Agenda Item 8C - Supplemental Material #1 — Torrance City Council, May 20, 2025

8C
Date: Tuesday, May 20, 2025
To: Honorable Mayor and Members of the City Council
From: Kim Turner, Transit Director
By: David Mach, Transit Planning Manager | [email protected] Subject: Transit - Supplemental Material #1 for Agenda Item 8C

DISCUSSION
A scrivener’s error was detected on page 3 of Attachment 1 for Item 8C. The error has been corrected in the Title VI Program Report.

ATTACHMENT

1. Title VI Program Report 2025-2028 (Revised)

Over 85 Years of Dedicated Service to the South Bay Community…

Torrance Transit
Title VI Program: CY 2010
-
2012

Title VI
Program

Report

August 1, 2025 –
July 31, 2028

City of Torrance, California

TRANSIT DIRECTOR
Kim Turner

Deputy Transit Director
Godfrey Offoegbu

MANAGEMENT TEAM
Administration Fleet Services Planning Transit Services Operations James Lee Art Estrada David Mach Melody Lawrence Luis Figueroa

Torrance Transit Title VI Program: CY 2025-2028
Contents

CITY COUNCIL

George K. Chen

Mayor

Bridgett Lewis

Asam Sheikh

Sharon Kalani

Aurelio
Mattucci

Jeremy Gerson

Jon Kaji

CITY CLERK

CITY TREASURER

Rebecca Poirier

Tim Goodrich

CITY MANAGER

Aram Chaparyan

ASSISTANT CITY MANAGER

Danny Santana

CHAPTER I: TORRANCE TRANSIT OVERVIEW ................................................................................ 1 A. Purpose ............................................................................................................................................... 1 B. Background of the City ...................................................................................................................... 1 C. Torrance Transit ................................................................................................................................. 5 D. System Map ...................................................................................................................................... 10 CHAPTER II: GENERAL REQUIREMENTS ......................................................................................... 7 A. Notice of Rights under Title VI ......................................................................................................... 7 B. Complaint Procedures ....................................................................................................................... 7 C. Current Title VI Investigations, Complaints or Lawsuits .............................................................. 9 D. Public Participation Plan ................................................................................................................. 12 E. Limited English Proficiency (LEP) Plan ........................................................................................ 13 F. Racial Breakdown of Non-Elected Advisory Councils ................................................................ 14 G. Sub-recipient Monitoring ................................................................................................................ 14 ATTACHMENT A: Copy of Notice of Civil Rights ............................................................................ 15 ATTACHMENT B: Complaint Form ................................................................................................... 16 ATTACHMENT B1: Department SOP on Title VI Policies and Procedures ................................ 18 ATTACHMENT C: Public Participation Plan .................................................................................... 20 ATTACHMENT D: LEP Plan ............................................................................................................... 43 ATTACHMENT E: Service Standards, Policies, And Monitoring ………………………………………………58 ATTACHMENT F: Governing Board Approval of Title VI Program……………………………………………99

List of Title VI program requirements and where they are located in the program report.

General Requirements (Chapter III):
• Title VI Notice to the Public, including a list of locations where the notice is posted – Pg. 7 and 15
• Title VI Complaint Procedures (i.e., instructions to the public regarding how to file a Title VI discrimination complaint) – Pg. 7-192
• Title VI Complaint Form – Pg. 16-17
• List of transit-related Title VI investigations, complaints, and lawsuits – Pg. 9-11 • Public Participation Plan, including information about outreach methods to engage minority and limited English proficient populations (LEP), as well as a summary of outreach efforts made since the last Title VI Program submission – Pg. 20-41
• Language Assistance Plan for providing language assistance to persons with limited English proficiency (LEP), based on the DOT LEP Guidance – Pg. 42-57 • A table depicting the membership of non-elected committees and councils, the membership of which is selected by the recipient, broken down by race, and a description of the process the agency uses to encourage the participation of minorities on such committees – Pg. 14
• Primary recipients shall include a description of how the agency monitors its sub- recipients for compliance with Title VI, and a schedule of sub-recipient Title VI Program submissions – Pg. 14. Torrance Transit does not have any sub- recipients
• A Title VI equity analysis if the recipient has constructed a facility, such as a vehicle storage facility, maintenance facility, operation center, etc. – Pg 90-101 • A copy of board meeting minutes, resolution, or other appropriate documentation showing the board of directors or appropriate governing entity or official(s) responsible for policy decisions reviewed and approved the Title VI Program. For State DOT's, the appropriate governing entity is the State's Secretary of Transportation or equivalent. The approval must occur prior to submission to FTA. Additional information as specified in chapters IV, V, and VI, depending on whether the recipient is a transit provider, a State, or a planning entity (see below) – Pg. 102

Requirements of Transit Providers (Chapter IV):
• All requirements set out in Chapter III (General Requirements) – See above pages
• Service standards – Pg. 58-67
• Vehicle load for each mode – 67-68 and 77-78
• Vehicle headway for each mode - Pg. 68-69 and 79-80

• On time performance for each mode - Pg. 69-70 and 80-81 • Service availability for each mode – Pg. 70-71 and 81-82 • Service policies – Pg. 87
• Transit Amenities for each mode – Pg. 72-75
• Vehicle Assignment for each mode – Pg. 71-72 and 82-83

Transit providers that operate 50 or more fixed route vehicles in peak service and are located in an Urbanized Area (UZA) of 200,000 or more people must submit:

These are optional as Torrance Transit currently operates 41 peak buses. • Demographic and service profile maps and charts – Pg. 4 and 100-105 • Demographic ridership and travel patterns, collected by surveys – Pg. 105 • Results of their monitoring program and report, including evidence that the board or other governing entity or official(s) considered, was aware of the results, and approved the analysis – Pg. 91-99 and 119-125
• A description of the public engagement process for setting the "major service change policy," disparate impact policy, and disproportionate burden policy – • Results of service and/or fare equity analyses conducted since the last Title VI Program submission, including evidence that the board or other governing entity or official(s) considered, was aware of, and approved the results of the analysis - Pg. 106-113

Torrance Transit Title VI Program: CY 2022-2025
CHAPTER I: TORRANCE TRANSIT OVERVIEW

A. Purpose

The Federal Transit Administration (FTA) within the U.S. Department of Transportation requires that federally funded transit agencies submit a triennial program to ensure compliance with Title VI of the Civil Rights Act of 1964. Title VI regulations were set forth to assure equal access to transit services regardless of race, color, or national origin. To demonstrate compliance with these provisions, Torrance Transit is submitting this program in accordance with FTA Circular 4702.1B.

B. Background of the City
The City of Torrance is 21 square miles, 12,312 acres, and situated halfway between Los Angeles and Orange Counties and bordered by the Pacific Ocean on the west. Incorporated in 1921, the 2020 Census American Community Survey 5- Year Estimates reports that the present population is 147,067, making Torrance the eight largest city in Los Angeles County and the 40th largest city in California.

The median age is presently 43.7 years (notably higher than the Los Angeles County median age of 38.6). The breakdown of the population in terms of race is as follows:

Race/Ethnicity City of Torrance
Residents
Percentage
White 51,913 35.3%
Black or African American 4,781 3.3%
Asian 51,857 35.3%
American Indian/Alaska Native 235 0.2%
Native Hawaiian/Pacific Islander 523 0.4%
Other 980 0.7%
Two or More Races 8,698 5.9%
Hispanic/Latino (any race) 28,080 19.1%
TOTAL 147,067 100%

C. Torrance Transit
Torrance Transit has operated weekday service in the City of Torrance continuously since January 23, 1940. As a response to the railroad corporation stopping service between Torrance and Los Angeles, Resolution No. 1374 gave permission to use buses for public transportation. This was supposed to be a temporary solution to the 2 problem, but Torrance Transit continued to grow as the public’s need for transportation became apparent. As of April 30, 2022, Torrance Transit operates a fleet of sixty-three (63), forty-foot (40’) buses, including its contingency reserve.

During FY 2019, Torrance Transit provides 4 million trips to its customers annually via local, freeway express, and Rapid services with 44 peak operating buses. For FY2025 Torrance Transit has been providing over 2 million trips on 12 routes covering 108 square-mile service area. Three (3) of the routes provided service and circulation within the City of Torrance, while the other remaining routes provided regional connections. Due to pandemic service reduction and continued bus operator shortages, Torrance Transit currently operates a peak of 41 buses and is expecting to increase as hiring efforts continues.

Torrance Transit provides important regional connections within the South Bay region of Los Angeles County. Figure 1 provides the peak frequencies by service day for the routes we currently operate.

Figure 1: Service Days and Operating Frequency by Route Route

Description

Peak Frequency (in minutes)
Weekday Saturday Sunday
1 Del Amo Center Mall (Torrance) to
Harbor Freeway Station 40-50 40-65 45-70
2 Del Amo Center Mall (Torrance) to El
Camino College 70-80
3 Redondo Beach Pier to Long Beach
Transit Gallery 15-35 15-40 20-45
R3
Mary K. Giordano Regional Transit
Center (Torrance) to Long Beach
Transit Gallery 10-95
4X
Hawthorne Blvd at Pacific Coast Hwy
(Torrance) to Union Station 55-130 50-60
5 Pacific Coast Highway to El Camino
College 70-80
6 Del Amo Center Mall (Torrance) to
Metro A Line Artesia Station 70-85
7 Redondo Beach Pier to Wilmington via
Sepulveda Blvd 50-80 50-75
8 Hawthorne Blvd at Pacific Coast Hwy
(Torrance) to LAX Transit Center 30-50 40-90 65-90
9 Del Amo Center Mall (Torrance) to
Lomita Blvd at Avalon Blvd 50-80 50-75
3 10
Crenshaw Blvd at Pacific Coast Hwy
to Inglewood (via Crenshaw Station) 50-80 55-75 50-75
13 Redondo Beach to Metro A Line
Artesia Station 25-45 55-65 55-65

Note: Shaded areas indicate no service on those days.

In addition to bus service, Torrance Transit also provides a demand-response taxi service for elderly and disabled residents 24 hours a day, seven days a week through taxi contractors. Torrance Transit also participates in the Los Angeles County’s Access Services, a non-profit agency that provides paratransit services and meets Americans with Disabilities Act (ADA) mandates.

On December 11, 2024, Torrance Transit launched a one-year pilot on-demand microtransit servie called Connect Torrance. This service supplements the current demand-response taxi service for Torrance residents who are 65 years or older and residents who have a disability. Connect Torrance also provides service for the general public who are traveling within a specified zone.

https://city.ridewithvia.com/connect-torrance
4 5

D. System Map
.

6 7

CHAPTER II: GENERAL REQUIREMENTS

A. Notice of Rights under Title VI

Torrance Transit System is committed to ensuring that no person is excluded from participation in, or denied the benefits of services on the basis of race, color and national origin as protected by the Civil Rights Act of 1964, as amended.

No person or group of persons will be discriminated against with regards to fares, routing, scheduling or quality of transportation service that Torrance Transit furnishes, on the basis of race, color or national origin.

In addition, the frequency of service, age and quality of Torrance Transit vehicles assigned to routes, and location of routes will not be determined on the basis of race, color or national origin.

Notices of Title VI Policies are posted on all buses and facilities in our service area.

These facilities include our own bus yard, Administration building, Regional Transit Center and the City Clerk’s building.

This information can be accessed via Torrance Transit’s website at:
https://transit.torranceca.gov/our-city/transit/rider-information/title-viv.

The information is also posted on all Torrance Transit buses ( ATTACHMENT A of this document is a copy of the car card of the Title VI Policy posted on buses.)

B. Complaint Procedures

The procedure for filing a formal complaint is outlined on the Transit website which can be accessed at:
https://transit.torranceca.gov/our-city/transit/rider-information/title-viv.

Torrance Transit allows up to one hundred eighty (180) days for an individual or individuals to file a written complaint. ATTACHMENT B of this document is a copy of the Title VI complaint form, and ATTACHMENT B1 is a copy of the department policy and procedure for handling formal Title VI complaints.

Individuals who feel they have been discriminated against can also contact Torrance Transit via:

Telephone: (310) 618-6266 (Voice)
Facsimile: (310) 618-6229
Email: [email protected]
8 Receipt of the Title VI Complaint

Formal Title VI complaints may be received via e-mail, mail, phone, walk-in, other department, field supervisor and other Transit staff. The following outlines the process upon receipt of a complaint (a draft of the proposed Title VI complaint form is attached):

1. Submission of Complaint: Any person who feels that he or she, individually, or as a member of any class of persons, on the basis of race, color, or national origin has been excluded from or denied the benefits of, or subjected to discrimination under any program or activity receiving federal financial assistance through Torrance Transit may file a written complaint with the Administration and/or Operations Manager of the Department. Such complaint must be filed within 180 calendar days after the date the person believes the discrimination occurred.

2. Referral to Review Officer: Upon receipt of the Complaint, the Transit Administration Manager and/or Operations Manager shall assign one or more staff (most likely a department Analyst, Supervisor or the Senior Business Manager), to evaluate and investigate the complaint. Staff shall complete this investigation in consultation with the City of Torrance City Attorney’s Office, and most likely with the involvement of the Risk Manager and Human Resources Division. Transit staff assigned shall complete their review no later than 60 calendar days after the date Torrance Transit received the Title VI Complaint. If more time is required, the Administration Manager and/or Operations Manager shall notify the Complainant of the estimated time-frame for completing the review. Upon completion of the review, staff shall make a recommendation regarding the merit of the Complaint and whether remedial actions are available to provide redress.

Additionally, Transit staff may recommend improvements to Torrance Transit’s processes relative to Title VI, as appropriate. Transit staff shall forward their recommendations to the Administration Manager and/or Operations Manager for concurrence. If s/he concurs, s/he shall issue Torrance Transit’s written response to the Complainant.

3. Request for Reconsideration: If the Complainant disagrees with the response, he or she may request reconsideration by submitting the request, in writing, to the Transit Director within 10 calendar days after its receipt. The request for reconsideration shall be sufficiently detailed to contain any items the Complainant feels were not fully understood by the Administration Manager and/or Operations Manager. The Transit Director will notify the Complainant of his/her decision either to accept or reject the request for reconsideration within 10 calendar days. In cases where the Transit Director agrees to reconsider, the matter shall be returned to the staff review officer(s) to re-evaluate in accordance with Paragraph 2, above.
9 4. Appeal: If the request for reconsideration is denied, the Complainant may appeal the Transit Director’s response to the Complaint by submitting a written appeal to the Assistant City Manager of the City of Torrance, no later than 10 calendar days after receipt of the Transit Director’s written decision rejecting reconsideration.

5. Submission of Complaint to the Federal Transit Administration: The complainant may also file a complaint directly with the Federal Transit Administration at FTA Office of Civil Rights, 1200 New Jersey Ave. SE, Washington, DC 20590.

C. Current Title VI Investigations, Complaints or Lawsuits

Since the last update of the plan, Torrance Transit System received receive one (1) Title VI related complaint form. However, the complaint form was not completely filled out and left out necessary information for our Administration Manager to identify the nature of the complaint. After thorough review, our staff determined that the complaint was not related to Title VI discrimination on the basis of race, color or national origin.
10 11

12 Additional information on Title VI can be accessed via Torrance Transit’s website at:
https://transit.torranceca.gov/our-city/transit/rider-information/title-viv

The complaint may be filed in writing with Torrance Transit Customer Service at:

Torrance Transit System
Attention: Administration Manager
20500 Madrona Ave.

Torrance, CA 90503

D. Public Participation Plan

Torrance Transit makes every effort to engage the community and stakeholders to participate in the development of Transit-related projects and services.

Stakeholders such as low-income and minority communities, Limited English Proficiency populations, community based organizations, and businesses are invited to share their views and opinions to ensure that the analysis of all projects and service changes include the needs of those stakeholders impacted.

13 On Thursday, May 1, 2025 @ 11am, Torrance Transit hosted an in-person public hearing in both English and Spanish to allow the public to provide feedback regarding the public participation plan, major service change threshold, and disparate impact and disproportionate burden thresholds. Additionally, Torrance Transit also hosted a virtual public meeting on Monday, May 5. The comment period for this plan was open for 30 days prior as part of the overall Title VI Program Update. The public comment session was announced on the Daily Breeze Newspaper, La Opinion (Spanish Newspaper), our City Clerk’s Notice Board, our social media sites Facebook and Twitter, and car cards on our buses.

Attachment C is an example of Torrance Transit’s policy and procedure for public comment and participation in service and fare changes. Our public Participation Plan is posted on our agency’s website.

This Plan guides all of Torrance Transit’s outreach to gather important public input on possible changes to bus service, new projects in planning and construction, fare changes and other programs. The goal of this plan is to ensure that the public, especially minority and low-income populations, along with important stakeholders have and understanding that they have a stake in the process and that their buy-ins are important to the agency as we seek to make changes. This transformation through transportation will impact stakeholders throughout the region. As such, it is essential that Torrance Transit continues to bridge connections with communities and individuals who have deep relationships and insights into community specific needs and opportunities through a comprehensive and sustained public participation program regarded as the nation’s gold-standard.

This Plan meets and exceeds the requirements set forth by the FTA, FHWA, and Title VI. It is accountable, first and foremost, to the public, and it reflects the agency’s dedication to provide a robust and inclusive public engagement program that sustains, strengthens and deepens our relationships with stakeholders in our service area.

E. Limited English Proficiency (LEP) Plan

Torrance Transit is committed to ensuring that no person is excluded from participation in or denied the benefits of its transit services on the basis of race, color, or national origin. Torrance Transit developed a Limited English Proficiency (LEP) Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access services provided. As defined in 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. The plan outlines how to identify a person who may need 14 language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available. In order to prepare this plan, the Torrance Transit undertook the U.S. Department of Transportation’s four-factor LEP analysis which considers the following factors:

1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a Torrance Transit program, activity or service.

2. The frequency with which LEP persons come in contact with Torrance Transit programs, activities or services.

3. The nature and importance of programs, activities or services provided by Torrance Transit to the LEP population.

4. The resources available to Torrance Transit and overall cost to provide LEP assistance.

ATTACHMENT D of this document is Torrance Transit’s LEP Plan that was developed in late 2011, adopted in early 2012 and last updated in April of 2022 to account for the demographic and system changes that had in the last 3 years.

F. Racial Breakdown of Non-Elected Advisory Councils

Torrance Transit has a high priority goal of providing customer-driven transit service, and particularly values the views and concerns of the large percentage of minority and low-income populations that utilize our system on a daily basis.

Transit reports directly to two advisory bodies (both seated by publicly elected officials):

• Torrance Transportation Committee – Chaired by a Torrance City Council Member (elected) and comprised of two additional City Council Members (elected)
• Torrance City Council – Chaired by the Mayor of Torrance (elected) and comprised of six City Council Members (elected).

As all of the individuals are elected into office, a racial breakdown of these advisory councils is not required.

G. Sub-recipient Monitoring

Torrance Transit is a direct recipient of federal funds and does not have any sub- recipients.
15 ATTACHMENT A: Copy of Notice of Civil Rights

16 ATTACHMENT B: Complaint Form

Title VI Complaint Form

(Complaints must be filed within 180 days of the alleged act of discrimination) Section I
Name:

Address:

Home
Telephone:

Work
Telephone:

Email:

Accessible
Format
Requirements
Large Print
[ ] Yes
[ ] No
TDD
[ ] Yes
[ ] No
Audio Tape
[ ] Yes
[ ] No
Other
[ ] Yes
[ ] No
Section II

Are you filing this complaint on your own behalf?

[ ] Yes* [ ] No
* - If you answered “Yes” to the question above, please go to Section III If you not, please provide the name
and relationship of the person for
whom you are filing this complaint.

Please explain why you are filing for this person.

Please confirm that you have obtained the permission of the person complaining if you are filing on their behalf: [ ] Yes [ ] No

Section III
I believe the discrimination I
experienced was based on (check
all that apply):
[ ] Race
[ ] Color
[ ] National Origin

17 Date of Alleged Discrimination :

Please explain what happened and why you believe were discriminated against.

Describe all persons who were involved. If you know the name and contact information of the person you believe discriminated against you, please include it here. Also include the name of any witnesses.

Section IV
Have you previously filed a Title VI complaint with the Torrance Transit System? [ ] Yes [ ] No
Have you filed a complaint with any
other Federal, State or local agency,
or with any Federal or State Court?
[ ] Federal Agency [ ] State
Agency [ ] Federal Court [ ]
Local Agency [ ] State Court
Please attach any additional written materials or information that you think is relevant to your complaint.

Name/Signature Date:

Please mail your completed form to: Or you can send your form by:

Torrance Transit System Fax: (310) 618-6229
20500 Madrona Avenue Email: [email protected] Torrance, CA 90503
Attn: Administration Manager
18 ATTACHMENT B1: Department SOP on Title VI Policies and Procedures

TORRANCE TRANSIT SYSTEM

DIVISION: Administration and Operations

POLICY: The Administration and Operations Division shall have a policy for handling Title VI Complaints

PROCEDURE:

The Torrance Transit System is committed to ensuring that no person is excluded from participation in, or denied the benefits of services on the basis of race, color and national origin as protected by the Civil Rights Act of 1964, as amended.

In addition, the frequency of service, age and quality of Torrance Transit vehicles assigned to routes, and location of routes will not be determined on the basis of race, color, and national origin. This information can be accessed via Torrance Transit’s website at: https://transit.torranceca.gov/our-city/transit/rider- information/title-viv

The following is the guideline of procedural steps to be followed.

Receipt of the Title VI Complaint – may be via e-mail, mail, phone, walk-in, other department, field supervisor and other Transit staff. A draft of the proposed Title VI Complaint Form is attached.

2. Referral to Review Officer: Upon receipt of the Complaint, the Transit Administration Manager and/or Operations Manager shall assign one or more staff (most likely a Department Analyst, Supervisor or the Senior 19 Business Manager), to evaluate and investigate the Complaint, in consultation with the City of Torrance City Attorney’s Office, and most likely with the involvement of the Risk Manager and Personnel Department.

Transit staff assigned shall complete their review no later than 60 calendar days after the date Torrance Transit received the Title VI Complaint. If more time is required, the Administration Manager and/or Operations Manager shall notify the Complainant of the estimated time-frame for completing the review. Upon completion of the review, staff shall make a recommendation regarding the merit of the Complaint and whether remedial actions are available to provide redress. Additionally, Transit staff may recommend improvements to Torrance Transit’s processes relative to Title VI, as appropriate. Transit staff shall forward their recommendations to the Administration Manager and/or Operations Manager for concurrence. If s/he concurs, s/he shall issue Torrance Transit’s written response to the Complainant.

4. Appeal: If the request for reconsideration is denied, the Complainant may appeal the Transit Director’s response to the Complaint by submitting a written appeal to the Assistant City Manager of the City of Torrance, no later than 10 calendar days after receipt of the Transit Director’s written decision rejecting reconsideration.

5. Submission of Complaint to the Federal Transit Administration: You may also file a complaint directly with the Federal Transit Administration at FTA Office of Civil Rights, 1200 New Jersey Ave. SE, Washington, DC 20590.

20 ATTACHMENT C: Public Participation Plan

City of Torrance Transit System

Public Review and Participation of Torrance Transit’s on-going effort to ensure non- discrimination and equal access to transit services regardless of race, color, or national origin is crucial.

Staff posted legal notice regarding the Title VI Program Report on April 24, 2025 to the Daily Breeze Newspaper, La Opinion, Transit’s website and social media pages in order to notify the public. In addition, staff also allowed the public 30 days to provide feedback and comments regarding the plan as required by FTA. On Thursday, May 1, 2025 @ 11am, Torrance Transit hosted an in-person public hearing in both English and Spanish to allow the public to provide feedback regarding the public participation plan, major service change threshold, and disparate impact and disproportionate burden thresholds. Additionally, Torrance Transit also hosted a virtual public meeting on Monday, May 5, 2025.

Both English and Spanish presentations were available at the public hearing.

A copy of the Draft Title VI Program Report, which included the participation plan and how we set major service change, disparate impact and disproportionate burden threshold, was placed in our administrative office for any members of the public to come and read. A pdf version of the plan was also posted on our website at https://transit.torranceca.gov/our-city/transit/rider-information/title-viv

21 22

23 24

On May 20th, 2025, Torrance Transit’s governing board (The Torrance City Council) approved our program report along with our public participation plan. See Attachment F.

Guidelines for Public Review and Participation: Fare and Service Changes Updated: 5/31/2025

The Torrance Transit System’s policy on Required Public Comment conforms to the requirements of the Federal Transit Administration, state and local transit authorities, and the City of Torrance Procedure. The purpose of this policy is to ensure the opportunity for public participation prior to making significant changes in fares or service, which impact riders on the Torrance Transit System. In addition, this plan is to ensure that the public, especially minority and low-income populations, along with important stakeholders have and understanding that they have a stake in the process and that their buy-ins are important to the agency, as we seek to make changes and improvements to the service.

I. Fare Changes Requiring Public Review
A. All changes to the existing fare structure, including transit passes (whether an increase or decrease) by the Torrance Transit System (TTS) shall require the solicitation of public comment.

II. Service Changes Requiring Public Review
A. All changes to the existing level of service (whether an increase or decrease) on any of TTS’s existing twelve (12) routes of greater than twenty (25) percent of revenue vehicle hours or revenue vehicle miles shall necessitate the solicitation of public comment.

B. Any proposed new route or routing coverage change greater than 25 percent in revenue miles or hours for an existing route shall be deemed a major service change and require public comment.

C. Experimental service changes of more than 180 days will require public comment.

D. Emergency service changes of more than one year will require public comment.

III. Procedures for Conduct of Public Review
A. A public hearing is mandatory for any fare change or for any service change, greater than 25 percent as described in the previous sections.

Any new proposed routes or service coverage changes shall also require public hearing. The public hearing may be held in conjunction with a meeting of the Torrance City Council or at separate meetings organized by staff. Spanish speaking translators were present to 25 address LEP language population during all public engagement meetings.

B. Publish legal notice describing proposed change in service or fares prior to the hearing date. Notice will be in both English and Spanish and languages that are identified under the LEP Plan.

C. Notice will appear in both English and Spanish car cards and take ones on all of 63 buses. Social media posts regarding public hearing dates will also appear on Torrance Transit’s Facebook and Twitter accounts in both English and Spanish. Our website
transit.torranceca.gov will also have notices of public outreach sessions and information on all upcoming changes.

D. Notice will also appear on local newspaper and major Spanish language newspaper media for both English and Spanish and languages that are identified under the LEP Plan.

E. Notification of intent to change fares or change levels of service and information on public hearing will be posted on TTS (where appropriate) transit vehicles and at the West Annex Transit Center.

F. Public comment will be accepted at public hearing and by written submission, telephone voice mail or message, and e-mail.

G. Consideration will be given to all public submissions and comments.

Summary of Recent Public Review and Participation

Background
In June 2022, Torrance Transit initiated a comprehensive public outreach effort to carry out our phase two Torrance Transtit Tomorrow Plan which included improving the rider experience, increasing ridership, and integrating the future Torrance Transit Regional Terminal. Torrance Transit Tomorrow Plan was a 16-month study examined service design, operations, ridership, demographics, travel patterns, and planned development in the region. The study, branded Torrance Transit Tomorrow, also included rider, operator, and stakeholder engagement. The outcome of the study is an implementable 6-year plan to optimize and expand Torrance Transit.

As recommended in the Torrance Transit’s approved Tomorrow Plan, Starting in June 2023, Torrance Transit will connect Lines 1, Rapid 3, 4X, 5, 6, and 10 with our new state-of-the-art Mary K. Giordano Regional Transit Center located at 465 Crenshaw Boulevard in Torrance between Torrance Boulevard and Del Amo Boulevard.

Torrance Transit will also terminate Lines 2 and 5 at El Camino College, increase weekday frequency on Line 3, add back Rapid 3 service, connect Line 2 with the new Redondo Beach Transit Center (located at 1521 Kingsdale Avenue in Redondo Beach), and extend the Line 10 from the Crenshaw C Line Station to Downtown Inglewood. All 26 lines would run on weekdays while Lines 1, 3, 8, 10, and 13 would run on Saturdays and Sundays.

Public Hearings
In March and April of 2022, Torrance Transit held a series of virtual public hearings that allowed for riders and the public to give their input on Torrance Transit’s proposed service changes and expansion.

Public Hearing Dates
Meeting Date Location
Torrance Transit Summer 2022
Service Changes Public Hearing
Monday | March 28, 2022 | 6:00 pm Virtual
(Zoom)
Torrance Transit Summer 2022
Service Changes Public Hearing
Tuesday | March 29, 2022 | 6:00 pm Virtual
(Zoom)
Torrance Transit Summer 2022
Service Changes Public Hearing
Saturday | April 2, 2022 | 10:00 am Virtual
(Zoom)

Public Hearing Format
The public hearings were all virtual with the option to watch online or listen by phone.

Each meeting started with prerecorded presentations of Torrance Transit’s Summer 2022 Service Changes, both in English and Spanish, followed by questions and comments from the public. Those unable to attend a live public hearing had the option to watch the pre-recorded presentations available on our YouTube page.

There were five ways to comment:
- Virtual public hearings either through chat function or verbally - Voicemail to (310) 781-6925
- By email to [email protected]
- By mail to 20500 Madrona Ave, Torrance, CA
- By Google Form at https://forms.gle/VufrzX3kSxf1yx1y7

Public Information Distribution
In early March 2022, a number of public notices were posted and outreach was conducted to raise awareness for our public hearings and to gather input from the 27 public. This outreach included the use of car cards, take ones, social media posts, messages through the Transit App, and online posts on our website.

The Transit App banner allowed for us to reach 17,803 users, 1,752 (9.8%) of whom clicked through to view the information.

Notification for Public Hearings
Notification of Public Hearings
Print Notices • Car cards placed in all of our fleet of 63 buses • English and Spanish take-ones were placed in our fleet of 63 buses
Digital
Communications
• Torrance Transit’s website included meeting information and videos of the presentations
• 11 Torrance Transit social media posts (Facebook and
Twitter) published regarding our public hearings and how to submit input
• Publication of information through the Transit App in the form of a banner which riders could tap in order to quickly access Torrance Transit’s website

Comments Received
A total of 88 comments were received throughout the comment period. 26 were submitted via Zoom during public hearings, 7 through email, 46 through Google Form, 1 through phone calls/voicemails, and 8 through social media. Comments from the public fell into a few recurring subjects:
• A desire for improved frequency during all service periods (Weekday, Saturday, and Sunday)
• Questions surrounding the Mary K. Giordano Regional Transit Center • Questions regarding the ongoing operator shortage
• 50-80% Support for all of the proposed changes except Line 2 and 5 terminating at El Camino College with only 34% Support

Public Hearing Notices
28 Print Notices on Torrance Transit Buses

29 30

31 Digital Communications

32 33

34 35

Digital Communications: Facebook

36 37

38 39

Digital Communications: Twitter

40 41

Digital Communication: Transit App

42 ATTACHMENT D: LEP Plan

City of Torrance Limited English Proficiency Plan

Updated May 2025

43 LIMITED ENGLISH PROFICIENCY [LEP] PLAN

TORRANCE TRANSIT SYSTEM

CITY OF TORRANCE, CALIFORNIA
Updated May 2025

Introduction

This Limited English Proficiency (LEP) Plan has been prepared to address Torrance Transit’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 which 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 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”.

Torrance Transit is committed to ensuring that no person is excluded from participation in or denied the benefits of its transit services on the basis of race, color, or national origin.

This plan was developed to guide Torrance Transit in its administration and management of Title VI related activities.

Plan Summary

Torrance Transit has developed this Limited English Proficiency Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency [LEP] who wish to access services provided. As defined in 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. This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available. In order to prepare this plan, the Torrance Transit undertook the U.S. Department of Transportation’s four-factor LEP analysis which considers the following factors:

1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a Torrance Transit program, activity or service.

2. The frequency with which LEP persons come in contact with Torrance Transit programs, activities or services.

3. The nature and importance of programs, activities or services provided by Torrance Transit to the LEP population.
44 4. The resources available to Torrance Transit and overall cost to provide LEP assistance.

A summary of the results of the four-factor analysis is in the following section.

Four-Factor Analysis

1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a Torrance Transit program, activity or service.

Torrance Transit reviewed 2023 (ACS 5-year estimates) U.S Census tract level data.

Those census tracts that were within ¼ mile of a Torrance Transit bus stop were considered part of the Torrance Transit service area. The review indicated that the total service area has a population of reportedly 786,084 individuals who are five years of age or older. Of those persons, 172,520 (21.95%) speak English “less than very well”.

Of those persons with limited English proficiency, 111,535 (64.65%) speak Spanish.

The next languages listed with the highest number of persons that speak English “less than very well” were: 1) Korean at 15,856 persons (9.19%); Chinese (including Mandarin and Cantonese) at 9,068 (5.26%); Filipino/Tagalog at 9,088 (5.27%); and Vietnamese at 3,957 (2.29%). A number of other language groups (i.e. – Japanese, Arabic, Persian, Hindi, etc.) make up the remainder of limited English speaking persons in the service area.

2. The frequency with which LEP persons come in contact with Torrance Transit programs, activities or services.

Torrance Transit reviewed the frequency with which staff and drivers have, or could have, contact with LEP persons. This includes reviewing phone inquiries and surveying bus operators and customer service staff. To date, Torrance Transit bus operators and staff have had almost 60% report they received requests for assistance in languages other than English. In an optional survey of bus operators and customer service staff, approximately 35% indicated a fairly high level of interaction with LEP persons. Most (86%) bus operators and customer service staff surveyed indicated that they have daily interaction with LEP persons. Approximately 10% of bus operators surveyed interact with LEP persons 10 or more times a day.

The predominant language encountered by bus operators is Spanish (53%), with 45 some interaction with Korean-speaking passengers (9%). There have been few requests made to bus operators for language translation of public information, with 39% of operators indicating that passengers do not request translated materials.

46 47

In a 2018 survey for the Torrance Transit Tomorrow Plan riders were asked about the languages they speak. Most respondents are fluent in English (82%) and it is the most 48 common language spoken at home. Spanish is the next most common language (28%), followed by Tagalog (6%). Four percent of respondents chose “Other” as an option.

None of the written responses accounted for a majority of those who selected “Other.”

49 Figure 1: Torrance Transit Service Area Census Tracts and Route Network

50 Figure 2: Percentage of Population Speaks English Only

51 Figure 3: Percentage of Population Speaks with Little or No English Proficiency

52 3. The nature and importance of programs, activities or services provided by Torrance Transit to the LEP population.

As detailed in Figures 1 through 3, census tracts with the majority of limited English speaking persons were located primarily in the Downtown Los Angeles area and I-110 Freeway corridor as well as portions of the service area in the communities of Wilmington and Long Beach. Because Torrance Transit service to Downtown Los Angeles is express-oriented with few stops, the largest geographic concentration of LEP individuals in the Torrance Transit service area that has access to local bus service is in the Wilmington area. Between 15% - 45% of the Wilmington community is Spanish- speaking with little or no English proficiency. The Wilmington Branch of the Los Angeles Public Library System, located near Torrance Transit Line 3, provides literacy programs to community residents as well as residents of surrounding communities. In speaking with the literacy program director, many program participants use transit, although it is unknown how much they use Torrance Transit compared to other local transit providers (Metro, City of Los Angeles DASH). The director expressed that many individuals in the community look to the library as a source for information, and it was noted that the LEP population is usually reluctant to inquire about services or resources due to their residency status, their lack of fluency of English and illiteracy in Spanish.

These factors contribute to their unwillingness to make their needs known regarding transit and other issues.

4. The resources available to Torrance Transit and overall cost to provide LEP assistance.

Torrance Transit reviewed its available resources that could be used for providing LEP assistance, which of its documents would be the most valuable to be translated if the need should arise, and evaluated resources that could be used for outreach and translation efforts. Based on the four-factor analysis, Torrance Transit developed its LEP Plan as outlined in the following sections.

Language Assistance

A person who does not speak English as their primary language and who has a limited ability to read, write, speak or understand English may be a Limited English Proficient person and may be entitled to language assistance with respect to Torrance Transit’s programs and activities. Language assistance can include interpretation, which means oral or spoken transfer of a message from one language into another language and/or translation, which means the written transfer or a message from one language into another language. Torrance Transit will determine when interpretation and/or translation are needed and are reasonable. How the Torrance Transit staff may identify an LEP person who needs language assistance:

53 • Examine records to see if requests for language assistance have been received in the past, either at meetings or over the phone, to determine whether language assistance might be needed at future events.
• When Torrance Transit sponsors an event, have a staff person greet participants as they arrive. By informally engaging participants in conversation it is possible to gauge each attendee’s ability to speak and understand English. • Have Census Bureau Language Identification Flashcards available at Torrance Transit events near the registration table. Individuals self-identifying as persons not proficient in English may not be able to be accommodated with translation assistance at the event, but it will assist the sponsoring agency in identifying language assistance needs for future events.
• Network with local human service organizations, such as the Wilmington Library, that provide services to LEP individuals and seek opportunities to provide information on transit services.
• Vehicle operators and other front-line staff, including bus operators, supervisors, customer service representatives, clerical staff and dispatchers will be informally surveyed periodically on their experience concerning any contacts with LEP persons during the previous year.

Language Assistance Measures - Torrance Transit will strive to offer the following measures to LEP individuals, that is, persons who speak English “less than very well”,:

• Torrance Transit’s Title VI Policy and Torrance Transit staff will take reasonable steps to provide the opportunity for meaningful access to LEP clients who have difficulty communicating in English. Torrance Transit has been providing Spanish translation for important documents such as presentations, advertisements, car cards, and take ones. Torrance Transit will also provide translation to other languages when requested.
• If a client asks for language assistance and Torrance Transit determines that the client is an LEP person and that language assistance is necessary to provide meaningful access, reasonable efforts will be made to provide free language assistance. If reasonably possible, Torrance Transit will provide the language assistance in the LEP client’s preferred language. Torrance Transit has the discretion to determine whether language assistance is needed, and if so, the type of language assistance necessary to provide meaningful access. • Torrance Transit will periodically assess client needs for language assistance based on requests for interpreters and/or translation, as well as the literacy skills of the clients.
• When an interpreter is needed, in person or on the telephone, staff will attempt to determine what language is required and then access language assistance at one or more of the available resources identified under the section “Formal Interpreters” on Page 9.

54 Safe Harbor Stipulation

Federal law provides a “Safe Harbor” stipulation so that recipients can ensure with greater certainty that they comply with their obligations to provide written translations in languages other than English. A “safe harbor'' means that if a recipient provides written translations under certain circumstances, such action will be considered strong evidence of compliance with the recipient's written-translation obligations under Title VI.

The failure to provide written translations under the circumstances does not mean there is noncompliance, but rather provides a guide for recipients that would like greater certainty of compliance than can be provided by a fact-intensive, four-factor analysis.

For example, even if a safe harbor is not used, if written translation of a certain document(s) would be so burdensome as to defeat the legitimate objectives of its program, it is not necessary. Other ways of providing meaningful access, such as effective oral interpretation of certain vital documents, might be acceptable under such circumstances.

Strong evidence of compliance with the recipient's written-translation obligations under ‘safe harbor’ includes providing written translations of vital documents for each eligible LEP language group that constitutes 5% or 1,000, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered. Torrance Transit’s translation of other documents, if needed, can be provided orally.

This safe harbor provision applies to the translation of written documents only. It does not affect the requirement to provide meaningful access to LEP individuals through competent oral interpreters where oral language services are needed and are reasonable. However, within the past 2 years, Torrance Transit have been providing oral translation in Spanish at all of our public hearing sessions and in person outreach.

Only the Spanish, Chinese (including Mandarin and Cantonese), Korean, and Tagalog- speaking LEP language groups in the Torrance Transit service area constitutes the 5% or 1,000 persons of population threshold for which written translations of vital documents should be provided to meet the safe harbor standard. Given the small number of LEP language group members speaking other languages, the Torrance Transit budget, and the number of staff, it is deemed that written translations of core documents in languages other than Spanish would be so burdensome as to defeat the legitimate objectives of our programs. It is more appropriate in these cases for Torrance Transit to proceed with oral interpretation options for compliance with LEP regulations. With the identification of Korean, Tagalog, and Chinese-speaking population (including Mandarin and Cantonese) exceeding the threshold, Torrance Transit will translate important documents related to policies and programs in these two languages moving forward.

55 Staff Training

The following training will be provided to Torrance Transit staff:

• Information on the Title VI Policy and LEP responsibilities. • Description of language assistance services offered to the public. • Use of the Language Identification Flashcards.
• Documentation of language assistance requests.
• How to handle a potential Title VI/LEP complaint.

Information will be distributed to all Torrance Transit staff.

Translation of Documents

• In those cases where the need arises for LEP outreach, Torrance Transit will consider the following options:
o When staff prepares a document, or schedules a meeting, for which the target audience is expected to include LEP individuals, then documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population.
o Bus schedules, maps, and other transit publications will be made available in an alternative language for the known LEP population.

Formal Interpreters

56 • When necessary to provide meaningful access for LEP clients, Torrance Transit will provide qualified interpreters, including any bilingual staff of the City of Torrance, if available. At important stages that require one-on-one contact, written translation and verbal interpretation services will be provided consistent with the four-factor analysis used earlier.
• Torrance Transit may require a formal interpreter to certify to the following:
o The interpreter understood the matter communicated and rendered a competent interpretation.
o The interpreter will maintain private information. Non-public data will not be disclosed without written authorization from the client. o Bilingual City employees, when available, can provide limited assistance to Torrance Transit staff and LEP clients as part of their regular job duties.

Informal Interpreters

• Informal interpreters may include the family members, friends, legal guardians, service representatives or advocates of the LEP client. Torrance Transit staff will determine whether it is appropriate to rely on informal interpreters, depending upon the circumstances and subject matter of the communication. However, in many circumstances, informal interpreters, especially children, are not competent to provide quality and accurate interpretations. There may be issues of confidentiality, competency, or conflict of interest.
• An LEP person may use an informal interpreter of his or her own choosing and at their expense, either in place of or as a supplement to the free language assistance offered by Torrance Transit. If possible, Torrance Transit should accommodate an LEP client’s request to use an informal interpreter in place of a formal interpreter.
• If an LEP client prefers an informal interpreter, after Torrance Transit has offered free interpreter services, the informal interpreter may interpret. • If an LEP client wants to use his or her own informal interpreter, Torrance Transit reserves the right to also have a formal interpreter present.

Monitoring

Monitoring and Updating the LEP Plan - Torrance Transit will update the LEP as required by
U.S. DOT. At a minimum, the plan will be reviewed and updated when data from the 2023 U.S.

Census is available, or when it is clear that higher concentrations of LEP individuals are present in the Torrance Transit service area. Updates will include the following:

• The number of documented LEP person contacts encountered annually 57 • How the needs of LEP persons have been addressed
• Determination of the current LEP population in the service area • Determination as to whether the need for translation services has changed • Determine whether local language assistance programs have been effective and sufficient to meet the need
• Determine whether transit system’s financial resources are sufficient to fund language assistance resources needed
• Determine whether Torrance Transit fully complies with the goals of this LEP Plan
• Determine whether complaints have been received concerning the agency’s failure to meet the needs of LEP individuals

Dissemination of the Torrance Transit LEP Plan

• A link to the Torrance Transit LEP Plan and the Title VI Plan will be included on the City of Torrance website.
o https://transit.torranceca.gov/our-city/transit/rider-information/title-viv • Any person or agency with internet access will be able to access and download the plan from the City of Torrance website. Alternatively, any person or agency may request a copy of the plan via telephone, fax, mail, or in person, and shall be provided a copy of the plan at no cost. LEP individuals may request copies of the plan in translation which Torrance Transit will provide, if feasible. • Questions or comments regarding the LEP Plan may be submitted to Torrance Transit, 20500 Madrona Avenue, Torrance, CA 90503, phone (310) 618-6266.

58 ATTACHMENT E:

SERVICE STANDARDS, POLICIES, AND MONITORING

TORRANCE TRANSIT SYSTEM

TITLE VI SERVICE STANDARDS, POLICIES, AND MONITORING

May 22, 2025

59 BACKGROUND

Federal Title VI requirements of the Civil Rights Act of 1964 were recently updated by the Federal Transit Administration (FTA) and now require each public transportation provider's to adopt five standards and policies:

•Major Service Change Policy;
•Disparate Impact Policy;
•Disproportionate Burden Policy;
•System-wide Service Standards; and
•System-wide Service Policies

Torrance Transit staff has developed draft standards and policies and included them within this document for review and adoption by the Torrance City Council.

The first policy defines "major service change" as a threshold for when an agency will conduct a thorough analysis of the potential effects of service changes on protected populations. For the second and third policies, agencies are required to define thresholds for when they will find that a fare change or major service change will result in a "disparate impact" on the minority population or a "disproportionate burden" on the low-income population. The last two policies define service standards and policies to be used when determining whether service and amenities are distributed equitably to minority and non-minority routes and facilities.

Information about the Title VI process, complaint procedures, and the proposed standards and policies are available via the Torrance Transit website as well by calling the customer service phone number.

These policies are in draft form and will be revised based on input from the public and the Board. They will be brought back as final recommendations for approval by the Torrance City Council at a later time.

60 MAJOR SERVICE CHANGE POLICY

All major increases or decreases in transit service are subject to a Title VI Equity Analysis prior to Board approval of the service change. A Title VI Equity Analysis completed for a major service change must be presented to the Torrance City Council for consideration and included in the Torrance Transit Title VI Program with a record of action taken by the City Council.

A major service change is defined as:

A. All changes to the existing level of service (whether an increase or decrease) on any of TTS’s existing eleven routes, of greater than twenty five (25) percent of revenue vehicle hours or revenue vehicle miles shall necessitate the solicitation of public comment.

B. Experimental service changes of no more than 12 months will not require public comment.

C. Emergency service changes of no more than 12 months will not require public comment.

D. All fare changes (including passes) shall require public comments.

Major Service changes and fare changes are subject to Service and Fare Equity Analysis (SAFE) as well, as stipulated by the Federal Transit Administration’s enforcement of Title VI of the Civil Rights Act of 1964. Impacts of the proposed changes are analyz ed to specifically ensure that they do not disproportionately impact the minority or low income population utilizing the service. The analysis accomplishes the following goals:

1. Defines and evaluates the impact on rider.

2. Identifies adverse impacts to low -income and minority riders as defined by the FTA’s enforcement of Title VI.

3. Considers alternatives or mitigating solutions to proposed service changes if there are adverse impacts.

DISPARATE IMPACT POLICY
This policy establishes a threshold for determining whether a given action has a disparate impact on minority populations. Per FTA Circular 4702.1 B:
61 Disparate impact refers to a facially neutral policy or practice that disproportionately affects members of a group identified by race, color, or national origin, where the recipient's policy or practice lacks a substantial legitimate justification and where there exists one or more alternatives that would serve the same legitimate objectives but with less disproportionate effect on the basis of race, color, or national origin.

The policy shall establish a threshold for determining when adverse effects of [fare/] service changes are borne disproportionately by minority populations. The disparate impact threshold defines statistically significant disparity and may be presented as a statistical percentage of impacts borne by minority populations compared to impacts borne by non minority populations. The disparate impact threshold must be applied uniformly... and cannot be altered until the next Title VI Program submission.

In the course of performing a Title VI Equity Analysis, Torrance Transit must analyze how the proposed action would impact minority as compared to non - minority populations. In the event the proposed action has a negative impact that affects minorities more than non-minorities with a disparity that exceeds the adopted Disparate Impact Threshold, or that benefits non -minorities more than minorities with a disparity that exceeds the adopted Disparate Impact Threshold, Torrance Transit must evaluate whether there is an alternative that has a more equitable impact. Otherwise, Torrance Transit must take measures to mitigate the impact of the proposed action on the affected minority population and demonstrate that a legitimate business purpose cannot otherwise be a ccomplished and that the proposed change is the least discriminatory alternative.

The Disparate Impact Threshold to determine if the adverse impacts of a major service change (as defined in the first part of this document) or a fare adjustment is established at fifteen (15) percent based on the cumulative impact of the proposed service and/or fare changes. This threshold applies to the difference of the impacts borne by minority populations compared to the same impacts borne by non -minority populations. The table below provides the existing minority population by route, based on the 202 3 American Community Survey 5 -Year Estimates Census Trac ts. Minority is defined as those who do not identify as “white alone” or “non -Hispanic”. Minority Routes are defined as any Torrance Transit route that has minority percentage higher than the overall minority percentage within Torrance Transit service area (1/4 mile radius of our bus routes).
62 63

Route
Population (Within 1/4
mi.) Percent Minority
Minority
Route?
Line 1 116,499 80.5% Yes
Line 2 104,784 62.1% No
Line 3 213,952 65.5% No
Rapid 3 165,783 68.7% No
Line 4X 254,376 75.8% Yes
Line 5 101,545 64.9% No
Line 6 91,428 77.8% Yes
Line 7 108,921 63.2% No
Line 8 130,036 56.9% No
Line 9 107,979 63.8% No
Line 10 190,425 77.4% Yes
Line 13 167,071 61.0% No
System-wide 829,194 69.9%

DISPROPORTIONATE BURDEN POLICY

This policy establishes a threshold for determining whether a given action has a disproportionate burden on low-income populations versus non-low-income populations. The Disproportionate Burden Policy applies only to low -income populations that are not also minority populations. Per FTA Circular 4702.1 B:

The policy shall establish a threshold for determining when adverse effects of [fare/]service changes are borne disproportionately by low -income populations. The disproportionate burden threshold defines statistically significant disparity and may be presented as a statistical percentage of impacts borne by low-income populations as compared to impacts born by non-low-income populations ... The disproportionate burden threshold must be applied uniformly ... and cannot be altered until the next [Title VI] program submission.... At the conclusion of the analysis, if the transit provider finds that low -income populations will bear a disproportionate burden of the proposed fare[lservice] change, the transit provider should take steps to avoid, minimize, or mitigate impacts where practicable. The transit provider should describe alternatives available to low -income 64 populations affected by the fare [service] changes.

The Torrance Transit’s Disproportionate Burden Threshold to determine if the adverse impacts of a major service change (as defined in the first part of this document) or a fare adjustment is established at fifteen (15) percent based on the cumulative impac t of the proposed service and/or fare changes. This threshold applies to the difference of the impacts borne by low -income populations compared to the same impacts borne by non -low-income populations. The table below provides the existing low -income population by route, based on the US American Community Survey 2018-2022 by Census Tract. The low income status is defined as households and families earning less than or equal to $ 68,150, which is the very low income threshold for a three-person household in Los Angeles County. This monetary figure typically reflects 50 percent of the median family income for Los Angeles County as determined by the U.S. Department of Housing and Urban Dev elopment revised on April 15, 2025 . Low-income Routes are defined as any To rrance Transit route that has low-income population percentage higher than the overall low-income percentage within Torrance Transit service area (1/4 mile radius of our bus routes).
65 66

Route Population (within 1/4 mi)
Percent Low
Income

Low-
Income
Route?
Line 1 116,499 19.1%

No
Line 2 104,784 6.5%

No
Line 3 213,952 16.7%

No
Rapid 3 165,783 21.5%

No
Line 4X 254,376 25.0%

Yes
Line 5 101,545 3.4%

No
Line 6 91,428 4.9%

No
Line 7 108,921 3.1%

No
Line 8 130,036 8.0%

No
Line 9 107,979 6.9%

No
Line 10 190,425 23.1%

Yes
Line 13 167,071 6.8%

No
System-wide 829,194 21.7%

SYSTEMWIDE SERVICE STANDARDS

Pursuant to requirements set forth in The Federal Transit Administration's (FTA) Circular 4702.1 B Torrance Transit must establish and monitor its performance under quantitative Service Standards and qualitative Service Policies. These service standards co ntained herein are used to develop and maintain efficient and effective fixed -route transit service. In some cases, these standards differ from standards used by Torrance Transit for other purposes.

The FTA requires all fixed -route transit providers of public transportation to develop quantitative standards for the following indicators. Individual public 67 transportation providers set these standards; therefore, these standards will apply to each individual agency rather than across the entire transit industry:

• Vehicle Load Factor;
• Vehicle Headways;
• On-Time Performance; and
• Service Availability

For the purposes of defining service standards and policies for Torrance Transit fixed -route service, the agency has split its system into three route categories:

Local: Moves passengers on arterial streets with stop spacing on average of

0.25 mile between major transfer points, employment centers, shopping areas, and other points of interest.

Rapid: A limited stop service on arterial streets with minimum stop spacing on average of 0.8 mile.

Express: Serves passengers during peak hours and Saturday in and out of downtown Los Angeles via HOT ExpressLane with limited stops.

Category Line Number
Local 1, 2, 3, 5, 6, 7, 8, 9, 10
Rapid Rapid 3
Express 4X, Line 10X

The categories were not developed to, and in fact do not, differentiate routes by minority or income status of the areas or passengers served. Torrance Transit also defines service standards differently for peak and off-peak service. “Off-Peak" refers to weekday midday and evening service, as well as Saturday, Sunday, and Holiday service. Peak travel times are defined between 6 a.m. and 9 a.m. and 3 p.m. and 7 p. m.

1. Vehicle Load Factor

Vehicle Load Factor is described as follows by FTA Circular 4702.1 B:

Vehicle load can be expressed as the ratio of passengers to the total number of seats on a vehicle. For example, on a 40-seat bus, a vehicle load of 1.1 means all seats are filled and there are approximately 12 standees. A vehicle load standard is generally expressed in terms of peak and off-peak times. Transit providers that operate multiple modes of transit must describe the specific vehicle load standards for peak and off-peak times for each mode of fixed-route transit service (i.e., bus, express bus, 68 bus rapid transit, light rail, heavy rail, commuter rail, passenger ferry, etc., as applicable), as the standard may differ by mode.

Torrance Transit calculates Vehicle Load Factor by dividing the average peak passenger load on each route by the number of seats on the type of bus typically assigned to that route. Vehicle Load Factor is monitored regularly to ensure customer comfort and to determine whether additional capacity needs to be added to specific trips or routes based on changing demand patterns.

Vehicle Load Factor standards are presented in the table below.

Category Peak Off-
peak
Local Service 1.1 1.1
Rapid Service 1.1 N/A
Express Service 1.0 1.0

2. Vehicle Headway
Service demand, scheduling, constraints, fiscal constraints, and time’s capital resources are considerations to setting Torrance Transit’s vehicle headways. Vehicle headway is described as follows by FTA Circular 4702.1 B:

Vehicle headway is the amount of time between two vehicles traveling in the same direction on a given line or combination of lines. A shorter headway corresponds to more frequent service. Vehicle headways are measured in minutes (e.g., every 15 minutes); service frequency is measured in vehicles per hour (e.g., four buses per hour). Headways and frequency of service are general indications of the level of service provided along a route. Vehicle headway is one component of the amount of travel time expended by a passenger to reach his/her destination. A vehicle headway standard is generally expressed for peak and off-peak service as an increment of time (e.g., peak: every 15 minutes; and off peak: every 30 minutes). Transit providers may set different vehicle headway standards for different modes of transit service. A vehicle headway standard might establish a minimum frequency of service by area based on population density. For example, service at 15 - minute peak headways and 30 -minute off- peak headways might be the standard for routes serving the most densely populated portions of the service area, whereas 30 -minute peak headways and 45-minute off-peak headways might be the standard in less densely populate d areas. Headway standards are also typically related to vehicle load. For example, a service standard might state that vehicle headways will be improved 69 first on routes that exceed the load factor standard or on routes that have the highest load factors.

Torrance Transit calculates headway by determining the average length of time between buses on each route during peak and off-peak times. In the event a route regularly exceeds Vehicle Load Factor standards, Torrance Transit will evaluate whether frequency on that route should be adjusted within the confines of existing or expected funding levels. Vehicle headway standards are presented in the table below.

Category Peak Off-peak
Local Service 20 - 90 min 30 - 90 min
Rapid Service 20 - 55 min N/A
Express Service 55 - 90 min 60 – 90 min

3. On Time Performance

Torrance Transit has a system-wide on-time performance goal of 80%.

On-time performance is described as follows by FTA Circular 4702.1 B:

On-time performance is a measure of runs completed as scheduled. This criterion first must define what is considered to be "on time." For example, a transit provider may consider it acceptable if a vehicle completes a scheduled run between zero and five minutes late in comparison to the established schedule. On -time performance can be measured against route origins and destinations only, or against origins and destinations as well as specified time points along the route. Some transit providers set an on-time performance standard that prohibits vehicles from running early (i.e., ahead of schedule) while others allow vehicles to run early within a specified window of time (e.g., up to five minutes ahead of schedule). An acceptable level of performance must be defined (expressed as a percentage). The percentage of runs completed system-wide or on a particular route or line within the standard must be calculated and measured against the level of performance for the system. For example, a transit provider might define on -time performance as 95 percent of all runs system-wide or on a particular route or line completed within the allowed line time window.”

A bus is determined to be late if it departs the scheduled "time point" five (5) or more minutes later than the published time. Buses are considered early if they depart from a published time point one (1) minute or more prior to the scheduled departure. I t is Torrance Transit' goal to be on -time at least 70 70 percent of the time. On -time performance is tracked and published on a quarterly basis and is included in the Key Performance Indicator report to the Torrance Transit Director and Managers. Transit Operations staff regularly performs on road monitoring and on-time performance is one of the areas checked. Operators who consistently fail to meet on -time performance standards are counseled and advised as to how to best meet this requirement.

Discussions with bus operators are also used to identify vehicle sch eduling issues which are corrected through service changes four times annually. On - time performance standards are presented in the table below.

Category Peak Non-
peak
Local Service 80% 80%
Rapid Service 80% N/A
Express Service 80% 80%

4. Service Availability
Service availability/transit access is described as follows by FTA Circular 4702.1 B:

Service availability is a general measure of the distribution of routes within a transit provider's service area. For example, a transit provider might set a service standard to distribute routes such that a specified percentage of all residents in the service area are within a one-quarter mile walk of bus service or a one-half mile walk of rail service. A standard might also indicate the maximum distance between stops or stations. These measures related to coverage and stop/station distances might also vary by population density. For example, in more densely populated areas, the standa rd for bus stop distance might be a shorter distance than it would be in less densely populated areas, and the percentage of the total population within a one-quarter mile walk of routes or lines might be higher in more densely populated areas than it would be in less densely populated areas. Commuter rail service or passenger ferry service availability standards might include a threshold of residents within a certain driving distance as well as within walking distance of the stations or access to the terminal.

Torrance Transit’s goal is to ensure 70% percent of minority residents live within walking distance (i.e. - one quarter mile) of a bus stop. Torrance Transit service is particularly strong in communities with significant minority and low - income populations. Transit access is determined by mapping all active bus stops within the system and then calculating the population (based on latest Census data) within one -quarter mile radii of those stops. This information is 71 then compared to the total service area population. Overall systemwide minority population within ¼ mile of our bus stop s is 70%.

SYSTEMWIDE SERVICE POLICIES

The FTA requires fixed -route transit providers to develop a policy for each of the following service indicators. Transit providers also may opt to set policies for additional indicators. The following system -wide policies differ from service standards in t hat they are not necessarily based on meeting a quantitative threshold, but rather qualitative evaluation results:

• Vehicle Assignment; and
• Transit Amenities

1. Vehicle Assignment

Torrance Transit operates a fleet of 63 Alternative -Fuel Buses - 53 Compressed Natural Gas (CNG) 40 -foot coaches and 10 Gasoline -Electric Hybrid (GE) 41 -foot buses. Five diesel -powered buses are maintained as the emergency/contingency fleet, though they ra rely see operation presently. All coaches are wheelchair accessible, air -conditioned, including bike racks, and are low -floor design and have a kneeling feature for ADA wheelchair ramp.

Additionally, all Torrance Transit buses are also equipped with on bo ard Computer Aided Dispatch/Automatic Vehicle Locator (AVL) system, which includes on board camera, passenger counters, and automatic voice annunciators. All vehicles have electronic head signs and validating fare boxes.

Vehicle assignment is described as follows by FTA Circular 4702.1 B:

Vehicle assignment refers to the process by which transit vehicles are placed into service in depots and on routes throughout the transit provider's system. Policies for vehicle assignment may be based on the age of the vehicle, where age would be a proxy for condition. For example, a transit provider could set a policy to assign vehicles to depots so that the age of the vehicles at each depot does not exceed the system -wide average. The policy could also be based on the type of vehicle. For example, a transit provider may set a policy to assign vehicles with more capacity to routes with higher ridership and/or during peak periods. The policy could also be based on the type of service offered. For example, a transit provider may set a policy to assign specific types of vehicles to express or commuter service. Transit providers deploying vehicles equipped with technology designed to reduce emissions could choose to set a policy for how these vehicles will be deployed throughout the service area.

Torrance Transit's policy with respect to vehicle assignment is service -specific. 72 Torrance Transit currently has three modes of service (e.g. – Local, Rapid and Express). With the exception of the Rapid buses, which are specifically designated for those services, all Fixed Route buses are continuously rotated in service so that all the buses serve all lines on a rotational basis.

All buses have the same level of amenities available to riders. Buses are assigned in such a manner to ensure they are distributed equitably among the communities Torrance Transit serves. Buses are not assigned to a specific community or city within Torra nce Transit’s area based on vehicle age, size or propulsion system or size.

When new buses are purchased, they are distributed based on the age and mileage of the coaches at the yard. Coaches with the highest mileage or the oldest are selected first for retirement and replaced with a new bus.

2. Distribution of Transit Amenities

Transit amenities is described as follows by FTA Circular 4702.1 B:

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. Transit providers may have different policies for the different modes of service that they provide. Policies in this area address how these amenities are distributed within a transit system, and the manner of their distribution determines whether transit users have equal access to these amenities. This....is not intended to impact funding decisions for transit amenities. Rather, this ... applies after a transit provider has decided to fund an amenity.

Transit amenities are distributed on a system -wide basis. Transit amenities include shelters, benches and trash receptacles. The location of transit amenities is determined by factors such as ridership, individual requests, staff recommendations, and vendor preference (in the case of shelters which feature advertisements).

Torrance Transit is responsible for the transit amenities at all bus stops located within the City of Torrance. Other bus stop locations system -wide that are outside if the City of Torrance are maintained by individual cities in cooperation with Torrance T ransit. Additionally, Torrance Transit will also help those cities identify high traffic bus stops by providing ridership information and information regarding the bus routes servicing individual stops.

A. Bus Shelters

73 Local policy states that shelters are considered for installation based on the following criteria:

• Stops where more than 30 passengers boardings/transfer per day Local policy also states that all bus shelters within Torrance city limits shall include trash receptacles and that all stops with shelters and benches will be cleaned and have their trash receptacles emptied twice per week.

B. Bus Stop Benches

Benches are considered for installation based on the following criteria:

• Stops where more than 20 passengers boards.

C. Trash Receptacles

Trash receptacles are considered for installation based on the following criteria:

• Required by law for all stops with Torrance city boundaries.

Torrance Transit utilizes a contractor and City staff to empty bus stop trash receptacles within the City of Torrance at least once each week.

Since the previous program update, Torrance Transit has open a new Transit Center (non -federally funded) and replace 8 new benches and trash receptacles at bus stops . These enhancements are funded by local tax measures strictly for (non -federal fund) to enhance transit amenities. The new Transit Center and the bus stops are also served by Line 1, Line 4X, Line 6, and Line 10, which are minority routes.

As reported in previous Title VI program, Torrance Transit opened a new Regional Transit Center at 465 Crenshaw Blvd. in the City of Torrance. The new facility was funded under a local half -cent sales tax Transportation Measure called Measure R (for Los Angeles County) to pay for transportation projects and improvements . The Measure R was approved by voters in L.A.

County. In addition, the location of the facility was chosen and proved by the Torrance City Council, which consist of all elected officials.

Bus Stop Guidelines

The placement of bus stops is usually dependent on multiple factors including density of the area as well as location of the bus stop at the intersection. This section provides a guideline for Torrance Transit when seeking to relocate existing or determine new bus stops.

74 1. Bus Stop Spacing

The spacing of bus stops is important in ensuring a free -flow level of service, maintaining on -time performance threshold, and providing access to passengers within the area of a bus stop. When bus stops are located too closely to one another, the walking distance will be reduced. However, the operating speed of the bus significantly increases. Buses will also have to stop and pick up passengers more often and will not reach an optimum speed desired. Closely-spaced bus stops will create an overall longer bu s trip time.

The goal of Torrance Transit is ensure that passengers have easily accessible bus stops, while at the same time, our buses can maintain optimal system speeds. The table below provides minimum and maximum spacing to all three modes of service provided by To rrance Transit. These threshold will be used when reviewing bus stop placement on any given line.

Category Minimum Spacing (Mile) Maximum Spacing (Mile)
Local Service 0.25 0.5
Rapid
Service 0.8 1.25
Express
Service 0.5 2.5

Whenever possible, bus stops will be placed at the minimum spacing to allow for reduced travel times throughout the system. When a route travels on freeway or through a low density land use area (e.g. commercial, industrial, etc.), minimum spacing may incr ease due to the lack of safe location to stop.

2. Bus Stop Placement

Torrance Transit utilizes a possible of three locations at any given intersection for a bus stop: near -side, (immediately before the intersection), mid -block (between two intersections), and far -side (immediately after the intersection).

As a guideline, wh en relocating or installing new bus stops, bus poles should be installed on the far -side of an intersection. Far -side stops are often a preferential option over mid -block or near -side because far -side locations are better in terms of safety and schedule ad herence. In the case of our Rapid 3 Line, fare -side stops also compliments to the Bus Signal Priority Program (BSP).

Near-side stops are also acceptable when a school or hospital is located on the same side as it eliminates the vulnerability of the passengers having to cross 75 the street. In this case, near-side stop is often preferred as they provide a safer environment for passengers. Below is an assessment of our bus stops improvements process for new service beginning June 2023. Minority routes are proposed to have a 6.78% reduction in stops compared to 7.65% for non - minority routes, or a difference of 0.88 percentage points.

Low-income routes will not see a reduction in stops, while non -low income routes will see an 8.54% reduction.

GUIDELINES FOR MONITORING SERVICE STANDARDS AND

PROCEDURES

In compliance with FTA Circular 4702.1B, Torrance Transit must perform a system-wide monitoring process of its performance relative to its service standards and service policies provide in previous sections not less than every three years. The monitoring process includes comparing minority transit routes to non -minority transit routes to ensure that equal service is being provided system wide. Similar process is also compared between low -income and non - low-income routes.

A minority route is defined as one in which the route’s minority population percentage is greater than the minority population percentage found in the service area. The table below describes existing minority routes and non - minority routes within the system.

Route Population (Within 1/4 mi.) Percent Minority
Minority
Route?

76 Line 1 116,499 80.5% Yes
Line 2 104,784 62.1% No
Line 3 213,952 65.5% No
Rapid 3 165,783 68.7% No
Line 4X 254,376 75.8% Yes
Line 5 101,545 64.9% No
Line 6 91,428 77.8% Yes
Line 7 108,921 63.2% No
Line 8 130,036 56.9% No
Line 9 107,979 63.8% No
Line 10 190,425 77.4% Yes
Line 13 167,071 61.0% No
System-wide 829,194 69.9%

The low income status is defined as households and families earning less than $68,150, which is the very low income threshold for a three-person household in Los Angeles County. This monetary figure typically reflects 50 percent of the median family income determined by the U.S. Department of Housing and Urban Development revised on April 15, 2025. A low-income route is defined as one in which the route’s low -income percentage is greater than the overall low-income percentage found in the service area. The table below describes existing minority routes and non-minority routes within the system.

Route Population (within 1/4 mi)
Percent Low
Income

Low-
Income
Route?
Line 1 116,499 19.1%

No
Line 2 104,784 6.5%

No
77 Line 3 213,952 16.7%

No
Rapid 3 165,783 21.5%

No
Line 4X 254,376 25.0%

Yes
Line 5 101,545 3.4%

No
Line 6 91,428 4.9%

No
Line 7 108,921 3.1%

No
Line 8 130,036 8.0%

No
Line 9 107,979 6.9%

No
Line 10 190,425 23.1%

Yes
Line 13 167,071 6.8%

No
System-wide 829,194 21.7%

Additionally, service standards to be analyzed by route and minority vs. non- minority and low-income vs. non-low-income are:

1. Vehicle load

2. Vehicle headway

3. On-time performance

4. Service availability

Service policies to be analyzed system -wide:

1. Vehicle assignment

2. Distribution of transit amenities

METHODOLOGY FOR TITLE VI SERVICE STANDARD AND POLICY

ASSESSMENT

Vehicle Load: Vehicle loads will be analyzed by individual route during peak and off peak times. Peak travel times are defined as 6 a.m. to 9 a.m. and 3 p.m. to 7 p.m. Off -peak times are early morning, midday, late evening, as well as Saturday, Sunday, and holidays. Ma ximum load factors is defined as the maximum achievable capacity calculated by dividing the actual total seated and 78 standing capacity by the seated capacity of the vehicle. In this analysis, Torrance Transit staff will utilize data from the most recent schedule change.

The tables below provide examples that will be included in the results of the analysis. Data may also be presented in graphical format.

AM Peak Off-Peak PM Peak
Route Low
Income
Route
Minority
Route
Average
Load
Factor
Standard
Load
Factor
Average
Load
Factor
Standard
Load
Factor
Average
Load
Factor
Standard
Load
Factor
1 No Yes 0.4 1.3 0.5 1.1 0.6 1.3
2 No No 0.1 1.3 0.2 1.1 0.3 1.3
3 No No 1.1 1.3 1.7 1.1 1.8 1.3
5 No No 0.2 1.3 0.3 1.1 0.3 1.3
6 No Yes 0.3 1.3 0.4 1.1 0.5 1.3
7 No No 0.2 1.3 0.4 1.1 0.5 1.3
8 No No 0.4 1.3 0.8 1.1 0.9 1.3
9 No No 0.2 1.3 0.4 1.1 0.4 1.3
10 Yes Yes 0.5 1.3 0.6 1.1 1.0 1.3
4X Yes Yes 0.5 1.3 0.7 1.1 0.9 1.3
R3 No No 0.3 1.3 0.6 1.1 0.8 1.3
13 No No 0.8 1.3 0.9 1.1 1.1 1.3

Based on staff’s analysis, only Line 3 during off -peak and pm peak service hours have exceeded vehicle load factor standard of 1.1. Staff is planning to increase service in the next service change to alleviate the overcrowding during these time periods. Line 3 is not considered a minority or low -income route

AM Peak Off-Peak PM Peak
Route Average
Load
Factor
Standard
Load
Factor
Average
Load
Factor
Standard
Load
Factor
Average
Load
Factor
Standard
Load
Factor
Average
Minority
Route

0.4 1.3 0.6 1.1 0.7 1.3
Average
Non-
Minority

0.4 1.3 0.7 1.1 0.7 1.3

79 Route

AM Peak Off-Peak PM Peak
Route Average
Load
Factor
Standard
Load
Factor
Average
Load
Factor
Standard
Load
Factor
Average
Load
Factor
Standard
Load
Factor
Average
Low
Income
Route

0.5 1.3 0.6 1.1 0.9 1.3
Average
Non-
Low
Income
Route

0.4 1.3 0.6 1.1 0.7 1.3

Vehicle Headway: Vehicle headway will be analyzed by individual route during peak and off peak times. Peak travel times are defined as 6 a.m. to 9 a.m. and 3 p.m. to 7 p.m. Off-peak times are early morning, midday, late evening, as well as Saturday, Sunday, and holidays. Maximum load factors is defined as the maximum achievable capacity calculated by dividing the actual total seated and standing capacity by the seated capacity of the vehicle. In this analysis, Torrance Transit staff will utilize data from the most recent s chedule change.

The tables below provide examples that will be included in the results of the analysis. Data may also be presented in graphical format.

AM Peak Off-Peak PM Peak
Route
Minority
Route?
Low
Income?
Actual
Headway
Standard
Headway
Actual
Headway
Standard
Headway
Actual
Headway
Standard
Headway
1 Yes No 45.12 min 20-90 min 52.06 min 30-90 min 46.28 min 20-90 min 2 No No 71.67 min 20-90 min 73.63min 30-90 min 77.17 min 20-90 min 3 No No 25.74 min 20-90 min 27.36 min 30-90 min 24.27 min 20-90 min R3 No No 20.36 min 20-55 min N/A N/A 40.25 min 20-55 min 4X Yes Yes 75.29 min 55-90 min 63.5 min 60-90 min 77.26 min 55-90 min 5 No No 72.43 min 20-90 min 72.75 min 30-90 min 76.77 min 20-90 min 6 Yes No 57.67 min 20-90 min 58.54 min 30-90 min 58.52 min 20-90 min 7 No No 63.32 min 20-90 min 61.29 min 30-90 min 66.33 min 20-90 min 8 No No 42.24 min 20-90 min 59.86 min 30-90 min 45.48 min 20-90 min 9 No No 57.17 min 20-90 min 62.14 min 30-90 min 60.63 min 20-90 min 10 Yes Yes 59.17 min 20-90 min 62.14 min 30-90 min 60.63 min 20-90 min 13 No No 41.02 min 20-90 min 53.89 min 30-90 min 39.90 min 20-90 min 80 AM Peak Off-Peak PM Peak
Route
Actual
Headway
Standard
Headway
Actual
Headway
Standard
Headway
Actual
Headway
Standard
Headway
All Minority
Routes 59.29 min 20-90 min 59.06 min 30-90 min 60.66 min 20-90 min All
Non-Minority
Routes 49.24 min 20-90 min 58.70 min 30-90 min 53.85 min 20-90 min

AM Peak Off-Peak PM Peak
Route
Actual
Headway
Standard
Headway
Actual
Headway
Standard
Headway
Actual
Headway
Standard
Headway
Average Low-
Income Routes

67.23 min
20-90
min 62.82 min
30-90
min

68.95 min 20-90 min
Average Non-Low-
Income Routes

49.67 min
20-90
min 57.95 min
30-90
min

53.56 min 20-90 min

On-time Performance: On-time performance will be analyzed by individual route during weekday and weekends for peak and off -peak time period.

Torrance Transit shall include comparisons of overall on -time performance of minority lines and non-minority lines. A bus is determined to be late if it departs the scheduled "time point" five (5) or more minutes later than the published time. Buses are considered early if they depart from a published time point one (1) minute or more prior to the scheduled departure. In this analysis, Torrance Transit staff will utilize data from the most recent schedule change. The tables below provide examples that will be included in the results of the analysis. Data may also be presented in graphical format.

AM Peak Off-Peak PM Peak
Route
Minority
Route?
Low
Income?
Actual
OTP
Standard
OTP
Actual
OTP
Standard
OTP
Actual
OTP
Standard
OTP
1 Yes No 88.0% 80.0% 86.3% 80.0% 83.7% 80.0%
2 No No 82.9% 80.0% 89.4% 80.0% 85.6% 80.0%
3 No No 81.0% 80.0% 79.4% 80.0% 72.8% 80.0%
R3 No No 75.8% 80.0% -- -- 74.1% 80.0%
4X Yes Yes 80.8% 80.0% 72.5% 80.0% 63.8% 80.0%
5 No No 77.1% 80.0% 79.2% 80.0% 78.7% 80.0%
6 Yes No 92.0% 80.0% 80.0% 80.0% 78.1% 80.0%
7 No No 93.2% 80.0% 92.4% 80.0% 88.3% 80.0%
8 No No 79.7% 80.0% 78.9% 80.0% 69.0% 80.0%
9 No No 87.6% 80.0% 90.6% 80.0% 78.4% 80.0%
10 Yes Yes 85.8% 80.0% 83.6% 80.0% 64.1% 80.0%
81 13 No No 80.7% 80.0% 79.5% 79.9% 80.0%
Average
System
Wide

83.4% 81.7% 75.4%

AM Peak Off-Peak PM Peak
Route
Actual
OTP
Standard
OTP
Actual
OTP
Standard
OTP
Actual
OTP
Standard
OTP
Average Minority
Routes 87.1% 80.0% 83.3% 80.0% 73.9% 80.0%
Average Non-Minority
Routes 81.7% 80.0% 80.9% 80.0% 76.1% 80.0%
Average System
Wide 83.4% 80.0% 81.7% 80.0% 75.4% 80.0%

AM Peak Off-Peak PM Peak
Route
Actual
OTP
Standard
OTP
Actual
OTP
Standard
OTP
Actual
OTP
Standard
OTP
Average Low-Income
Routes 83.8% 80.0% 80.9% 80.0% 64.0% 80.0%
Average Non-Low-
Income Routes 83.3% 80.0% 81.8% 80.0% 77.2% 80.0%
Average System Wide 83.4% 80.0% 81.7% 80.0% 75.4% 80.0%

Service Availability: Service availability will be analyzed and measured by comparing the percentage of minority and non-minority population within ¼ mile of Torrance Transit bus stops. These numbers will also be used to compare with the overall service area percentage. Below i s our service availability for the most recent service change . Almost 7 0% of minority will have access to bus stops within our service area, based on a ¼ mile walking distance.

Population Within 1/4 Mile
Minority 505,146
Non-Minority 698,685
System-Wide 829,194

Category Population Within 1/4 Mile
Local
Service
Minority 896,939
Non-Minority 435,701
Rapid
Service
Minority 113,968
Non-Minority 51,815
Minority 192,924
82 Express
Service Non-Minority 61,452

Vehicle Assignment: Torrance Transit operates a fleet of 63 Alternative -Fuel Buses - 53 Compressed Natural Gas (CNG) 40-foot coaches and 10 Gasoline- Electric Hybrid (GE) 41 -foot buses. Five diesel -powered buses are maintained as the emergency/contingency fleet, though they ra rely see operation presently. Torrance Transit's policy with respect to vehicle assignment is service-specific. Torrance Transit currently has three modes of service (e.g. – Local, Rapid and Express). With the exception of the Rapid bu ses, which are specifically designated for those services, all Fixed Route buses are continuously rotated in service so that all the buses serve all lines on a rotational basis.

Using the table below, Torrance staff will compare minority and non -minority routes being served by the types of buses, average age of the buses, and their purchase dates. Data may also be presented in a graphical format as well.

Type of Buses
No. of Minority
Routes Served
Avg. Age of
Buses
Avg. Date of
Purchase
Compressed Natural
Gas (CNG) 6 6 2013
Gasoline-Electric
Hybrid 6 6 2013
Diesel-Powered -- -- --

Distribution of Transit Amenities: As mentioned in our “Service Policies” section, Torrance Transit is responsible for the transit amenities at all bus stops located within the City of Torrance. Other bus stop locations system -wide that are outside if the City of Torrance are maintained by individual cities in cooperation with Torrance Transit. Additionally, Torrance Transit will also help those cities identify high traffic bus stops by providing ridership information and information regarding the bus routes servicing individual stops.

Torrance Transit staff will provide a map of our system wide transit amenities including, transit centers, bus shelters, benches, trash receptacles, etc. relative to the location of the bus routes overlaying the locations of minority and non - minority populations. Additionally, a separate map will be provided showing just the transit amenities located in the City of Torrance overlaying the locations of minority and non -minority populations within the city. Data may also be presented in table format in additi on to transit amenities overlay maps.

Since the previous program update, Torrance Transit has open a new Transit 83 Center (non -federally funded) and replace 8 new benches and trash receptacles at bus stops. These enhancements are funded by local tax measures strictly for (non -federal fund) to enhance transit amenities. The new Transit Center and the bus stops are also served by Line 1, Line 4X, Line 6, and Line 10, which are minority routes.

As reported in previous Title VI program, Torrance Transit opened a new Regional Transit Center at 465 Crenshaw Blvd. in the City of Torrance. The new facility was funded under a local half -cent sales tax Transportation Measure called Measure R (for Los Angeles County) to pay for transportation projects and improv ements. The Measure R was approved by voters in L.A.

County. In addition, the location of the facility was chosen and proved by the Torrance City Council, which consist of all elected officials. 84 DEMOGRAPHIC OF RIDERSHIP

Torrance Transit conducted two surveys, one in 2020 and another in 2021 to further understand our riders and their travel patterns. Both surveys were administered online due to ensuring the safety and comfort of our staff and riders. These surveys were also advert ised on our buses, on our website, and through Transit App. Transit App has shown to help improve outreach to disadvantaged communities.

53.50%

21.80%

11.90%

12.90%
Torrance Transit Riders by
Income
Below $25,000 $25,000 - $49,999
85 59.40%

37.60%
1% 0% 2%
Torrance Transit Riders by
Gender Identity
Male Female
4%

37.60%

27.70%

23.80%

6.90%
Torrance Transit Riders by
Age
Below 18 19 - 30 31 - 50 51 - 64 65 or above
86 When are people riding Torrance Transit?

16.80%
1%

18.80%
2%

25.70%

35.60%
Torrance Transit Riders by
Race/Ethnicity
African American
American Indian/Alaskan Native
Asian
Native Hawaiian/Pacific Islander
Caucasian/White
Hispanic/Latino

25.30%

27.30%

24.20%

12.10%

11.10%
Torrance Transit Riders' Satisfaction
Very Satisfied Satisfied Neutral
Unsatisfied Very Unsatisfied
87 Why do people use Torrance Transit?

33.30%

31.30%

24.20%

11.10%
5:00 am - 8:59 am 9:00 am -1:59 pm 2:00 - 6:59 pm 7:00 pm - 11:00 pm

59.60%
4%
2%

13.10%

8.10%
13%
Work Medical Care Care for Someone Grocery Shopping/Pharmacy School Misc. 88 51.50%

29.30%

12.10%

6.10% 1%
Torrance Transit Riders' Level of Safety
Very safe Somewhat safe Neutral
Somewhat unsafe Very unsafe

50.50%

31.30%

11.10%

6.10% 1%
Torrance Transit Buses' Cleanliness
Very clean Somewhat clean
Neutral Somewhat unclean
Very unclean
89 TRAVEL PATTERNS

For what reason are you taking public
transit?
0 20 40 60 80 100 120

Work
Medical Care
Care for Someone
Grocery Shopping/Pharmacy Tips

Other
Which Torrrance Transit line do you
currently use?
20 40
60 80
Line 1
Line 2
Line 3
Line R3
Line 4X
Line 5
Line 6
Line 7
Line 8
Line 9
Line 10
90 SERVICE AND FARE EQUITY ANALYSIS

A Title VI Equity Analysis completed for a major service change or proposed fare change must be presented to the Torrance City Council for consideration and included in the Torrance Transit Title VI Program with a record of action taken by the City Council . Additionally, Torrance Transit has developed threshold for disparate impact and disproportionate burden per FTA Circular C 4702.1B. These thresholds are intended to ensure that major service changes or fare changes do not unfairly burden minority and low -income populations within our service area.

In order to meet with the requirements of the Circular, Torrance Transit must evaluate each service change and determine if it exceeds the major service change threshold. Should that threshold is exceeded, or when a fare change is proposed, Torrance Transit must provide analysis of the service change based on the disparate impact and disproportioned burden policies.

Major Service Change Analysis: As stated and defined in our major Service Change Policy, all major increases or decreases in transit service of greater than 25 percent of revenue vehicle hours or revenue vehicle miles shall subject to a Title VI Equity Analysis prior to Board approval of the service change and shall necessitate the solicitation of public comment.

The minority population of the entire service area is 70 percent and the low - income population of the entire service area is 21.7 percent. The Data for the minority population was derived from the 2023 American Community Survey 5-Year Estimates Census Tracts. The low-income data was determined by the U.S. Department of Housing and Urban Development revised on April 15, 2025. The table below provides an example of what our agency have been using to perform an analysis for all major service changes. The analysis compares the number of people trips before and after the service change for each individual route and the cumulative impact as a whole with respect to minority and low -income populations. The analysis will also compare the impact borne by minority and low- income groups for the service changes against the respective service area average.

A comprehensive public engagement process was conducted between March 9 through April 9, 2022 to gather public feedback and providing the public with the Service and Fare Equity Analysis for the proposed changes. The service change was launched on June 10, 2023, which included Torrance Transit adding some service back into the system as our agency continues to aggressively hire more bus operators.
91 Route Population
Percent
Minority
Percent
Low-
Income
Minority
Route?
Low-
Income
Route? Population
Proposed
Percent
Minority
Proposed
Percent
Low-
Income
Minority
Route?
Low-
Income
Route?
Disparate
Impact
Disproportionate
Burden
Line 1 121,888 82.9% 27.0% Yes No 121,891 82.9% 27.0% Yes No 0.0% 0.0% Line 2 186,127 75.8% 21.2% Yes No 105,653 63.7% 13.8% No No -11.1% -7.4% Line 3 218,976 74.7% 23.9% No No 218,976 74.7% 23.9% Yes No 0.0% 0.0% Rapid 3 214,945 74.6% 24.0% No No 175,844 76.7% 26.2% Yes No 1.9% 2.2% Line 4X 360,210 80.1% 37.3% Yes Yes 360,213 80.1% 37.3% Yes Yes 0.0% 0.0% Line 5 127,679 71.7% 15.2% No No 98,491 64.2% 12.8% No No -10.7% -2.4% Line 6 88,895 79.6% 19.7% Yes No 94,871 78.3% 19.2% Yes No 3.4% -0.5% Line 7 108,439 63.3% 14.1% No No 108,439 63.3% 14.1% No No 0.0% 0.0% Line 8 131,128 53.3% 11.6% No No 131,128 53.3% 11.6% No No 0.0% 0.0% Line 9 108,976 67.7% 16.1% No No 108,976 67.7% 16.1% No No 0.0% 0.0% Line 10 123,655 73.8% 15.5% No No 207,924 80.6% 22.6% Yes No 5.7% 7.0% Line 13 N/A N/A N/A No No 173,535 61.8% 15.9% No No 100% 100% System-wide 830,443 74.9% 27.9% 935,060 74.5% 27.5% -0.4% -0.4% Total
Pre-Pandemic June 2022
Route Revenue Miles Revenue Hours Number of Trips Revenue Miles Revenue Hours Number of Trips Revenue Miles Revenue Hours Number of Trips Minority Route Low-Income Route Line 1 225,967 14,809 16,780 141,115 9,337 9,455 -38% -37% -44% Yes No Line 2 127,821 8,603 9,810 53,525 4,467 7,140 -58% -48% -27% No No Line 3 557,990 38,890 31,835 336,527 25,850 19,030 -40% -34% -40% Yes No Rapid 3 120,694 8,339 7,395 58,194 3,991 3,570 -52% -52% -52% Yes No Line 4X 148,379 7,956 6,855 118,848 6,698 4,590 -20% -16% -33% Yes Yes Line 5 196,421 9,354 11,015 82,745 5,831 7,395 -58% -38% -33% No No Line 6 126,184 8,717 10,710 65,907 4,301 4,590 -48% -51% -57% Yes No Line 7 95,677 6,767 10,905 64,857 4,743 7,395 -32% -30% -32% No No Line 8 275,377 19,838 20,645 130,790 9,750 8,925 -53% -51% -57% No No Line 9 84,556 4,775 10,230 59,157 4,080 7,140 -30% -15% -30% No No Line 10 232,445 15,121 19,940 169,342 14,951 10,950 -27% -1% -45% Yes No Line 13 - - - 230,603 16,686 14,630 100% 100% 100% No No Total 2,191,511 143,167 156,120 1,511,609 110,684 104,810 -31% -23% -33% Pre-Pandemic (2019-10d) June 2022 Percent Change
92 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 379,395 24,803 25,775 October 2019 628,352 40,084 44,155 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 901,611 69,195 64,405 October 2019 1,563,159 103,083 111,965 Revenue Miles Revenue Hours Number of Trips
Minority -39.6% -38% -41.6%
Non-Minority -42.3% -33% -42.5%
Revenue Miles Revenue Hours Number of Trips

2.7% 5% 0.9%
Minority Routes
Non-Minority Routes
Percent Change from October 2019 to June 2022 Service Period Difference in Percent Change (Non Minority - Minority)
93 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 118,848 6,698 4,590 October 2019 148,379 7,956 6,855 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 1,162,158 87,299 85,590 October 2019 2,043,132 135,211 149,265 Revenue Miles Revenue Hours Number of Trips
Low Income -20% -15.8% -33%
Non-Low Income -43% -35.4% -43%
Revenue Miles Revenue Hours Number of Trips
23% 19.6% 10%
Difference in Percent Change (Low Income and Non-Low Income) Low Income Routes
Non-Low Income Routes
Percent Change from October 2019 to June 2022 Service Period 94 Route Population
Percent
Minority
Percent
Low-
Income
Minority
Route?
Low-
Income
Route? Population
Proposed
Percent
Minority
Proposed
Percent
Low-
Income
Minority
Route?
Low-
Income
Route?
Disparate
Impact
Disproportionate
Burden
Line 1 121,888 82.9% 27.0% Yes Yes 121,891 82.9% 27.0% Yes No 0.0% 0.0% Line 2 186,127 75.8% 21.2% Yes No 105,653 63.7% 13.8% No No -9.7% -13.1% Line 3 218,976 74.7% 23.9% Yes No 218,976 74.7% 23.9% Yes No 0.0% 0.0% Rapid 3 N/A N/A N/A N/A N/A 175,844 76.7% 26.2% Yes No 100% 100% Line 4X 360,210 80.1% 37.3% Yes Yes 360,213 80.1% 37.3% Yes Yes 0.0% 0.0% Line 5 127,679 71.7% 15.2% No No 98,491 64.2% 12.8% No No -9.2% -14.1% Line 6 88,895 79.6% 19.7% Yes No 94,871 78.3% 19.2% Yes No 4.8% -7.7% Line 7 108,439 63.3% 14.1% No No 108,439 63.3% 14.1% No No 0.0% 0.0% Line 8 131,128 53.3% 11.6% No No 131,128 53.3% 11.6% No No 0.0% 0.0% Line 9 108,976 67.7% 16.1% No No 108,976 67.7% 16.1% No No 0.0% 0.0% Line 10 123,655 73.8% 15.5% Yes No 207,924 80.6% 22.6% Yes No 7.1% -4.3% Line 13 173,535 61.8% 15.9% No No 173,535 61.8% 15.9% No No 0.0% 0.0% System-wide 866,069 73.4% 26.9% 935,060 74.5% 27.5% 1.1% 0.6% November 2021 June 2022
Route Revenue Miles Revenue Hours Number of Trips Revenue Miles Revenue Hours Number of Trips Revenue Miles Revenue Hours Number of Trips Minority Route Low-Income Route Line 1 134,087 9,137 9,910 141,115 9,337 9,455 5% 2% -5% Yes Yes Line 2 86,340 6,214 6,630 53,525 4,467 7,140 -38% -28% 8% No No Line 3 336,527 25,702 19,030 336,527 25,850 19,030 0% 1% 0% Yes No Rapid 3 - - - 58,194 3,991 3,570 100% 100% 100% Yes No Line 4X 111,800 6,231 4,590 118,848 6,698 4,590 6% 8% 0% Yes Yes Line 5 153,377 6,834 7,650 82,745 5,831 7,395 -46% -15% -3% No No Line 6 66,116 4,497 5,610 65,907 4,301 4,590 0% -4% -18% Yes No Line 7 64,857 4,752 7,395 64,857 4,743 7,395 0% 0% 0% No No Line 8 130,700 9,555 9,490 130,790 9,750 8,925 0% 2% -6% No No Line 9 59,157 3,999 7,140 59,157 4,080 7,140 0% 2% 0% No No Line 10 96,510 6,796 8,160 169,342 14,951 10,950 75% 120% 34% Yes No Line 13 240,853 17,463 15,285 230,603 16,686 14,630 -4% -4% -4% No No Total 1,480,325 101,178 100,890 1,511,609 110,684 104,810 2% 9% 4% Percent ChangeNovember 2021 June 2022
95 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 943,458 69,594 59,325 November 2021 831,380 58,575 53,930 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 568,152 41,090 45,485 November 2021 648,944 42,603 46,960 Revenue Miles Revenue Hours Number of Trips
Minority 13.5% 18.8% 10%
Non-Minority -12.4% -3.6% -3%
Revenue Miles Revenue Hours Number of Trips

25.9% 22.4% 13%
Non-Minority Routes
Minority Routes
Percent Change from November 2021 to June 2022 Service Period Difference in Percent Change (Non Minority - Minority)
96 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 259,963 16,035 14,045 November 2021 245,886 15,367 14,500 Service Period Revenue Miles Revenue Hours Number of Trips June 2022 1,251,646 94,649 90,765 November 2021 1,234,438 85,811 86,390 Revenue Miles Revenue Hours Number of Trips
Low Income 5.7% 4% -3%
Non-Low Income 1.4% 10% 5%
Revenue Miles Revenue Hours Number of Trips

4.3% 6% 8%
Difference in Percent Change (Low Income - Non- Low Income) Low Income Routes
Non-Low Income Routes
Percent Change from November 2021 to June 2022 Service Period 97 Fare Equity Analysis: According to our Fare Change Policy, all fare changes are subject to Equity Analysis as stipulated by the Federal Transit Administration’s enforcement of Title VI of the Civil Rights Act of 1964. Impacts of the proposed changes are analyzed to specifically ensure that they do not disproportionately impact the minority or low income population utilizing the fare media.

As part of the Fare Equity Analysis, Torrance Transit staff will provide graphical information regarding fare payment by ridership groups (minority, low -income and overall ridership). Additionally, the staff will also provide a table similar to the one shown below to identify a pattern in fare media usage by groups, the percent change of the fare media proposed, and how that proposed fare media change will affect minority and low -income groups compared with the overall usage based on our disparate impact and disproportionate burden threshold policies.

Torrance Transit did not make any fare change since the previous update on Title VI Service Standards, Policies, and Monitoring Report.

However, Torrance Transit is currently participating in a pilot regional GoPass program (Fareless System Initiative) to provide free fare to students only. The program is being paid by the school districts and Torrance Transit System charges the school districts for the same fare under existing student pricing.

Therefore, there is no change in fare structure or pricing. Torrance Transit has identified that our agency is only serving less than 1% of the overall number of students in Los Angeles County that a re utilizing the GoPass. Other agencies like L.A. Metro and Big Blue Bus currently serve more districts that have opted in to pay for the program. This program is currently being spearheaded by LA Metro, a county transportation authority. LA Metro has applied on the behalf of other participating agencies a waiver to extend the pilot.

98 99

100

Percent
of Total Cost Change Usage by Group
Fare Type Existing Proposed Absolute Percentage Minority Low-
Income Overall
Local Base
Fare
L.A.

Express
Base Fare
Senior
Local Fare
Senior L.A.

Express
Fare
Children
Base Fare
Students
Local Fare
Students
L.A.

Express
Fare
Disable
Local Fare
Disable
L.A.

Express
Fare
Blind Base
Fare
Medicare
Local Fare
Medicare
L.A.

Express
Fare
Interagenc
y Transfer
Regular
Local Pass
Regular
L.A.

Express
Pass
Student
Local Pass
Student
L.A.

Express
Zone Fare
101

Local EZ
Pass
L.A.

Express
EZ Pass
Senior
Local EZ
Pass
Senior L.A.

Express
EZ Pass

102

ATTACHMENT F: BOARD/GOVERNING BODY APPROVAL

The City of Torrance no longer provide copy minutes or resolution for any council items.

However, the public may view recorded council meeting videos at the following link with regards to any council items discusses at the particular council meeting. On Tuesday, May 20th, 2025, the Torrance City Council approved the program under consent calendar for Torrance Transit’s Title VI Program Report. http://torrance.granicus.com/ViewPublisher.php?view_id=8

Torrance City CouncilMay 20, 2025

Torrance City Council
May 20, 2025