DATE:
APRIL 22, 2015
TO:
ATN BOARD OF DIRECTORS
FROM:
DIANA KOTLER, EXECUTIVE DIRECTOR
RE:
AGENDA ITEM #2 - PUBLIC HEARING
RECOMMENDATION:
In accordance Civil Rights Act of 1964 and Federal Transit Administration (FTA) requirements, conduct a
public hearing for receiving public input in consideration of the Anaheim Transportation Network’s draft
Title VI Plan. Receive public comments in regard to ATN’s:
A.
B.
C.
D.
Title VI Plan
Limited English Proficiency Plan
Public Participation Plan; and
ADA Complementary Transportation Plan
DISCUSSION:
Title VI of the Civil Rights Act of 1964 provides that “no person in the United States shall, on the grounds
of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subject
to discrimination under any program or activity receiving federal financial assistance.” To fulfill this basic
civil rights mandate, each agency that receives federal financial assistance, for any program, must prepare
and update, every three (3) years, their Title VI Plan and make the Plan available for public review and
comment.
Consistent with its commitment to meet FTA regulatory requirements, ATN updates and submits these
documents to Orange County Transportation Authority (OCTA). The ATN conducted several public
workshops, in accordance with the schedule approved by the ATN Board of Directors at its March 27,
2015, meeting. Public workshops were held on April 8, 2015, at the ATN’s administrative office and on
April 9, 2015 at Anaheim Regional Transportation Intermodal Center (ARTIC). ATN did not receive any
public comments in regard to the Title VI Plan. Pursuant to any public comments received at today’s
Public Hearing, the ATN Board of Directors shall consider these comments, prior to the final adoptions of
the Title VI Plan at May 27, 2015, ATN Board of Directors meeting. Upon completion of the public review
and adoption of its Title VI Plan, ATN will submit the Plan to OCTA.
The purpose of the Title VI Plan is to document practices and operations to ensure that, for all programs
and activities supported by federal financial assistance, the ATN provides services without exclusion or
discrimination on the grounds of race, color or nationality, or through creation of barriers to the use of
the ATN’s Anaheim Resort Transportation (ART) system.
1354 South Anaheim Boulevard  Anaheim, California 92805  714.563.5287  714-563-5289 fax  www.RideArt.org
ATN 2015 Title VI Plan is consistent with the Plan approved in by the Board in 2012; however, since the
ATN fleet exceeds the 50-bus threshold, additional elements need to be incorporated in the Title VI Plan
to evaluate potential impacts on minority populations. These elements include the following
components:
1. DISPARATE IMPACT AND BURDEN POLICY:


Adverse affects on minority population, due to a major service change, which impacts twenty
percent (20%) or more than the average minority population; or
Positive affect on non-minority population may occur, due to a major service change, which
impacts twenty percent (20%) or more that the average non-minority population.
Under the Disparate Analysis, the ATN will evaluate if a disparate impact may occur for the span of service
and service frequency changes. If specific routes and/or route segments are changed, these routes will
be examined on an individual basis. Should a disparate impact exist as a result of the proposed change(s),
alternatives shall be considered to lessen the impact on minority population. If no viable alternatives are
available, a substantial and legitimate justification shall be provided for ATN Board of Directors
consideration.
2. PUBLIC REVIEW AND INPUT
A major service change shall be subject to a Public Hearing and Adoption by the ATN Board of Directors.
Public input will be actively sought in regard to the proposed changes prior to the public hearing.
Customers, stakeholders, and the general public will be invited to provide comments as outlined in the
ATN’s Public Participation Plan.
When required, the public comment period will begin with the publishing of a legal notice seven (7) days
in advance of the public hearing date in the local newspaper of general circulation. The notice will set a
specific place, date, and time for one or more public hearings and in accordance with the ATN’s Public
Participation Plan.
The primary purpose of the Title VI Plan is to ensure that no discrimination exists on the grounds of race,
color or national origin, including ATN procedures for:
1.
2.
3.
4.
5.
6.
7.
Filing of civil rights complaints;
Consideration of investigations, complaints, and lawsuits (if any);
Provision of meaningful access to persons with limited English proficiency;
Distribution of information to ensure meaningful access to programs and services;
Policies and standards under which ATN operates;
Clear process for major service change considerations; and
Evaluation to meet service standards and the levels of service provided to the various
communities served by the ATN.
1354 South Anaheim Boulevard  Anaheim, California 92805  714.563.5287  714-563-5289 fax  www.RideArt.org
In addition to the elements specific to the Title VI Plan’s non-discrimination parameters, this Plan includes
segments dealing with:

Limited English Proficiency Plan (LEP) – accommodation of populations who do not speak
English as their primary language and have limited ability to read, speak, write or understand
English. To comply with the LEP requirements, the ATN has programs and services to
accommodate LEP populations.

Public Participation Plan (PPP) – availability of procedures that allow for, encourage, and
monitor participation of all citizens in the ATN service area, including but not limited to low
income and minority individuals, and those with Limited English Proficiency (LEP). The goal
of the PPP is to offer real opportunities for the engagement of all citizens of the ART system
service area.

American with Disabilities Act (ADA) Complementary Paratransit Plan – availability of ADA
Complementary Paratransit Plan paratransit services that are “comparable” to the fixed route
service levels and availability. ATN contracts with OCTA for the provision of ADA
Complementary Paratransit services.
In conclusion, the ATN is committed to the enforcement of US DOT’s Title VI regulations and will provide
the most effective and efficient public transit service possible, with full accountability to the constituency
we serve. Through these established service standards and policies, ATN will ensure that no person, or
group of persons, shall be discriminated against with regard to the routing, scheduling, or quality of transit
service based on race, color or national origin.
1354 South Anaheim Boulevard  Anaheim, California 92805  714.563.5287  714-563-5289 fax  www.RideArt.org