Title VI Compliance
Your rights under Title VI of the Civil Rights Act of 1964:
Title VI, 42 U.S.C. § 2000d et seq, was enacted as part of the Civil Rights Act of 1964. It prohibits discrimination on the basis of race, color or national origin in programs and activities receiving federal financial assistance.
Compliance with Title VI of the Civil Rights Act of 1964 is a federal mandate for all agencies providing public services. Title VI applies to all aspects of the services provided by Capital Metro, which are required to be provided without regard to race, color or national origin. In addition, agencies must also comply with Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency."
Proposed Title VI Program Policy Updates
Every three years, Capital Metro must submit an updated Title VI program to the Federal Transit Administration (FTA). The Title VI program ensures Capital Metro’s services and fares meet federal requirements. Capital Metro is now in the window of submitting its program, due July 31, 2021. This is the only time an agency can make changes to components of its program. All agency funding is subject to a compliant Title VI program.
Capital Metro receives federal funding and is required to:
- Consider impacts to minority and low-income populations
- Adopt policies with thresholds for when to conduct an analysis for service and fares to determine their impacts on minority and low-income populations.
- Inform the board of equity analysis prior to a service or fare change
Capital Metro will be updating the Major Service Change, Disparate Impact and Disproportionate Burden policies. These policies establish which service and fare changes will be analyzed to determine if minority and low-income riders experience an unfair impact. The board must approve these policies prior to approving the entire Title VI Program. As part of the approval process, Capital Metro will hold a public meeting on May 3 and public hearing on May 12.
Public Meeting Information
En Capital Metro, estamos actualizando nuestras polízas relacionadas con el Título VI, que miden el impacto de los servicios en los miembros de bajos ingresos de la comunidad y los que pertenecen a grupos minoritarios. Únase a la próxima reunión pública virtual para obtener más información.
Fecha: el 19 de mayo a las 6 p.m.
Lugar: vía Zoom - Registrar aquí
Public Hearing Information
When: Wednesday May 12 at 12 p.m.
Due to the COVID-19 pandemic, at this hearing Public Comment will be allowed via telephone only -- no in-person input will be allowed. Advance registration is required and can be done by leaving a message at 512-369-6040, or by emailing email@example.com
and giving a name, email address and telephone number. The deadline to register is one business day in advance of the hearing (noon on Tuesday, May 11). The public is encouraged to participate.
Reasonable modifications and equal access to communications are provided upon request. Please provide notice at least two days in advance. Contact Martin Kareithi at (512) 389-7583 or email firstname.lastname@example.org for more information or to request informational materials in another format.
Capital Metro’s current policies were adopted over seven years ago and need updating to reflect the demographic changes in our service area. This is also an opportunity to incorporate feedback received from the FTA during the past three years and learn from the experience of our peers and best practices.
To assist with updating of these policies, Capital Metro brought in a consulting team with national experience assisting transit agencies to develop Title VI Programs. This will ensure that Capital Metro’s policy update is compliant with FTA guidance and is forward looking with Project Connect improvements, including new modes.
The consulting team started the revision process by reviewing the policies of our peers to see how Capital Metro compared to similar agencies. It was observed that Capital Metro’s thresholds did not align with peers. The threshold, communicated as a percentage, is a measure of the impact on minority and low-income communities versus non-minority and non-low-income communities.
Policy Change Recommendations
Staff is recommending one consolidated policy, instead of three separate policies.
Proposed changes to the Major Service Change Policy include:
- Clarifying the use of how annual revenue hours/miles are used instead of daily revenue hours/miles
- Removing specific references to modes to make the policy universal and timeless
- Explicitly stating that all fare changes require equity analysis
- Adding exceptions for things beyond Capital Metro’s control (e.g., construction)
Proposed changes to policies related to low-income and minority populations include:
- Increasing the threshold of impact from 2% to 10%
This change is not only consistent with how our peers measure their services, but also addresses the need for flexibility to meet the greatest need and bring the service where it is needed. Capital Metro’s current threshold of 2% does not meet any of these objectives, while the proposed 10% threshold focuses efforts on areas that need it the most and guides analysis to better identify unfair impact.
Capital Metro is obligated to avoid, minimize or mitigate impacts to the minority populations and low-income populations. This is accomplished by reviewing the proposed change and making adjustments that could reduce impacts. If a less discriminatory alternative does not exist, the FTA allows transit agencies to implement the proposed changes if:
- The agency has a substantial legitimate justification for the proposed change; and
- The agency can show there are no alternatives that would have a less disparate impact on minority riders, while still accomplishing the agency’s legitimate program goals.
The final decision regarding a change is made by the Capital Metro Board of Directors.
Language Assistance Plan Survey
The survey distributed to community-based organizations found that respondents reported that Spanish is the language most often heard when interacting with their community members. Second language most often heard is English, third is Arabic, fourth is
Burmese, fifth is French and sixth is Chinese. The following languages were selected by 1-3 respondents: Tagalog, Vietnamese, Korean, Russian, Telugu, and Hindi.
The survey results showed that 82% (23) of respondents have had a community member inquire about how to access public transportation or expressed a need for public transportation service. This shows the importance of Capital Metro services to the Limited-English
Proficiency community. 60% of responding community members seek information about Capital Metro services or programs varying from daily, weekly and monthly. 39% respondents said they were not sure how often community members sought Capital Metro services
Respondents recommended the following methods for how Capital Metro can best to reach LEP communities in Central Texas including:
- Having the website in different languages
- Having a language assistance line available to staff, particularly bus operators
- Text messages sent in riders' preferred language with general messaging, such as “bus is running late”
- Training staff about the language assistance services available to them 8-10 times a year, with emphasis on frontline staff
Response from the individual translated service was low. The Spanish survey had 3 respondents and the Vietnamese survey had 1 respondent. All 4 respondents are users of Capital Metro services and are familiar with several services and programs including bus, train, Pickup, MetroBike, CARTS, Project Connect, Transit Store, Trip-planning, Transit Adventures and Customer Service or Go Line.
No responses were received from the Arabic, Mandarin, Korean, and Hindi surveys.
Title VI Compliance
Capital Metro's office of Diversity integrates program requirements when implementing fare and service changes, as well as any other areas requiring Title VI compliance.