Cities Index.
Special Transportation Title VI Program

Riverside City Council
April 21, 2026

Document
Special Transportation Title VI Program
Meeting
April 21, 2026
Body
Riverside City Council
Original file
1.7 MB
Text extracted from the city's file for reading and search. Open the original on riversideca.legistar1.com. That file is the official record.

City of Riverside

PARKS, RECREATION AND COMMUNITY SERVICES DEPARTMENT
2026-2029 Title VI Plan

SPECIAL TRANSPORTATION DIVISION

1 | Page

Table of Contents
Section 1 Introduction .............................................................................................................................. 2 Section 2 System Overview ....................................................................................................................... 2 Section 3 Title VI Notice to the Public and Locations ............................................................................... 4 Public Posting Locations ........................................................................................................................ 4 Vehicle Notices ...................................................................................................................................... 5 Online and Printed Materials ................................................................................................................ 5 Section 4 Title VI Complaint Procedures and Forms ................................................................................. 8 Title VI Nondiscrimination Policy Statement ........................................................................................ 8 How to File a Complaint ........................................................................................................................ 8 Complaint Review and Investigation .................................................................................................... 8 Human Relations Commission (HRC) .................................................................................................. 17 Purpose of HRC ................................................................................................................................... 17 Section 5 Title VI-related Investigations, Complaints, and Lawsuits ...................................................... 17 Section 6 Public Participation Plan ......................................................................................................... 18 Summary of Ongoing Public Outreach ................................................................................................ 18 Sampling of Completed Public Outreach ............................................................................................ 20 Section 7 Four Factor Analysis ................................................................................................................ 21 Description of Service Area ................................................................................................................. 21 Service Area Demographics ................................................................................................................ 21 Section 8 Language Assistance Plan (LAP) .............................................................................................. 27 Section 9 Membership of Non-Elected Committees and Councils ......................................................... 30 Section 10 Subrecipient Monitoring ....................................................................................................... 31 Section 11 Title VI Equity Analysis .......................................................................................................... 31 Section 12 City Council Minutes Approval of 2026-2029 Title VI Plan ................................................... 32

2 | Page

Section 1 Introduction
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that "no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance." (42 U.S.C. Section 2000d). The Civil Rights Restoration Act of 1987 clarified the intent of Title VI to include all programs and activities of Federal- aid recipients, sub - recipients, and contractors whether those programs and activities are federally funded or not. During the Obama Administration, the Federal Transit Administration (“FTA”) placed renewed emphasis on Title VI issues, including providing meaningful access to persons with Limited English Proficiency (“LEP”).

Recipients of public transportation funding from FTA are required to develop policies, programs, and practices that ensure federal transit dollars are used in a manner that is nondiscriminatory as required under Title VI. This document details how the City of Riverside incorporates nondiscrimination policies and practices in providing services to the public.

Section 2 System Overview
Special Transportation, a division of the City of Riverside Parks, Recreation and Community Services Department, has provided paratransit service to the Riverside community since 1975. The City’s dial-a-ride program, known as Riverside Connect, offers demand-response transportation within the

81.51-square-mile incorporated boundaries of the City of Riverside. The service area is illustrated in Figure 2.1.

Figure 2.1 Riverside City Limits

3 | Page

Owned and operated by the City of Riverside, Riverside Connect provides origin- to-destination, shared-ride transportation for eligible residents. The service is available to individuals 60 years of age and older (Figure 2.2) and to persons with disabilities (Figure 2.3). Individuals requesting service based on a disability must provide documentation from a physician, and eligibility determinations for disabled passengers are administered by the Riverside Transit Agency (RTA).

In addition to senior and disab led transportation, Riverside Connect offers Human Services Transportation for limited populations, including agency or institutional clients, social service organizations, and developmentally disabled adults. These riders are not required to be ADA-certified and may use the service only during their program hours, unless they separately qualify through age or ADA certification.

Figure 2.2 Age of Population
Riverside, California
Age of Population Estimate Percent

Total population 323,792 0%
Under 5 years 15,836 4.9%
5 to 9 years 20,230 6.2%
10 to 14 years 20,748 6.4%
15 to 19 years 29,684 9.2%
20 to 24 years 25,467 7.9%
25 to 34 years 51,109 15.8%
35 to 44 years 48,243 14.9%
45 to 54 years 40,408 12.5%
55 to 59 years 14,904 4.6%
60 to 64 years 17,672 5.5%
65 to 74 years 23,256 7.2%
75 to 84 years 12,209 3.8%
85 years and over 4,026 1.2%
60 years and over TOTAL 57,163 17.7%
Source: 2024 American Community Survey 1-Year Estimates, Table DP05

4 | Page

Figure 2.3 Persons with Disabilities
Riverside, California
Age Total With a disability Percent with a
disability
Total civilian
noninstitutionalized population 321,960 41,447 12.9%
AGE
Under 5 years 15,836 294 1.9%
5 to 17 years 55,005 3,922 7.1%
18 to 34 years 91,726 7,444 8.1%
35 to 64 years 121,162 15,210 12.6%
65 to 74 years 22,808 6,642 29.1%
75 years and over 15,423 7,935 51.4%
Source: 2024 American Community Survey 1-Year Estimates, Table S1810 Riverside Connect operates 362 days per year , suspending service only on Thanksgiving Day, Christmas Day, and New Year’s Day. Regular service hours are 8:00 a.m. to 5:30 p.m. , Monday through Friday, and 9:00 a.m. to 4:00 p.m. on weekends and holidays.

Ride reservations may be made by calling the Riverside Connect reservation line during business hours: 8:00 a.m. to 5:00 p.m. on weekdays and 9:00 a.m. to 3:00 p.m. on weekends and holidays. An answering machine is available outside of business hours for passengers to leave cancellation messages.

Section 3 Title VI Notice to the Public and Locations
Title 49 CFR §21.9(d) requires recipients of U.S. Department of Transportation (DOT) funding to inform the public of their obligations under Title VI and to advise individuals of the protections available to them against discrimination. The City of Riversi de meets this requirement by ensuring that Title VI notices are accessible in multiple public locations and formats.

Public Posting Locations
The City posts its Title VI notice in at least the following locations:
• Special Transportation page of the Parks, Recreation and Community Services website • Commission on Disabilities page of the General Services Department website • Public areas of the Special Transportation Administration Office, including the reception desk
• All federally funded public transit vehicles

5 | Page

Vehicle Notices
City of Riverside Special Transportation informs patrons, caretakers, and the general public of its Title VI commitment by placing bilingual (English and Spanish) stickers in each vehicle. These notices state that the City prohibits discrimination based on race, color, or national origin in programs and activities receiving federal financial assistance.

Online and Printed Materials
The Title VI notice is available:
• On the City’s website: https://riversideca.gov/generalservices/title-vi • By using the hyperlink Title VI | riversideca.gov
• In the Title VI brochure, City of Riverside and You
Brochures are distributed in the Special Transportation Administration Office reception area.

Figure 3.1 Public Notice in Federally Funded Vehicles in English and Spanish

6 | Page

Figure 3.2 Public Notice in English

7 | Page

Figure 3.3 Public Notice in Spanish

8 | Page

Section 4 Title VI Complaint Procedures and Forms
Title VI Nondiscrimination Policy Statement
The City of Riverside Special Transportation program is committed to ensuring that no person is excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any of its services on the basis of race, color, or national origin, as protected by Title VI of the Civil Rights Act of 1964, as amended.
• No individual or group will be discriminated against in the routing, scheduling, or quality of transportation services provided by Special Transportation on the basis of race, color, or national origin.
• The frequency of service, as well as the age and quality of vehicles assigned to trips, will not be determined by race, color, or national origin.

How to File a Complaint
Any person who believes they have been discriminated against on the basis of race, color, or national origin may file a Title VI complaint with the City of Riverside’s Title VI Coordinator. The complaint must be filed within 180 days of the date of the alleged discriminatory act. To file a formal complaint, individuals may complete and submit a written or online Title VI Complaint Form.

The Title VI Complaint Procedures and the Complaint Form can be obtained in four ways:

1. Website: https://riversideca.gov/generalservices

2. Website: https://riversideca.gov/park_rec/programs-sports/seniors/special-transportation- division

3. Phone: Title VI Coordinator 951-826-2211 or Special Transportation 951-687-8080

4. Brochure: City of Riverside and You

Complaint forms are readily available in both English and Spanish. Upon request, forms can be made available in additional languages or in Braille.

Complaint Review and Investigation
Complainants will receive written acknowledgment that their complaint has been received. The Title VI Coordinator will review the complaint to determine whether it falls within the City of Riverside’s jurisdiction. Complaints determined to be within the City’s jurisdiction will be investigated promptly, and a written notice of findings will be issued upon completion of the investigation.

If a complaint does not fall under the City of Riverside’s jurisdiction, it will be referred —when possible—to the appropriate agency, such as the California Department of Transportation, the

9 | Page

Federal Highway Administration, the U.S. Department of Transportation, or the U.S. Department of Justice. The complainant will be advised accordingly.

Figure 4.1 Complaint Form in English

10 | Page

11 | Page

Figure 4.2 Complaint Form in Spanish

12 | Page

13 | Page

Figure 4.3 City of Riverside and You Brochure

14 | Page

15 | Page

16 | Page

17 | Page

Human Relations Commission (HRC)
The City of Riverside is committed to ensuring that all individuals have equitable access to and can fully participate in City programs, services, and benefits regardless of religion, national origin, language, immigration status, sex, sexual orientation, gender identity, gender expression, disability status, economic status, or cultural background.

To support this commitment, the City established the Human Relations Commission (HRC) in 1986.

The Commission meets on the fourth Thursday of each month in Council Chambers. Its fifteen members advise the Mayor and City Council on issues related to discrimination and work to promote diversity, inclusion, and equal opportunity within the community. Commissioners represent a broad range of fields, including education, medicine , health and welfare, law, real estate, industry, business, finance, law enforcement, and labor.

Purpose of HRC
The HRC was created to ensure that all community members of the City of Riverside receive or participate in:

1. Equal justice before the law.

2. Equal socio-economic and political opportunities.

3. Protection of dignity and integrity of every individual.

4. Responsible citizenship.

5. Responsive redress of grievances.

6. Equitable opportunities in health, housing, education and employment.

7. Respect and support of the law.

8. Education related to basic human rights and responsibilities.

9. Reduction and eventual elimination of prejudice among people based on race, religion, national origin, sex, age, disability, or sexual orientation.

Email: [email protected]
Website: www.riversideca.gov/hrc

Section 5 Title VI-related Investigations, Complaints, and Lawsuits In accordance with Federal Transit Administration (FTA) Circular 4702.1B, all recipients of federal transit funding are required to maintain a list of any of the following that allege discrimination on the basis of race, color, or national origin:
18 | Page

• Active investigations conducted by FTA or by entities other than FTA • Lawsuits
• Complaints naming the recipient (City of Riverside Special Transportation) Since the development of the prior Title VI Program, the City of Riverside Special Transportation has not been the subject of any complaints alleging discrimination based on race, color, or national origin related to service delivery or other transit benefits.

Any future complaints that require investigation as potential Title VI matters will be documented and tracked using the matrix shown in Figure 5.1.

Figure 5.1 Title VI Complaint Log

TITLE VI COMPLAINT LOG

Date Plaintiff Complaint Type Allegation Outcome Status

Section 6 Public Participation Plan
Summary of Ongoing Public Outreach
The City of Riverside employs a range of public participation strategies, using both traditional and non-traditional outreach methods to ensure meaningful engagement with community members.

These approaches are designed to provide the public with opportunit ies to participate in the decision-making process and to offer input on programs, services, and policies that may affect them.

This section outlines the mechanisms the City uses to involve the public, as well as the outreach activities conducted since the previous submission of the Title VI Plan to the Federal Transit Administration.

19 | Page

Traditional Public Outreach

City Council
The City of Riverside utilizes public meetings of the City Council to adopt annual Transit budgets, Program of Projects, transportation planning policies, service reductions, and fare increases as required by applicable Federal, State and local regulations.

Parks and Recreation Commission
The Parks and Recreation Commission provides oversight and guidance on matters related to parks, recreational facilities, and community services within the City of Riverside under the Parks, Recreation and Community Services Department, which includes the Special Transportation program. The Commission reviews transit -related items such as annual ridership updates, proposed fare increases, and the Short Range Transit Plan, ensuring that community needs and priorities are reflected in transit planning and decision-making.

Commission on Disabilities (COD)
The COD advises the City Council on issues affecting individuals with disabilities. It reviews policies, programs, and actions impacting this community and promotes public awareness in areas such as housing, employment, and transportation.

Commission on Aging (COA)
The COA works to enhance the quality of life for seniors by studying local senior issues, evaluating current programs, identifying future needs, and reviewing best practices. The Commission provides recommendations to the Mayor and City Council to help maintain Riverside’s status as a Senior Friendly Community.

Commission of the Deaf
Thirteen commissioners act in an advisory capacity to the Mayor and City Council on facilitating the removal of barriers toward integration and participation of persons of the deaf community into all economic, political and community living areas.

Transit staff regularly attend the above listed commission meetings to maintain strong communication with senior riders and riders with ADA eligibility and to gather ongoing feedback that helps improve service quality. Other City advisory bodies may also provide input on transit matters through public comment or when transit-related items appear on their agendas.

Non-Traditional Public Outreach
Website and E-Notifications
The City’s website and e -notification system are used to share information about transit services, public meetings, community events, and opportunities for public input. The 20 | Page

e-notification system allows targeted distribution of information to subscribers based on their areas of interest, enabling staff to tailor messaging for greater effectiveness.

Social Media
The City uses its social media platforms to provide timely updates on transit-related topics.

Built-in translation features allow users to view information in their preferred language, expanding accessibility.

Community Events and Partnerships
The City participates in a wide range of community events to increase awareness of and access to City programs and services. These events strengthen partnerships with community organizations, particularly those serving underserved populations.

Print Media
The Parks, Recreation and Community Services Department publishes the Riverside Activity Guide three times per year in both print and digital formats. The guide highlights classes, parks, facilities, libraries, and other City offerings. The Transit program maintains a full-page advertisement in every edition, making the guide an important outreach and awareness tool.

Sampling of Completed Public Outreach
Figure 6.1 provides a sampling of the public outreach activities conducted by Special Transportation since the previous submission of the Title VI Plan. These examples illustrate the City’s ongoing efforts to engage riders, community members, and stakehold er groups in discussions related to transit services, accessibility, and program improvements.

Figure 6.1 Sampling of Completed Public Outreach
Sampling of Outreach Efforts Made Since Last Title VI Plan Event Date Start Time Event Outreach Method Location
6/1/2023 N/A Customer Satisfaction Survey USPS Mail Client's home address 8/23/2023 9:30 AM Proposed Rate Increase Public Meeting Flyer, Website Dales Senior Center 8/29/2023 10:00 AM Proposed Rate Increase Public Meeting Flyer, Website Bordwell Park/Stratton Center 8/30/2023 1:00 PM Proposed Rate Increase Public Meeting Flyer, Website La Sierra Senior Center 9/14/2023 9:30 AM Proposed Rate Increase Public Meeting Flyer, Website Villegas Park 9/18/2023 4:00 PM Commission on Aging - Proposed Rate Increase Public Notice,
Website City Hall-- Council Chambers
9/18/2023 6:30 PM Park and Rec Commission - Proposed Rate Increase Public Notice,
Website City Hall-- Council Chambers
9/21/2023 10:30 AM Proposed Rate Increase Public Meeting Flyer, Website Janet Goeske (Senior) Center 9/21/2023 5:30 PM Commission on Disabilities - Proposed Rate Increase Public Notice,
Website City Hall-- Council Chambers
5/28/2024 9:30 AM Mayor's Senior Forum-Updates and Questions Website Arlanza Community Center 1/29/2025 4:00 PM Commission on Aging
Public Notice,
Website City Hall-- Council Chambers
21 | Page

4/21/2025 5:00 PM Commission on Aging
Public Notice,
Website City Hall-- Council Chambers
5/3/2025 9:00 AM Community Outreach Flyer
Mission Village Mobile Home
Park
6/11/2025 6:00 PM Concerts in the Park- Community Outreach Website Fairmount Park 6/25/2025 6:00 PM Concerts in the Park- Community Outreach Website Fairmount Park 6/28/2025 9:00 AM Senior Health Fair Flyer First United Methodist Church 7/14/2025 10:00 AM Riverside Transit Agency ADA Meeting Website Dales Senior Center 7/16/2025 6:00 PM Concerts in the Park- Community Outreach Website Fairmount Park 7/17/2025 5:30 PM Commission on Disabilities
Public Notice,
Website City Hall-- Council Chambers
7/23/2025 6:00 PM Concerts in the Park- Community Outreach Website Fairmount Park 8/7/2025 9:00 AM Mayor's Senior Forum- Updates and Questions Website La Sierra Senior Center 8/20/2025 8:30 AM Senior Expo Flyer, Website
Villegas Park Community
Center
9/15/2025 6:00 PM Commission on Aging
Public Notice,
Website City Hall-- Council Chambers
9/19/2025 N/A Customer Satisfaction Survey USPS Mail Client's home address 10/14/2025 10:00 AM Mayor's Senior Forum-Updates and Questions Website Arlanza Community Center 10/15/2025 10:00 AM 50 and Better Health Fair Flyer, Website Janet Goeske Center 10/17/2025 11:00 AM Presentation of Services Flyer Blindness Support Services 10/20/2025 6:30 PM Park & Recreation Commission Update
Public Notice,
Website City Hall-- Council Chambers
11/5/2025 10:00 AM Medicare Expo Flyer, Website Janet Goeske Center 11/18/2025 11:00 AM Community Outreach Flyer Victoria Springs Apartments 11/18/2025 3:00 PM Community Outreach Flyer Victoria Springs Apartments 12/10/2025 9:00 AM Mayor's Senior Forum-Updates and Questions Website Janet Goeske Center 12/11/2025 10:30 AM Mobile App Tutorial Flyer Janet Goeske Center

Section 7 Four Factor Analysis
Description of Service Area
Riverside is a leading Southern California city that offers a blend of hometown charm, history, and hospitality alongside the vision, energy, culture, and diversity of a sophisticated metropolitan area.

With a population exceeding 323,792 residents, Riverside proudly holds the title of the 12th largest city in California and the 6th largest in Southern California, serving as the economic powerhouse of one of the fastest growing regions in the United States, offering a dynamic environment for residents, businesses and visitors alike.

Service Area Demographics
The service area demographic analysis identifies Title VI -protected populations residing within the Special Transportation service area and provides an overview of their approximate size. Title VI-protected populations within the service area include racial minority groups and individuals with Limited English Proficiency (LEP). For this analysis, particular attention is given to Hispanic/Latino residents and Spanish-speaking households.
22 | Page

The 2024 American Community Survey (ACS) provides demographic and socio -economic data across multiple topics and geographic levels. For the purposes of this Title VI Program, the analysis relies on ACS population estimates for the City of Riverside’s geographic boundaries. Due to rounding within ACS datasets, totals may not equal the sum of individual race or ethnicity categories.

Figure 7.1 Racial Breakdown
Riverside, California
Race Estimate Percent

Total population 323,792 100%
White 161,401 49.8%
Black or African American 28,788 8.9%
American Indian and Alaska Native 10,595 3.3%
Asian 33,239 10.3%
Native Hawaiian and Other Pacific Islander 1,137 0.4%
Some Other Race 166,369 51.4%
Ethnicity
Hispanic/Latino 187,499 57.9%
Source: 2024 American Community Survey 1-Year Estimates, Table DP05

The racial composition of Riverside is shown in Figure 7.1. Because the U.S. Census does not classify Hispanic/Latino as a race, individuals of any race may identify as Hispanic or Latino. For this reason, the Hispanic/Latino population is presented separately from the racial categories. In Riverside, approximately 57.9 percent of residents identify as Hispanic or Latino, making it the largest ethnic group in the city.

Figure 7.2 Language Spoken at Home
Riverside, California
Total
Population
% of
Total
Population
Speak
English
less than
"very
well"
Percent
speak
English
less than
"very
well"
Population 5 years and over 307,956 (X) 45,818 14.9%
Speak only English 169,434 55.0% (X) (X)
Speak a language other than English 138,522 45.0% 45,818 33.1%

23 | Page

Figure 7.2 Language Spoken at Home (cont’d)

SPEAK A LANGUAGE OTHER THAN

ENGLISH
# of Total
Speakers
% of Total
Population
Speak
English
less than
"very
well"
Percent
speak
English
less than
"very
well"
Spanish 112,823 36.6% 37,235 12.09%
Other Indo-European languages 8,356 2.7% 2,246 0.73%
French, Haitian, or Cajun 821 0.3% 32 0.01%
German or other West Germanic
languages 495 0.2% 24 0.01%
Russian, Polish, or other Slavic languages 371 0.1% 70 0.02% Other Indo-European languages 6,669 2.2% 2,120 0.69%
Asian and Pacific Island languages 13,593 4.4% 5,383 1.75% Korean 928 0.3% 408 0.13%
Chinese (incl. Mandarin, Cantonese) 5,410 1.8% 2,452 0.80% Vietnamese 2,460 0.8% 1,389 0.45%
Tagalog (incl. Filipino) 3,269 1.1% 613 0.20%
Other Asian and Pacific Island languages 1,526 0.5% 521 0.17% Other languages 3,750 1.2% 954 0.31%
Arabic 2,514 0.8% 876 0.28%
Other and unspecified languages 1,236 0.4% 78 0.05%
Sources: 2024 American Community Survey 1-Year Estimates, Tables S1601 and C16001

Figure 7.2 summarizes language use among Riverside residents age five and older. According to the American Community Survey, 55 percent of residents speak only English at home, while 45 percent speak a language other than English. Of those who speak another language, 14.9 percent of the total population speaks English “less than very well.”
Spanish is the most common non -English language spoken in Riverside, with 37,235 individuals (12.09 percent) reporting limited English proficiency. Spanish is also the only language that meets the Safe Harbor threshold under Title VI, which requires translation of vital documents when at least five percent or 1,000 residents speak English “less than very well.” While other languages appear in the community, none meet the Safe Harbor criteria; however, they still warrant consideration through the Four-Factor Analysis.

Four-Factor Analysis
The U. S. Department of Transportation (USDOT) requires public transit funding recipients to take reasonable steps to ensure meaningful access to programs by limited English proficient (LEP) persons. As a recipient of federal funds, the City of Riverside must perform a Four-Factor Analysis to evaluate language needs within the community and determine the appropriate measures to ensure LEP persons can effectively access and utilize Special Transportation services. 24 | Page

Estimating the number or proportion of LEP individuals that may be encountered by S pecial Transportation will help further identify the populations covered by the USDOT’s Safe Harbor Provision. This provision stipulates that if an LEP group speaking a given 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, the service provider may be required to make certain materials and services available in that language, including:
• Translated vital documents
• Language assistance services
• Public notices and outreach materials in the identified language • Other measures necessary to ensure meaningful access
The size of the population alone does not automatically trigger the Safe Harbor Provision. All four factors must be considered in determining whether a specific language should be included in an operator’s Language Access Plan. The four factors analyzed are discussed below.

Factor 1: The number or proportion of Limited English Proficiency (LEP) persons eligible to be served or likely to be encountered by Special Transportation services.

Factor 1 evaluates the number and proportion of Limited English Proficiency (LEP) individuals who are eligible to be served or are likely to be encountered by Special Transportation services. Because the City’s transit program is available to residents aged 60 and older and individuals with disabilities throughout the entire City of Riverside, this factor considers the total population within the City’s geographic boundaries. This approach ensures that the analysis captures not only current riders but also individuals who may reasonably be expected to use the service.

Riverside has a total population of 323,792, of which 307,956 individuals are age five and older.

Among this population, 45,818 individuals (14.9 percent) are identified as having Limited English Proficiency. Within this group:
• 37,235 (12.09 percent) speak Spanish
• 2,452 (0.8 percent) speak Chinese
• 1,389 (0.45 percent) speak Vietnamese
• 613 (0.2 percent) speak Tagalog
• 408 (0.13 percent) speak Korean
• 876 (0.28 percent) speak Arabic
Other languages are either grouped into broader categories or represent less than one-hundredth of one percent of the population.

Factor 1 Finding
25 | Page

Riverside serves a linguistically diverse community; however, Spanish remains the predominant non-English language encountered by Special Transportation. The concentration of Spanish-speaking individuals who report speaking English “less than very well” (12 .09 percent) continues to make this the primary LEP group within the service area.

Under USDOT’s Safe Harbor Provision, translation of vital written materials is required for any LEP language group that constitutes five percent or 1,000 individuals, whichever is less, of the population likely to be served. Spanish meets both thresholds and therefore qualifies as a Safe Harbor language.

The City already provides Spanish- language materials and assistance for Special Transportation, reflecting the high usage of the program by Spanish-speaking residents.

Factor 2: The frequency with which LEP persons come into contact with the City’s transit services.

Factor 2 evaluates how often Limited English Proficiency (LEP) individuals come into contact with the City’s transit services. To better understand rider language needs and communication preferences, Special Transportation staff conducted a short rider sur vey from September 19 to October 17, 2025. The survey was provided in both English and Spanish and mailed to every rider in the program’s database. Each survey packet included a cover letter from the Transit Manager, a postage-paid return envelope, and a free ride incentive for returning a completed survey.

A total of 276 surveys were returned. Of these, 251 were completed in English and 25 in Spanish. A total of 260 respondents answered the question regarding preferred language. Among those respondents:
• 227 indicated English as their preferred language
• 25 indicated Spanish
• 8 selected “Other”
These results show that while English remains the predominant language among riders, Spanish-speaking individuals continue to represent a meaningful portion of the population served by Special Transportation.

Factor 2 Finding
The 2025 customer survey confirmed that Spanish-speakers are the most likely LEP persons to come into contact with Special Transportation. However, there is usage by LEP persons who speak other languages, that do not mee t the Safe Harbor thresholds. Given the frequency of usage by Spanish speaking LEP individuals, it is essential the City continue to provide vital documents and service information in Spanish, to ensure compliance with the Safe Harbor Provision as well as to meet the needs of Spanish-speaking LEP customers.

26 | Page

Factor 3: The nature and importance of the City’s transit services to affected LEP populations.

Factor 3 evaluates how essential the City’s transit services are to Limited English Proficiency (LEP) populations within the service area, as well as the reasons LEP individuals rely on Special Transportation.

Special Transportation provides a vital mobility option for senior and disabled residents of Riverside.

With affordable fares and service offered seven days per week, 362 days per year, riders are able to travel anywhere within City limits during operating hours. According to Special Transportation’s scheduling software, trips are routinely provided to essential and quality -of-life destinations, including medical appointments, employment, vocational training workshops, senior centers, grocery stores, pharma cies, shopping centers, entertainment venues, and other community locations.

Factor 3 Finding
Factor 3 reaffirms that Spanish is the most prevalent non-English language spoken in Riverside and that Special Transportation services are particularly important to many Spanish- speaking customers. Hispanic/Latino and other minority riders rely on Special Transportation to reach essential destinations such as medical care, employment, and recreational activities. The importance of these services underscores the need for continued language access measures to ensure meaningful participation and equitable service for LEP populations.

Factor 4: The resources available to the recipient for LEP outreach, as well as the costs associated with that outreach.

Factor 4 evaluates the resources available to the City for providing language assistance to Limited English Proficiency (LEP) populations, as well as the costs associated with those efforts. Unlike the other factors, this assessment focuses on the City’s capacity to deliver meaningful language access.

As identified in Factor 1, the Spanish-speaking LEP population in Riverside is large enough to require targeted language -access measures. In response, Special Transportation provides Spanish-language versions of vital documents necessary for using Riversid e Connect and ensures that Spanish-speaking staff are available to assist customers.

Other LEP populations— such as Chinese and Tagalog speakers— were also identified through the Four-Factor Analysis. However, none of these groups meet the Safe Harbor thresholds of five percent or 1,000 individuals. While some members of these communities do use Special Transportation, the City is not required to translate vital documents into these languages. Even so, the City benefits from having transit staff who speak additional languages, including Spanish and Korean, which enhances the ability to assist riders as needed.

27 | Page

Factor 4 Finding
The City is responsible for ensuring that vital documents and essential service information — including responses to verbal inquiries— are available in Spanish. While providing these services involves some cost, all recommended strategies fall within the City’s avail able resources. When possible, existing or future staff members who speak languages encountered by customer- facing personnel should be utilized to provide interpretation support. These measures ensure that Special Transportation continues to meet the needs of its LEP riders while maintaining compliance with federal requirements.

Section 8 Language Assistance Plan (LAP)
This Language Assistance Plan was developed alongside the City of Riverside Special Transportation’s Title VI Program to ensure that Riverside Connect services remain accessible to individuals with Limited English Proficiency (LEP). Two federal mandates require recipients of federal funding to provide meaningful access to LEP individuals:
• Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin by federally funded agencies. National origin discrimination includes failing to provide meaningful access to LEP individuals.
• Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency” (August 11, 2000) directs federal agencies to ensure that recipients of federal financial assistance provide meaningful access to LEP persons in all federally conducted or assisted programs and activities.

Together, these mandates require the City of Riverside to evaluate language needs within the community and implement appropriate measures to ensure LEP individuals can fully access and benefit from Special Transportation services.

Language Assistance Goals
A core objective of the City’s Title VI Program is to ensure meaningful access for Limited English Proficient (LEP) individuals to all Special Transportation services, information, and materials. To achieve this, the City maintains a comprehensive Language Assistance Plan and regularly evaluates the effectiveness of its outreach methods, communication tools, and language -access strategies.

These efforts help ensure that LEP customers can fully understand, navigate, and benefit from Riverside Connect services.

28 | Page

Language Service Provision

Bilingual Services
Whenever possible, the City utilizes bilingual employees to support the needs of Limited English Proficient (LEP) individuals. The City maintains a list of designated bilingual Spanish- speaking employees across all departments, and Special Transportation b enefits from having several Spanish-speaking staff members in supervision, dispatch/scheduling, and driver positions. These employees are available to assist customers in person or by phone in Spanish, ensuring riders can communicate effectively about their transportation needs.

Spanish-speaking transit employees routinely interact with Spanish-speaking LEP customers in their preferred language, providing real -time assistance and improving the customer experience.

Bilingual employees who speak additional languages also provide sup port when available, further enhancing the City’s ability to serve a diverse ridership.

Interpretation/Translation Services
Real-time interpretation at public events will be determined on a case -by-case basis by examining several factors:

• The type and size of the event,
• The availability of a City staff member to interpret, or • The availability of a staff member of a host organization to interpret.

For outreach events, senior fairs, or transit awareness events, bilingual staff members will assist with interpretation where appropriate and feasible. These efforts help ensure that LEP individuals can meaningfully engage with Special Transportation staff and access information during in-person events.

Translation of Vital Documents
Based on the results of the Four Factor Analysis, the following vital documents and key service information will be made available in Spanish, the only identified LEP language within the Special Transportation service area.

Vital Documents

1. Title VI Program
• Title VI Notice to the Public
• Complaint form
• Complaint procedures

2. Service Information
• Dial-A-Ride handbook
• Online service information
29 | Page

• Onboard notices related to service information
• Customer Surveys
• Special Transportation brochure/flyers
• Dial-A-Ride application

Per the City policy on Translation Guidelines, vital documents, those with a legal requirement to be translated, and other critical customer communications, will be translated by a professional certified translator. In other cases, an in-house resource may be used when appropriate.

Monitoring, Evaluating, and Updating the LAP
A comprehensive review of this Language Assistance Plan (LAP) will be conducted every three years, concurrent with the update and submission of the City’s Title VI Program. During each review cycle, the City will reassess LEP populations within the service area to ensure that all significant language groups are appropriately reflected in the City’s language -assistance efforts. The following ongoing reporting and evaluation activities will guide updates to the LAP.

The City of Riverside will regularly assess the effectiveness of how it communicates with LEP individuals by:
• Including questions about language assistance and information needs on any community surveys;
• Holding conversations with stakeholders, organizations, and entities which work with LEPs; • Conducting as-needed outreach with LEP groups.

The City will monitor its language assistance efforts, including:
• Reporting on customer service interactions with LEP individuals, • Incorporating discussion of Title VI into regular operations meetings, and • Updating the Language Assistance Plan based on public feedback.

Should this monitoring of the City’s language assistance efforts reveal any challenges or deficiencies, the City will refine its existing customer service procedures to address specific Title VI concerns and ensure continued meaningful access for LEP individuals.

Staff Training
During the orientation and training period, newly hired dispatchers who do not speak Spanish are instructed to refer Spanish- language calls to the lead dispatcher or the transit supervisor on duty.

The supervisor then contacts a Spanish- speaking staff memb er to assist with the call, or, if the supervisor is bilingual, they will handle the call directly.

Given the increasing presence of additional languages within the City of Riverside’s Special Transportation service area, the City will expand Title VI –specific training over the next three years.

This training will ensure that all staff understand Title VI requirements, the protections it affords, and 30 | Page

the types of requests or situations that may constitute a Title VI issue. Strengthening this knowledge base will help staff recognize civil rights–related concerns and respond appropriately.

Dispatchers, and other staff as necessary, will receive training in:
• Responding to LEP callers
• Responding to written correspondence from LEP individuals • Assisting LEP customers in person
• Documenting LEP needs and interactions
• Identifying when a complaint may be a civil rights/Title VI issue • Responding appropriately to civil rights complaints
Drivers will also receive additional training on how to effectively interact with LEP customers onboard transit vehicles, including how to document encounters and requests for information.

Drivers and other customer-facing personnel will be trained on the language guide referenced above as part of their initial onboarding, with annual refresher training provided thereafter.

Four-Factor Analysis Findings
Considering the significant population of persons speaking Spanish who speak English less than “very well,” combined with th eir high utilization of Special Transit, the City should provide vital documents and essential service information in Spanish per the Safe Harbor Provision.

The following documents used by Special Transportation are available in English and Spanish.

Vital Documents

1. Title VI Program
• Title VI Notice to the Public
• Complaint form
• Complaint procedures

2. Service Information
• Dial-A-Ride handbook
• Online service information
• Onboard notices related to service information
• Customer Surveys
• Special Transportation brochure/flyers
• Dial-A-Ride application
Section 9 Membership of Non-Elected Committees and Councils Not applicable. There are no transit-related, non-elected planning boards, advisory councils or committees created specifically for Special Transportation. 31 | Page

Section 10 Subrecipient Monitoring
The City of Riverside has no subrecipients, and therefore does not have a developed monitoring program.

Section 11 Title VI Equity Analysis
The City of Riverside has not constructed any new facilities since the submission of the prior Title VI Plan and therefore was not required to conduct an equity analysis.

32 | Page

Section 12 City Council Minutes Approval of 2026-2029 Title VI Plan

← All documents from this meeting