2013 Title VI Report
October 2013
DRAFT
Central Ohio Transit Authority
2013 Title VI Report
1 – General Reporting Requirements
CENTRAL OHIO TRANSIT AUTHORITY (COTA)
2011 - 2013
TITLE VI TRIENNI...
2013 Title VI Report
1 – General Reporting Requirements
Central Ohio Transit Authority
Board of Trustees
Appointment
Dawn ...
2013 Title VI Report
Table of Contents
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Table of Contents
1 GENERAL REPORTING REQUIREMENTS...
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List of Tables
Table 2-1 Bus Stop Spacing Guideli...
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1 GENERAL REPORTING REQUIREMENT...
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following information describes...
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Figure 1-1 COTA Service Area
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1.2 REQUIREMENTS TO PROVIDE TIT...
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1.4 REQUIREMENT TO NOTIFY BENEF...
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managers, supervisors and emplo...
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 Solicit suggestions from cust...
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4. Two (2) months prior to each...
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 Any other activities deemed n...
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 Reducing or discontinuing un...
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 Columbus City Council
o John...
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Corporate Communications and M...
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COTA’s Pass Sales office has o...
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1.8 REQUIREMENT TO PROVIDE MEA...
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How LEP persons interact with ...
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Local articles about demograph...
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Those in attendance were taugh...
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In May 2013, at two different ...
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COTA’s Community Relations Man...
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1.9 MINORITY REPRESENTATION ON...
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NAME RACE SEX REPRESENTS
John ...
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1.10 PROVIDING ASSISTANCE TO S...
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COTA has and will continue to ...
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The total approved budget of t...
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Figure 1-3 and Figure 1-4 show...
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During 2011, COTA worked with ...
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Figure 1-3 and Figure 1-4 show...
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CENTRAL OHIO TRANSIT AUTHORITY (COTA)
2011 - 2013
TITLE VI TRIENNIAL REPORT
BASED ON PROGRAM GUIDELINES
FOR
TITLE VI
INFORMATION SPECIFIC TO FTA PROGRAM
FTA CIRCULAR C 4702.1B, OCTOBER 1, 2012

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2013 title vi_report_draft_i

  1. 1. 2013 Title VI Report October 2013 DRAFT Central Ohio Transit Authority
  2. 2. 2013 Title VI Report 1 – General Reporting Requirements CENTRAL OHIO TRANSIT AUTHORITY (COTA) 2011 - 2013 TITLE VI TRIENNIAL REPORT BASED ON PROGRAM GUIDELINES FOR TITLE VI INFORMATION SPECIFIC TO FTA PROGRAM FTA CIRCULAR C 4702.1B, OCTOBER 1, 2012 PREPARED BY COTA CONTACT: DATE Elliott C. Doza Senior Transit Planner Department of Capital Projects & Planning Central Ohio Transit Authority 33 N. High Street Columbus, Ohio 43215 (614) 308-4402 (614) 275-5805 fax dozaec@cota.com
  3. 3. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority Board of Trustees Appointment Dawn Tyler Lee, Chair City of Columbus Kevin E. Wood, Vice Chair City of Columbus William A. Anthony, Jr. City of Columbus James E. Daley City of Reynoldsburg Mabel G. Freeman, Ph.D. City of Bexley James E. Kunk City of Columbus Harry W. Proctor Franklin County J. Cleve Ricksecker City of Columbus Craig P. Treneff City of Westerville Robert J. Weiler, Sr. City of Columbus Richard R. Zitzke City of Whitehall Jean Ryan City of Columbus Vacant Franklin County Administration President/CEO W. Curtis Stitt Vice President, Planning & Service Development Doug B. Moore Vice President, Human Resources Kristen M. Treadway Vice President, Operations Patrick G. Stephens Vice President, Legal Affairs/General Counsel Marchelle E. Moore Vice President, Finance/CFO Marion White Vice President, Communications Robert M. Stutz
  4. 4. 2013 Title VI Report Table of Contents Central Ohio Transit Authority i Table of Contents 1 GENERAL REPORTING REQUIREMENTS......................1-1 1.1 INTRODUCTION .......................................................................................................1-1 1.2 REQUIREMENTS TO PROVIDE TITLE VI ASSURANCES .......................................1-4 1.3 REQUIREMENT TO PREPARE AND SUBMIT A TITLE VI PROGRAM ....................1-4 1.4 REQUIREMENT TO NOTIFY BENEFICIARIES OF PROTECTION UNDER TITLE VI .................................................................................................................1-5 1.5 REQUIREMENTS TO DEVELOP TITLE VI COMPLAINT PROCEDURES AND COMPLAINT FORM...........................................................................1-5 1.6 REQUIREMENT TO RECORD AND REPORT TRANSIT-RELATED TITLE VI INVESTIGATIONS, COMPLAINTS AND LAWSUITS ............................................1-6 1.7 PROMOTING INCLUSIVE PUBLIC PARTICIPATION ...............................................1-6 1.8 REQUIREMENT TO PROVIDE MEANINGFUL ACCESS TO LEP PERSONS..........................................................................................................................1-14 1.9 MINORITY REPRESENTATION ON PLANNING AND ADVISORY BODIES..............................................................................................................................1-20 1.10 PROVIDING ASSISTANCE TO SUBRECIPIENTS..................................................1-22 1.11 MONITORING SUBRECIPIENTS............................................................................1-22 1.12 DETERMINATION OF SITE OR LOCATION OF FACILITIES..................................1-22 2 REQUIREMENTS AND GUIDELINES FOR FIXED- ROUTE TRANSIT PROVIDERS.......................................2-1 2.1 REQUIREMENT TO SET SYSTEM-WIDE SERVICE STANDARDS AND POLICIES ....................................................................................................................2-1 2.2 REQUIREMENT TO COLLECT AND REPORT DEMOGRAPHIC DATA .................2-12 2.3 REQUIREMENT TO MONITOR TRANSIT SERVICE ..............................................2-13 2.4 REQUIREMENT TO COLLECT AND REPORT DEMOGRAPHIC DATA .................2-16
  5. 5. 2013 Title VI Report Table of Contents Central Ohio Transit Authority ii List of Tables Table 2-1 Bus Stop Spacing Guidelines................................................................................. 2-4 Table 2-2 Requirement to Monitor Service........................................................................... 2-15 Table 2-3 Title VI Service Analysis....................................................................................... 2-17 Table 2-4 2012 Fare Change ............................................................................................... 2-17 List of Figures Figure 1-1 COTA Service Area .............................................................................................. 1-3 Figure 1-2 Westview Turnaround ......................................................................................... 1-25 Figure 1-3 COTA Facilities – Minority Tracts........................................................................ 1-26 Figure 1-4 COTA Facilities – Low-income Tracts ................................................................. 1-27 Figure 2-1 Example BSSIP Analysis ...................................................................................... 2-4 List of Appendices Appendix A ............................................................................... LEP Materials and News Articles Appendix B ................................................................... Public Notice and Complaint Procedures Appendix C ...........................................................................................Public Outreach Activities Appendix D .............................COTA Base Map, Census Tracts and 2008 On-board Survey and Shelter Locations Appendix E ..................................................................................Policies and Board Resolutions Appendix F....................................................Minority/Low-Income Routes and Bus Assignments Appendix G............................................................Service Change Monitoring Tables and Maps Appendix H ..................................................................2013 Short-Range Transit Plan Chapter 3
  6. 6. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-1 1 GENERAL REPORTING REQUIREMENTS 1.1 INTRODUCTION Enclosed are data and analysis detailing the Central Ohio Transit Authority's (COTA) compliance with Title VI of the 1964 Civil Rights Act regarding transit services and related-benefits. The contents follow the format provided in the FTA Circular 4702.B dated October 1, 2012. Data collection and analysis was conducted by COTA staff. This report serves as an update to COTA’s 2010 Title VI report submittal, including any new requirements. This Title VI report covers the December 2010 through June 2013 time period although select data set timeframes may be limited by reporting constraints. It is COTA’s goal to ensure equal opportunities to all persons without regard to race, color, national origin or income level, to participate in transit planning and decision-making processes under COTA’s control. COTA understands its responsibility to ensure that all transit service and access to its facilities are equitably distributed and provided without regard to race, color, religious creed, or national origin. Additionally, COTA will continue to ensure that equal opportunities are afforded to all individuals in its service area without regard to race, color, religious creed or national origin, as they relate to community participation in public transit planning and decision-making processes. Upon close examination of the contents, it will be seen that COTA provides comparable transit service to the minority, low-income, and non-minority residential populations, and those individuals with limited English proficiency. Further, it will be seen that COTA, as an employer and as a contractor, attempts to utilize governmental and revenue monies in an equitable and fair manner. Description of COTA’s Transit Services Public transit service is provided throughout the COTA service area that includes Franklin County and select portions of Delaware, Fairfield, Union and Licking Counties (See Figure 1-1). COTA’s service is provided via two primary service operations: fixed-route bus service and paratransit mobility services. The
  7. 7. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-2 following information describes in greater detail the important roles each of these programs serves in providing transit service to central Ohio residents. Fixed-Route Service The backbone of COTA’s public transit system is fixed-route bus service. Service is provided on a repetitive, fixed-schedule basis along specific routes, with vehicles stopping to pick up passengers at, and deliver passengers to, specific locations. COTA operates four types of fixed routes: Local: Makes all stops and travels through or ends Downtown; Express: Makes few or limited stops and starts or terminates Downtown or at major destinations, such as the Ohio State University; Crosstown: Operates between two non-downtown points; and LINK: Circulates through major activity centers or residential neighborhoods. LINK routes are designed for smaller (approximately 30’) buses, and serve as a connector to regular fixed-route services and to COTA transit centers. COTA currently operates no LINK routes. A timed transfer system goes into effect at 10:00 p.m. on weekdays allowing passengers to conveniently transfer in the downtown. Currently, the final trip from the downtown is 12:00 a.m. on weekdays and Saturdays, and 9:00 p.m. on Sundays. Paratransit Service “Mainstream” is complementary paratransit service for individuals who are unable to use the regular fixed-route bus service due a disability. The service is based on Americans with Disabilities Act (ADA) eligibility criteria. COTA contracts this service with First Transit, and is in the second year of a three-year contract that expires.
  8. 8. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-3 Figure 1-1 COTA Service Area
  9. 9. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-4 1.2 REQUIREMENTS TO PROVIDE TITLE VI ASSURANCES A current DOT Title VI assurance is on file with the FTA Regional Office in Chicago. 1.3 REQUIREMENT TO PREPARE AND SUBMIT A TITLE VI PROGRAM COTA submitted its most recent Title VI report to the FTA in November 2010. Since that time, Title VI-related transit policies, procedures, and service have not changed substantially. COTA has incorporated Title VI notification and complaint procedures into its website. Led by the Manager of Public Affairs and Director of Marketing, over the past three years COTA has greatly increased its community outreach program to minority, low-income and LEP populations, resulting in greater awareness within the community of COTA’s commitment to provide fair and equitable transit services. The following sections include the following general reporting activities: 1. A copy of the Board of Trustees resolution approving the Title VI Program. (Appendix E) 2. COTA’s notice to the public that it complies with Title VI and instructions to the public on how to file a discrimination complaint (Appendix B). 3. A copy of instructions to the public for submitting a Title VI complaint. 4. A list of any Title VI investigations, complaints, or lawsuits filed with COTA since the time of the last submission including procedures for tracking and investigating Title VI complaints. 5. A summary of public outreach and involvement activities undertaken since the previous submission (Appendix C) and a description of steps taken to ensure that minority and low-income people had meaningful access to these activities. 6. A copy of the agency’s material for providing language assistance for persons with limited English proficiency (Appendix A) 7. List of the racial breakdown of advisory boards. 8. Sub-recipient compliance efforts. 9. A summary of the construction of facilities and Title VI equity analysis conducted
  10. 10. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-5 1.4 REQUIREMENT TO NOTIFY BENEFICIARIES OF PROTECTION UNDER TITLE VI COTA disseminates to the public their rights under Title VI in several ways including its website and commuter bulletins. COTA’s Title VI web public notification statement can be found in Appendix B. Notices include the following information: 1. A statement that COTA provides all services and programs without regard to race, color, and national origin. 2. A description of the procedures that members of the public should follow in order to request additional information on COTA’s nondiscrimination obligations. 3. A description of the procedures that members of the public should follow in order to file a discrimination complaint against COTA. 4. A description of required policies adopted by COTA. 1.5 REQUIREMENTS TO DEVELOP TITLE VI COMPLAINT PROCEDURES AND COMPLAINT FORM COTA provides a mechanism for handling customer complaints, including those involving Title VI related issues. Title VI complaints filter through the Authority’s complaint procedures. COTA has adopted a Standard Operating Procedure (SOP) for handling complaints. COTA recommends a ten business day response time for all contacts. COTA maintains an electronic database of all customer contacts. In 2013, in response to the updated Title VI circular, COTA developed a new Title VI complaint form that is available on COTA’s website or in paper format through Customer Service. Title VI complaints filed with customer service are not only recorded through the SOP but also within the new form. Customer service agents are to aid the individual filing a complaint in completing the form. Complaints that allege discrimination in the provision of transit services by COTA and its employees are referred to the Legal Division and the Planning Division's Service Planning and Scheduling Department and/or the Operations Division for resolution. Matters requiring legal review or legal opinions are referred to the Legal Division for review and response. Complaints referred to another division or department must be reviewed and addressed consistent with and within the time periods provided in the Customer Service Complaint process. All
  11. 11. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-6 managers, supervisors and employees share in the responsibility for making COTA’s Title VI Program a success. All complaints, including Title VI, can be filed through COTA’s customer service telephone line at (614) 228-1776, via walk-ins to the COTA Pass Sales Office in downtown Columbus, or through COTA’s website at www.cota.com. The Legal Division, in its discretion, will determine whether matters referred to it should be handled as a Legal Department matter or continue to be processed as a customer complaint. 1.6 REQUIREMENT TO RECORD AND REPORT TRANSIT-RELATED TITLE VI INVESTIGATIONS, COMPLAINTS AND LAWSUITS COTA is prepared to record Title VI complaints and lawsuits. During the reporting period, one complaint was filed. COTA’s legal team investigated the complaint and found no potential Title VI violations. The complaint was filed and addressed through COTA’s customer service with a response developed by COTA’s legal team and Capital Projects and Planning staff. 1.7 PROMOTING INCLUSIVE PUBLIC PARTICIPATION Public Involvement is the cornerstone of COTA’s service planning strategy. COTA has created the following Public Participation Plan. Public Participation Plan COTA holds public meetings prior to making changes to its fixed-route service. COTA makes modifications and adjustments to its service three (3) times a year: January, May and September. Prior to each service change, no fewer than four (4) public meetings are held. The purpose of public meetings held prior to making service modifications and adjustments are to:  Explain potential modifications and adjustments to existing fixed-route service;  Solicit feedback from the general public and customers about potential modifications and adjustments to existing fixed-route service;
  12. 12. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-7  Solicit suggestions from customers and the general public about service modifications and adjustments;  Learn about impacts potential and proposed service modifications and adjustments may have on customers, potential customers, businesses and other stakeholders before changes modifications and adjustments are planned;  Identify specific needs and desires of COTA stakeholders related to fixed-route service. Public Comment Process for Service Changes COTA refines its fixed route services on the first Monday of January, May, and September of each year. In an effort to gather input from the public and to inform transit users of all such scheduled changes to service (including major service reductions, which are defined as a 25% or more reduction in annualized service hours on a route) COTA will adhere to the following procedures. 1. COTA will gather input continually and engage in dialogue with the public through Customer Service call center contacts, commuter bulletins posted at stops, comments submitted via cota.com, handouts on buses, comments/requests received via social media (Facebook, Twitter) letters, and regularly scheduled Community Outreach and public comment meetings. In addition, COTA will survey its users and employers/employees who have requested some modification to the transit service or whose input is sought on proposed changes. 2. Biennially, COTA will prepare an update to the schedule of service improvements for the next five years, which will be included in the Short Range Transit Plan (SRTP). The service changes in the SRTP are then reviewed and discussed in the following public meetings: MORPC’s Citizens Advisory and Transportation Advisory committees and COTA Board of Trustees. 3. Prior to implementing any service change, COTA will conduct two rounds of public meetings, including meetings in neighborhoods that will be most directly affected by the change, as needed. When a proposed change would eliminate a route or significantly reduce the span of service or frequency of service along a route, COTA will actively solicit and consider input from the affected area through commuter bulletins, additional neighborhood meetings, and/or on-board surveys. A significant reduction in the span of service on a route is defined as the elimination of a time period, such as midday service or weekend service. A significant reduction in the frequency of service on a route is defined as a 100% increase or more in the headway of the route.
  13. 13. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-8 4. Two (2) months prior to each service change, the list of proposed modifications is provided to COTA’s Board of Trustees. Board meetings are open to the public for comments and discussion. 5. The following activities take place prior to the effective date of all service modifications in order to inform all stakeholders of the changes:  A minimum of four (4) public meetings will be held to solicit public input regarding potential service modifications. Two (2) meetings are held three months prior to the service change implementation date in order to encourage public feedback to service proposals, and, if feasible, adjustments are made by staff to the potential modifications based on feedback. A second set of two (2) information meetings will be held one (1) month prior to the service change to present the final draft list of modifications and to solicit additional feedback.  All material from the public meetings (handouts, presentations, etc.) will be available on the web site and in paper form.  Commuter bulletins will be posted at bus stops affected by a proposed modification one month prior to implementation. Bulletins posted at bus stops include a description of the proposed modification, maps (if applicable), and instructions regarding how to provide feedback to COTA about the proposed changes. Commuter bulletins will also be posted on COTA buses which indicate the routes that will be affected. For major service changes, additional warning bulletins may be necessary as per COTA’s major change criteria;  Press releases describing the changes will be sent to newspaper, radio, and TV stations and posted on COTA’s website;  Prior to each service modification, COTA publishes a “Service Change Book” which details all service modifications, maps and all other relevant information regarding service changes. In addition, the book contains a system “User’s Guide” which explains COTA services, how to ride COTA and other customer information. The service change book (and all COTA-published customer information) will be made available in accessible formats and translated into Spanish and Somali upon request.  Service change booklets are distributed as described below*  New public timetables will be produced, printed and distributed on buses serving affected routes;  Handouts describing the changes will be passed out at the Downtown express terminals and/or on selected trips, at the discretion of COTA;
  14. 14. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-9  Any other activities deemed necessary by COTA. Below is a typical schedule of distribution of Service Change Books. Usually 4,800 - 5,000 are published. 300 to 500 copies are maintained for distribution during the service change period. Internal Distribution Fields Transportation 150 Lunch Room - 33 North High, 2nd Floor 20 McKinley Transportation 150 Mobility Services/First Transit 100 Operator Dayroom - 33 North High St. 50 Outreach/Event Activities - 619 Pass Sales - 33 North High, Lobby 830 Phone Operators 100 Radio Room/Street Supervisors 50 Total 2069 External Distribution ADA/Mainstream Customers (PDF supplied to Mobility Services) N/A Chambers of Commerce 14 Charter Cities 12 Civic/Business Associations 35 Employers 135 Libraries 850 Misc. Social Service Agencies/Groups/Organizations 315 Pass Outlets 450 Recreation Centers 400 Senior Centers 220 Total 2431 TOTAL 4500 Special Outreach Among the other types of changes for which public meetings are held include:  Changes to fares;  Establishing new service;
  15. 15. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-10  Reducing or discontinuing underutilized service;  Adding or reducing the number of bus stop locations along fixed- routes;  Establishing new park and ride facilities and service;  Constructing new facilities for transit related activities;  COTA reserves the right to schedule and host public involvement meetings in other circumstances where COTA service is affected and where COTA stakeholders are impacted. COTA also executes a public involvement process for large projects. For example, a public involvement program was implemented for the Northeast Corridor Bus Rapid Transit (BRT) Project Alternatives Analysis. Public Notices COTA informs all stakeholders of public meetings by posting meeting notices on cota.com, social media (Facebook, Twitter), news media releases, commuter bulletins on every fixed-route bus, and monitors installed at COTA downtown administrative headquarters and sales office. Meeting notices are posted two (2) weeks prior to meetings. **Below is the schedule of public meeting notice distribution. Distributing Public Meeting Notices In order to ensure that COTA stakeholders are informed about public meetings COTA holds to solicit comments, ideas and other important feedback about our service, we disseminate information through as many channels as possible. COTA’s Corporate Communications department produces and distributes news releases to all local media (traditional and non-traditional) in our service territory (Responsibility: Media Relations Manager) We also send meeting notices to other key stakeholders:  Columbus Mayor Michael Coleman’s office o Dan Williamson, Communications Director o Ashley Senn, Community Relations Coordinator
  16. 16. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-11  Columbus City Council o John Ivanic, Communications Director o Adam Leddy  Franklin County Commissioners o Hanna Greer o Marty Homan o Michael Daniels, Aide to Commissioner Brown o Justin Shaw, Aide to Commissioner Brooks o Sharon Keels, Aide to Commissioner O’Grady  City of Columbus Area Commissions  Member municipalities Mayor’s and PIO offices  COTA Advisory Panel  COTA’s Mobility Advisory Board  Accessible Transportation Advisory Committee (Mobility Services)  Mid-Ohio Regional Planning Commission-MORPC o Laura Koprowski o Bernice Cage  Ohio State student PAC and Transportation and Parking officials  Columbus College of Art and Design  Columbus City Schools  Transit Columbus (community transit advocacy organization) Continuing Outreach On an annual basis, COTA develops a Community Outreach and Education Plan, overseen by COTA’s Community Relations Manager. COTA’s President/CEO, members of the Leadership Team; Mobility Services; Planning;
  17. 17. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-12 Corporate Communications and Marketing staff assist in the design, production and implementation of the Plan and other community outreach activities. The Plan serves as a guide in the Authority’s effort to inform all stakeholders about COTA activities, programs, services, expansion plans and other major initiatives. As a result, COTA has cultivated new constituencies and community partnerships; engaged the community in its service planning process; strengthened public involvement in public transit and increased COTA’s visibility and value throughout central Ohio. Ongoing outreach activities include, but are not limited to, convening targeted community leaders for roundtable discussions (4-6 annually); serving on planning committees for special projects and events; serving on organizational Boards; and delivering presentations to neighborhood groups, business, social and civic organizations. The plan also targets outreach for refugees; immigrants; English as a Second Language and Limited English Proficiency constituents offering travel training, bilingual print materials, advertising and marketing activities. COTA has also hired bilingual customer service office staff and bus operators who speak Spanish and Somali, two of the largest non-English speaking constituencies in Franklin County. Each calendar year, COTA makes formal presentations to, conducts and/or participates in over 350 community outreach activities. Minority and Low-Income Outreach In COTA’s service territory, there are segments of the population who speak Spanish and Somali as their first language. However, data from the U.S. Census reviewed by staff in the Communications, Marketing & Customer Service Division indicates that the numbers and percentages of languages other than English are below the numbers established by FTA to produce materials in languages other than English. However, COTA translated and published its “How to Ride Guide” and fare cards in English, Spanish and Somali. It is COTA’s policy to translate and publish any customer materials in Spanish and Somali upon request. COTA’s Customer Service Call Center has three (3) employees who speak fluent Spanish and are available to assist Spanish speaking customers. Two (2) full time employees and one (1) part time employee.
  18. 18. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-13 COTA’s Pass Sales office has one (1) employee who speaks fluent Spanish, French and Creole. COTA Community Relations Manager has established contacts with organizations and agencies providing services and other assistance to members of the Hispanic (Spanish speaking) and Somali/African (mostly Somali speaking) communities. Staff has relationships and partnerships with the Hispanic Chamber of Commerce, and Nationwide Children’s Hospital. Plans for Improvement Below are three (3) projects staff is working on or recommending to improve outreach to low income, minority or LEP populations: 1. COTA is currently in the process of redesigning its web site: www.cota.com. Technology that will enable all visitors to the Web site to read and interact with the web site in languages other than English is under consideration so that the site and all COTA information will be available to speakers and readers of many languages. 2. A cursory review of agency web sites in COTA’s service territory yielded the following:  City of Columbus web site offers Google Translate on its homepage.  Franklin County does not feature other languages on its homepage.  American Electric Power (electric utility) offers contact information in Spanish.  Columbus Department of Health offers its Directory of Services brochure in Spanish and Somali. Marketing staff managing the redevelopment of COTA’s web site has been directed to explore options available to report on progress of multi- lingual opportunities for the new cota.com for its introduction in spring 2014. 3. Recruitment efforts for call center representatives include seeking candidates who are fluent Somali speakers. 4. COTA is conducting an inventory of its internal placard customer information program aboard all fixed-route buses. The analysis will include possibly installing informational placards in Spanish and Somali.
  19. 19. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-14 1.8 REQUIREMENT TO PROVIDE MEANINGFUL ACCESS TO LEP PERSONS Developing a Language Assistance Plan COTA currently provides materials translated into Spanish and Somali. The Language Assistance Plan (LAP) contains a description of COTA’s fulfillment of LEP requirements, Four Factor Analysis, which includes services provided to LEP populations, and monitoring and training methods. LEP Requirements Based upon the Four Factor Analysis, COTA has determined that the ability to translate vital documents at request constitutes strong evidence of compliance of LEP requirements. The largest population of individuals who speak English “Less than very well” or “Not at all” are Spanish speakers constituting 1.6% of the total population of Franklin County, or 18,712 individuals, which is entirely within COTA’s service area. The second largest population of individuals who speak English “Less than very well” or “Not at all” are Somali speakers, constituting %0.1 of the total population of Franklin county or 1,533 individuals. COTA translated and published its “How to Ride Guide” and fare cards in English, Spanish and Somali. However, it is COTA’s policy to translate and publish any customer materials in Spanish and Somali upon request, including, but not limited to, complaint forms, notices of rights and notices of change in transit service. Request for translation of vital documents have not been substantial. For individuals that require further assistance beyond translated written material, COTA offers travel training and works with community organizations to provide translators. Four Factor Analysis 1. The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient.
  20. 20. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-15 How LEP persons interact with COTA COTA translated and published its “How to Ride Guide” and fare cards in English, Spanish and Somali. It is COTA’s policy to translate and publish any customer materials in Spanish and Somali upon request. Alternative language materials are available for viewing and printing on COTA’s website and are presented in Appendix A. COTA’s Customer Service Call Center has three (3) employees who speak fluent Spanish and are available to assist Spanish speaking customers. Two (2) full time employees and one (1) part time employee. All COTA materials are available by calling (614) 228-1776, requested through www.cota.com or via Facebook and Twitter. The same contacts offer assistance with travel training and any other assistance with accessing all services provided by COTA. Inside COTA buses, both English and Spanish language notices are provided to help ensure the comfort and safety of all passengers (see Appendix A). COTA strives to make it just as easy for a Spanish-speaking patron of limited English proficiency to travel on our system, as it is for a person that is fully proficient in English. Identification of LEP communities In the central Ohio region, Spanish and Somali are the two most common languages for residents whose first language is not English. However, these groups represent a small but growing part of the community. Utilizing American FactFinder, 2011 data files reveals the following population characteristics for Franklin County: Total Populations that “Speak English less than very well” or “not at all”: Spanish - 18,712 (+/- 2,672) Somali - 1,533 (+/- 482) Approximately 1,237,687 residents live within COTA’s taxing district and 1,163,414 residents within Franklin County.
  21. 21. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-16 Local articles about demographic changes in central Ohio are presented in Appendix A. Literary Skills of LEP Populations in their Native Tongue According to the CIA World Factbook, 37.8% of the Somali population, age 15 or older, are literate. However, according to the Somali Community Association of Ohio, 25% of Somali immigrants speak English well enough to get a job, 80% live with their families, 40% have become citizens and 57% are eligible to become citizens (www.somaliohio.org). It is likely that Somali immigrants to central Ohio have a higher literacy rate or have access to a family member that reads and speaks English and/or Somali. Spanish speaking populations have a high Spanish literacy rate. Mexico, for instance, has a literacy rate of 86.1% while Cuba has a literacy rate of 99.8%. Whether LEP Persons are Underserved COTA has not received complaints about lack of material for Somali or Spanish speakers. To date all, requests for specific training or available material for Somali and Spanish speakers have been met. 2. The Frequency with which LEP persons come into contact with the program Customer Service Center COTA’s customer service center employs one full time and two part time representatives who are fluent in both English and Spanish and COTA’s Pass Sales Outlet employs one employee fluent in English, Spanish, French and Creole. Travel Training and Mobility Services COTA Mobility Services department provided individualized, one-on-one travel training for potential riders. In August 2011 two travel training sessions were done for the Ethiopian Tewahedo Social Services group. This group is primarily refugees from Ethiopia, but includes some individuals also from Somalia, Burma and India. The first training was at their Morse Road location and included 14 individuals.
  22. 22. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-17 Those in attendance were taught how to read bus schedules, introduction to COTA’s website and basic bus riding skills. After the classroom training the group of individuals took a trip downtown to COTA’s main office were they learned to get passes, schedules and assistance. The second group of individuals was from Ethiopian Tewahedo Social Services Mt. Vernon branch and there were 13 individuals. Both groups of individuals had a student that was more proficient in English and assisted the COTA representative with translating, when needed. Most of the individuals in both these groups had a good grasp of English as their second language. In August 2012, at two different times, a COTA representative was scheduled to meet with the Westerville School Latino Parents Group. The person coordinating this was going to be the translator for COTA. COTA personnel showed but no individuals attended the session for travel training. In February 2013, a COTA representative did a travel training session with a group from Us Together. This group consists of refugees from Ethiopia, Somalia, Burma and India. Those in attendance were taught how to read bus schedules and basic bus riding skills. A bus was taken to their site for orientation to COTA buses. There were 12 individuals in attendance plus 3 interpreters; the interpreters are individuals Us Together already contracts with for translation purposes. A field trip will be scheduled for a later date. In February 2013, a COTA representative did a travel training session with a group from Us Together. This group consists of refugees from Ethiopia, Somalia, Burma and India. Those in attendance were taught how to read bus schedules and basic bus riding skills. A bus was taken to their site for orientation to COTA buses. There were 24 individuals in attendance plus 3 interpreters; the interpreters are individuals Us Together already contracts with for translation purposes. A field trip will be scheduled for a later date. In May 2013, a travel training bus field trip was held with a COTA representative leading a group of individuals from Us Together. This group consists of refugees from Ethiopia, Somalia, Burma and India. Those in attendance took a bus trip on the fixed route bus system from their point of origin to Nationwide Children’s Hospital. It was felt by the staff of Us Together that this was a good trip for them since many of them take their children there for care. They got to practice bus transfer and the use of passes. There were 23 individuals in attendance plus 3 interpreters; the interpreters are people their organization already contracts with.
  23. 23. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-18 In May 2013, at two different times a COTA representative did a travel training session with individuals from the Ethiopian Tewahedo Social Services group. Both of these trainings were done at their Farris Road facility. The first group of individuals included 23 individuals. Those in attendance were taught how to read bus schedules and basic bus riding skills. After the classroom training they took a trip downtown to COTA’s main office were they learned to get passes, schedules, and assistance. The first group had a good concept of English as their second language but there was also a student available in case they did not understand something the representative was saying. The second group was held a week later and had 18 individuals. This group is not as advanced in ESL so their instructor was with the representative to assist with questions. Those in attendance were taught how to read bus schedules and basic bus riding skills. After the classroom training the group took a trip downtown to COTA’s main office were they learned to get passes, schedules, and assistance. In June 2013, the Ethiopian Tewahedo Social Services staff was in contact with COTA’s travel training department to assist with a large group of individuals for a field trip in which they wanted to get all their facilities to one place for a luncheon. The morning of this trip there was a power outage because of storms and the trip was cancelled. 3. The nature and importance of the program, activity or service provided by the program to people’s lives COTA’s Mobility Services offers on-site travel training classroom and bus training to all people and groups that request it. This includes learning to read schedules, web site orientation, bus rules and field trips to a destination that would be frequently visited. Additionally, COTA’s Mobility Advisory Board provides comments and recommendations to COTA on transportation challenges and services for individuals with mobility difficulties, including LEP individuals with mobility difficulties, older adults and those who need transportation to work not served by COTA’s fixed-route. The membership is comprised of social and community services that require specialized transportation services as well as the Mid-Ohio Regional Planning Commission (MORPC). The board meets once a month with COTA staff.
  24. 24. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-19 COTA’s Community Relations Manager works closely with the City of Columbus’ “New Americans” department, which is housed and operates in conjunction with the City’s Community Relations Commission (http://crc.columbus.gov/content.aspx?id=29033), to serve the needs of LEP populations. COTA routinely communicates with New Americans staff, and partners with them on special outreach activities and projects throughout the community. 4. The resources available to the recipient for LEP outreach, as well as the costs associated with that outreach. No substantial costs to COTA are associated with providing non-English language materials. Incremental, minor costs include additional pay to multi- lingual customer service employees and translation of documents from English. However, resources available to COTA come from a variety of social organizations as well as the City of Columbus’ “New Americans” department. Mobility Services also works with community groups to secure a translator if needed during travel training sessions, often at no additional cost to COTA. Monitoring and Training COTA monitors demand for non-English language materials and information requests through its customer service center and public meetings. A Standard Operating Procedure (SOP) has been adopted for handling public requests, including a time-frame for response. It is recommended a comment be responded to within ten business days. COTA maintains an electronic database of all customer contacts using TrapezeCOM. Requests can be made in person, through a phone call, email, social media or standard mail. COTA’s customer service staff and management monitor non- English language material requests. If requests for languages other than Spanish and Somali become substantial, COTA will pursue translation of like materials.
  25. 25. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-20 1.9 MINORITY REPRESENTATION ON PLANNING AND ADVISORY BODIES COTA Board of Trustees The Board of Trustees currently consists of thirteen members; seven appointed by the City of Columbus, two appointed by the Franklin County Commissioners, and four city appointed slots rotated among the other member cities. The Board is the governing body of COTA and is responsible for overseeing COTA with the power vested in it by the Ohio Revised CODE 306.30 to 306.50 inclusive. Members are appointed for three-year terms by the governing or executive body the member represents. NAME RACE SEX REPRESENTS Dawn Tyler Lee Black F Columbus Kevin Wood White M Columbus William Anthony Black M Columbus James Daley White M Reynoldsburg Jean Ryan White F Columbus Mabel Freeman White F Bexley James Kunk White M Columbus Harry Proctor Black M Franklin County Cleve Ricksecker White M Columbus Craig Treneff White M Westerville Robert Weiler White M Columbus Richard Zitzke White M Whitehall Vacant Franklin County COTA Advisory Panel As provided for in the COTA Charter, an Advisory Panel was established to advise COTA management in the development and implementation of public transit in Central Ohio. Each member appointed to the Advisory Panel shall be a resident and have a familiarity with public transit needs in Central Ohio. The Advisory Panel meets quarterly and is used by COTA management as a resource in making decisions on public transit and, as appropriate, incorporate advice from the Panel into programs presented to the Board. NAME RACE SEX REPRESENTS Glen Soden White M Bexley Steven Campbell White M Columbus Ann Bohman White F Dublin
  26. 26. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-21 NAME RACE SEX REPRESENTS John O’grady White M Franklin County Brandi Braun White F Gahanna Edward Hastie III White M Grandview Heights Titus LeFlore Black M Reynoldsburg Joe Valentino N/A M Upper Arlington Jason Bechtold White M Westerville Paul Feldman White M Worthington Vacant Grove City Vacant Hilliard COTA Mobility Management Advisory Board This committee is comprised of organizations who serve persons with disabilities, older adults as well as clients who need transportation to work. The group meets monthly on the third Wednesday of each month. Committee members are often referred by other members or are asked to become members by COTA or the clients they serve. NAME RACE SEX ASSOCIATION Jane Acri White F Central Ohio Area Agency on Aging Janice Aselin White F AARP Lynn Aspey White F Jewish Family Services Pamela Brown Black F Godman Guild Paul Chanderlin White M Franklin County Board of DD Susan Colbert Black F OSU Extension Kathleen Dessault White F City of Columbus Mike Finelli White M National Church Residences Jennifer Flynn White M MOBILE Mary Ann Frantz White F MORPC John Gregory White M Life Care Alliance Renee Johnson Black F Jessie’s World, Inc. Kaiser Jones Black M Goodwill Columbus Mike McCaman White M FCDJFS Denise Robinson Black F Alvis House Lynn Robinson Black F MORPC Steve Simmons White M Columbus City Schools Barbara Sullivan White F Franklin County Office of Aging Andy Taylor White M MORPC Audrey Todd White F Food for Good Thought Keith Wollenberg White M Columbus State Comm Coll
  27. 27. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-22 1.10 PROVIDING ASSISTANCE TO SUBRECIPIENTS COTA is the designated recipient for federal funds in the Columbus Urbanized Area and has subrecipients for the JARC and New Freedom funds as required by the grant programs. Currently COTA has four (4) subrecipients: LifeCare Alliance, Yellow Cab of Columbus, Canal Winchester Human Services, and the Mid-Ohio Regional Planning Commission. The subrecipients are held to the same non- discriminatory standards as COTA when providing service. The subrecipients sign an agreement that holds them accountable to the FTA Master Agreement as well as more defined guidelines based on their particular projects. Each subrecipient is also responsible to sign a certification and assurances form each year as they become available. Subrecipients access COTA’s Title VI notice of rights, complaint form and procedures and adopted policies (Major Service Change, Disparate Impact, Disproportionate Burden and Fare Change) on COTA’s website (http://www.cota.com/Title-VI.aspx). All Title VI complaints regarding services provided with JARC or New Freedom funds are to be addressed to COTA as well as the recipient using COTA’s complaint procedures. 1.11 MONITORING SUBRECIPIENTS COTA’s grant administrator performs site visits to each subrecipient to ensure their projects are in compliance with the signed agreement and FTA standards. The administrator receives monthly reports that are entered into FTA TEAM quarterly. The subrecipients submit monthly invoices to COTA for reimbursement. Additional information may be requested in the event documentation is needed for reimbursement or project operations to ensure they are in compliance. 1.12 DETERMINATION OF SITE OR LOCATION OF FACILITIES When determining the location of a new facility or renovations to an existing facility COTA takes careful consideration of the impacts to the neighboring communities. Particularly with new facilities, COTA meets with community organizations, city councils and, in the case of Columbus, area commissions.
  28. 28. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-23 COTA has and will continue to integrate community input into final decision making. For instance, the construction of the Westview Turnaround, found below, included substantial public input prior to site selection. Summaries of newly constructed and renovated facilities between December 2010 and July 2013 are found below. McKinley Conversion to CNG Located in Columbus at 1600 McKinley Avenue, this 400,000 square foot bus storage and maintenance facility was completed in 1980. After more than thirty years in service, this facility has experienced numerous mechanical, electrical, and equipment failures. Consequently, COTA facility staff is undertaking a plan to prioritize major repairs and upgrades to the building and grounds. This includes renovating the facility to service compressed natural gas (CNG) vehicles. A CNG large vehicle fueling station was constructed in late 2012 and early 2013. Additionally, a CNG small vehicle fueling station is planned to be completed in 2014. COTA is in the process of forming a partnership with the City of Columbus to allow city vehicles to use COTA’s fueling station, saving the city the cost of constructing their own station. The facility is being renovated to a “like new” condition with CNG compliance and COTA anticipates a LEED Silver certification. The renovation will also:  Improve energy efficiency;  Reduce greenhouse gas emissions;  Meet all code requirements for CNG operations and ADA accessibility;  Improve operational flow efficiencies and best practices;  Expand fleet storage capacity to 275 buses; and  Accommodate current and long-term facility administration programming needs. The estimate completion date for the all renovations is 2016 although the bulk of the renovations will occur in 2014.
  29. 29. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-24 The total approved budget of the project is $75.7 million. The funding is coming from a mix of local, Federal and state programs such as CMAQ and State of Good Repair funds. Figure 1-3 and Figure 1-4 show the location of the McKinley Avenue facility atop minority and low-income census tracts. Based on the 2010 Census tracts, the facility is in tract 004300 with a population of 5,613, a minority population of 1,138 and a low-income population of 1,797 (2011 ACS data). There are no residential properties adjacent to the facility, with the closest neighborhood approximately 0.3 mi away. 1325 Essex Avenue – Street and Remote Maintenance Facility In 2008, COTA purchased a 2.23 acre site at 1325 Essex Avenue with an existing 12,000 square foot building. COTA moved the Street and Remote maintenance operations into this facility after making only minor modifications. The current facility was constructed in the late 1980s. This site is one component that makes up our Fields Avenue Campus. As described above, the Fields Campus also includes the Mainstream facility and the fixed-route transportation facility at 1333 Fields Avenue. This facility houses staff and equipment for the Street and Remote department to support the maintenance of bus stops and shelters located throughout our approximately 560 square-mile service area. The Street and Remote department performs a variety of support functions for more than 4,000 bus stops, including: pavement repairs, concrete work, and excavation, installation of sign poles, new shelter installation, and special event support. In July 2012, COTA began a renovation and expansion of the Essex Avenue facility with completion scheduled for January 2013. The design includes renovation of the current facility and the addition of 8,000 square feet of maintenance/storage space to meet current operational demands and future system growth. The current estimated cost for this renovation and expansion is $3.7 million which is 100% locally funded. The work, in summary, includes: renovation of an existing 12,000 square foot facility, a redesigned office wing, construction of an 8,000 square foot addition, expansion and resurfacing of the parking lot, construction of a salt dome, and installation of new mechanical/electrical systems. Similar to recent renovation projects, COTA’s design will seek LEED “Silver” certification. This renovation and expansion project will increase operational productivity by consolidating all equipment required for Street and Remote operations to a single location. This will help reduce operational costs while improving overall productivity.
  30. 30. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-25 Figure 1-3 and Figure 1-4 show the location of the Essex Avenue facility atop minority and low-income census tracts. Based on the 2010 Census tracts, the facility is in tract 001400 with a population of 1,543, a minority population of 1,341 and a low-income population of 1,082 (2011 ACS data). Most of the population is located in the far north-eastern portion of the census tract and was not affected by the construction of the Essex Avenue Facility. Westview Turnaround – Fixed-Route Bus Turnaround Over the past several decades, COTA utilized the Graceland Shopping Center as a bus layover and turnaround location for three routes serving the area:  #2 North High Local;  #4 Indianola Local, and  #95 Morse/Henderson Crosstown Layover time, or the amount of time between when the bus arrives at the end of one trip and before it leaves for the next trip, allows a bus which may be running late to recover and get back on schedule for the next trip. Additionally, scheduled layover time provides a break for an operator during their route. During the past five years, the owner of the shopping center has made significant infrastructure improvements by updating existing store fronts and constructing new buildings. As a result, this location has attracted several new tenants, while negatively impacting traffic flow and available property for a bus turnaround/layover area. In addition, future plans call for the continued development of new facilities within Graceland that will further limit the physical use of the site for transit operation. Due to this development activity, the property owner requested that COTA relocate to another site that is more appropriate for bus operations. Figure 1-2 Westview Turnaround
  31. 31. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-26 During 2011, COTA worked with the Clintonville Area Commission and other civic and community groups in identifying the northwest corner of High Street and Westview Avenue as a potential relocation site. Following the necessary approvals for this site, COTA moved forward with design and construction, completing the project for operations in December 2012. The new layover site allows for continuation of service for passengers wishing to patronize Graceland Shopping Center, and extends service approximately a half mile further north on High Street. As a result of this relocation, each of the routes listed above were modified to serve the new, COTA-owned facility. Transit service is still provided inside the Graceland Shopping Center by the #2 North High Street local at approximately 30 minute frequency of service on weekdays, with a reduced level of service offered during evenings and weekends. Buses at Graceland now simply enter and exit the site without laying over. The Westview Layover/Turnaround began operations on January 7, 2013. The cost for the property, design, and construction was $2.56 million. Figure 1-3 COTA Facilities – Minority Tracts
  32. 32. 2013 Title VI Report 1 – General Reporting Requirements Central Ohio Transit Authority 1-27 Figure 1-3 and Figure 1-4 show the location of the McKinley Avenue facility atop minority and low-income census tracts. Based on the 2010 Census tracts, the facility is in tract 006821 with a population of 3,327, a minority population of 948 and a low-income population of 2,886 (2011 ACS data). There are no residential properties adjacent to the facility, with the closest neighborhood approximately 0.3 mi away. Figure 1-4 COTA Facilities – Low-income Tracts
  33. 33. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-1 2 REQUIREMENTS AND GUIDELINES FOR FIXED-ROUTE TRANSIT PROVIDERS 2.1 REQUIREMENT TO SET SYSTEM-WIDE SERVICE STANDARDS AND POLICIES Effective Practices to Fulfill the Service Standard Requirement COTA’s adopted service design standards are contained within each iteration of its short-range transit plan. The COTA Board of Trustees normally approves the plan every two years. The most recent version, COTA’s 2013-2017 Short-Range Transit Plan, was adopted in May, 2013. The service standards are outlined below as required within FTA C 4702.1B Chap. IV sec. 4.1. COTA’s service standards are listed below: Vehicle load - The intent of load standards is to balance passenger comfort and safety with operating costs. These standards define maximum passenger loads at different times of day to ensure acceptable levels of rider comfort and safety, while providing COTA good operating efficiencies. The load standards shown below represent the total number of riders as a percent of the number of seats on the bus: Time Period Local Express Crosstown LINK Weekday AM, PM peak 120% 100% 120% 120% Midday 100% 100% 100% 100% Night 100% 100% 100% 100% Saturday 100% 100% 100% 100% Sunday 100% 100% 100% 100% These load standards should be applied to the average ridership and number of seats per bus for a period of 60 minutes. Passenger loading on individual bus trips may exceed the standard. If the load standard is exceeded for any 60- minute period, COTA will evaluate the potential for improving the service frequency (i.e., reducing the headway, or interval between buses). If the standard is exceeded for particular trips, but not for a sustained 60-minute period, COTA will evaluate the possibility of adjusting schedule times to focus more service before and after the overloaded trip(s).
  34. 34. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-2 The maximum time that an individual passenger should be expected to stand on a given trip is 15 minutes. Vehicle headway - The frequency of service on a particular route (i.e., headway, or time interval between successive buses) will be based on the existing or projected ridership and load standards (i.e., maximum number of passengers onboard a bus). However, on some routes, during certain periods of low ridership, determining frequency based on ridership demand may lead to very infrequent service. So infrequent, in fact, that the service is no longer viewed by passengers as a reliable or convenient means of travel. Therefore, minimum standards of service frequency may be applied to assure that a reliable, attractive level of service is available throughout the day. The following are minimum guidelines for COTA service frequency for each Service Category: Time Period Local Express Crosstown LINK Weekday AM, PM peak 30 min. 60 min. 30 min. NA Midday 60 min. NA 60 min. NA Night 60 min. NA NA NA Saturday 60 min. NA 60 min. NA Sunday 60 min. NA 60 min. NA Clock headways (e.g., service frequency intervals of 10, 15, 20, 30 and 60 minutes) should be maintained whenever possible. This helps to make the service easier to understand and more predictable to a rider, which is particularly important during periods when the service is infrequent (i.e., more than 30 minutes). Although clock headways are recommended, current funding levels and vehicle availability make this operating structure difficult to implement on a system-wide basis. On-time performance – To ensure that transit riders have confidence that the service will perform reliably in accordance with the public timetables prepared and distributed by COTA, on-time performance standards have been established. A vehicle is considered “on-time” when its arrival is from zero to 4 minutes and 59 seconds after the scheduled time. A vehicle is considered “late” when it arrives five minutes or more after the scheduled time. No vehicles should arrive before the scheduled time, or “early”.
  35. 35. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-3 It is impossible to achieve and maintain 100% on-time performance due to varying traffic and weather conditions, construction activity, detours, accidents and other service interruptions. Nevertheless, every effort will be made to ensure that all COTA buses operate on-time. The following on time performance standards shall apply:  80 - 90% of all buses should arrive at scheduled time points “on-time”. If a route or individual trip(s) is consistently running late, then a review of the schedule will be conducted and remedial actions (e.g., schedule and/or run modification if needed, improved on-street supervision, etc.) taken at the earliest opportunity. Service Availability for Fixed-Route Service - COTA attempts to meet the transit industry standard of 1/4 of a mile, with relation to the distance a person must travel to gain access to the system. Additionally, COTA set bus stop spacing guidelines and began an initiative to analyze all the bus stops within the fixed-route system to determine if the stop should be in service based upon the guidelines. Bus Stop Service Improvement Project (BSSIP) Bus stops should be spaced to balance the need for a quick in-vehicle travel time with considerations of the distance customers must walk to access the stop. When stops are spaced closely together, customers have convenient access as they are likely walking a short distance to the nearest bus stop. However, closely spaced stops are likely to result in a longer ride for customers because of the number of times the bus needs to decelerate, come to a complete stop, and then accelerate and re-merge into traffic. Having fewer stops along a bus route will inconvenience some customers who will be required to walk further to the nearest stop, especially if they have a mobility limitation. At the same time, having a greater distance between bus stops benefits passengers by reducing the in-vehicle travel time and benefits the transit agency through reduced maintenance costs of underutilized bus stops. Therefore, optimally spacing bus stops can have positive impacts on quality of service as well as operational effectiveness and efficiency.
  36. 36. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-4 COTA developed new bus stop spacing guidelines in 2009, as seen in Table 2-1 below. These guidelines were developed based on review of research studies on the optimal spacing of bus stops, existing bus stop spacing standards at other transit agencies, and feedback from the public, municipalities, and other stakeholders. Table 2-1 Bus Stop Spacing Guidelines Density Bus Stop Spacing Range High Density, CBD, Shopping (>20 persons/acre) 500 – 700 ft. Fully developed residential area (10 – 20 persons/acre) 700 – 850 ft. Low density residential (3 – 10 persons/acre) 850 – 1200 ft. Rural (or Express Bus Service) (0 – 3 persons/acre) 1200+ ft. Figure 2-1 Example BSSIP Analysis
  37. 37. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-5 It is important to note that these are general guidelines and that the actual placement of bus stops is influenced by more than these factors. When placing new bus stops or analyzing existing stop spacing COTA examines the following criteria:  Ridership – COTA will prioritize removing stops with low ridership rather than stops with very high ridership, which may result in uneven spacing on portions of the lines, if for example two very high ridership stops exist in close proximity to each other.  Crosswalks- COTA will prioritize placing new stops at intersections with safe crosswalks to discourage unsafe pedestrian crossings, which may result in uneven stop spacing on portions of the lines.  Accessibility – COTA may choose not to place or to remove stops along unsafe roadways with no pedestrian amenities, even if the spacing guidelines call for more closely spaced stops.  Special Populations – COTA may place stops more closely together if the stops are in close proximity to concentrations of people with mobility limitations, elderly populations, or medical facilities.  Nearby Destinations – COTA may place stops more closely than the guidelines call for if there are major trip-generating destinations such as employment centers.  Transfer Opportunities – COTA may place stops more closely together than recommended if it is necessary to do so in order to make transfers possible between multiple lines. In 2010, COTA began a multi-year project to analyze all existing bus stops to determine if spacing is consistent with the new guidelines. Many of the communities in COTA’s service area have changed over time and the existing bus stop spacing may not reflect current land use and population density. At least five months prior to each service change (the first Monday of January, May, and September), COTA selects routes to analyze, comprising about 500 bus stops. The spacing between each stop on each route is mapped and analyzed along with data collected from on-site investigations of each bus stop. Based on this analysis, COTA recommends bus stops to be consolidated, moved, or added. COTA uses a number of methods to notify customers and other stakeholders of these potential changes including:  Posting commuter bulletins on all potentially affected bus stops;
  38. 38. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-6  Posting information on the COTA website;  Holding public meetings; and  Notifying municipalities. Customers can respond during a three week open comment period through various methods, including the website, completing comment cards and verbally commenting at service change meetings, and phoning COTA to speak to a customer service representative. Based on the feedback received about the proposed bus stop changes, COTA will make the final decisions and notify the public of the final changes prior to implementation. It is expected that COTA will complete the Bus Stop Service Improvement Project by 2015. Effective Practices to Fulfill the Service Policy Requirement Distribution of transit amenities – Passenger shelters, bus stops, and passenger information are COTA’s primary amenities. Passenger Shelters COTA currently owns and maintains 302 passenger shelters. A map of COTA shelter locations is found in Appendix D. As the map shows, the majority of the shelters are located in low-income and minority census tracts. These shelters are located throughout the Franklin County area and serve major boarding/transfer locations, park and ride lots, turnarounds, shopping areas, medical/elderly facilities, etc. Shelter Site Selection Process COTA uses ridership figures as the primary criterion for determining which bus stops warrant shelters. Locations with 35 passenger boardings per day or more will be considered for shelters. Yet, there are additional criteria that are taken into account that support the placement of a shelter:  Proximity to medical facilities;  Proximity to senior housing;  Frequent wheelchair lift usage;  Major transfer point;
  39. 39. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-7  Serves a park & ride;  Serves a major activity center; and  Shelters funded and maintained by others. If a bus stop meets COTA’s shelter criteria, it may be considered for passenger shelter placement. Meeting these criteria, however, does not guarantee shelter installations. Existing site conditions such as the following may make shelter placement unfeasible:  Adequate shelter of some type is readily available  Shelter location is not approved by the local authorities  Shelter location generates severe local citizen/business opposition  Inadequate Right-of-Way  Lack of existing pedestrian amenities Features to be available with each COTA shelter are divided into two categories, necessary and desired. The following features are necessary:  Benches (not necessarily full length).  Accessible to passengers with disabilities.  Security of the shelter by limitation of nearby vegetation and non-obscured visibility and nearby/attached lighting.  Bus stop location is directly accessible from the shelter. The following features are desired:  Newspaper facilities  Full shelter site  Public service announcements (with no other advertising). Fifty-seven shelters and receptacles were installed in 2011 and thirty-six in 2012. Shelters are installed throughout our service area, with the largest concentration for shelter installations occurring along N. High St. and E. Broad St. In 2013 and
  40. 40. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-8 2014, most shelters in downtown Columbus will be replaced with new, uniquely designed shelters. Downtown Shelters COTA partnered with students from the Columbus College of Art and Design (CCAD), to design new passenger shelters that will replace those currently installed along High Street in the downtown Columbus area. The installation will be completed in 2014. A review of the COTA system may result in some service changes in the downtown area. If this results in a significant increase in bus volumes on another downtown street, the new shelters may also be placed at the downtown stops along that street. Bus Stop Signs As of January 2013, COTA has 3,885 unique bus stops throughout the service area. Most bus stops have COTA managed bus stop signs. Those without COTA signs are primarily in downtown Columbus but are indicated by either a shelter or a city of Columbus regulatory sign indicating a bus stop zone. COTA has an adequate inventory of bus stop signs and signposts for the 2010 calendar year. In late 2012 and throughout 2013 COTA has begun a new stop inventory process. Passenger Information COTA provides information to its customers and other stakeholders in a variety of ways:  Web site and social media;  Timetables: COTA designs, updates and produces a printed timetable for every route with maps and departure and arrival times at timepoints and other information for customers;  System Map: COTA designs, updates and produces a large fold out map of COTA’s system along with customer information about COTA and how to use public transit in central Ohio;  Brochures: COTA designs and produces brochures on various topics to inform new and existing customers about special programming, how to access public transit in central Ohio and other topics. A sampling of brochures available include: senior services, how to ride guide, fares, opportunities for Ohio State students and seasonal Summer YouthPass;
  41. 41. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-9  On board placards: COTA designs, produces and installs on board placards with information about riding COTA, regulations and expected behaviors, security information and other topics to inform customers about riding public transit and tips to make their experience as pleasant as possible. COTA Connection Customer Service Center COTA’s pass sales and customer service center is located in the lobby of the William J. Lhota Building at 33 N. High St. in downtown Columbus. Monthly passes, DayPasses, Senior Discount and Key-Cards, system maps, and schedule information can be obtained at this location, and it serves as COTA’s “Lost and Found” location. A customer information center (which provides telephone information to the public), and COTA's Quality Service offices are operated at McKinley Operations, 1600 McKinley Ave. In 2012, COTA’s customer information call center received 1,933,028 calls. Additionally, monthly passes and DayPasses are available for purchase at 93 locations throughout Franklin County. In early 2013, COTA installed an automatic pass dispensing machine at 33 N. High Street providing 24-hours pass sales providing access to passes to riders traveling to, from or through downtown Columbus. COTA service information is also easily accessible via an automated customer information system named Trapeze INFO. Consisting of several software modules, Trapeze INFO allows customers to obtain schedule and other information interactively via the telephone or COTA’s website 24 hours a day. COTA Website and Social Media In 2012, unique visits to www.cota.com averaged at 50,000 per month. In 2013, to meet the growing demand, COTA is redeveloping the website to include real time information that is available on a desktop or mobile device. Customers will more easily access bus schedules and arrival times, destinations, service changes, public meetings, employment and vendor opportunities. Information will be displayed as HTML and PDFs for customers’ convenience. In addition, COTA will provide detours and delays, changes in schedules and COTA programs and initiatives (e.g., Bus Stop Service Improvement Project). Customers will still have the ability to plan their trip using Google Transit. Customers will also be able to sign up for rider alerts to their phone or email.
  42. 42. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-10 In addition to the website, COTA now manages a Facebook, Twitter and YouTube account to stay engaged with customers. In addition, COTA evaluating other social media tools, such as Four Square, to determine their value to COTA and customers alike. As part of the SRTP, COTA will continue to monitor and invest in the latest computer hardware and software, and Internet technologies available to deliver accurate and timely transit information to central Ohio residents. Automatic Vehicle Announcement Over the past several years, COTA has made a significant investment in Intelligent Transportation Systems (ITS), to better manage and improve how COTA communicates and offers services to the public. One component of ITS, the Automatic Vehicle Annunciator (AVA) is a project that was initiated in January of 2003 and was fully functional for public use in May 2005 (see section 9.2). The AVA automatically announces and displays next stop information for the benefit of hearing and vision-disabled passengers. This system also improves service to COTA’s riders, especially to people not familiar with the stops of a particular route; or, to all riders when visibility is poor or limited due to night time hours or inclement weather conditions. As part of the AVL replacement project mentioned above, the AVA system will also be replaced on all buses. This project was completed in 2012. The AVA System enables COTA to meet or exceed all ADA requirements and will be included in all future bus buys. Traveler Information Systems Google Transit - In July 2008, COTA made available through a partnership with Google Transit, an online public transit trip planning tool, providing customers with a new tool for planning their bus trips in central Ohio. To use Google’s trip planner, customers simply enter their starting address and destination in the Trip Planner box on COTA’s homepage. Integrated with Google Maps, the Internet-based trip planner locates the nearest bus stop to the customer and gives step-by-step directions and detailed mapping for the trip. COTA riders receive travel times, any pertinent bus transfer and walking information, and the quickest way to reach the destination. COTA schedules are also available directly via Google Maps when users search for directions within the service area; public transit directions appear as an alternative to driving
  43. 43. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-11 directions. The Street View feature of Google Maps offers a visual preview of the trip and planned destination. Trip PRO - While Google Transit is COTA’s primary online trip-planning option, COTA continues to offer “Trip PRO” as a secondary option. Trip PRO is comprised of applications relying on Trapeze Software. The program includes an online trip planner; users can select dates, times, landmarks or put in an address to generate an itinerary. Initiated in 2009, COTA installed new CAD/AVL software and in 2012 fully replaced the Orbital system on fixed-route and paratransit buses with a system from Trapeze ITS, a division of Trapeze Group, a leading global provider of solutions for public urban passenger transportation. In 2013 COTA will complete the installation of this newer technology that also incorporates and completes several planned ITS components:  Electronic manifest for paratransit operations;  Driver training and on-board vehicle component and performance monitoring;  Transit intelligence system named Trapeze ViewPoint. ViewPoint is a reporting, monitoring and analysis solution which will allow staff to access, analyze and distribute operational data, and comes equipped with over 200 standard reports and dashboards; and  Paratransit demand response systems (IVR and Internet based reservation communication and automated notification). Vehicle assignment COTA utilizes buses that are equipped with Automatic Passenger Counter (APC) equipment to collect unlinked passenger trips and passenger miles required as part of the National Transit Database program. Because of this, buses must be assigned in a random manner. A check of bus assignments confirmed that there is no difference found in the age and quality of buses assigned to minority/low- income routes and non-minority/non-low-income routes. A route is defined as minority or low-income if one-third of its route directional miles are located in minority or low-income census tracts. A list of minority routes and samples of random bus assignment data is found in Appendix F.
  44. 44. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-12 2.2 REQUIREMENT TO COLLECT AND REPORT DEMOGRAPHIC DATA Demographic and Service Profile Maps and Charts COTA staff has prepared demographic and service profile maps and charts using 2010 Census data and 2011 American Community Survey Data (ACS). The ACS data was provided by MORPC and applied to the 2010 Census tracts. A copy of COTA’s base map which shows census tracts, major streets and highways, bus routes, transit facilities, major employment centers, hospitals, etc. is shown in Appendix D. Additionally, a poster size map is included with this submission. Those census tracts with minority populations greater than 32% (the total service-area minority population percentage) are shaded in grey. Additionally, those census tracts with a low-income population greater than 16.5% (the service-area low-income population) are shaded in grey. A chart listing the totals, by census tract is included in Appendix D. Demographic Ridership and Travel Patterns During the month of October 2008, an on-board passenger survey was conducted on all COTA routes. The survey was conducted in partnership with MORPC, the region’s metropolitan planning organization. The purpose of the survey was to capture accurate and reliable travel patterns and socio- demographic characteristics of the community’s transit passengers. The details obtained through the use of the survey are being utilized to help update MORPC’s regional transportation model, and to assist with future transit planning and marketing efforts. Available in both English and Spanish versions, the survey asked questions about how often riders use transit service, their origin and destination, how passengers complete their trip and how they transfer within the system. The survey collected important demographic information regarding vehicle ownership, income levels, and access modes. Open-ended comments regarding the provision of COTA’s transit service were also collected and summarized in report form. Approximately 14,590 surveys were handed out and a total of 5,995 complete and usable surveys as well as 5,076 partial records were collected. Key findings from the survey as well as English and Spanish versions of the survey are included in Appendix D.
  45. 45. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-13 In early 2013, COTA initiated another On-Board Survey, again in cooperation with MORPC. The survey will finish in September and data available late 2013 or early 2014. Subsequent Title VI reports will utilize the 2013 survey data. 2.3 REQUIREMENT TO MONITOR TRANSIT SERVICE Performance Assessment In order to comply with 49 CFR Section 21.5(2), 49 CFR Section 21.5(b)(7) and Appendix C to 49 CFR part 21, COTA has provided a sample of minority, non- minority, low-income and non-low-income bus routes with required analysis. A description of the level of service quality methodology is provided below, with the corresponding service analysis found in Table 2-3. The analysis reflects no significant difference in service quality between low-income/minority census tracts and non-low-income/non-minority tracts. To compare the service design and performance of COTA’s bus lines, five minority/low income bus lines and five non-minority/non-low income bus lines were randomly chosen for comparison to COTA’s adopted service standards. The minority and low-income status of COTA’s bus lines are defined as 1/3 of the line serving minority or low-income census tracts. Each of the ten selected bus lines was analyzed for its compliance with COTA’s minimum standards for service design, as adopted in the 2013-2017 Short- Range Transit Plan. The elements analyzed include service hours (span of service) for each day of the week and frequency of service for each day of the week and time of day (weekday only). Table 2-2 below represents the results of this analysis, showing either yes, no, or not applicable for each bus line indicating whether or not that line meets the standards. The standards for service design that were used for this analysis can be found in Chapter 3 of COTA’s 2013-2017 Short-Range Transit Plan available on COTA’s website http://www.cota.com/2013-17ShortRangeTransitPlan.aspx. (Appendix H) This analysis demonstrates that COTA’s minority and low-income bus lines meet COTA’s own design standards better than the non-minority and non-low income bus lines. This difference is due to the fact that COTA must often determine span and frequency of service based on passenger demand. In general, there is less demand for transit service in areas with higher average incomes and lower percentage of minority populations than in low-income, high-minority areas. Therefore some of COTA’s bus lines serving non-minority/non-low income areas do not have strong demand for transit resulting in lower levels of service.
  46. 46. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-14 Board Resolutions In August 2013, COTA briefed the Board of Trustees on the results of the Title VI program through a summary of the report and copy of the draft report. The board passed a resolution approving the submittal and results of the report. See Appendix E for more details.
  47. 47. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-15 Table 2-2 Requirement to Monitor Service
  48. 48. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-16 2.4 REQUIREMENT TO COLLECT AND REPORT DEMOGRAPHIC DATA Service Equity Analysis Major Service Change Policy In June 2013 COTA adopted an updated Major Service Change Policy in accordance with FTA Circular C 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, see Appendix E for the adopted policy. The threshold indicating a major service change is a 25% or greater change in service hours. COTA refines its fixed route services on the first Monday of January, May and September of each year. In an effort to gather input from the public and to inform transit users of all such scheduled changes to the service (including major service reductions, which are defined as a 25% or more reduction in annualized service hours on a route) COTA will adhere to the following procedures. 1 COTA will gather input continually from the public through telephone conversations, letters, website, social media and regularly scheduled public outreach meetings. In addition, COTA will survey its users and employers/employees who have requested some modification to the transit service. 2 Bi-annually, COTA will prepare an update to the schedule of service improvements for the next five years which will be included in the Short- Range Transit Plan (SRTP). The service changes in the SRTP are then reviewed and discussed in the following public meetings: MORPC’s Citizens Advisory, Transportation Advisory, and Policy committees; COTA Advisory Panel (consisting of representatives from various local municipalities), COTA Planning Committee of the Board of Trustees; and COTA Board of Trustees. 3 Prior to finalizing any service change, COTA will conduct Community Outreach meetings in neighborhoods which will be most directly affected by the change. When a proposed change would eliminate a route or significantly reduce the span of service or frequency of service along a route, COTA will actively solicit and consider input from the affected area through neighborhood meetings and/or on-board surveys. A significant reduction in the span of service on a route is defined as the elimination of a time period (such as, midday service) or weekend service. A significant reduction in the frequency of service on a route is defined as a 100% increase or more in the headway of the route. 4 Two months prior to each service change, the proposed modifications are presented to COTA’s Planning Committee of the Board of Trustees and the
  49. 49. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-17 full Board of Trustees for their review and approval. Such meetings are open to the public for comments and discussion. 5 The following activities take place prior to the effective date of all approved changes in order to inform users of the changes:  A minimum of four public meetings will be held to solicit public input regarding potential service modifications. Two meetings are held four months prior to the service change implementation date in order to encourage public feedback to service proposals, and if feasible, adjustments are made by staff to the potential modifications. A second set of two community outreach meetings will be held to present the final draft list of modifications, and to solicit additional feedback. A minimum of two meetings are held within a designated Title VI area.  Commuter bulletins will be posted at bus stops affected by a proposed service modification. Bulletins posted at bus stops include a description of the proposed modification, maps (if applicable), and instructions regarding how to provide feedback to COTA about the proposed changes. Commuter bulletins will also be posted on COTA buses which indicate the routes that will be affected;  Press releases describing the changes will be sent to newspaper, radio and TV stations, and posted on COTA’s website;  COTA operators will pass out new public timetables on affected routes;  Handouts describing the changes will be passed out at the downtown express terminals and/or on selected trips, at the discretion of COTA;  Any other activities deemed necessary by COTA. Adverse Effects During the December 2010 to June 2013 reporting period there were no major service reductions of system-wide hours of service. However, five lines were discontinued due to low-ridership. With the addition of the 0.25% ten-year renewable sales tax approved by voters in 2006, COTA reversed a previous trend of painful service reductions which resulted in a 25% decrease in service hours from 2001 to 2006. While COTA utilized the 2006 LRTP and 2007 SRTP as roadmaps for ramped up service expansion beginning in 2007, expansion slowed as a result of the nation’s recent worst economic recession since the Great Depression. The economic downturn negatively impacted COTA’s projected sales tax receipts, and caused a
  50. 50. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-18 significant rise in the region’s unemployment rate. In order to ensure a balanced budget and prudent management of COTA’s financial resources, in January 2010, COTA reduced the yearly service hour expansion rate by nearly 50%, from approximately 60,000 annual hours of new service to 40,000 hours of new service each year. However, starting in 2013, in response to improving economic conditions, COTA will be able to expand service by approximately 50,000 hours per year from 2013 to 2017. Through a continued expansion effort, COTA SRTP serves to maintain a commitment for fixed-route service improvements that focus on five key areas of improvement:  Improved service frequency;  Expanded service coverage area;  Decreased travel times;  Improved on-time performance; and  Expanded hours of operation on selected routes. During the Title VI reporting period, as a result of low ridership, the following routes were discontinued #26 Beechwold express, #42 Johnstown reverse express, #51 ODOT/ODPS reverse express, #62 Bethel reverse express, #74 Linden Link. In order to keep pace with inflation and as projected in the LRTP, a fare increase was implemented in January 2012. This increase was necessary to maintain a balanced budget and avoid operating deficits. Appendix C contains a summary of COTA’s public outreach activities for all service changes and fare increases during this Title VI reporting period. Various service change analysis was conducted during the Title VI reporting period. A spreadsheet analysis was conducted which analyzed the percentage change in service hours, miles, and trips for each route. Based on census tract data, each route was classified as minority, low-income, or non-minority/non-low income (see Appendix G). Appendix G also includes maps which were created to reflect by area, service modifications which occurred during the January 2007- September 2010 service change period.
  51. 51. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-19 Discontinued Routes from November 2010 to November 2013 Route Reason for Discontinuation Date of Discontinuation Routes Effected Other Accessible Routes #26 Beechwold Express Low ridership September 2012 None #4 Indianola provides local service 7 days a week along the same alignment. #42 Johnstown Express Low ridership January 2012 None None #51 ODOT/ODPS Express Low ridership January 2011 None ODOT/ODPS location would still be served by the #10 W. Broad 7 days a week, and the #222 W. Broad/Casino Friday and Saturday late night. #62 Bethel Low ridership September 2011 None #18 Kenny provides local service to the origin and destination stops 7 days a week. #74 Linden LINK Low ridership May 2013 None The #1 Cleveland/Livingston and #8 Hamilton Ave/Frebis serve the same area 7 days a week. Each route has a higher frequency and span of service than the #74. Disparate Impact Policy In June 2013, COTA’s Board of Trustees adopted a disparate impact policy in accordance with FTA Circular C 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients. COTA defines the threshold for a “disparate impact” as follows: Should the impact of any major service change require a minority population to bear adverse effects twenty percent (20%) or greater than those adverse effects borne by the non-minority population, that impact will be deemed a disparate impact. The complete adopted policy can be seen in Appendix E.
  52. 52. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-20 Disproportionate Burden Policy In June 2013, COTA’s Board of Trustees adopted a disproportionate burden policy in accordance with FTA Circular C 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients. COTA defines the threshold for a “disproportionate burden” as follows: Should the impact of any major service change require a low-income population to bear adverse effects twenty percent (20%) or greater than those adverse effects borne by the non- low-income population, that impact will be deemed a disproportionate burden. The complete adopted policy can be seen in Appendix E. Public Participation To comply with the requirements of FTA Circular C 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, COTA sought public comment on its Proposed Title VI and EJ policies. COTA conducted two public meetings (April 30, 2013 and May 2, 2013) at its administrative offices to present these policies and to solicit public comment. The public meetings were held at different times of the day to provide the fullest opportunity for public engagement. COTA advertised these meetings on its website, social media channels and aboard all coaches. Additionally, COTA posted its Proposed Title VI and EJ policies online throughout the public notice and comment phase (April 16–May 16, 2013). Attendance at the public meetings was not required to comment. COTA also welcomed public comments via telephone, e-mail, and online—through its website comment portal and social media channels. Data Analysis COTA staff has prepared demographic and service profile maps and charts using 2010 Census data and 2011 American Community Survey Data (ACS). The ACS data and Census 2010 data was provided by the Mid-Ohio Regional Planning Commission (MORPC) and applied to the 2010 Census tracts. ArcGIS was used to display the data on 2010 Census tracts. The status of a census tract as minority or non-minority was determined by selecting all tracts within COTA’s service area, calculating the average percentage of minority residents within the service area then comparing each
  53. 53. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-21 tract to the average. Tracts above that average were determined to be minority tracts while tracts below were not. The status of a census tract as low-income or non-low-income was determined by using the ACS indication of individuals in poverty, selecting all tracts within COTA’s service area, calculating the average percentage of low-income residents within the service area then comparing each tract to the average. Tracts above that average were determined to be low-income tracts while tracts below were not. Additionally, data from COTA’s 2008 On-Board survey is used for analyzing Fare changes. Assessing Service Impacts Since the adoption of the updated Title VI circular in October 2012, COTA has had one service change in May 2013 in which to evaluate service using the new requirements within FTA Circular C 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients. While COTA did have a service change in January 2013, the changes were finalized before October 2012, prior to the adoption of the updated circular. Appendix H displays how COTA tracks major service changes based on service hours, number of trips and miles by line. Changes of 25% or greater are highlighted in either green for increase or red for a decrease. COTA continuously updates the tracking sheet and monitors changes on weekday, Saturday and Sunday. Table 2-3 below shows the lines that meet the Major Service Change threshold, having had a 25% change in service hours for the May 2013 service change. Minority and low-income population data was collected using the 2010 Census and 2011 ACS data respectively. The percentage of minority and low-income populations were compared to that of the total service area. Although all the lines meet the Major Service Change threshold, only the #74 Linden LINK had a reduction in service (100%) and was the only line with a disparate impact and disproportionate burden. COTA’s threshold for both disparate impact and disproportionate burden is 20%. While the #7 had a greater than 20% difference between low-income individuals served by the #7 and the entire system, the service was in favor of low-income populations.
  54. 54. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-22 The #74 was discontinued due to low ridership (36 per weekday) over multiple years. The service provided circulator service through a primarily minority and low-income neighborhood northeast of downtown Columbus. Many riders used the service to transfer to nearby, higher frequency local lines. Although the line was discontinued, the #1 Cleveland/Livingston, #8 Hamilton/Frebis and #81 Hudson/Ohio (crosstown) still serve the neighborhood, with most unique stops on the #74 within ¼ mile walking distance. The exception is one stop just outside of ¼ mile walking distance. The service hours from the #74 were reinvested in the system. May 2013 improvements within the neighborhood the #74 served include improving on-time performance on the #1 Cleveland/Livingston on weekdays.
  55. 55. 2013 Title VI Report 2 – Requirements and Guidelines for Fixed-Route Transit Providers Central Ohio Transit Authority 2-23 WeekdaySatSunTotalPopMinorityTotalPopLow-Income%Minority%Poverty%Minority%Poverty May-1374Circulator-100%N/AN/ADiscontinuationduetolowridership.Minority/Low-Income 75.11,25.10,15,14,9.20,9.10, 7.30,7.20192331650818463794585.8%43.0%32%16.50%YesYes May-134Local0%31.00%0.00%FrequencyImprovement.Minority/Low-Income 88.25,88.22,88.21,88.11,87.2, 77.4,77.3,107,69.24,69.21,69.1, 68.22,42,68.21,68.1,61,60,58.2, 58.1,57,56.2,56.1,53,52,40,30, 23,22,21,18.2,18.1,17,16,14,13, 12,10,3.1,2.2,2.1,1.2,7.2,7.1,6, 5,4.2,1.1138812379891322483945827.4%29.8%32%16.50%NoNo May-135Local42.40%100.62%0.00%FrequencyImprovement.Minority/Low-Income 85,84,82.42,82.41,81.42,79.54, 79.53,79.41,78.3,66,52,43,42, 40,30,22,20,19.02,19.01,18.2, 18.1,17,11.28754320658840211875623.6%22.3%32%16.50%NoNo May-137Local0.00%29.00%44.60%FrequencyImprovement.Minority/Low-Income 11.22,78.2,78.12,87.1,11.21,42, 59,58.1,57,56.2,56.1,55,52,40, 32,30,22,21,20,18.2,18.1,17,13, 12,11.1,10,6,5,4.19858928269854523314928.7%38.8%32%16.50%NoNo May-1316Local0.00%0.00%78.48%FrequencyImprovement.Minority/Low-Income 72.02,71.99,91,90,75.51,88.22, 88.21,75.34,101,42,61,58.2,58.1, 57,75.5,52,40,38,37,36,30,29, 28,26,25.2,74.24,25.18603641579827432161848.3%26.1%32%16.50%NoNo May-1389Crosstown37.19%0.00%0.00%FrequencyImprovement.Minority/Low-Income 94.3,93.61,93.5,93.4,93.25,93.23, 93.22,92.5,92.4,92.1,94.95,102, 93.26,93.73,94.1,94.27412037338728981205250.4%16.5%32%16.50%NoNo May2013DisparateImpactandDisproportionateBurdenAnalysis Disparate Impact Disproportionate BurdenChangeTitleVIStatus CensusTractswithin1/4mi. (3904900XX)TrimesterLineType LineSystemTractsServiceHourChangeACSData Table2-3TitleVIServiceAnalysis

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