Sample Title VI Plan

Title VI
Program Update
Effective: February 10, 2016
Revised: March 2017

Greater Bridgeport Transit
Title VI Program Update
Effective Date: February 10, 2016
Revised: March 2017
Prepared by:
Greater Bridgeport Transit
One Cross Street
Bridgeport, Connecticut 06610
Tel: (203) 366-7070
URL: gogbt.com

TABLE of CONTENTS
INTRODUCTION | 1

GBT’s Commitment to Civil Rights | 1
GENERAL REQUIREMENTS | 3

Notice to the Public | 3

Discrimination Complaint Procedures | 4

The Procedure | 4
GBT’s PUBLIC PARTICIPATION PLAN | 6

Key Principles | 6

Early, Continuous and Meaningful | 6

Goals of the Public Participation Plan | 7

Objectives of the Public Participation Plan | 7

GBT’s Public Participation Process | 8
LANGUAGE ASSISTANCE PLAN | 13

Improving Access for People

with Limited English Proficiency | 13
OUTCOMES | 24

New tools and alerting riders

of language assistance | 24
DECISION MAKING BODIES | 26

Non-Elected Committees and Councils | 26

Service Review Committee | 26

Passenger Advisory Committee (PAC) | 27
SERVICE STANDARDS and POLICIES | 27

Vehicle Load | 29

Vehicle Headway (Frequency) | 29

On-Time Performance | 30

Service Availability – Access to the Bus | 30

Vehicle Assignment Policy | 30

Transit Amenity Policy | 30

Monitoring Service Standards | 31

Summary of Changes | 31

Construction Equity Analysis | 32
PROGRAM SPECIFIC REQUIREMENTS | 32
GRANTS, REVIEWS and CERTIFICATIONS | 33
CONTACT | 34
BOARD ADOPTION of POLICY | 35

INTRODUCTION

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GBT’s Commitment to Civil Rights
This update of Greater Bridgeport Transit’s (GBT) Title VI Program has been prepared to ensure
that the level and quality of GBT’s fixed route and demand response services are provided in a
nondiscriminatory manner and that the opportunity for full and fair participation is offered to GBT’s
riders and other community members. Additionally, through this program, GBT has examined the
need for services and materials for persons for whom English is not their primary language and who
have a limited ability to read, write, speak, or understand English.
While it is a matter of principle that GBT is committed to ensuring that no person is excluded from
participation in, or denied the benefits of, or subjected to discrimination in the receipt of any of
GBT’s services on the basis of race, color or national origin, the contents of this program have been
prepared in accordance with Section 601 of Title VI of the Civil Rights Act of 1964 and Executive
Order 13116 (Improving Access to Services for Persons with Limited English Proficiency).

“No person shall, on the grounds of race,

color, or national origin, be excluded from
participation in, be denied the benefits of, or be
subjected to discrimination under any program
or activity receiving federal assistance.”
—Civil Rights Act of 1964

Effective February 10, 2016 | Title VI Program

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“Federal agencies are to examine the services they

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provide, identify any need for services to those with
limited English proficiency, and develop and implement a
system to provide those services so LEP persons can have
meaningful access to them.”
—Executive Order 13166

Under the Civil Rights Act of 1964, and as a recipient of federal funding
under the programs of the Federal Transit Administration (FTA) of the
U.S. Department of Transportation (US DOT), GBT has an obligation to
ensure that:
• The benefits of its bus services are shared equitably throughout the service area;
• The level and quality of bus services are sufficient to provide equal access to all riders in
its service area;
• No one is precluded from participating in GBT’s service planning and development process;
• Decisions regarding service changes or facility locations are made without regard to
race, color or national origin and that development and urban renewal benefitting a
community as a whole not be unjustifiably purchased through the disproportionate allocation of its adverse environmental and health burdens on the community’s minority
population; and
• A program is in place for correcting any discrimination, whether intentional or unintentional.
GBT has engaged the public in the development of this program. The service standards detailed
in this program, along with the public engagement process and the events triggering public
outreached were all presented and discussed at a public information meeting in December
of 2012. To develop a system to provide services to those with limited English proficiency, GBT
engaged a number of community organizations and over 176 riders.
GBT’s Board of Commissioners was actively involved in the update of this program. In November
2012, the Board authorized the public review of the public participation process and updated
service standards. The content of the program was approved and adopted by the Board at a
special meeting on February 7, 2013.
This program contains all of the elements required of a transit provider operating in an urbanized area of 200,000 or more in population and operating less than fifty vehicles in peak service.
It supersedes GBT’s Title VI Program of 2013 and is effective as of February 10, 2016. It has been
prepared using data from the most recent U.S. Census.

Title VI Program | Effective February 10, 2016

GENERAL REQUIREMENTS
Notice to the Public
To make GBT’s riders aware of its commitment to Title VI compliance, and of their right to file a
civil rights complaint, GBT has presented the following language, in both English and Spanish, on its
website goGBT.com, on posters at its Bus Station and in its System Timetable.
GBT alerts its riders and other community members of its Civil Rights policy and complaint process
under Title VI using the following:
• Bi-lingual (English/Spanish) Web-based information available on the “Know your Civil
Rights” section of gogbt.com
• Bi-lingual (English/Spanish) signage on GBT Access paratransit buses;
• Bi-lingual (English/Spanish) signage on GBT fixed route buses; and
• Bi-lingual (English/Spanish) signage on GBT’s bus terminal platforms.

Your Civil Rights
Greater Bridgeport Transit (GBT) operates its programs and services without regard to
race, color, and national origin in accordance with Title VI of the Civil Rights Act. Any
person who believes they have been aggrieved by any unlawful discriminatory practice
under Title VI may file a complaint with GBT . For more information on GBT’s civil rights
program and the procedures to file a complaint, please contact 203-366-7070; email
[email protected] or visit our administrative office at One Cross Street, Bridgeport, CT
06610 from 8:30 am to 4:30 pm Monday through Friday. A complainant may file a
complaint directly with the Federal Transit Administration by filing a complaint with the
Office of Civil Rights, Attention:Title VI Program Coordinator, East Building, 5th Floor –
TCR, 1200 New Jersey Ave., SE, Washington DC 20590 For more information about GBT
programs and services, visit www.gogbt.com. If information is needed in another language,
please contact 203-366-7070.

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Discrimination Complaint Procedures

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GBT has established a process for riders to file a complaint under Title VI. Any person who believes
that she or he has been discriminated against on the basis of race, color, or national origin by GBT
may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint available
at our administrative offices or on our website goGBT.com.

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Complaint forms are translated in all Safe Harbor languages and are available on the website.

The Procedure
Civil rights complaints should filed immediately. However, GBT will investigate complaints up to 180
days after the alleged incident. GBT will process complaints that are complete. Once the complaint
is received, GBT will review it and the complainant will receive an acknowledgement letter
informing them whether the complaint will be investigated by GBT.
GBT has up to thirty days to investigate the complaint. If more information is needed to resolve the
case, the GBT may contact the complainant. The complainant has thirty days from the date of the
letter to send requested information to the investigator assigned to the case.
If GBT’s investigator (from the Department of Human Resources) is not contacted by the complainant or does not receive the additional Information within thirty days, GBT can administratively
close the case. A case can be administratively closed also if the complainant no longer wishes to
pursue their case.
After the investigator reviews the complaint, one of two letters will be issued 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.
A LOF summarizes the allegations and the interviews regarding the alleged incident, and explains
whether any disciplinary action, additional training of the staff member, or other action will occur.

Title VI Program | Effective February 10, 2016

If the complainant wishes to appeal the decision, she/he has ten days after the date of the letter
or the LOF to do so.
A person may also file a complaint directly with the Federal Transit Administration, at:
Federal Transit Administration
Office of Civil Rights
1200 New Jersey Avenue SE
Washington, DC 20590.
Title VI Complaint Form

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Active Lawsuits, Complaints or Inquiries Alleging Discrimination
GBT maintains a list of active investigations conducted by FTA and entities other than FTA, including
lawsuits and complaints naming GBT that allege discrimination on the basis of race, color or
national origin. This list includes the date that the transit-related Title VI investigation, lawsuit or
complaint was filed; a summary of the allegation(s); the status of the investigation, lawsuit or
complaint; and actions taken by GBT in response, or final findings related to the investigation,
lawsuit, or complaint.
As of the writing of this program, there are no service complaints pending which allege
discrimination on the grounds of race color, national origin or any other form of discrimination.

Active Lawsuits, Complaints or Inquiries Alleging Discrimination
Type
(Investigation, Lawsuit,
Complaint)

Date

Summary of Complaint

Status

Action(s)
Taken

There are no current
or pending lawsuits,
complaints or inquiries.

Effective February 10, 2016 | Title VI Program

GBT’s PUBLIC PARTICIPATION PLAN
Key Principles
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GBT’s Public Participation Plan (PPP) has been prepared to ensure that no one is precluded from
participating in GBT’s service planning and development process. It ensures that:
• Potentially affected community members will have an appropriate opportunity to
participate in decisions about a proposed activity that will affect their environment
and/or health;
• The public’s contribution can and will influence GBT’s decision making;
• The concerns of all participants involved will be considered in the decision-making
process; and
• GBT will seek out and facilitate the involvement of those potentially affected.
Through an open public process, GBT has developed a public participation plan to encourage and
guide public involvement efforts and enhance access to GBT’s transportation decision-making
process by minority and Limited English Proficient (LEP) populations. The public participation plan
describes the overall goals, guiding principles and outreach methods that GBT uses to reach its
riders.

Limited English Proficient (LEP)
LEP refers to persons for whom English is not their primary language and who have a
limited ability to read, write, speak, or understand English. It includes people who reported
to the U.S. Census that they speak English less than very well, not well, or not at all.

Early, Continuous and Meaningful
The steps outlined in the public participation plan offer early (in the planning process), continuous
and meaningful opportunities for the public to be involved in the identification of social, economic
and environmental impacts of proposed transportation decisions at GBT. It is a guide for how GBT
engages its diverse community. GBT may continue to improve its public participation methods
over time based on feedback from all of its riders and community members including low-income,
minority and LEP populations as well as customer and community-based organizations.

Title VI Program | Effective February 10, 2016

Goals of the Public Participation Plan
The overarching goals of GBT’s PPP, which were presented for public review in December 2012
include:
• Clarity in Potential for Influence - The process clearly identifies and communicates
where and how participants can have influence and direct impact on decision
making.
• Consistent Commitment - GBT communicates regularly, develops trust with riders
and our community and builds community capacity to provide public input.
• Diversity - Participants represent a range of socioeconomic, ethnic and cultural
perspectives, with representative participants including residents from low income
neighborhoods, ethnic communities and residents from Limited English Proficiency
• Accessibility - Every reasonable effort is made to ensure that opportunities to
participate are physically, geographically, temporally, linguistically, and culturally
accessible.
• Relevance - Issues are framed in such a way that the significance and potential
effect is understood by participants.
• Participant Satisfaction - People who take the time to participate feel it is worth the
effort to join the discussion and provide feedback.
• Partnerships - GBT develops and maintains partnerships with communities through
the methods described in its public participation plan.
• Quality Input and Participation - That comments received by GBT are useful,
relevant and constructive, contributing to better plans, projects, strategies and
decisions.

Objectives of the Public Participation Plan
GBT’s Public Participation Plan is based on the following principles:
• Flexibility - The engagement process will accommodate participation in a variety of
ways and be adjusted as needed.
• Inclusiveness - GBT will proactively reach out to and engage low income, minority
and LEP populations from the GBT service area.
• Respect - All feedback will be given careful and respectful consideration.
• Proactive and Timeliness - Participation methods will allow for early involvement and
be ongoing.
• Clear, Focused and Understandable - Participation methods will have a clear
purpose and use for the input, and will be described in language that is easy to
understand.
• Honest and Transparent - Information provided will be accurate, trustworthy and
complete.
• Responsiveness – GBT will respond and incorporate appropriate public comments
into transportation decisions.
• Accessibility – Meetings will be held in locations which are fully accessible and

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welcoming to all area residents, including, but not limited to, low-income and
minority members of the public and in locations relevant to the topics being
presented and discussed.
GBT will use its public participation plan when considering fare changes, modifications to routes
and schedules and other transit planning projects when:

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• A fare increase or significant change in the method of fare payment is being
considered;
• A new route is established;
• An existing route is proposed for elimination;
• Considering the total discontinuance of service on any line or group of lines on any
given day when service is currently offered;
• Any system-wide change in service hours that exceeds (plus or minus) 10% of current
total service hours;
• Routing on any given route or group of routes that affects more than 25% of the
riders using the affected route(s); or
• Schedules are changed on any given route or group of routes that reduces the total
number of one-way bus trips by more than 25% of the current number of bus trips.
• For minor schedule and service changes not rising to the level of those above, GBT
will post service change notices on appropriate buses and stops sixty days in advance
of the change date.

Regional Partnership/Capital Programming
For its capital programming, including major facility and bus procurements, GBT uses the
Greater Bridgeport Regional Council’s adopted public participation plan dated February
2008. This plan clearly indicates that the MPO’s public participation process satisfies the
GBT’s public participation requirements for the its Program of Projects. The notices for the
regional Transportation Improvement Program (TIP) also state that the notice of public
involvement activities and time established for public review of and comments on the TIP
will satisfy FTA’s program of projects requirement.

GBT’s Public Participation Process
Outreach Efforts – Alerting Riders and Encouraging Engagement
GBT’s PPP includes many new mediums extending beyond the traditional approach which relied on
legal notices and intermittent media coverage. While GBT maintains these elements to its outreach
program along with traditional seat-drop flyers, GBT has availed itself of the communication
methods more widely used by members of our community and riders.
While there may be minor variation in the outreach process from time-to-time, the outline below
provides the general steps for engaging riders in the decision making process using a fare or
service change as an example.

Title VI Program | Effective February 10, 2016

1. A service/fare change proposal is developed internally or as a result of public
comment;
2. An internal review by the appropriate committees is conducted (for example, GBT’s
Service Review Committee, detailed later in this program, will review all service
change proposals);
3. Proposals are reviewed by GBT’s Passenger Advisory Committee (PAC);
4. A Title VI review of the proposal is conducted;
5. If required, authorization from the GBT Board of Commissioners is sought to proceed
to a public comment period;
6. Public outreach venues, dates and times are determined with consideration of the
proposed changes and their impact on specific locations/populations within the GBT
service area;
7. Bilingual (English and Spanish) public outreach materials and a program are
developed;
8. Outreach In advance of public information sessions is released (using tool-box of
mediums listed below);
9. An Email is transmitted to GBT community partners;
10. Local radio station WICC or WCUM interviews may be conducted (if available);
11. The public comment period ends;
12. A GBT Board of Commissioners summary package is presented detailing the outcome
of the public participation process along with staff recommendations;
13. The final service/fare change date is set;
14. Outreach is conducted in advance of any service or fare change;
15. Bilingual system timetable and website updated in advance of the proposed change.

Selection of Meeting Locations
When determining locations and schedules for public meetings, GBT will:
• Schedule meetings at times and locations that are convenient and accessible for
minority and LEP communities;
• Employ different meeting sizes and formats including town hall type meeting formats;
• Coordinate with community organizations, educational institutions, and other
organizations to implement public engagement strategies that reach out specifically
to members of affected minority and/or LEP communities;
• Consider radio, television, or newspaper ads as well as podcasts that serve LEP
populations.
• Provide opportunities for public participation through means other than written
communication, such as one-on-one interviews or use of audio or video recording
devices to capture oral comments.

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GBT Mediums (Bi-lingual)

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•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Print – Newspapers and other periodicals
Outdoor – Advertising on-board buses (interior and exterior) and in bus shelters
Website – GBT has assembled a comprehensive website with automatic alerts
Web-Based Feedback - (Report It, Shout It, Suggest It, and How Are We Doing).
Social Media – GBT has used Facebook (1347+ followers in 2015) and Twitter (834+
followers in 2015) since 2009 to help engage community
Email – GBT has developed an email newsletter which now reaches 740+ opt-in
readers
Video/YouTube – GBT has developed a How to Use the Fare Box video that is
available at gogbt.com and on GBT’s YouTube channel
Radio (if available and appropriate)
Seat Drops, On-board Flyers – GBT regularly uses seat drops and flyers to provide
riders with details of service changes and schedules of public meetings and hearings.
On- board Scrolling messages
On-Board Audio Messaging
In Terminal Public Address System and scrolling messages
Direct Mail to Community Partners
Public Information Sessions
Public Hearings
Legal Notices

Facebook

Title VI Program | Effective February 10, 2016

Seat Drops

Email

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Twitter

Effective February 10, 2016 | Title VI Program

Addressing Comments
The Incorporation of Public Comments into Decisions

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All comments received through the public participation plan are given careful, thoughtful consideration. Because there are a number of different ways riders or members of the community can
comment on proposed service or fare changes (mail, email, social media, public meetings and
others), all comments are assembled into a single document for presentation the GBT Board of
Commissioner for consideration.

Identification of Stakeholders
Our Community Partners
Stakeholders are those who are either directly or indirectly affected by a plan, or the recommendations of that plan. Those who may be adversely affected, or who may be denied benefit of
a plan’s recommendation(s), are of particular interest in the identification of specific stakeholders.
Stakeholders can come from a number of groups including general citizens/residents, minority and
low-income persons, public agencies, and private organizations and businesses. While stakeholders
may vary based on the plan or program being considered, GBT has assembled a listing of
stakeholders with whom we regularly communicate through email and direct mail. A complete list
of GBT’s community stakeholders can be obtained by contacting GBT.

Stakeholder List
Any community organization or person can be added to GBT’s mailing list and receive
regular communications regarding service changes by contacting the GBT administrative
office at (203) 366-7070 Extension 100. Local organizations and businesses can also
request that a speaker from GBT attend their regular meeting at the same number or
through the GBT website gogbt.com

Title VI Program | Effective February 10, 2016

LANGUAGE ASSISTANCE PLAN
Improving Access for People
with Limited English Proficiency
In order to ensure meaningful access to programs and activities, GBT uses the information obtained in a Four Factor Analysis to determine the specific language services that are appropriate.
This analysis helps GBT to determine if it communicates effectively with LEP persons and informs
language access planning.
The Four Factor Analysis is a local assessment that considers:
1. The number or proportion of LEP persons eligible to be served or likely to be
encountered by GBT;
2. The frequency with which LEP persons come into contact with GBT services and programs;
3. The nature and importance of GBT’s services and programs in people’s lives; and
4. The resources available to GBT for LEP outreach, as well as the costs associated with
that outreach.

Factor 1 - Number of LEP Persons in Service Region
The first step in determining the appropriate components of a Language Assistance Plan is understanding the proportion of LEP persons who may encounter GBT’s services, their literacy skills in
English and their native language, the location of their communities and neighborhoods and, more
importantly, if any are underserved as a result of a language barrier.
To do this, GBT evaluated the level of English literacy and to what degree people in its service area
speak a language other than English and what those languages are. Data for this review is derived
from the United States Census Bureau “American Fact Finder” web portal data from 2014. Data was
reviewed for GBT’s four member municipalities as well as Fairfield County in its entirety.

Fairfield County Overview
GBT’s service system encompasses an eighty-two square mile area of Fairfield County, Connecticut
and is home to a diverse population of more than thirty-eight languages groups. Of the total
County population (891,911), 12.03% (107,296) residents report speaking English less than very
well. The most populous groups in the category are shown below. Of the remaining populations,
those reporting speaking English “less than very well” range from 0% to 0.3% of the total County
Population.

Effective February 10, 2016 | Title VI Program

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Speak English Less than Well (County)
This data reveals that at the county level, while there are numerous languages spoken at home,
there is a significant Spanish speaking population which reports speaking English less than well.
Speak English
“Less than Very Well”

Population Speaking English
“Less than Very Well”

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Percent of
County
Population

Spanish or Spanish Creole

62,555

7.0%

Portuguese or Portuguese Creole

9,350

1.0%

Chinese

3,640

0.4%

French Creole

3,145

0.4%

Because GBT’s service area does not include all of Fairfield County and is centered on four member
municipalities, additional census data was reviewed at the municipal level.

Bridgeport
Within the City of Bridgeport, 46% of the population of 135,898, reports speaking a language
other than English. As suggested by the county-wide data, 32% percent of the total population
speaks Spanish or Spanish Creole (a total of 43,487 people) and of that number, 53% (23,048)
report speaking English “less than well”. Second to Spanish or Spanish Creole speaking residents
are residents speaking other European languages (13,454) or 9.9%, with more than half (7,131)
reporting speaking English “less than very well”.

Fairfield, Stratford, Trumbull
While the core of the service area and more than 80% of all GBT services are within the City of
Bridgeport, some GBT routes travel to suburban communities with less dense populations. While
the populations are lower, the same general characteristics e.g., after English, the next most
popular language spoken at home being Spanish or Spanish Creole exist in GBT’s other member
municipalities. The table below summarizes language spoken at home and “less than very well” in
GBT’s suburban communities.

Speak English Less than Well (Suburban Portion of GBT’s Service Area)
As indicated by the current County wide data and supported by data at the municipal level, there
is a high percentage of Spanish or Spanish Creole speaking residents in the GBT service area and
while the overall number is lower in suburban portions of the service area, the largest population
reporting speaking a language at home other than English and reporting speaking English “less
than very well” remains the Spanish or Spanish Creole speaking residents.

Title VI Program | Effective February 10, 2016

Municipality

Percent Overall

Percent Speaking

Percent Speaking

Speaking English

Spanish or Spanish

Spanish or Spanish

“Less than Very Well”

Creole

Creole speaking English
“Less than Very Well”

Fairfield

5.0%

4.0%

32%

Stratford

7.3%

9.2%

33.9%

Trumbull

5.2%

4.4%

32.5%

The Locations of the LEP Community
While the need to provide language services to the Spanish speaking population in the GBT service
area is clearly demonstrated in the tables above; it is helpful to understand where in the service
area populations of limited English proficiency reside. The map below provides a spatial display of
residents who speak Spanish at home and report speaking English “less than well.”

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GBT has long been aware of the significant Spanish speaking population in its service area. The
map indicates locations where this population is concentrated in the service area; most notably
in the Bridgeport downtown area and neighborhoods in the East End/East Side, North End, Mill Hill
and the west end, including Black Rock. It is also noteworthy that there are “pockets” of residents
reporting speaking English “Less than Well” in Stratford’s South End and Center.

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Several conclusions can be drawn from this review:
• Approximately twelve percent of residents of the County report speaking English “less
than well”;
• Of those reporting speaking English “less than well”, the largest population speaks
Spanish or Spanish Creole at home;
• This pattern largely also holds true when data is reviewed at the municipal level; and
• The largest LEP language group (Spanish or Spanish Creole speaking) is concentrated
in the core of GBT’s service area.

Safe Harbor Provision
Beyond those reporting speaking Spanish or Spanish Creole at home and speaking English “less
than very well”, there are nine Safe Harbor languages groups, which are likely to be encountered in
its services area, which meet the Safe Harbor Provision thresholds, “of five percent or 1,000 persons,
whichever is less, of the total population of persons eligible to be served or likely to be affected or
encountered”. Those language groups are depicted in the table below.
Safe Harbor Language Group

Population

Percent of Service Area
Population

Service Area Population

277,061

100%

Spanish or Spanish Creole

51,707

18.7%

French

2,066

0.7%

French Creole

4,333

1.6%

Italian

3,006

1.1%

Portuguese or Portuguese Creole

6,229

2.2%

Polish

1,663

0.6%

Title VI Program | Effective February 10, 2016

Safe Harbor Language Group

Population

Percent of Service Area
Population

Chinese

1,694

0.6%

Vietnamese

1,714

0.6%

Arabic

1,413

0.5%

To ensure members of these language groups are not excluded from participating in or denied the
benefits of GBT services, due to a limited ability to read, write, speak or understand English, GBT
provides free language services, to ensure inclusion of persons, whose primary Language is not
English. These services include, Google Translation, On Phone Translation (OPT) services, bilingual
signage and documents, in person interpreters, employee language training and guides. These
services are discussed in more detail at points throughout this document.
As the data in the table above indicates, Spanish or Spanish Creole is by far the largest language
group to likely be encountered by GBT. Further surveys of GBT’s riders and employees support
this conclusion. As a matter of practice, many of GBT’s written and verbal communications and
documents are provided in both English and Spanish.
Documents pertaining to vital subject matter are translated into the Safe Harbor languages noted
above. GBT will provide language assistance for all other languages upon request. Those vital
documents include:
•
•
•
•
•
•
•
•
•
•
•

Complaint forms
Intake and application forms
Notices of denials, losses or decreases in benefits or services
ADA complementary paratransit eligibility applications
Guidance on how to apply for ADA complementary paratransit service
Title VI complaint forms
Notices of a person’s rights under Title VI
Fare and half fare information
Guidance on how to obtain schedule and route information
Guidance on how to receive notice of and participate in public events and outreach
Guidance on how to contact GBT or file a complaint

GBT has provided a brochure, which contains the below notice, translated into the nine Safe Harbor
language groups, informing members of those groups, of the language services provided to them,
by GBT, free of charge.
“Greater Bridgeport Transit (GBT) is committed to ensuring that no person(s) is excluded from
participating in or denied the benefits of GBT services, due to a limited ability to read, write, speak

Effective February 10, 2016 | Title VI Program

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or understand English. These services include, Google Translation, On Phone Translation (OPT)
services, bilingual signage and documents, in person interpreters.

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As a matter of practice, many of GBT’s written and verbal communications and documents are
provided in both English and Spanish. However, documents pertaining to vital subject matter are
also translated into this language upon request. Those vital documents include:
Complaint forms
Intake and application forms
Notices of denials, losses or decreases in benefits or services
ADA complementary paratransit eligibility applications
Guidance on how to apply for ADA complementary paratransit service
Title VI complaint forms
Notices of a person’s rights under Title VI
Fare and half fare information
Guidance on how to obtain schedule and route information
Guidance on how to receive notice of and participate in public events and outreach
Guidance on how to contact GBT or file a complaint”

Factor 2 - Frequency of LEP Use
There are a large number of places where GBT riders and members of the LEP population can
come into contact with GBT services including the use of fixed route and demand response buses,
calls to customer service representatives, reservation agents and GBT’s outreach materials. An
important part of the development of GBT’s Language Access Plan is the assessment of major
points of contact, including:
• The use of the bus service (on-board signage, announcements and driver language
skills);
• Communication with GBT’s customer service staff;
• Bus pass sales;
• Printed outreach materials;
• Web-based outreach materials;
• Public meetings;
• Demand response reservation agents;
• Local news media (print and radio);
• Automatic, service related audio announcements on-board GBT buses; and
• Service related posters at GBT’s bus terminal.
To better understand the frequency with which LEP riders come into contact with GBT services,
GBT conducted internal surveys of customer service staff, paratransit reservation agents, administrative staff and both fixed route and demand response drivers. The survey tool was aimed at
determining what language skills already exist among GBT employees and the number and nature
of encounters with riders or other community members where language has been a barrier.
GBT distributed a language surveys to its employees. The objective of the survey was to evaluate
Title VI Program | Effective February 10, 2016

the needs of GBT customers who are not able to communicate in English. The first question
asked employees was if they could communicate in a language other than English, and if so, what
language or languages.
Although varying degrees of fluency were indicated, 33 of 69 respondents could speak one or
more languages other than English.
•
•
•
•
•
•
•
•
•
•
•

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19

32 speak Spanish or Spanish Creole
3 speak French or French Creole
1 speak Italian
2 speaking Brazilian Portuguese
1 speaking Laotian
1 speaking Haitian
1 speaking Indu
1 speaking Japanese
2 speaking Vietnamese
2 Sign language
1 African languages

Next, the survey asked if in the previous year employees had encountered customers who were
unable to communicate in English and how often they heard or did not hear one of fourteen
languages.

Effective February 10, 2016 | Title VI Program

LEP Customer Encounters
Rarely

Sometimes

Often

Not Applicable

2

25

31

0

9

14

7

24

Italian

17

11

3

22

Portuguese or

11

19

3

19

German

13

4

0

36

Greek

13

7

0

33

Persian

13

2

0

36

Hindi

13

5

6

28

Chinese

15

11

3

23

Japanese

15

8

1

28

Russian

16

4

0

31

Spanish or Spanish
Creole

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20

French or French
Creole

Portuguese Creole

The three other languages were identified as Toko, an African dialect, Arabian, and lip reading.
The next survey question asked what type of needs or requests for assistance had employees
received from LEP customers. Those responses included:
•
•
•
•
•
•
•

Help with fastening a seat (demand response)
Help with shopping bags
Help with a cane, walker or mobility device
Street or venue location (directions)
Making a reservation (demand response)
To discuss the fare
Schedule and route information

The information obtained through this survey indicates a high number of GBT staff members
responding to the survey (50%) speak one or more languages other than English, many speaking
Spanish. Additionally, riders speaking Spanish are among the most frequently encountered LEP
populations.

Title VI Program | Effective February 10, 2016

Community Partners
As part of this assessment, GBT also canvassed eight of its community partners to assess the extent
to which they come into contact with LEP populations. GBT asked the partner agencies to estimate
the percent of clients they interact with who would have limited English proficiency using the
following questionnaire:
Do you encounter non-English speaking/reading people who need your services?
All eight respondents noted that they did encounter clients with limited English proficiency.
If so, what are the top three languages that you encounter?
The eight respondents noted the following languages; Spanish, Spanish Creole, Portuguese,
French, Haitian Creole, Asian, and African Languages.
How do you address language barriers?
Respondents use a variety of processes to address language barriers including bi-lingual
staff, Language Line, translation services and family members.
Do you find language to be a barrier in preventing you from providing service?
While some expressed some difficulty in dealing with limited English skills, none of the
respondents were prevented from providing their services as a result of a language barrier.

Community Partners
•
•
•
•
•
•
•
•

Action for Bridgeport Community Development
The Center for Family Justice
Connecticut Commission on Human Rights & Opportunities
Hall Neighborhood House
Bridgeport Child Advocacy Coalition
Career Resources
Cardinal Sheehan Center
The Kennedy Center (Mobility Services)

Effective February 10, 2016 | Title VI Program

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Consulting Directly with the LEP Population
In addition to the census data, internal survey of employees and outreach to community partners,
GBT applied a survey to its riders asking the following questions:

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22

•
•
•
•

Languages spoken at home?
Is language a barrier to accessing GBT services?
Is language a barrier to accessing GBT outreach materials?
Is language a barrier to access GBT customer service?

More than 176 riders responded to the survey, applied in-person on-board and at the GBT bus
station. When asked what language they spoke at home, 24 (14%) reported Spanish or Spanish
Creole. The 10 other languages reported in the survey represented 15% of the respondents.
When asked if language was a barrier to accessing GBT buses 154 (88% of respondents) reported
that language was not a barrier while 6% responded that language was a barrier or was
sometimes a barrier.
When asked if language was a barrier to accessing outreach materials 156 (89% of respondents)
reported that language is not a barrier to accessing GBT outreach materials while 6% reported
that language is a barrier or sometimes a barrier.
When asked if language is a barrier to accessing GBT customer service representatives (telephone
and in-person) 158 (90% of respondents) reported that language was not a barrier to accessing
customer service representatives while 5% reported that language was or was sometimes a barrier.

Riders surveys were applied at the GBT bus station in
Downtown Bridgeport and on-board GBT services.

Title VI Program | Effective February 10, 2016

Factor 3: The Importance of GBT Service to People’s Lives
Access to the services provided by GBT, both fixed route and demand response are critical to the
lives of many in the region. Many depend on GBT’s fixed route services for access to jobs and for
access to essential community services like schools, shopping and medical appointments. Riders
eligible for service under the American’s with Disabilities Act (ADA) require service for the same
reasons. Because of the essential nature of the services and the importance of these programs in
the lives of many of the region’s residents, there is a need to ensure that language is not a barrier
to access.
In a Fall 2012 survey of 854 GBT riders, 588 (68%) reported depending on the service for work
related transportation. During the same survey applied in Factor 2 of the LEP analysis, GBT also
asked riders: For what purpose do you use the bus. Ninety three percent of the riders responding
reported that they use the bus more than several times a week with purposes ranging from work
(47%), shopping (38%), school (15%) – all essential trip purposes.
If limited English is a barrier to using these services, then the consequences for the individual could
limit their access to obtain health care, education or employment. Critical information from GBT
which can affect access includes:
•
•
•
•
•
•
•
•

Route and schedule information
Fare and payment information
Information regarding making the best use of the system (How To)
Service announcements
Safety and security announcements
Complaint and comment forms
Outreach related to opportunity for public comments
Information about demand response services under the ADA and other special
programs
• What to do in an emergency (where to look for service change announcements)

Example: GBT Interior Signage

Effective February 10, 2016 | Title VI Program

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Factor 4 - Resources and Costs for LEP Outreach
GBT has committed resources to improving access to its services and programs for LEP persons.
Today, bilingual information (English/Spanish) is distributed in an extensive number of mediums
including:

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24

• A bi-lingual English/Spanish website
• A complete bilingual English/Spanish system timetable
• A complete bilingual English/Spanish Rider’s Guide to demand response services (ADA
paratransit)
• Bilingual English/Spanish outreach materials (seat drops and service change alerts)
• Bilingual English/Spanish representation at public meetings
• Bilingual English/Spanish customer service representatives
• Bilingual English/Spanish Demand Response reservation agents/customer service
representatives
• Bilingual English/Spanish on-board signage
• Bilingual English/Spanish guides and training for GBT drivers.
• Increased use of Bilingual English/Spanish Twitter Feeds and Facebook posts (not yet
100%)
• A bilingual English/Spanish video on how to use GBT’s new farebox.
To date, the costs associated with these efforts fit within the GBT’s marketing and outreach budget.
Costs are predominantly associated with translation services and material production.

OUTCOMES
New tools and alerting riders of language
assistance
Following the “Four Factor Analysis” conducted with GBT’s 2013 Title VI Program update, it was
concluded that, while there are currently extensive outreach and materials for LEP populations
of the service area, additional services would be beneficial, particularly to less prevalent LEP
populations in the region. These additional services included:
1. The addition of Google Translate to GBT’s website, which was completed in 2014. The
available languages for this service were further updated to include all nine “Safe
Harbor” language groups identified in this Title VI program update.
2. The addition of translation services for telephone communications is anticipated to
be in service by the time this program update is submitted (February 2016).
3. In 2015, GBT assigned new staff, charged with improving GBT’s community
engagement process.
4. GBT is creating a new page, with multiple languages for print system timetables and
web-based postings, indicating how GBT provides language assistance. Additionally,

Title VI Program | Effective February 10, 2016

a brochure, discussed previously in this program update, will be created to ensure
that members of the nine previously identified “Safe Harbor” language groups are
able to understand how to and obtain vital materials in the language they feel most
proficient in. These projects are expected to complete in April 2016.
Additional recommendations gleaned from the internal staff survey include:
1.
2.
3.
4.

Use a smart phone with a translation application;
Offering employees conversational or transit specific language training;
Recruiting more multilingual employees;
A multi-language touch screen monitor where passengers can access bus route information at the terminal
5. On-board announcements in different languages
GBT is considering all of these items.

Oversight
Monitoring, Evaluating and Updating the Language Assistance Plan and Public
Participation Process
In February 2013, GBT created a new staff position charged with improving community
engagement. It is the responsibility of this staff member to ensure compliance with GBT’s Title
VI Plan, Public Participation Program, Language Assistance Plan and other community outreach
efforts. The monitoring of the Language Assistance Plan will include:
•
•
•
•

Periodic reviews of regional census data for changing patterns of LEP populations;
Ongoing collaboration with regional partners;
Ongoing review of Google Translate requests at GBT’s website; and
Post Event Assessments (PEA)

Post-Event Assessments
Following service changes, fare increases and planning projects, GBT Manager of Planning and
Service Development assesses the effectiveness of public involvement against the goals established
in this plan. This assessment will ask the questions:
1. Did the public know there was an opportunity to participate?
2. Was the purpose of the participation clearly articulated to the public?
3. Did the public have access to appropriate resources and information to allow for
meaningful participation?
4. Did the decision making process allow for consideration and incorporation of public
input?
5. Were there complaints about the public engagement process?
6. Were the public engagement efforts cost effective?
7. What additional methods could have been employed to improve the process?
8. Should the Public Participation Process or Language Assistance Plan be amended?

Effective February 10, 2016 | Title VI Program

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25

Training Employees
As part of their regular training, GBT operators are provided an one hour module on Spanish for
transit employees. All staff are provided with the booklet “Basic Spanish for Transit Employees”
prepared Colorado Mountain College in association with the Colorado Department of Transportation.

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26

Translation of Vital Documents
GBT has translated many vital documents into Spanish and is in the process of translating others.
•
•
•
•
•
•

Civil Rights Complaint Form – Translated into Spanish in March 2013
ADA Eligibility Applications – Translated in 2006
ADA Service Overview Booklet – Translated into Spanish in 2006
Service change announcements – Translated into Spanish since 2001
On-board notices – Translated into Spanish since 2001
Notification of free language services – New print and web-based content will be
complete in 2016
• Maps and schedules, rider information, ADA service information, news and event announcements are all translated into Spanish on GBT’s website www.gogbt.com
• Service Complaint Forms – Translated in March 2013

DECISION MAKING BODIES
Non-Elected Committees and Councils
GBT Board of Commissioners
At GBT, decisions regarding policy, service changes, fares, capital programming and facility
locations are made by a municipally appointed Board of Commissioners. GBT’s Board of
Commissioners is composed of ten members representing four cities and towns who are
members of GBT. These members are appointed by the chief elected officials of these member
municipalities. Currently GBT has no mechanism to influence who is appointed. Meetings of the GBT
Board of Commissioners are always open to the public, held at GBT’s bus station or administrative
offices and noticed on our calendar of events at gogbt.com.

Body

Board of Commissioners

Caucasian

Latino

African
American

Asian
American

Native
American

8

0

1

0

0

Title VI Program | Effective February 10, 2016

Non-Decision Making Working Groups

GBT also works with two informal working groups, composed of meetings of Bus Operators and
Riders. The Service Review Committee and the Passenger Advisory Committee meet to discuss
routes, schedules, and other topics important to the community and our riders and contribute
valuable ideas to GBT’s planning and operations.

PA G E

Service Review Committee
The Service Review Committee is an informal technical meeting of GBT Bus Operators, who are
selected to discuss specific aspects of GBT’s service. Attendees are selected based on their
experience with a specific service or services. For example, a committee meeting to discuss
modifications to GBT’s Route 1 service would consist of current Route 1 Bus Operators. Attendance
at these meetings is voluntary. However, GBT’s employees are often eager to share their ideas
and while this is not a decision making body, the services that the Agency puts out are greatly
benefited by their input.

Passenger Advisory Committee (PAC)
Passenger Advisory Committee (PAC) is an open public meeting of riders, which meets quarterly, to
discuss all aspects of GBT’s Services, from the perspective of the public. All riders are encouraged
to attend and these meetings are noticed publically. Interested attendees can sign up to be
notified by mail or email of upcoming meetings and all meeting dates are posted on GBT’s website.
Attendance at these meetings is fluid and while some attendees do attend regularly. While this is
not a decision making body, the services that the Agency puts out are greatly benefited by their input.

SERVICE STANDARDS and POLICIES
GBT has developed a set of quantifiable service standards and policies. These service standards
were updated in 2012 through a public participations process, approved by GBT’s Board of
Commissioner’s and with the input of GBT’s Passenger Advisory Committee (PAC).
These service standards and policies include:
•
•
•
•
•
•

Vehicle Load
Headways (Frequencies)
On-time Performance (Schedule Adherence)
Service Availability
Vehicle Assignment Policy
Transit Amenity Policy

Following the internal updating of these policies and standards, GBT advertised and held a public
information session to receive comments on the proposed standards. During the session, GBT staff
presented an overview of the components of GBT’s public participation process as well as the
various policies and standards. A copy of the presentation is available by contacting GBT.

Effective February 10, 2016 | Title VI Program

27

Example: Public Meeting Announcements on Facebook and Email

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28

RESCHEDULED from 12/5/12:

Service Standards
Public Meeting
December 19, 2012
5 pm - 7 pm
at the GBT Bus Station in the
Community Room, 2nd floor

The outcome of the public session was agreement on
the service standards and policies as detailed below.

GBT is updating its service
standards and would like
your input. We have a series
of service standards that are
used to guide our planning
and improve the service we
provide. They are goals we
work toward and service
conditions that arise that alert
us that service changes are
needed. They cover things
like on time performance, the
locations of bus shelters, bus
frequency, accessibility and
the number of passengers on
each bus.
Join us to find out more. We
hope to see you there.

Title VI Program | Effective February 10, 2016

Vehicle Load
Vehicle load is expressed as the ratio of passengers to the total number of seats on a vehicle.
Vehicle Type

Seated
Capacity

Standing
Capacity

Total
Capacity

Preferred

Average
Load

Maximum
Load

35' NewFlyer

29

20

49

1

1.5

2

40' NewFlyer

39

20

59

1

1.5

2

40' NewFlyer

38

20

58

1

1.5

2

40' Gillig

40

25

65

1

1.5

2

Mini Bus Ford

20

0

20

1

NA

NA

10

0

10

1

NA

NA

Hybrid

F-450
Mini Bus Chevy
3500

Vehicle Headway (Frequency)
Vehicle headway is the amount of time between two buses traveling in the same direction on a
given route. GBT buses are scheduled with a variety of frequencies based generally on demand.
Routes are schedule in 30 and 60 minute frequencies. GBT will also consider more frequent (20min.) service where ridership levels warrant and funding levels permit and less frequent services
where demand dictates.

Policy Headways and Periods of Operation
Service

GBT Local and

Weekday
Peak

30

Weekday
Off Peak

60

Saturday

30

Saturday
Off Peak

60

Sunday
Peak

30

Sunday
Off Peak

60

Express Services

Effective February 10, 2016 | Title VI Program

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On-Time Performance
Among the most important service standard for riders is on-time performance or adherence to
published schedules.

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• A vehicle is considered on time if it departs a scheduled time point no more than two
minutes early and no more than 5 minutes late.
• GBT’s on-time performance objective is 90% or greater.

Service Availability – Access to the Bus
GBT currently provides transit service so that 90% of all residents of the City of Bridgeport are
within a 1,300 feet (1/4 mile) walk of bus service. Consideration is given to new markets as demand
warrants and as resources become available.

Vehicle Assignment Policy
With several practical considerations, GBT assigns buses to service so that average age of the
buses serving each route does not exceed the average age of the fleet. Bus assignments take
into account the operating characteristics of buses of various lengths, which are matched to the
operating characteristics of the route. Hybrid buses are not permitted on routes with clearance
restrictions and service to Routes 13 and 17 is provided only with 35’ buses due to turning radius
limitations on those routes.

Transit Amenity Policy
GBT has over 1,400 stops in the service area – many located and installed more than 30 years ago.
Stops, shelters and benches will be placed according to industry standards (TCRP Report 19) with
consideration of permitting and for local and special needs.
The installation of new bus amenities can be requested through the customer service office,
through the “Suggest it” form on GBT’s website or at public meetings.
When the annual cost of repairs to any amenity (beyond the cost of normal cleaning) is greater
than the cost of the structure, GBT reserves the right to permanently remove the amenity.

Title VI Program | Effective February 10, 2016

Monitoring Service Standards
For the on-going monitoring and measurement of service standards and policies, GBT uses the
following schedule and methods.

Service
Standard/Policy

Sample Schedule

Methodology

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31

Vehicle Load

All Routes Bi-Annually

Automatic Passenger Counters
on Fixed Route Buses

Vehicle Headways

Assessed Annually as Part of Service
Planning

Automatic Vehicle Location
System

On-Time
Performance

Assessed Monthly

Automatic Vehicle Location
system

Service Accessibility

Assessed Annually as Part of Service
Planning

Planning Desk/Geographic
Information System Review

Vehicle Assignment
Policy

Assessed Quarterly

Automatic Vehicle Location
System

Summary of Changes
Service Change Evaluations/Taking Action/Summary of Significant
Service Changes Since 2013
Since GBT’s 2013 Title VI Plan Submission there have been no changes in GBT’s fare structure or
service reductions.

“The development and urban renewal befitting a
community as a whole will not be unjustifiable
purchased through the disproportionate allocation
of its adverse environmental and health burdens
on the community’s minorities”.
—Executive order 12898: Federal Actions to Address
Environmental Justice in Minority and Low Income Populations

Effective February 10, 2016 | Title VI Program

Construction Equity Analysis

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32

When GBT plans to construct or expand a facility, such as a vehicle storage facility, maintenance
facility, transit hub or operation center, the agency will include a copy of the Title VI Equity Analysis
conducted during the planning stage with regard to the location of the facility. The following
principles will be applied in the analysis:
1. To avoid, minimize, or mitigate disproportionately high and adverse human health
and environmental effects, including social and economic effects, on minority
populations and low-income populations;
2. To ensure the full and fair participation by all potentially affected communities in the
transportation decision-making process; and
3. To prevent the denial of, reduction in, or significant delay in the receipt of benefits by
minority and low-income populations.
GBT will follow federal guidance provided in FTA Circular 4703.1 (August 2012).

PROGRAM SPECIFIC
REQUIREMENTS
Title VI Monitoring (from 2010 Title VI Plan)
The results of the ongoing monitoring of service standards as defined in the GBT’s 2009 program
can be obtained by contacting GBT.

Subrecipient Compliance
During this report period, GBT did not engage with any subrecipients.

Equity Analysis for Facility
During the past three years, GBT has not constructed a vehicle storage, operations center or
maintenance facility.

Demographic Service Profile
Because GBT operates fewer than 50 buses in peak service, a demographic service profile was not
prepared for this plan update.

Title VI Program | Effective February 10, 2016

GRANTS, REVIEWS
and CERTIFICATIONS
Pending Applications for Financial Assistance
GBT has no pending applications for financial assistance from any federal agency other than the
FTA.

Pending FTA Grants
GBT has no pending grants

Open FTA Grants
CT-04-0015-00 Bus Maintenance Facility Rehabilitation
CT-04-0026-00 Bus Maintenance Facility Roof Replacement (State of Good Repair)
CT-39-0003-00 Bridgeport T.O.D. - Alternative Modes Analysis Task
CT-90-X455-00 Facilities, Shelters, Vehicles, Farebox Replacement
CT-90-X512-00 Transit Amenity Improvement Projects
CT-90-X526-00 2015 – Multiple Capital Projects
CT-90-X900-00 Multiple Project Capital Improvements
CT-95-X013-00 Regional T.O.D. Pilot Program
CT-95-X018-00 Purchase of Replacement Hybrid Buses

Civil Rights Compliance Reviews in the Past 3 Years
GBT has not been the subject of any such reviews since its 2013 submission.

Recent Annual Certifications and Assurances
GBT executed its most recent Certifications and Assurances to the FTA in January 2015 and is in the
process of executing 2016 Certifications and Assurances.

Previous Triennial Review Findings
GBT’s 2013 Triennial Review resulted in no findings with respect to its Title VI Plan/activities.

Effective February 10, 2016 | Title VI Program

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CONTACT
For addition information on the Greater Bridgeport Transit Authority’s Title VI Plan, or its efforts to
comply with the Civil Rights Act of 1964 or Executive Order 13166 Improving Access to Services for
Persons with Limited English Proficiency, please contact:

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Douglas C. Holcomb, General Manager/Chief Executive Officer
Greater Bridgeport Transit Authority
One Cross Street
Bridgeport, Connecticut 06610
Tel: (203) 366-7070 Extension 124
E-Mail: [email protected]

Title VI Program | Effective February 10, 2016

BOARD ADOPTION of POLICY
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Effective February 10, 2016 | Title VI Program