HomeMy WebLinkAboutItem 04 - Adoption of the City of San Luis Obispo Transit's Federal Fiscal Year 2021-23 Title VI Plan
Department Name: Public Works
Cost Center: (5201) Transit
For Agenda of: January 21, 2020
Placement: Consent
Estimated Time: (N/A)
FROM: Shelly Stanwyck, Assistant City Manager - Community Services
Prepared By: Gamaliel Anguiano, Transit Manager
SUBJECT: ADOPTION OF CITY OF SAN LUIS OBISPO TRANSIT’S FEDERAL
FISCAL YEAR 2021-23 TITLE VI PLAN
RECOMMENDATION
Adopt the City of San Luis Obispo Transit’s Federal Fiscal Year 2021-23 Title VI Plan.
DISCUSSION
Background
The US Department of Transportation’s (DOT) Federal Transit Administration (FTA)
contributes funding to the City’s transit program (“SLO Transit”). As a result, SLO Transit is
subject to the rules, regulations and policies of the FTA. In compliance with FTA regulations, the
SLO Transit, must routinely develop and adopt a Title VI Plan (Attachment A) that addresses
discrimination including the prohibition of discriminatory actions by the City, its agents, and
contractors.
Title VI
Title VI of the Federal Civil Rights Act, 42 U.S.C. § 2000d et seq., prohibits discrimination by
recipients of Federal financial assistance on the basis of race, color, and national origin;
including the denial of meaningful access for Limited English Proficient (LEP) persons. This
prohibition is a requirement for all programs and activities receiving Federal financial assistance.
Under the DOT’s Title VI regulations, recipients of Federal financial assistance are prohibited
from using “criteria or methods of administering its program which have the effect of subje cting
individuals to discrimination based on their race, color, or national origin.” For example, facially
neutral policies or practices that result in discriminatory effects or disparate impacts violate the
DOT's Title VI regulations, unless the recipient can show the policies or practices are
substantially justified and there is no less discriminatory alternative.
A Title VI plan must be developed and adopted to prevent even unintentional practices that could
be interpreted as discriminatory. The City last submitted and received approval of its Title VI
plan in 2016. The proposed Title VI plan for Council’s consideration is consistent with prior
SLO Transit plans and outlines public outreach methods and non-English speaking alternatives
for the SLO Transit program. The plan promotes accessible, open-to-the-public, and non-
demographic conscious criteria for administrating the SLO Transit program and its services.
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Tri-Annual Submission of the Title VI Plan
The FTA requires that all funding recipients document their regulatory compliance by submitting
a Title VI Plan to its FTA regional civil rights officer once every three years. The Title VI
Program must be approved by the direct or primary recipient’s board of directors or appropriate
governing entity or official(s) (Council in this instance) responsible for policy decisions prior to
submission to FTA. FTA will review and either concur with the submitted work or request the
recipient provide additional information or revisions.
The City submitted its last Title VI Plan in 2016 (FY 15-16 to 18-19). A revised version thru
2023 is now needed. Staff has reviewed the most recent Federal Circular 4702.1.B regarding
Title VI obligations, participated in webinars and coordinated directly with FTA staff before
revisiting the SLO Transit program’s Title VI plan. The SLO Transit program’s Title VI plan
remains consistent with previously adopted plans but further clarifies and reaffirms SLO
Transit’s commitment to Title VI statutes.
Policy Context
The City Council is the legislative authority which sets the policies under which the City’s
programs operate. The City Council has the power to adopt ordinances, resolutions, plans,
establish policies, approve programs, establish fees, appropriate funds, adopt budgets and
approve contracts.
Correspondingly, FTA as the requires that the Title VI program be approved by the direct or
primary recipient’s board of directors or appropriate governing entity or official(s) responsible
for policy decisions prior to submission to FTA Council’s approval for the Title VI Plan is
sought with this Agenda Report.
Public Engagement
In accordance with Federal requirements, the updated Title VI Plan were brought before the
public in a special meeting held on December 5, 2019 and was made available for public review
and comment prior to final recommended adoption. All public meetings are held in accordance
to the City Public Engagement Manual and SLO Transit’s Public Engagement Policies.
CONCURRENCE
A draft of the revised plan was shared with FTA’s Civil Rights Officer for initial feedback and
review. The revised plan has received tentative approval.
ENVIRONMENTAL REVIEW
The California Environmental Quality Act does not apply to the recommended action in this
report, because the action does not constitute a “Project” under CEQA Guidelines Sec. 15378.
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FISCAL IMPACT
Budgeted: No Budget Year:
Funding Identified: N/A
Fiscal Analysis:
Funding Sources Current FY Cost
Annualized
On-going Cost
Total Project
Cost
General Fund N/A
State
Federal
Fees
Other:
Total
There is no impact on the City’s General Fund by submitting the revised Title VI Plan to the
Federal Transit Administration. However, Federal funds could be withheld from the Transit
Enterprise fund should the City fail in submitting an updated Title VI Plan.
There are no impacts to the City’s General fund nor the Transit Fund for developing and
adopting a current Title VI plan. The program is a continuation of the Title VI plan currently in
effect. The Transit program could however be adversely affected if one is not adopted, as having
a Title VI plan is a required for receiving continual federal funding assistance.
All operational needs and requirements stemming from Title VI are considered with each
Financial Plan and appropriated budget allocations.
ALTERNATIVES
1. Deny the adoption of the Title VI but this is not recommended as this would cause the
Transit program to lose federal financial assistance.
2. Alter the Title VI plan but any changes should be considered closely with FTA
representatives and could require an extension request for submitting a delayed plan.
Attachments:
a - SLO Transit Title VI Program - FFY 2020-22
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Office of the City Clerk
r 990 Palm Street, San Luis Obispo, CA 93401-3218
805.781.7100
slocity org
CERTIFICATION
I, Teresa Purrington, City Clerk, do hereby certify under penalty of perjury the foregoing
instrument to be a full, true and correct copy of the City of San Luis Obispo Transit Title VI
Program for Federal Fiscal Year 2020-22, adopted by the San Luis Obispo City Council on January
21, 2020, now on file in my office.
WITNESS MY HAND AND THE SEAL OF THE CITY OF SAN LUIS OBISPO.
DATED: ('uAu a-1ry 2 2 , '4!iAl�
r
��eresa Purrington
City Clerk
City of San Luis Obispo
City of San Luis Obispo Transit – Title VI Program – FFY 2020-22 | Page 1
Title VI Program
Federal Fiscal Year (FFY) 2020-22
City of San Luis Obisp o Transit
(SLO Transit)
919 Palm Street
San Luis Obispo, CA 93401
slotransit.org
Date Adopted: January 21, 2020
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Table of Contents
Title VI Program ................................................................................................................................... 1
I. Title VI Policy Statement ................................................................................................................... 4
Applicability.................................................................................................................................................... 4
II. General Requirements and Guidelines ............................................................................................ 5
III. Subcontractors and Vendors .......................................................................................................... 6
IV. Complaint Procedures and Appeals ............................................................................................... 6
How to File a Title VI Complaint with the City of San Luis Obispo Transit ..................................................... 6
What happens to the complaint after it is submitted? ................................................................................. 7
Procedures for Investigating Complaints ....................................................................................................... 7
Appeals Process ............................................................................................................................................. 8
Filing a Title VI Complaint with the FTA Office of Civil Rights ........................................................................ 8
V. Investigations, Complaints or Inquiries ........................................................................................... 9
VI. Record Keeping ............................................................................................................................... 9
VII. Title VI Information Dissemination ................................................................................................ 9
List of Public Locations Title VI Notice Is Posted .......................................................................................... 10
VIII. Public Participation Plan ............................................................................................................. 10
Public Meeting and Comment Period for Major Service Reduction and Fare Increase .............................. 11
Public Noticing Procedure ............................................................................................................................ 11
Scheduling Public Meeting Locations and Times ......................................................................................... 12
Procedures for Conducting Public Meetings ............................................................................................... 13
Documentation of Public Meetings ............................................................................................................. 13
Addressing Public Comments Received ....................................................................................................... 13
Outreach to Engage Minority and Limited English Proficient (LEP) Populations......................................... 13
Mass Transportation Committee (MTC) ...................................................................................................... 14
Membership of Non-Elected Committees and Councils .............................................................................. 15
Summary of Community Outreach Efforts Made Since Last Title VI Program Submission ......................... 15
IX. Limited English Proficiency (LEP) Plan .......................................................................................... 18
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Four Factor Analysis ..................................................................................................................................... 19
Language Assistance Plan (LAP) ................................................................................................................... 21
1. Identifying LEP Individuals who need Language Assistance....................................... 21
2. Language Assistance Measures .................................................................................. 21
3. Training Staff ............................................................................................................... 23
4. Providing Notice to LEP Persons ................................................................................. 23
5. Monitoring and Updating the LEP Plan ...................................................................... 23
X. Efforts to Ensure Subrecipient Compliance with Title VI ............................................................... 24
XI. Systemwide Service Standards and Policies ................................................................................. 25
Vehicle Load ................................................................................................................................................. 25
Vehicle Headway .......................................................................................................................................... 26
On-Time Performance .................................................................................................................................. 27
Service Availability ....................................................................................................................................... 27
Distribution of Transit Amenities ................................................................................................................. 27
Vehicle Assignment ...................................................................................................................................... 28
XII. Determination of Site or Location of Facilities ............................................................................ 28
APPENDIX A Title VI Notice to Public ........................................................................................... 29
Title VI Notice ............................................................................................................................................... 29
Title VI Notice on City Website .................................................................................................................... 30
Title VI Notice on Buses ............................................................................................................................... 31
Title VI Notice in User Guide ........................................................................................................................ 32
APPENDIX B Employee Annual Education Form ........................................................................... 33
APPENDIX C Acknowledgement of Receipt of Title VI Program ................................................... 34
APPENDIX D Title VI Complaint Form ........................................................................................... 35
APPENDIX E Sample Letter Acknowledging Receipt of Complaint ............................................... 37
APPENDIX F Sample Letter Notifying Complainant that the Complaint Is Substantiated ........... 38
APPENDIX G Sample Letter Notifying Complainant that the Complaint Is Not Substantiated .... 39
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I. Title VI Policy Statement
The City of San Luis Obispo Transit (SLO Transit) is committed to ensuring that no person is
excluded from participation in, denied the benefits of, or otherwise subjected to discrimination
under any of its programs, activities, or services on the basis of race, color, or national origin, as
protected by Title VI of the Civil Rights Act of 1964.
Title VI, 42 U.S.C. Section 2000d, of the Civil Rights Act of 1964 states:
“No person in the United States shall, on the ground 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.”
As a Federal Transit Administration (FTA) fund recipient, the City of San Luis Obispo Transit will
ensure that its programs, policies, and activities comply with the Department of Transportation
(DOT) Title VI Regulations of the Civil Rights Act of 1964.
The City of San Luis Obispo Transit will ensure that the level and quality of its transportation
service is provided without regard to race, color, or national origin.
The City of San Luis Obispo Transit will promote full and fair participation of all affected
populations in the transportation decision-making process.
The City of San Luis Obispo Transit will ensure that Limited English Proficient (LEP) individuals have
access to the City’s transit program, activities, and services.
The City of San Luis Obispo Transit, in compliance with Title 49 CFR Section 21.9 (d), will provide
information to the public regarding its obligations under the DOT Title VI regulations and apprise
members of the public of the protections against discrimination afforded to them by Title VI.
The City of San Luis Obispo Transit will not condone retaliation against an individual for his/her
involvement in asserting his/her rights pursuant to Title VI or because he/she filed a complaint or
participated in an investigation under Title VI, and/or this regulation.
Applicability
This policy is applicable to all City of San Luis Obispo employees, members of the public , and all
contractors hired by the City of San Luis Obispo.
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As of July 1, 2016, the City of San Luis Obispo Transit has an established contract with First Transit,
Inc. for operations and maintenance of the City of San Luis Obispo fixed-route public transit
system (SLO Transit). The contractor(s), by extension, will also assist and comply with the adopted
Title VI policy.
Failure of a City of San Luis Obispo Transit employee to follow this policy and procedure may
subject such employee to disciplinary action up to and including employment termination.
II. General Requirements and Guidelines
The City of San Luis Obispo Transit, in ensuring that no person is excluded from participation in,
denied the benefits of, or otherwise subjected to discrimination under any of its programs,
activities, or services on the basis of race, color, or national origin, will not:
Provide any service, financial aid, or benefit that is different from that provided to others;
Subject an individual to segregation or separate treatment;
Restrict an individual in the enjoyment of any advantage or privilege enjoyed by others;
Deny any individual service, financial aid, or benefits under any of the City’s programs, services, or
activities;
Treat individuals differently in terms of whether they satisfy admission or eligibility requirements ;
Deny an individual the opportunity to participate as a member of a planning or advisory body.
The City of San Luis Obispo Transit shall evaluate systemwide service and fare changes at the
planning and programming stages to determine whether these changes have a discriminatory
impact on low-income and Limited English Proficient (LEP) individuals. This applies to major
service changes that affect 15 percent or more of systemwide service miles or hours.
The City of San Luis Obispo Transit schedules public meetings per the City of San Luis Obispo Major
Service Reduction and Fare Increase Policy.
The City of San Luis Obispo Transit will keep the public informed of protections against
discrimination afforded to them by Title VI and the City’s obligations under Title VI by posting a
Title VI Notice to Public (Appendix A) on the City website at slotransit.org, in transit vehicles, and
in public areas of the agency’s administrative office. The Title VI Complaint Form (Appendix D) will
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also both be posted on the City website at slotransit.org and is available at the City of San Luis
Obispo Public Works Department at 919 Palm Street in San Luis Obispo.
The City of San Luis Obispo Transit will provide information, upon request from FTA, in order to
investigate complaints of discrimination or to resolve concerns about possible Title VI
noncompliance.
The City of San Luis Obispo Transit Title VI Program has been prepared in accordance with FTA
Circular 4702.1B, dated October 1, 2012. The City of San Luis Obispo Transit will submit its Title VI
Program to the FTA Regional Civil Rights Officer every three years to ensure compliance with Title
VI Requirements.
III. Subcontractors and Vendors
All subcontractors and vendors who receive payments from the City of San Luis Obispo Transit
where funding originates from any federal assistance are subject to the provisions of Title VI of the
Civil Rights Act of 1964 as amended. Written contracts shall contain non-discrimination language,
either directly or through the bid specification package which becomes an associated component
of the contract.
IV. Complaint Procedures and Appeals
How to File a Title VI Complaint with the City of San Luis Obispo Transit
Any person who believes they have been excluded from participation in, denied the benefits of, or
otherwise subjected to discrimination on the basis of race, color, or national origin, may file a
signed, written complaint up to one hundred eighty (180) days from the date of the alleged
discrimination by contacting the Transit Manager (Title VI Coordinator) by phone, email, or in
writing:
City of San Luis Obispo
Transit Manager (Title VI Coordinator)
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
(805) 781-7121
slotransit@slocity.org
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The Title VI Complaint Form (Appendix D) may be used to file a Title VI Complaint with the City of
San Luis Obispo Transit. The complaint form can be obtained by downloading an electronic form
from the City website at slotransit.org or by calling the Title VI Coordinator at (805) 781-7121. The
complaint form will be made available in an accessible format upon request.
The City of San Luis Obispo Transit encourages all complainants to submit complaint forms by
certified mail, return receipt requested, through the U.S. Postal Service.
What happens to the complaint after it is submitted?
All complaints alleging discrimination on the basis of race, color, or national origin will be directly
addressed by the Title VI Coordinator. The City of San Luis Obispo Transit shall provide appropriate
assistance to complainants, including those persons with disabilities or limited ability to speak
English.
A letter acknowledging receipt of complaint will be mailed within thirty (30) working days of
receipt of complaint (Appendix E). Please note that in responding to any requests for additional
information, a complainant's failure to provide the requested information may result in the
administrative closure of the complaint.
Procedures for Investigating Complaints
Upon receipt of the complaint, the Title VI Coordinator will investigate the complaint and make a
determination. Formal investigation of the complaint will be confidential, to the extent allowed by
law, and will include, but is not limited to, details of the specific incident, frequency and dates of
occurrences, and names of any witnesses. The complainant will be notified of the resolution.
How will the complainant be notified of the outcome of the complaint?
The City of San Luis Obispo Transit will send a final written response letter to the complainant
within sixty (60) working days of receipt of complaint (Appendix F or G). In the letter notifying
complainant that the complaint is not substantiated (Appendix G), the complainant is also advised
of his or her right to 1) appeal within seven (7) calendar days of receipt of the final written
decision from the City of San Luis Obispo Transit, and/or 2) file a complaint externally with the U.S.
Department of Transportation (DOT) and/or the Federal Transit Administration (FTA).
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Appeals Process
If the complainant is not satisfied with the resolution, an appeal process is availab le. An appeal
request for review of a determination of unlawful denial of access or accommodation to the public
transportation must be filed, in writing, within seven (7) working days of receipt of the final
written decision from the City of San Luis Obispo Transit. The written appeal must include the
customer’s name, address, and telephone number. A statement of reason(s) why the complainant
believes the denial of the complaint was inappropriate is recommended.
The City of San Luis Obispo Public Works Director will set a mutually agreed-upon time and place
for the review process with the complainant and/or his/her representatives within thirty (30)
working days of the appeals request. The complainant may submit documents or other
information to be included with the record and considered in the review process. A record of the
review will be kept, as determined by the City of San Luis Obispo Public Works Director. Anyone
needing reasonable accommodations may contact the City at (805) 781-7121 for assistance.
Filing a Title VI Complaint with the FTA Office of Civil Rights
Individuals or organizations can also file a complaint directly with the Federal Transit
Administration (FTA) Office of Civil Rights. A complaint must be filed no later than one hundred
eighty (180) calendar days after the date of the alleged discrimination, unless the time for filing is
extended by FTA. Completed and signed Title VI Complaint forms should be sent to:
Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor – TCR
1200 New Jersey Ave., SE
Washington, DC 20590
Phone: 1-866-377-8642
The FTA Title VI Complaint Form can be found at the following link:
https://www.transit.dot.gov/regulations-and-guidance/civil-rights-ada/fta-civil-rights-complaint-
form
Once a complaint has been accepted by FTA for investigation, FTA will go through an investigative
process and make determinations based on findings. Investigative process and determination by
FTA should be completed within one hundred eighty (180) calendar days of the date the FTA
accepts the complaint for investigation. The City of San Luis Obispo Transit will cooperate with
FTA, when required, during the investigative process and will take appropriate actions when a
violation is determined. Upon completion of the investigation, FTA Office of Civil Rights will
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transmit to the complainant and the grantee a letter of finding and resolution. If either party
wishes to appeal the decision, the letter of finding and resolution will provide the opportunity and
instructions to do so.
V. Investigations, Complaints or Inquiries
The City of San Luis Obispo will maintain a list (a minimum of four years in active status) of any
Title VI investigations, complaint, or lawsuits filed which allege the City of San Luis Obispo
discriminated against a person or group on the basis of race, color, or national origin.
The list will include, at a minimum:
• The date the investigation, complaint, or lawsuit was filed
• A summary of the allegation(s)
• The status of investigation, complaint, or lawsuit
• Any actions or correction actions taken by the City in response to the investigation,
complaint or lawsuit.
The City of San Luis Obispo has had no complaints, investigations, or lawsuits which allege
discrimination on the basis of race, color, national origin, or any other form of discrimination
since the last Title VI Program submission effective December 1, 2016 through November 30,
2019 or active within the last four years.
VI. Record Keeping
The Title VI Coordinator will maintain permanent records, which include, but are not limited to,
signed acknowledgements of receipt from the employees indicating the receipt of the City of San
Luis Obispo Title VI Plan, copies of Title VI complaints or lawsuits and related documentation, and
records of correspondence to and from complainants, and Title VI investigations.
VII. Title VI Information Dissemination
Title VI information shall be publicly displayed in the City of San Luis Obispo Transit Facility at 29
Prado Road, the City of San Luis Obispo Transit Center at 990 Palm Street, and on fixed-route
revenue vehicles. The plan information, along with contact inf ormation for the City of San Luis
Obispo Transit Title VI Coordinator is available on the SLO Transit website at slotransit.org.
Additional information relating to nondiscrimination obligation can be obtained from the City of
San Luis Obispo Transit Title VI Coordinator.
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Title VI information shall be disseminated to SLO Transit employees annually via the Employee
Education form (Appendix B). This form reminds employees of the SLO Transit policy statement
and their Title VI responsibilities in their daily work and duties. During New Employee Orientation,
new employees shall be informed of the provisions of Title VI and City of San Luis Obispo Transit
expectations to perform their duties accordingly.
All employees shall be provided a copy of the Title VI Program and are required to sign the
Acknowledgement of Receipt (Appendix C).
Title VI information shall also be made available in non-English languages, consistent with the City
of San Luis Obispo Transit Limited English Proficiency (LEP) plan.
List of Public Locations Title VI Notice Is Posted
The City of San Luis Obispo Transit Title VI notice to the public is currently posted at the following
locations:
• City of San Luis Obispo Transit Facility, 29 Prado Road
• City of San Luis Obispo Transit Center, 990 Palm Street
• California Polytechnic State University, 1 Grand Avenue
• San Luis Obispo Amtrak Station, 1011 Railroad Avenue
• SLO Promenade, 313 Madonna Road
• Fixed-route revenue vehicles (Appendix A)
• SLO Transit User Guide (Appendix A)
• SLO Transit website, slotransit.org (Appendix A)
VIII. Public Participation Plan
Per the City of San Luis Obispo Major Service Reduction and Fare Increase Policy, the City of San
Luis Obispo shall maintain an open and participative process including the consideration of public
comment before any major service reduction or fare increase.
I. Purpose
49 U.S.C. section 5307(d)(1)(I) provides that urban grant recipients shall have:
“a locally developed process to solicit and consider public comment before raising a fare
or carrying out a major reduction of transportation.”
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The City of San Luis Obispo Transit is a recipient of Federal Transit funding and therefore must
establish an acceptable public meeting procedure with respect to fare increase and major service
reductions as required by Federal law.
Public Meeting and Comment Period for Major Service Reduction and Fare Increase
II. Definitions
a. A major service reduction is defined as a reduction in service of 15 percent of daily revenue
miles or hours or a number of indefinite service reductions in any given fiscal year that add
up to more than 15 percent of daily revenue miles or hours.
b. A fare increase is defined as any increase to a fare per price per unit of service.
c. An emergency service change is defined as a service change that is to be in effect for fewer
than thirty (30) days and the service change does not meet the criteria as a major service
reduction. Examples include but are not limited to those due to power failure, severe
weather, major construction, reconstruction, and improvement projects.
A public comment period shall be held at least forty-five (45) calendar days prior to
implementation of a major service change or fare increase.
Public Noticing Procedure
III. Procedure
a. If a major service reduction or fare increase is determined to be necessary by the City of
San Luis Obispo transit staff, a recommendation and supporting materials will be
submitted to the City of San Luis Obispo City Council for consideration.
b. If City Council determines that a major service reduction or fare increase to be necessary
based on staff recommendation and supporting documentation, staff will schedule and
advertise no less than two public meetings to be conducted in accordance with the City of
San Luis Obispo Public Engagement Manual. One meeting will be held during typical
workday hours (before 5 p.m.) and the other after workday hours (after 5 p.m.). At a
minimum, public notices for public meetings will be posted or electronically provided to
the following, in both English and Spanish:
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• City Hall, 990 Palm Street
• Downtown Transit Center, 990 Palm Street
• City/County Public Library, 995 Palm Street
• On-board fixed-route transit vehicles
• Government Access Channel 20
• City of San Luis Obispo Transit (SLO Transit) website
• City of San Luis Obispo website
• Social Media
• Paid and legal notices in local print periodicals
• Press releases
Scheduling Public Meeting Locations and Times
a. To the greatest extent possible, public meetings will be held in a convenient, accessible
and diverse location. All facilities used for a public meeting will be accessible to persons
with disabilities.
• The public meeting location will be along bus routes whenever possible;
• The public meeting will be held under the supervision of the City of San Luis Obispo
Transit Manager;
• The public comments will be recorded and filed;
• The public meeting may be held at a regular Mass Transportation Committee meeting;
• Spanish speaking assistance availability
a. Following the public meeting, staff will give a recommendation for City Council
consideration.
b. If City Council adopts a plan for Major Service Reduction or Fare Increase, the City of San
Luis Obispo Transit Manager shall be authorized and directed to implement the action
according to the approved transit schedule. The schedule shall provide a minimum of 45
calendar days public notice of the service or fare changes prior to implementation.
IV. Exemptions
The following criteria establish certain instances which are exempt from the requirement to solicit
public comment:
• Annual seasonal variations (i.e. academic service and summer service)
• Special events (i.e. marathon, triathlon, etc.)
• Changes imposed and under control by private organizations (i.e. Cal Poly)
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• Emergency service change
• Experimental service changes for a period of 180 days or less, unless the chang es
extend beyond 180 days and meet the criteria
• Any fare, ticket or pass rate changes that do not result in increased fares per unit of
service
• Increases in service
• Decreases in fares
Procedures for Conducting Public Meetings
Public meetings will begin with a welcome and introduction of staff present. The meeting purpose
and proposed action will be explained and clarified for attendees. When the explanation of
proposed actions is completed, the public will be invited to offer their comments. All pe rsons
wishing to comment will have the opportunity to do so. This public comment period will precede
the close of the workshop.
Documentation of Public Meetings
Records of City of San Luis Obispo Transit public meetings on major service reduction or fare
increase will be maintained on file for ten (10) years per the City of San Luis Obispo Records
Retention Policy and Schedule.
Addressing Public Comments Received
Public comments received either in writing or verbally during a public meeting or public co mment
period will be addressed by the City of San Luis Obispo Transit prior to the established date for
City Council decision regarding proposed major service reduction or fare increase. Public
comments will be entered into the public record of the comment process. Staff will evaluate and
analyze all relevant comments received to determine whether they are reasonable to meet.
Outreach to Engage Minority and Limited English Proficient (LEP) Populations
The City of San Luis Obispo Transit will continue assessing the language needs of citizens in its
service area per the Language Assistance Plan (LAP), which is described in greater detail in the
Limited English Proficiency (LEP) Plan section of this Title VI Program. To the greatest extent
possible, to elicit public participation from minority and LEP populations, the City will engage in
the following outreach activities:
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• Public outreach may include attending already existing community meetings and
gatherings in order to invite participation from LEP populations who may not attend
hosted public events.
• The City of San Luis Obispo Transit will ensure that non-English language interpretation will
be available at any public meeting and community event, as deemed necessary.
• Public meeting notices will be displayed in both English and Spanish, as deemed necessary.
• Event information on the City of San Luis Obispo Transit website will be posted in English
and Spanish, as deemed necessary.
• The City of San Luis Obispo Transit will distribute event information to community groups
and agencies that work with LEP populations, if such contacts exist.
• The City of San Luis Obispo Transit will contract to provide language assistance, or
interpretations services, for customers and callers that are non-English speaking, as
deemed necessary.
Mass Transportation Committee (MTC)
The City of San Luis Obispo Mass Transportation Committee (MTC) Advisory Body holds meetings
bi-monthly to review SLO Transit service and performance. The public is welcome to attend these
meetings and share in discussion. All meetings are compliant with the Brown Act of California
which guarantees the public the right to attend and participate in meetings of local legislative
bodies. Agendas and minutes are available on the City of San Luis Obispo website at slocity.org.
The City of San Luis Obispo Mass Transportation Committee (MTC) Advisory Body has nine (9)
members:
• Cal Poly designated employee
• Cal Poly student representative designated by Associated Students, Inc. (ASI)
• Senior citizen (62 years of age or older)
• Person from the business community
• Person with technical transportation planning experience
• Disabled person
• Member at-large
• Alternate members (2)
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Committee vacancies are listed on the City of San Luis Obispo website at slocity.org, as well as on
the SLO Transit website at slotransit.org and SLO Transit social media. The City Clerk’s Office and
City Council review the submitted applications in fairness and equity, evaluating the necessary
qualifications for the vacant position.
Public meetings may be held at regular MTC Advisory Body meetings. Spanish speaking assistance
is available.
Membership of Non-Elected Committees and Councils
The City of San Luis Obispo Transit does not select membership of non-elected committees and
councils.
Summary of Community Outreach Efforts Made Since Last Title VI Program Submission
The City of San Luis Obispo Transit has made the following community outreach efforts since the
last Title VI Program submission, effective December 1, 2016 through November 30, 2019,
summarized below:
January 31, 2017 Public Meeting
Fare Analysis +
Title VI Program
(FFY 2017-19)
Notice of public meeting posted (English/Spanish) at
City Hall, Downtown Transit Center, City/County
Public Library, Government Access Channel 20, City
website, SLO Transit website, social media, paid
notices (Tribune, New Times), press releases, and on-
board fixed route public transit vehicles
Meeting held in the City/County Library Room, a
convenient and accessible location
Meeting held at 4:30 PM and 5:30 PM and same
content was reviewed at both meeting times
Presentation regarding fare analysis and Title VI
Program
Draft plans available for review on SLO Transit
website at slotransit.org, the City of San Luis Obispo
Clerks Office at 990 Palm Street, and the City of San
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Luis Obispo Public Works Department at 919 Palm
Street
Solicited public comment for 45 days
April 4, 2017 Public Hearing
Transit Fare +
Advertising Rates
Update
Public Hearing for City Council adoption of the transit
fare and advertising rate update scheduled more than
45 days prior to implementation
Notice of public hearing posted (English/Spanish) at
City Hall, Government Access Channel 20, City
website, SLO Transit website, social media, paid
notice (Tribune, New Times), and on-board fixed
route transit vehicles
Public Hearing held at City Hall Council Chambers, a
convenient and accessible location
June 8, 2017 Public Meeting
Proposed DBE Goal
Notice of public meeting posted (English/Spanish) at
City Hall, Downtown Transit Center, City/County
Public Library, Government Access Channel 20, City
website, SLO Transit website, social media, paid
notices (Tribune, New Times), press releases, and on-
board fixed route public transit vehicles
Meeting held in the City/County Library Room, a
convenient and accessible location
Meeting held at 4:30 PM and 5:30 PM and same
content was reviewed at both meeting times
Presentation regarding Proposed DBE Goal
Draft plans available for review on SLO Transit
website at slotransit.org, the City of San Luis Obispo
Clerks Office at 990 Palm Street, and the City of San
Luis Obispo Public Works Department at 919 Palm
Street
Solicited public comment for 45 days
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December 5, 2019 Public Meeting
Title VI Program
(FFY 2020-22) +
Proposed DBE Goal
(FFY 2021-23)
Notice of public meeting posted (English/Spanish) at
City Hall, Downtown Transit Center, City/County
Public Library, Government Access Channel 20, City
website, SLO Transit website, social media, paid
notices (New Times), press releases, and on-board
fixed route public transit vehicles
Meeting held in the City/County Library Room, a
convenient and accessible location
Meeting held at 4:30 PM and 5:30 PM and same
content was reviewed at both meeting times
Presentation regarding Title VI Program and Proposed
DBE Goal
Draft plans available for review on SLO Transit
website at slotransit.org, the City of San Luis Obispo
Clerks Office at 990 Palm Street, and the City of San
Luis Obispo Public Works Department at 919 Palm
Street
Solicited public comment for 45 days
The City of San Luis Obispo Transit held public meetings regarding the Title VI Program (FFY 2017-
19 and FFY 2020-22), Proposed DBE Goal (FFY 2018-20 and FFY 2021-23), and fare analysis. Public
meetings were conducted in accordance with the City of San Luis Obispo Major Service Reduction
and Fare Increase Policy and held under the supervision of the City of San Luis Obispo Transit
Manager. Public comments were recorded and filed.
The City of San Luis Obispo Transit submits to the California Department of Transportation (DOT)
and Federal Transit Administration (FTA) annually an application for funding. The application
requests funding for both capital and operating assistance. Part of the annual application is a
public notice, which includes a 30-day public comment period.
Additionally, the City of San Luis Obispo Transit works with the transit agencies and stakeholder
organizations in the service area to review and discuss the planning and contribute to the
decision-making process. The City of San Luis Obispo Transit from time to time will provide on -
board survey handouts to customers for feedback.
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IX. Limited English Proficiency (LEP) Plan
Per the United States Department of Justice (U.S. DOJ) Executive Order 13166, Limited English
Proficient (LEP) persons are individuals who do not speak English as their primary lan guage and
have a limited ability to read, speak, write, or understand English. The City of San Luis Obispo
Transit is required to take responsible steps to ensure meaningful access to the benefits, services,
information and other important portions of our programs and activities of individuals who are
LEP. The City of San Luis Obispo Transit consulted the United States Department of Transportation
(U.S. DOT) LEP Guidance and performed a Four Factor Analysis of public engagement to determine
the appropriate mix of LEP services to offer.
The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, FTA Circular
4702.1B, dated October 1, 2012, which states that no person shall be subjected to discrimination
on the basis of race, color, or national origin.
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 City utilized the U.S. DOT Four Factor Analysis which considers
the following factors:
1. The number or proportion of LEP persons in the service area eligible to be served or likely
to be encountered by the City of San Luis Obispo Transit Program;
2. The frequency with which LEP persons come in contact with City of San Luis Obispo Transit
programs, activities, or services;
3. The nature and importance of programs, activities or services provided by the City of San
Luis Obispo Transit to the LEP population; and
4. The resources available to City of San Luis Obispo Transit and overall costs of providing LEP
assistance.
A summary of the results of the City of San Luis Obispo Transit Four Factor Analysis is in the
following section.
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Four Factor Analysis
1. The number or proportion of LEP persons in the service area eligible to be served or likely
to be encountered by the City of San Luis Obispo Transit Program;
Data was gathered from the following sources to identify information on persons who do speak
languages other than English at home and who speak it less than well or not at all and would be
classified as LEP:
• 2010 Census Data
• Census Bureau American Community Survey and Fact Finder Surveys
• Department of Labor LEP Special Tabulation website
A review of the census data on the numbers of LEP persons revealed that in San Luis Obispo,
California the highest percentage of total population five (5) years old and over that spoke a
language other than English at home were Spanish speakers. The total Spanish spea king
population was 14.7% of the total population of 45,119 in San Luis Obispo (see U.S. Census Bureau
Data). The number of Spanish speaking LEP individuals that spoke English “not well” or “not at all”
in San Luis Obispo was 13.9%.
Pursuant to the Safe Harbor Provision, an agency is obligated to provide translation of vital
documents for eligible LEP language groups that constitute either five percent (5%) or 1,000
persons of the population being served. Documents related to fares, transfers, passes, pass sale
locations, days of service, and contact information are available in both English and Spanish
translations. The City will provide additional information and interpretation when requested.
2. The frequency with which LEP persons come in contact with City of San Luis Obispo
Transit programs, activities, or services;
The City of San Luis Obispo Transit serves LEP persons daily via our fixed route transit system that
operates 15 peak vehicles from Labor Day to mid-June and reduced service from mid-June to
Labor Day. Within the First Transit, Inc. operations and maintenance staff located at 29 Prado
Road, there are ten (10) bilingual employees available for Spanish translation, including six (6)
drivers, one (1) safety manager, (1) dispatcher, and (2) technicians. Staff translated in person
approximately 10 to 15 times a month and over the phone 5 to 10 times a month during the
previous 12 months. Within the Public Works Department located at 919 Palm Street, there is one
(1) bilingual approved transit employee in addition to four (4) bilingual approved employees
available for Spanish translation. No calls or requests for translation were received by City of San
Luis Obispo staff during the previous 12 months.
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The City of San Luis Obispo Transit will continue to monitor the following key program areas such
as:
• Use of bus
• Participation in public meetings
• Customer service interactions
• Ridership surveys
• Operator surveys
• Purchase of passes and tickets through outlets, and the Rideshare website.
3. The nature and importance of programs, activities or services provided by the City of San
Luis Obispo Transit to the LEP population;
The City of San Luis Obispo is centrally located in California between Los Angeles and San
Francisco. The City has an estimated population of 45,119 (2010 Census Bureau estimate). San
Luis Obispo is also home to California Polytechnic State University (Cal Poly), a major source of
population, employment, and other overall economic and social impacts. SLO Transit, a program
operated out of the Department of Public Works, is the City of San Luis Obispo Transit provider
and operates fixed route service throughout the City and trolley service downtown. Other
regional and paratransit service providers also offer service to the City.
The City of San Luis Obispo Transit has an established contract with First Transit, Inc. for
operations and maintenance of the City of San Luis Obispo fixed -route public transit system (SLO
Transit) within the City of San Luis Obispo. SLO Transit operates a total of eight (8) regular routes
on weekdays, four (4) routes on weekends, as well as a San Luis Drive Tripper (SLT), Laguna Tripper
(LT), and Highland Tripper (HT) on academic weekdays, 6 Express on Thursday (September –
November), and a Downtown Trolley Thursday year-round, Friday (June – Labor Day), and
Saturday (April – October). Four routes operate weekday evenings during the academic year.
4. The resources available to City of San Luis Obispo Transit and overall costs of providing
LEP assistance.
SLO Transit currently provides some information in Spanish such as surveys, bus routes and fares,
public service announcements and information on the buses. Documents related to fares,
transfers, passes, pass sale locations, days of service, and contact information are available in both
English and Spanish translation. Within the First Transit, Inc. operations and maintenance staff
located at 29 Prado Road, there are ten (10) bilingual employees available for Spanish translation,
including six (6) drivers, one (1) safety manager, (1) dispatcher, and (2) technicians . Within the
Public Works Department located at 919 Palm, there is one (1) bilingual approved transit
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employee in addition to four (4) bilingual approved employees available for Spanish translation.
About $2,500/year could be allocated in FY 2020-22 for additional language services.
Language Assistance Plan (LAP)
Based on the Four Factor Analysis, the City of San Luis Obispo Transit developed the Language
Assistance Plan (LAP), comprised of the following five areas:
1. Identifying LEP Individuals who need Language Assistance
The City of San Luis Obispo Transit may identify an LEP person who needs language assistance
as follows:
• Bilingual approved, Spanish speaking translators are available upon request during
normal business hours for in person or phone translation
• Route and schedule information available on fixed-route vehicles in both English and
Spanish. Drivers can assist LEP persons boarding the bus by showing them the Spanish
translation in the route and schedule materials or contacting bilingual employees
within First Transit located at 29 Prado Road or Public Works Department located at
919 Palm Street
• Bilingual assistance will be available at public meetings and community events. By
greeting and welcoming attendees upon arrival, staff will be able to determine the
need for bilingual assistance
• Bilingual assistance requests, either at meetings or over the phone, will be monitored
to determine whether language assistance beyond Spanish is needed at future events
2. Language Assistance Measures
There are numerous language assistance measures available to LEP persons, including both oral
and written language services. There are also various ways in which the City of San Luis Obispo
Transit responds to LEP persons, whether in person, by phone, or in writing.
The City of San Luis Obispo Transit will assist LEP persons who need language assistance as
follows:
• Route and schedule information available on fixed-route vehicles in both English and
Spanish
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• Route and schedule information available in both English and Spanish on the City of San
Luis Obispo Transit Website at slotransit.org
• Bilingual approved, Spanish speaking translators are available upon request during normal
business hours for in person or phone translation
• The City of San Luis Obispo Title VI Notice (Appendix A) is posted in both English and
Spanish, per the List of Public Locations Title VI Notice Is Posted
• The City of San Luis Obispo Title VI Policy, Title VI Complaint Form (Appendix D), and LEP
Plan are posted in English and Spanish on the City of San Luis Obispo Transit website at
slotransit.org
• Per the Public Participation Plan, the public participation strategy will offer early and
continuous opportunities for the public, including LEP persons, to be involved in the
identification of social, economic, and environmental impacts of proposed transportation
decisions
• The City of San Luis Obispo Transit will ensure that non-English language interpretation will
be available at any public meeting and community event, as deemed necessary
• The City of San Luis Obispo Transit will contract to provide language assistance, or
interpretation services, for customers and callers that are non-English speaking, as deemed
necessary
• The City of San Luis Obispo Transit will provide outreach to the Spanish speaking
community in San Luis Obispo, which may include attending already existing community
meetings and gatherings in order to invite participation from LEP populations who may not
attend hosted public events
• Public participation opportunities through means other than written communication, such
as personal interviews or use of audio or video recording devices to capture oral comments
will be considered by the City of San Luis Obispo Transit
• Transit surveys to be conducted by the City of San Luis Obispo Transit and available in both
English and Spanish
• Radio, television, or newspaper ads on stations and in publications that serve LEP
populations to be considered by the City of San Luis Obispo Transit
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3. Training Staff
The City of San Luis Obispo Transit will train staff on its roles and responsibilities in providing
meaningful access to services for LEP persons:
• The City of San Luis Obispo Transit provides contractor staff with the Employee Annual
Education Form (Appendix B) and Acknowledgement of Receipt of Title VI Program
(Appendix C) for annual review of Title VI LEP requirements for providing meaningful
access to services for LEP persons
• The City of San Luis Obispo Transit has a list of simple phrases for responding to LEP
persons, as well as bilingual approved employees to be referenced for additional
translation as needed
4. Providing Notice to LEP Persons
The City of San Luis Obispo Transit will provide Notice to LEP persons, both oral and written
communications as follows:
• Pursuant to the Safe Harbor Provision, vital documents related to fares, transfers, passes,
pass sale locations, days of service, and contact information are available in both English
and Spanish translations
• The City of San Luis Obispo Title VI Notice (Appendix A) is posted in both English and
Spanish, per the List of Public Locations Title VI Notice Is Posted
• The City of San Luis Obispo Title VI Policy, Title VI Complaint Form (Appendix D), and LEP
Plan are posted in English and Spanish on the City of San Luis Obispo Transit website at
slotransit.org
• Public meeting notices will be displayed in both English and Spanish, as deemed necessary
• Additional information and interpretation will be provided as needed
5. Monitoring and Updating the LEP Plan
The City of San Luis Obispo Transit will perform the Four Factor Analysis every three years to
monitor changes in demographics and identify additional information or activities that might
improve non-discriminatory service to LEP persons. The City of San Luis Obispo Transit will
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consider whether new documents and services need to be made accessible for LEP persons . The
City will then evaluate the projected financial and personnel needed to provide the requested
services and assess which of these can be provided cost-effectively.
The City of San Luis Obispo Transit will examine and update the LEP plan as follows:
• Record and report on the number of LEP persons encountered annually
• Determine how the needs of LEP persons have been addressed
• Determine the current LEP population in the service area and 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 the City of San Luis Obispo Transit financial resources are sufficient to
fund language assistance resources needed
• Determine whether the City of San Luis Obispo Transit and its contractor have fully
complied with the foals of this LEP Plan
• Determine whether complaints have been received concerning the agency’s failure to
meet the needs of LEP individuals
The City of San Luis Obispo Transit will update the LEP Pl an as required by the U.S. DOT.
X. Efforts to Ensure Subrecipient Compliance with Title VI
As a primary recipient of FTA funds, the City of San Luis Obispo Transit is required to provide
assistance to subrecipients of federal financial assistance to supp ort subrecipient compliance with
Title VI regulations. Primary recipients are also required to monitor subrecipients for compliance
with regulations. The City of San Luis Obispo Transit currently does not extend FTA financial
assistance to subrecipients.
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XI. Systemwide Service Standards and Policies
Service standards and policies are designed to encourage and include public participation in the
decision-making process in order to deter any discrimination and/or exclusion. To review the
strategies and procedures set forth by the City of San Luis Obispo Transit , refer to the Public
Participation Plan in this document. In accordance with FTA Circular 4702.1B, Chapter IV, the City
of San Luis Obispo Transit is required to set service standards for each specific mode of fixed-route
transit provided, and at a minimum must include the following indicators:
a. Vehicle Load
b. Vehicle Headway
c. On-Time Performance
d. Service Availability
The City of San Luis Obispo Transit is also required, at a minimum, to set services policies for the
distribution of transit amenities for each mode and vehicle assignment.
The City of San Luis Obispo Transit currently has an active fleet of seventeen (17) buses that are
used for the City of San Luis Obispo fixed-route transit service. Only fifteen (15) of these buses are
used at peak periods of service. This does not trigger the threshold of additional service standards
which transit providers that operate fifty (50) or more fixed-route vehicles in peak service must
include as part of their Title VI Program.
The following sections outline the City of San Luis Obispo Transit service standards and policies for
its fixed-route services.
Vehicle Load
Vehicle load is expressed as the ratio of passengers to the total number of seats on a vehicle.
Vehicle load varies by route, time of day, and season. The City of San Luis Obispo Transit uses
fixed-route fleet of buses interchangeably systemwide based on ridership demand, vehicle
availability, and roadway constraints. Roadway constraints and passenger loads limit bus
interchangeability on certain routes.
The table below identified the maximum load factor for the City of San Luis Obispo fleet.
Bus Vehicle Type Seated Standing Total Maximum Load Factor
30-ft 2007 Gillig 25 15 40 1.6
35-ft 2008 Gillig 34 20 54 1.6
40-ft 2008 Gillig 38 25 63 1.6
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40-ft 2009 Alexander Dennis Trolley 83 40 123 1.5
28-ft 2011 El Dorado Cutaway 28 10 38 1.3
40-ft 2012 Gillig 38 25 63 1.6
40-ft 2013 Gillig 38 25 63 1.6
40-ft 2017 Gillig BRT 38 25 63 1.6
Vehicle Headway
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 with more frequent service.
Vehicle headways are measured in minutes (e.g. every 15 minutes) and are generally used to
determine the level of service provided along a route.
SLO Transit operates a total of eight (8) regular routes on weekdays, four (4) routes on weekends,
as well as a San Luis Drive Tripper (SLT), Laguna Tripper (LT), and Highland Tripper (HT) on
academic weekdays, 6 Express (6X) on Thursday (September – November), and a Downtown
Trolley Thursday year-round, Friday (June – Labor Day), and Saturday (April – October). The
following tables identify the average headways for each regular route, provided during different
periods of the day.
Academic Service
Routes Morning
6:00 AM - 12:00 PM
Afternoon
12:00 PM – 6:00 PM
Evening
6:00 PM – 11:00 PM
Route 1A 60 minutes 60 minutes 60 minutes
Route 1B 60 minutes 60 minutes 60 minutes
Route 2A 60 minutes 60 minutes 60 minutes
Route 2B 60 minutes 60 minutes 60 minutes
Route 3A 20 minutes 60 minutes 60 minutes
Route 3B 60 minutes 30 minutes (avg) 60 minutes
Route 4A 45 minutes 45 minutes 45 minutes
Route 4B 45 minutes 45 minutes 45 minutes
Summer Service
Routes Morning
6:00 AM - 12:00 PM
Afternoon
12:00 PM – 6:00 PM
Evening
6:00 PM – 8:00 PM
Route 1A 60 minutes 60 minutes 60 minutes
Route 1B 60 minutes 60 minutes none
Route 2A 60 minutes 60 minutes 60 minutes
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Route 2B 60 minutes 60 minutes none
Route 3A 60 minutes 60 minutes 60 minutes
Route 3B 60 minutes 60 minutes none
Route 4A 45 minutes 45 minutes 45 minutes
Route 4B 45 minutes 45 minutes none
Weekend Service
Routes Morning
8:00 AM - 12:00 PM
Afternoon
12:00 PM – 6:00 PM
Evening
6:00 PM – 8:00 PM
Route 1A 60 minutes 60 minutes 60 minutes
Route 2A 60 minutes 60 minutes 60 minutes
Route 3A 60 minutes 60 minutes 60 minutes
Route 4A 45 minutes 45 minutes 45 minutes
On-Time Performance
On-time performance is a measure of runs completed as scheduled, which is defined by the transit
operator. City of San Luis Obispo Transit routes are considered to be “on time” if the bus departs
an established timepoint no later than five (5) minutes as published on the route schedule. Buses
are not allowed to depart earlier than the scheduled timepoint. To ensure high quality of service,
on-time performance standard for the City’s fixed-route transit services is set at 95%.
Service Availability
Service availability is a general measure of the distribution of routes within a transit provider’s
service area. For the City of San Luis Obispo, transit routes are designed to provide transit access
within ¼ mile for 99 percent of residents within the City of San Luis Obispo.
Distribution of Transit Amenities
Transit amenities refer to the items of comfort, convenience, and safety that are available to the
general riding public. For the City of San Luis Obispo Transit, installation of transit amenities along
any specific route is based on ridership demand and the number of passenger boardings at stops
along these routes. Currently, SLO Transit riders have access to over 165 bus stops. The City of San
Luis Obispo Transit is responsible for maintaining bus stops and bus stop amenities.
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Vehicle Assignment
As previously stated, fleet vehicles are not route specific or assigned by service mode. Vehicles
with the highest seating capacity are assigned to routes with higher passenger ridership.
XII. Determination of Site or Location of Facilities
Title 49 CFR Section 21.9(b)(3), the City of San Luis Obispo Transit is required to conduct a Title VI
equity analysis during the planning stage of any facility in order to ensure that the project’s
location is selected without regard to race, color, or national origin. Since the last Title VI Program
submission, the City has not planned or constructed any facilities as defined by the circular.
Therefore, the City of San Luis Obispo Transit has not completed a Title VI Equity Analysis. An
Equity Analysis will be conducted should the City engage in planning for the construction of any
facility requiring analysis.
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APPENDIX A Title VI Notice to Public
Identified on the City website at slotransit.org, in transit vehicles, and in public areas of the agency’s
administrative office.
Title VI Notice
Title VI Policy
Title VI, 42 U.S.C. Section 2000d, of the Civil Rights Act of 1964 states:
“No person in the United States shall, on the ground of race, color, or national origin, be excluded
from participation in, be denied the benefits of, or be subjected to discrimination under any program
or activity receiving Federal financial assistance.”
The City of San Luis Obispo Transit (SLO Transit) respects civil rights and operates its programs and
services without regard to race, color or national origin. SLO Transit is committed to complying with
Title VI requirements in all of its programs and services.
Making a Title VI Complaint
Any person who believes he/she has been subjected to discrimination in the delivery of or access to
public transportation services on the basis of race, color, or national origin may file a complaint wit h
SLO Transit. Such complaint must be filed in writing with SLO Transit no later than 180 days after the
alleged discrimination. For a complete list of complaint procedures and the Title VI Complaint Form,
please visit the City of San Luis Obispo Transit Website at slotransit.org.
For more information on the Title VI transit obligations and how to file a complaint, please contact
SLO Transit as listed below:
City of San Luis Obispo
Transit Manager (Title VI Coordinator)
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
(805) 781-7121
slotransit@slocity.org
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Title VI Notice on City Website
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Title VI Notice on Buses
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Title VI Notice in User Guide
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APPENDIX B Employee Annual Education Form
Title VI Policy
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.
All employees of San Luis Obispo Transit (currently contracted by First Transit, Inc.) are expected to
consider, respect, and observe this policy in their daily work and duties. If a citizen approaches you
with a question or complaint, direct him or her to the City of San Luis Obispo Transit Manager (Title
VI Coordinator).
In all dealings with citizens, use courtesy titles (i.e. Mr., Mrs., Ms., or Miss) to address them without
regard to race, color, or national origin.
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APPENDIX C Acknowledgement of Receipt of Title VI Program
I hereby acknowledge the receipt of the San Luis Obispo Transit Title VI Program. I have read the plan
and am 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, as protected by Title VI in
Federal Transit Administration (FTA) Circular 4702.1.B.
_________________________________
Your signature
_________________________________
Print your name
_________________________________
Date
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APPENDIX D Title VI Complaint Form
City of San Luis Obispo Transit – SLO Transit
Name: ____________________________________________________________________________
Address: ___________________________________________________________________________
City: ______________________________________ State: ____________ Zip Code: ______________
Home Telephone No: ( ) ___________________________
Work Telephone No: ( ) ____________________________
Email Address: ______________________________________
What do you believe is the reason for your discrimination?:
Race Color National Origin
Date of Alleged Incident: ______________________________
Explain as clearly as possible what happened and how you believe you were discriminated against.
Indicate who was involved. Be sure to include the names and contact information of any witnesses. If
more space is needed please use the back of the form.
Have you filed this complaint with any other federal, state, or local agency; or with any federal
or state court?
Yes No
If yes, check all that apply:
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Federal agency Federal Court State Agency State Court Local Agency
Please provide information about a contact person at the agency/court where the complaint was
filed:
Name: ____________________________________________________________________________
Address: ___________________________________________________________________________
City: ______________________________________ State: ____________ Zip Code: ______________
Telephone Number: _________________________________
Please sign below. You may attach any written materials or other information that you think is
relevant to your complaint.
Signature: _______________________________________ Date: ____________________________
Please mail this form to:
City of San Luis Obispo
Transit Manager
(Title VI Coordinator)
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
(805) 781-7121
slotransit@slocity.org
Title VI of the Civil Rights Act of 1964 states: “No person in the United States
shall, on the grounds of race, color, or national origin, be excluded from
participation in, be denied the benefits of, or be subjected to discrimination
under any program or activity receiving Federal financial assistance.”
The City of San Luis Obispo Transit (SLO Transit) respects civil rights and
operates its programs and services without regard to race, color or national
origin. SLO Transit is committed to complying with Tile VI requirements in
all of its programs and services.
Any person who believes he/she has been subjected to discrimination in
the delivery of or access to public transportation origin, may file a
complaint with SLO Transit. Such complaint must be filed in writing with
SLO Transit no later than 180 days after the alleged discrimination. A letter
acknowledging receipt of complaint will be mailed within 30 days.
For more information on the Title VI transit obligations and how to file a
complaint, please contact SLO Transit: City of San Luis Obispo Transit
Manager (Title VI Coordinator), Public Works Department, 919 Palm Street,
San Luis Obispo, CA 93401
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APPENDIX E Sample Letter Acknowledging Receipt of Complaint
Today’s Date
Ms. Jo Doe
1234 Main St.
San Luis Obispo, California 93401
Dear Ms. Doe:
This letter is to acknowledge receipt of your complaint against San Luis Obispo Transit allegin g
_____________________________________________________________________________.
An investigation will begin shortly. If you have additional information you wish to convey or
questions concerning this matter, please feel free to contact this office by telephoning _____
___________, or write to me at this address.
Sincerely,
Title VI Coordinator
City of San Luis Obispo
Transit Manager
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
(805) 781-7121
slotransit@slocity.org
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APPENDIX F Sample Letter Notifying Complainant that the Complaint Is
Substantiated
Today’s Date
Ms. Jo Doe
1234 Main St.
San Luis Obispo, California 93401
Dear Ms. Doe:
The matter referenced in your letter of ______________ (date) against San Luis Obispo Transit
(SLO Transit) alleging Title VI violation has been investigated.
(An/Several) apparent violation(s) of Title VI of the Civil Rights Act of 1964, including those
mentioned in your letter (was/were) identified. Efforts are underway to correct these
deficiencies.
Thank you for calling this important matter to our attention. You were extremely helpful during
our review of the program. (If a hearing is requested, the following sentence may be
appropriate.) You may be hearing from this office, or from federal authorities, if your services
should be needed during the administrative hearing process.
Sincerely,
City of San Luis Obispo
Transit Manager (Title VI Coordinator)
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
(805) 781-7121
slotransit@slocity.org
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APPENDIX G Sample Letter Notifying Complainant that the Complaint Is
Not Substantiated
Today’s Date
Ms. Jo Doe
1234 Main St.
San Luis Obispo, California 93401
Dear Ms. Doe:
The matter referenced in your complaint of ______________ (date) against San Luis Obispo
Transit (SLO Transit) alleging ____________________________ has been investigated.
The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights
Act of 1964, had in fact been violated. As you know, Title VI prohibits discrimination based on
race, color, or national origin in any program receiving federal financial assistance.
San Luis Obispo Transit has analyzed the materials and facts pertaining to your case for
evidence of the City’s failure to comply with any of the civil rights laws. There was no evidence
found that any of these laws have been violated. I therefore advise you that your complaint has
not been substantiated, and that I am closing this matter in our files.
You have the right to 1) appeal within seven calendar days of receipt of this final written
decision from San Luis Obispo Transit, and/or 2) file a complaint externally with the U.S.
Department of Transportation and/or the Federal Transit Administration at
Federal Transit Administration Office of Civil Rights Attention: Title VI Program Coordinator East
Building, 5th Floor - TCR 1200 New Jersey Ave., SE Washington, DC 20590
Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not
hesitate to call me.
Sincerely,
City of San Luis Obispo
Transit Manager (Title VI Coordinator)
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
(805) 781-7121
slotransit@slocity.org
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