Revised March 2025
I. Overview
Title VI of the Civil Rights Act of 1964 is a federal statute that provides that no person shall, on the grounds of race, color, or national origin, be excluded from participation in, denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. All programs receiving financial assistance from the Federal Transit Administration (FTA) are subject to Title VI and the U.S. Department of Transportation’s implementing regulations at 49 CFR part 21. As the operator of Santa Rosa CityBus, the City of Santa Rosa’s Transit Division (within the Transportation and Public Works Department) is a recipient of financial assistance from FTA.
FTA requires that all direct and primary recipients of FTA financial assistance document their compliance by submitting a Title VI Program to their regional civil rights officer once every three years. The Title VI Program must be approved by the recipient’s governing body, in this case the Santa Rosa City Council, prior to submission. The required elements of the Title VI Program, as well as overall requirements for ensuring compliance with Title VI, are detailed in FTA Circular 4702.1B (dated October 1, 2012). The City of Santa Rosa’s Transit Division has prepared this Title VI Program in accordance with these requirements.
The Title VI Program encompasses the following areas:
- Equity analysis related to determination of the site or location of new transit facilities
- Language Assistance Plan
- Procedures for filing a Title VI complaint
- Public notice of the protections from discrimination provided by Title VI
- Public Participation Plan
- Racial breakdown of the membership of non-elected advisory boards or committees
- Systemwide service standards and policies
II. Title VI Notice to the Public
Title 49 CFR 21.9 (d) requires that recipients provide information to the public regarding the recipient’s obligations under DOT’s Title VI regulations and apprise members of the public of the protections against discrimination afforded to them by Title VI. At a minimum, recipients shall post a Title VI notice on the agency’s website and in the public areas of the agency’s office(s), such as reception desk and meeting rooms. Recipients are also advised to post Title VI notices at stations or stops and/or on transit vehicles.
The Title VI notice must include:
- A statement that the agency operates programs without regard to race, color, or national origin,
- A description of the procedures that members of the public should follow in order to request additional information on the recipient’s Title VI obligations, and
- A description of the procedures that members of the public shall follow in order to file a Title VI discrimination complaint against the recipient.
The required Title VI Notice is provided via the Santa Rosa CityBus Non-Discrimination Policy.
The Non-Discrimination Policy is available on the Transit Division website, in public areas of the Transit Division offices at the Transit Operations Building on posters at major transit hubs and onboard every CityBus revenue vehicle.
III. Title VI Complaint Procedures
In order to comply with 49 CFR 21.9 (b), recipients must develop procedures for investigating and tracking Title VI complaints filed against them and make the procedure for filing a complaint available to the public. Recipients must also develop a Title VI complaint form. The complaint form and procedure for filing a complaint must be available on the recipient’s website.
The Santa Rosa CityBus procedure for filing and investigating Title VI complaints is available online. The Title VI complaint procedures and form are available in English and Spanish as well as any other language indicated by Language Assistance Plan implementation. In addition, information for filing a Title VI is included in the Santa Rosa CityBus Non-Discrimination Policy.
IV. Title VI Investigations, Complaints, or Lawsuits
In order to comply with the reporting requirements established in 49 CFR 21.9 (b), FTA requires recipients to prepare and maintain a list of any of the following that allege discrimination based on race, color, or national origin: active investigations conducted by entities other than FTA, lawsuits, and complaints naming the recipient. The list must contain the date that the investigation, lawsuit, or complaint was filed; a summary of allegations; the status of the investigation, lawsuit, or complaint; and actions taken by the recipient in response, or final findings related to the investigation, lawsuit, or complaint.
Since the last Title VI Program submission (in March 2022), the Transit Division has received 5 complaints alleging discrimination based on race, color, or national origin. These are summarized in the Title VI Program.
V. Public Participation Plan
Recipients are required to comply with the public participation requirements of 49 USC Sections 5307(b) and 5307(c)(1)(I). These sections require a locally-developed process to consider public comment before raising a fare or carrying out a major reduction in transportation service. Recipients are required to submit a Public Participation Plan as part of their Title VI Program that includes an outreach plan to engage minority and limited English proficient populations, as well as a summary of outreach efforts made since the last Title VI Program submission.
The Title VI Public Participation Plan is available in the Title VI Program document.
VI. Providing Meaningful Access to Limited English Proficiency (LEP) Persons/Language Assistance Plan
Consistent with Title VI and the U.S. Department of Transportation (DOT) implementing regulations, recipients must take reasonable steps to ensure meaningful access to benefits, services, information, and other important portions of their programs and activities for individuals who are Limited English Proficient (LEP).
Recipients are required by FTA to conduct a “Four Factor Analysis” consistent with DOT’s LEP guidance, as well as develop a Language Assistance Plan based on the results of the analysis. The Language Assistance Plan shall 1) include the results of the Four Factor Analysis, 2) describe how the recipients provides language assistance services by language, 3) describe how the recipient provides notice to LEP persons about the availability of language assistance, 4) describe how the recipient monitors, evaluates, and updates the language assistance plan, and 5) describe how the recipient trains employees to provide timely and reasonable language assistance to LEP persons.
A copy of the Santa Rosa CityBus Language Assistance Plan is available here.
VII. Minority Representation on Planning and Advisory Bodies
Recipients may not, on the grounds of race, color, or national origin, deny a person the opportunity to participate as a member of a planning, advisory, or similar body which is an integral part of the program. Recipients that have transit-related, non-elected planning boards, advisory councils or committees, the membership of which is selected by the recipient, must provide a table depicting the racial breakdown of the membership of those bodies and a description of efforts made to encourage the participation of minorities on such bodies.
The City of Santa Rosa does not currently have any transit-related, non-elected boards, councils, or committees. The Santa Rosa City Council serves as the policy board for Santa Rosa CityBus.
VIII. Subrecipient Compliance
Primary recipients of FTA financial assistance are required to provide assistance to subrecipients of federal financial assistance to support subrecipients’ compliance with Title VI regulations. Primary recipients are also required to monitor subrecipients for compliance with regulations. The City of Santa Rosa does not extend FTA financial assistance to subrecipients.
IX. Determination of Site or Location of Facilities
Per 49 CFR 21.9 (b)(3), recipients may not select the site or location of facilities with the purpose or effect of excluding persons from, denying the benefits of, or subjecting them to discrimination on the basis of race, color, or national origin. Per 49 CFR 21, (The Public Participation Plan), the location of projects requiring land acquisition and the displacement of persons from their residences and business may not be determined on the basis of race, color, or national origin.
Facilities included in this provision include, but are not limited to, storage facilities, maintenance facilities, and operations centers. Bus shelters are not included in this provision as they are considered transit amenities and are covered by regulations discussed in Section X of this Title VI Program. Transit stations, power substations and similar facilities are not included in this provision as they are evaluated during project development and the NEPA process.
For facilities covered by this provision, recipients are required to:
- Complete a Title VI equity analysis during the planning state with regard to where a project is located to ensure the location is selected without regard to race, color, or national origin, and engage in outreach to persons potentially impacted by siting of facilities. The Title VI equity analysis must compare the equity impacts of various siting alternatives, and the analysis must occur before the selection of the preferred site.
- Give attention to other facilities with similar impacts in the area to determine if any cumulative adverse impacts might result. Analysis should be done at the Census tract or block group level where appropriate to ensure proper analysis of localized impacts.
- Provide substantial legitimate justification for locating a project in a location that will result in a disparate impact on the basis of race, color, or national origin, and show that there are no alternative locations that would have a less disparate impact on the basis of race, color, or national origin. In order to show that both tests have been met, the recipient must consider and analyze alternatives to determine whether those alternatives would have less of a disparate impact on the basis of race, color, or national origin, and then implement the least discriminatory alternative.
The City of Santa Rosa has no current or anticipated plans to develop new transit facilities covered by these requirements. No facilities covered by these requirements were developed since the last Title VI Program submission in March 2022.
X. Systemwide Service Standards and Policies
The requirement to set systemwide service standards and policies relates to the general prohibition on discrimination on the basis on race, color, or national origin (49 CFR 21.5) as well as the requirement that no person or group of persons shall be discriminated against with regard to the routing, scheduling, or quality of service of transportation service on the basis of race, color, or national origin (49 CFR 21, Appendix C). Specifically, frequency of service, age and quality of transit vehicles assigned to routes, quality of stations serving different routes, and location of routes may not be determined on the basis of race, color, or national origin.
Providers of fixed-route public transportation services are to set service standards and policies for each fixed-route mode provided. The standards and policies must address how services and amenities are distributed across the transit system and ensure that service design and operations practices do not result in discrimination on the basis of race, color, or national origin. Specific quantitative standards are required for the following indicators: 1) vehicle load, 2) vehicle headway, 3) on-time performance, and 4) service availability (a measure of how routes are distributed within the service area). Policies are required for the following service indicators: 1) distribution of transit amenities (including seating, shelters, printed and digital information, escalators, elevators, and waste receptacles) for each fixed-route mode operated, and 2) vehicle assignment for each fixed-route mode operated.
Adopted service standards and policies for Santa Rosa CityBus can be viewed in the Title VI Program.