Detroit Department of Transportation Title VI Program Plan


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Detroit Department of Transportation
Title VI Program Plan 2021-2023
November 1, 2020

TABLE OF CONTENTS
Introduction ............................................................................................................ 4 Organization Description .............................................................................................4 Title VI Policy Statement ..............................................................................................5
General Requirements .............................................................................................. 6 Title VI Notice to the Public & Location Where Title VI Notices are Posted .........................6 Title VI Complaint Procedures ......................................................................................7 Title VI Complaint Form...............................................................................................8 Title VI Investigations, Complaints, and Lawsuits .............................................................9 Title VI Training ..........................................................................................................9 DDOT Non-Elected Advisory Committees ................................................................... 10 Minority Representation on Committees ....................................................................... 11 Title VI Public Participation Plan ................................................................................. 12 Language Assistance Plan .......................................................................................... 21 Approval Signature Page...........................................................................................33 Subrecipient Assistance & Monitoring Plan ..................................................................34
Requirements for Fixed-Route Transit Providers ........................................................ 35 Service Standards and Policies ...................................................................................35 Service Standards Monitoring Report..........................................................................40 Service & Fare Equity Analysis .................................................................................... 41 Approval Signature Page...........................................................................................47 Results of Service and Fare Equity Analyses Conducted 2018-2020 ................................48 Demographic and Service Profile Maps and Charts .......................................................49 Demographic Ridership and Travel Patterns, Collected by Surveys ................................. 51 Approval Signature Page...........................................................................................53 Approval Signature Page...........................................................................................54

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TABLE OF CONTENTS
Appendix A: DDOT’s Title VI Complaint Form........................................................... 55 Appendix B: Title VI New Hire Acknowledgement Form ............................................. 59 Appendix C: Committee Membership Application...................................................... 60 Appendix D: Promotional Content ........................................................................... 62 Appendix E: Summary of Outreach Efforts October 2018–October 2020 ..................... 65 Appendix F: 2018 On-Board Survey Report Appendix G: LEP Training Handout Appendix H: October 2019 Service Monitoring Report Appendix I: 2018 Fare Change Equity Appendix J: January 2019 Service Change Equity Analysis Appendix K: June 2019 Service Change Equity Analysis Appendix L: November 2019 Service Change Equity Analysis Appendix M: Amenities Equity Analysis

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INTRODUCTION

Organization Description
The Detroit Department of Transportation (DDOT) provides service in the City of Detroit and destinations beyond the city limits in Wayne and Oakland counties. All fixed-route service is operated in-house. DDOT’s Detroit MetroLift paratransit service is provided by a contractor, Transdev, and subcontractors: Detroit Checker Cab Company, Comfort and Care Transportation, Delray United, Lakeside Division Inc., Moe Transportation, Odyssey Transportation, People’s Transit, and Wrightway Transportation. Paratransit trips are scheduled by Transdev staff. DDOT’s service area population is 679,865.
DDOT directly operates a network of 43 fixed routes with a fleet of 288 Federal Transit Administration (FTA)-funded buses. The current peak requirement is 231 vehicles. Detroit MetroLift paratransit service is operated using contractor-owned equipment. No FTA-funded equipment is used in MetroLift service. Both fixed-route and paratransit service are operated 24 hours a day.
On May 1, 2019, DDOT implemented a new fare structure named Dart. The basic adult fare for DDOT service is $2 for 4-hour unlimited rides on DDOT, SMART, and QLINE. The reduced fare is 50 cents for senior citizens, persons with disabilities, Medicare cardholders, and students. Students who have a DDOT identification card or a school issued identification card can ride at the reduced fare rate during all hours of service. In July 2019, DDOT implemented the Dart App, a mobile fare payment system using smartphone technology.
DDOT operates five (5) administrative, operations, and maintenance facilities, a transit center, and a transit hub as noted below. All facilities contain FTA interest.

ADMINISTRATIVE, OPERATIONS, AND MAINTENANCE Main Administrative Office Central Heavy Repair Building Gilbert Garage (Bus Operations and Maintenance) Coolidge Garage (Currently not in service) Shoemaker Garage (Bus Operations and Maintenance) TRANSIT CENTER Rosa Parks Transit Center TRANSIT HUB State Fair Transfer Hub

100 Mack, Detroit, MI 48201 1301 E. Warren, Detroit, MI 48207 5600 Wabash, Detroit, MI 48208 14044 Schaefer, Detroit, MI 48208 5149 St. Jean, Detroit, MI 48213
360 Michigan, Detroit, MI 48226
20110 Woodward, Detroit, MI 48203

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Title VI Policy Statement
It is the policy of the City of Detroit Department of Transportation (DDOT), in accordance with Title VI of the Civil Rights Act of 1964, DDOT’s Title VI Compliance and Implementation Plan to assure that “no person shall, based 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” for which DDOT receives federal financial assistance (42 U.S.C. Section 2000d). Furthermore, it is the policy of DDOT, as a recipient of federal-aid funding, to ensure nondiscrimination in all of its programs and activities.
To ensure compliance with Title VI of the Civil Rights Act of 1964, DDOT commits daily to promptly taking all measures necessary to ensure compliance with Title VI of the Civil Rights Act is upheld.
DDOT includes Title VI assurances in all written contracts and monitors for compliance when distributing federal aid funds to other entities. DDOT’s Title VI Program Coordinator is responsible for initiating and monitoring Title VI activities, preparing required reports, and other DDOT responsibilities as required by Title 49 CFR Part 21.
Individuals with questions or requiring additional information relating to this policy or the implementation of DDOT’s Title VI Program should contact the Office of Compliance Title VI Coordinator, Alicia Miller, at DDOT’s Main Office located at 100 Mack, Detroit MI 48201; by telephone at (313) 833-3658; or by email at [email protected]
As the Executive Director of Transit, I am fully committed to the goals of achieving nondiscrimination for all beneficiaries and participants, contractors, and subrecipients.

C. Mikel Oglesby, Executive Director of Transit

Date

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GENERAL REQUIREMENTS

Title VI Notice to the Public & Location Where Title VI Notices are Posted
The Detroit Department of Transportation (DDOT) posts a “Know Your Rights” notice to the public of rights under Title VI at the following locations listed in Table 1 below. The “Know Your Rights” notices are also publicly displayed on revenue vehicles.

TABLE 1 – PUBLIC NOTICE LOCATIONS

LOCATION NAME Main Administration Office

ADDRESS 100 Mack

CITY Detroit

Central Heavy Repair Building

1301 East Warren

Detroit

Rosa Park Transit Center

360 Michigan Avenue

Detroit

Gilbert Garage

5600 Wabash

Detroit

Shoemaker Garage

5149 St. Jean

Detroit

Website

www.ridedetroittransit.com or www.detroitmi.gov/ddot

DDOT’s Title VI notice are available on buses in English, Spanish, and Arabic (Figure 1). When DDOT’s outreach events and activities take place in geographic areas with known concentrations of French, Russian, Polish, Serbo-Croatian, Chinese, Vietnamese, African Languages, and other Slavic, Indic, Indo-European and unspecified languages that meet the “Safe Harbor” threshold, we will provide a Title VI notice translated in those languages as well.

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Figure 1 - Title VI Notice to the Public Poster – English, Spanish, and Arabic

Title VI Complaint Procedures
Any person who believes they have been subjected to discrimination based on race, color, or national origin may file a Title VI complaint by completing and submitting DDOT’s Title VI Complaint Form to DDOT’s Office of Compliance. A copy of the DDOT Title VI Complaint Form is shown in Figure 2 and is available on DDOT’s website. DDOT investigates complaints received no more than 180 days after the alleged incident. DDOT will process complaints that are complete. Signed complaint forms may be filed in writing via U.S. mail to:
Detroit Department of Transportation Office of Compliance Attention: Title VI Coordinator 100 Mack Detroit, MI 48201

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Complaint forms may also be faxed to DDOT’s Office of Compliance at (313) 833-1496.
Once the complaint is received, DDOT will review it to determine if DDOT has jurisdiction. The complainant will receive an acknowledgement letter informing him or her whether the complaint will be investigated by DDOT.
Investigation of Complaint DDOT has 60 days to investigate the complaint. If more information is needed to resolve the case, DDOT may contact the complainant. The complainant has 15 days from the date of the letter to send requested information to the investigator assigned to the complaint. If the investigator is not contacted by the complainant or does not receive the additional information within 15 days, DDOT may administratively close the complaint. A complaint can be administratively closed if the complainant no longer wishes to pursue their complaint.
After the investigator reviews the complaint, he or she will issue one of two letters to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed. An LOF summarizes the allegations and the interviews regarding the alleged incident and explains the actions of the agency in response to the finding. If the complainant wishes to appeal the decision, he or she has 10 days after the date of the closure letter or the LOF to submit a written request to the Executive Director of DDOT.
A person may also file a complaint directly with the Federal Transit Administration Office of Civil Rights:
Federal Transit Administration Office of Civil Rights East Building, 5th Floor - TCR 1200 New Jersey Avenue SE Washington, DC 20590
DDOT’s complaint form and all procedures are also located on our website: www.detroitmi.gov/ddot.
Title VI Complaint Form
A copy of the DDOT Title VI Complaint Form is shown in Appendix A and is available on DDOT’s website at www.detroitmi.gov/ddot.

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Title VI Investigations, Complaints, and Lawsuits
DDOT has evaluated three (3) Title VI complaints in the period of the 2018-2020 Title VI Program. A full record of Title VI complaints and investigations is summarized in Table 2.

CASE NUMBER DDOT-2019-1
DDOT-2019-02
DDOT-2020-01

Table 2 - Title VI Investigations, Complaints, and Lawsuits

COMPLAINANT RESPONDENT

DATE FILED

SUMMARY OF ALLEGATIONS

TYPE

DATE CLOSED

B. Barrow

B. Barrow

05/24/19

Racial discrimination driver would not lower the bus for an African American passenger but lowered the bus for a Caucasian passenger.

Complaint

Closed 7/11/19

Donald Rand

Donald Rand

11/19/19

Race, color, and national origin discrimination due to mid-city loop route is not a two-way route.

Complaint

Closed 12/20/19

Catherina Jones Jackson

Catherina Jones Jackson

02/09/20

Low-income community discrimination against student and seniors’ community due to schedule monitors and text my bus app not working. Also, service delays.

Complaint

Closed 2/12/20

DECISION
Unable to contact complainant. Complaint closed.
The title vi and ada coordinator made several attempts to contact the complainant for clarity and resolution, however, they were unsuccessful and administratively closed the complaint.
No violation found administratively closed

Title VI Training
The City of Detroit’s Human Rights/Resources Department provides Title VI training to all employees during new employee orientation training. All DDOT employees are required to read and sign an “Acknowledgement of Title VI Plan Policy” form during the onboarding process. The Acknowledgment of Title VI Plan Policy form is shown below in Appendix B. DDOT’s Office of Compliance Division conducts Title VI Awareness training for all safetysensitive and non-safety sensitive employees.

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DDOT Non-Elected Advisory Committees
DDOT has three non-elected advisory committees:
• DDOT Advisory Commission Council (DACC) • Local Advisory Council (LAC) • Paratransit Appeals Board (PAB)
DDOT actively encourages minority representation on the LAC, PAB, and DAC. We directly reach out to community-based organizations to increase awareness of the committees and solicit applications for new members. DDOT’s Office of Compliance and the Executive Office solicit applications during general public meetings, committee meetings, and community-based organizations events. DDOT encourages all interested individuals to apply via a downloadable application (Appendix C) and return it to us by email at [email protected] or mail (see address below). The application is also available in Spanish and Arabic. For committee openings, please call (313) 933-1300.
Mailing Address: Detroit Department of Transportation Attention: Office of Compliance 100 Mack Detroit, MI 48201
Local Advisory Council (LAC) The LAC serves as a liaison to the disabled community. This advisory body advises DDOT in areas relating to the planning, delivery, and operation of fixed route and Detroit MetroLift paratransit services. The meetings provide a forum for comments on proposed changes in service, policies, and procedures.
The purpose of the LAC is to review and comment on DDOT’s Section 10E plans, Americans with Disabilities Act Accessibility plan, and proposed service changes and policies. The LAC is composed of nine (9) members, with at least one (1) member being a resident of each of the seven (7) City Council Districts and two (2) at-large members, who shall represent the Detroit Area Agency on Aging. Meetings are held four (4) times a year on the third Tuesday of the months of February, May, August, and November.
Paratransit Appeals Board (PAB) The PAB is a requirement of the Americans with Disabilities Act of 1990 (ADA) (49 Part 37 Subpart F, Section 37.125), that DDOT will accept appeals from its determinations of eligibility. The PAB shall hear the appeals of individuals who were denied paratransit eligibility, service suspension, or limitations or conditions place on eligibility.

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Detroit Department of Transportation Title VI Program Plan