivity and transparency.
On February 23, 2022, the FTA provided the City of Riverside with a Triennial Title VI Program Update-Concur Letter. The letter identified comments from the FTA reviewer for future submittal of the next Triennial Title VI Program. Special Transportation has updated the plan to address the following FTA Reviewer Comments that were noted:
Recipient should attempt to identify whether LEP persons are underserved by the recipient due to language barriers.
Include a description of how you train employees to provide timely and reasonable language assistance to LEP populations.
Include a more specific description of how you monitor, evaluate, and update the language access plan. List public participation outreach.
Consider looking into how Asian and Pacific Islander languages and Other Indo-European languages may potentially fall under the Safe Harbor Provision.
STRATEGIC PLAN ALIGNMENT:
Special Transportation’s Title VI Program contributes to Strategic Priority 6 – Infrastructure, Mobility & Connectivity, and Goal 6.1 in addressing the transportation needs of the Senior and Disabled residents of Riverside.
This action aligns with each of the five Cross-Cutting Threads as follows:
Equity – Special Transportation’s Title VI Program ensures that equitable transportation is available to all seniors and disabled residents within the City limits of Riverside regardless of whether or not English is their primary language.
Community Trust – Special Transportation’s Title VI Program benefits the City’s diverse populations, and result in greater public good.
Sustainability and Resiliency – Special Transportation is committed to meeting the transportation needs of the present without compromising the needs of the future and ensuring the City’s capacity to persevere, adapt and grow during good and difficult times alike.
Innovation – Special Transportation is committed to ensuring that the transportation needs of the seniors and disabled individuals who reside in Riverside are provided regardless of their ability to speak English.
Fiscal Responsibility – The adoption of a Title VI Program will ensure that the civil rights of our residents are protected, and Federal funds can be used to support this service.
FISCAL IMPACT:
There is no fiscal impact related to this recommendation.
Prepared by: Pamela M. Galera, Parks, Recreation and Community Services Director Certified as to availability of funds: Edward Enriquez, Assistant City Manager/Chief Financial Officer Approved by: Kris Martinez, Assistant City Manager
Approved as to form: Phaedra A. Norton, City Attorney
Attachment: 2024 – 2026 Special Transportation Title VI Program