RTD's Title VI Policy Statement
The Regional Transportation District (RTD) operates its programs and services without regard to race, color, national origin or any other characteristic protected by law including Title VI of the Civil Rights Act of 1964.
Every department, division, and employee of RTD is responsible for carrying out RTD’s commitment to non-discrimination, including the requirements of Title VI. This includes:
- Ensuring the level and quality of transportation services are provided to all;
- Identifying and addressing, as appropriate the human health, social, economic, and environmental effects of RTD’s programs and activities on all populations;
- Promoting full and fair participation in transportation decision making;
- Providing meaningful access to RTD’s programs and services by person with limited English proficiency
For additional information on Title VI, please contact RTD's Transit Equity Manager at 303-299-2370.
Title VI Overview
Equity is a core principle of the Regional Transportation District’s (RTD) mission to provide mass transit service in the Denver Metro Area. An equitable mass transit system fairly distributes the benefits and adverse effects of transit service without regard for race, color, national origin, or low-income status. This principle is detailed and reinforced by Title VI of the Civil Rights Act of 1964 and Executive Order 12898 (Environmental Justice).
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs receiving federal financial assistance. Specifically, Title VI states, “No person in the United States shall, on the ground 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 financial assistance.”
In 1994, President Clinton issued Executive Order 12898, which states that each federal agency “shall make achieving environmental justice part of its mission by identifying and addressing disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations.”
The Federal Transit Administration’s (FTA) Circular 4702.1B provides its recipients of FTA financial assistance with instructions for achieving compliance with Title VI and Environmental Justice. In this circular, the FTA requires that RTD document measures are taken to comply with DOT’s Title VI regulations by submitting a Title VI Program to their FTA regional civil rights officer once every three years or as otherwise directed by FTA.
RTD serves the 2,340 square mile Denver Metro area, inhabited by more than 3 million people, with areas of high concentrations of minorities (above 35% representation in a Census block group) and low-income populations (above 19% representation in a Census block group).
RTD’s Title VI policy monitors compliance of four specific areas including public participation and language assistance, service standards and transit monitoring, fare change and equity analysis, and sub-recipient monitoring. These areas are explained in more detail below.
RTD’s Public Participation Plan and Language Assistance Plan detail how RTD engages minority populations, low-income populations, and populations that are Limited English Proficient (LEP). The Public Participation Plan also describes RTD’s approach to achieving diversity on its non-elected advisory committee(s).
FTA Circular 4702.1b Chapter VI requires fixed-route service providers of Urbanized Areas with a population of 200,000 or more to establish service standards and monitor their service to ensure service is provided accordingly. Service standards guide fixed-route service providers toward objective decision- making in the provision of service. The FTA further expects transit agencies to monitor their services to ensure service is provided in a non-discriminatory manner. Service is monitored by comparing a sampling of non-minority routes and minority routes, defined as 1/3 of revenue mileage borders census blocks with a minority population greater than the service area average.
The FTA requires RTD to establish policies to determine whether major service changes will have a disproportionately negative impact on minority or low-income populations. Accordingly, RTD established equity analysis policies and a service evaluation process to meet this requirement. These policies include a Major Service Change Policy, a Disparate Impact Policy, and a Disproportionate Burden Policy. Collectively, these policies provide foundational requirements for evaluating service change proposals for equity.
In the development of the equity policies, RTD sought public feedback on the disparity and disproportionate burden thresholds through a series of public meetings. These policies and their applicable thresholds are listed below:
- Major Service Change Policy: A major service change is defined as a 25 percent addition or reduction in the service hours of any route that would remain in effect for twelve (12) or more months. All major service changes will be subject to an equity analysis that includes an analysis of adverse effects. Adverse Effect is defined as a geographical or temporal reduction in service that includes, but is not limited to: eliminating a route, shortening a route by eliminating segments, rerouting an existing route, and increasing headways. RTD shall consider the degree of adverse effects and analyze those effects when planning major service changes.
- Service Disparate Impact Policy: A major service change should not adversely affect a minority population 10 percent more than non-minority populations; this level of impact is considered a disparate impact.
- Service Disproportionate Burden Policy: A major service change should not adversely affect a low-income population 10 percent more than non-low-income populations; this level of impact is considered a disproportionate burden. A low-income population is a group of households who are at or below 150 percent of the Department of Health and Human Services Poverty Guidelines.
- Fare Disparate Impact and Disproportionate Burden Policy: Per the policy, the difference in the adverse effects absorbed by minority and low-income persons as a result of any fare price change or the average of multiple fare changes shall not be greater than or less than 5% of impacts absorbed by the overall ridership.
RTD’s sub-recipients of federal financial assistance must also comply with Title VI of the Civil Rights Act of 1964. Sub-recipients typically include local jurisdictions or other qualified recipients of federal grants. To meet its enforcement responsibilities under Title VI, RTD has implemented a sub- recipient monitoring process.
The RTD Title VI Manager ensures the following actions are taken affirming that RTD and its sub- recipients comply with Title VI of the Civil Rights Act of 1964 and FTA Circular 4702.1B:
- Each year sub-recipients must provide RTD with an FTA Civil Rights Assurance/Signed Assurance that all records and other information required under FTA Circular 4702.1B have been or will be compiled, as appropriate, and maintained;
- Each sub-recipient must implement a Title VI complaint process and provide RTD with a list of active lawsuits and Civil Rights Complaint summary alleging discrimination on the basis of race, color or national origin;
- Each sub-recipient must post its Title VI Policy Statement in prominent, conspicuous and accessible locations throughout its facilities;
- Sub-recipients must take responsible steps to ensure meaningful access to the benefits, services, information, and other important portions of their programs and activities for individuals who are Limited English Proficient (LEP).
In general, sub-recipients should have a public participation process that offers early and continuous opportunities for the public to be involved in the identification of social, economic, and environmental impacts of proposed transportation decisions. Efforts to involve minority and low-income people in public involvement activities can include both comprehensive measures, such as placing public notices at all stations and in all vehicles, and measures targeted to overcome linguistic, institutional, cultural, economic, historical, or other barriers that may prevent minority and low-income populations from effectively participating in a recipient’s decision-making. Sub-recipients must file with RTD documentation of its public participation plan.
Each sub-recipient further agrees to comply with, and assure compliance by its third party subcontractors at any tier under the Project, with all requirements of the FTA Title VI Program pursuant to FTA Circular 4702.1B and 49 CFR 21.5(b)(2) and 49 CFR 21 .5(b)(7), Appendix C to 49 CFR Part 21.
Title VI Complaint Procedure
Any person who believes he or she has been excluded from participation in or denied the benefits of RTD’s programs, activities, or services due to discrimination on the basis of race, color or national origin may file a complaint with RTD. The written complaint must be filed within 180 days from the date of the alleged discrimination.
To file a complaint:
- Fill out a Title VI complaint form (PDF)
- By mail addressed to: Title VI Complaints, 1660 Blake St - BLK-31, Denver, CO 80202
- By fax addressed to: Transit Equity Manager at 303.299.2061
- By email sent to [email protected]
- Should a complainant choose to not use the complaint form, the written statement should minimally include the following:
- Complainant name, address, telephone number and any other contact information (email, fax, etc.)
- The basis of the complaint (race, color, national origin)
- Date(s) on which the alleged discriminatory event(s) occurred
- Details of the incident(s)
- Names and contact information of witnesses
- Other agencies where a complaint was filed regarding the same incident(s)
Call 303-299-6000 to request additional information about RTD’s Title VI Policy.
Once a complaint is filed, RTD will review the complaint and determine if we have jurisdiction. The complainant will receive a letter acknowledging receipt of the complaint and steps toward resolution.
RTD permits the use of a representative to file a complaint on behalf of the complainant. All communication following the complaint will be directed to the complainant’s representative primarily and the complainant secondarily.
The investigator may interview any individuals named as witnesses and any other individuals who may have information. The investigator may review relevant documentation. Failure of the complainant to respond to requests for information from the investigator may result in an administrative closure of the complaint.
Although RTD strives to promptly resolve complaints, this process will differ depending on the complexity of the complaint, the individuals involved, and other factors. Once the investigation has concluded, the complainant will receive a final written response to the complaint.
Title VI Complaint to the U.S. Department of Transportation
Individuals or organizations who believe they have been denied the benefits of, excluded from participation in, or subject to discrimination on the grounds of race, color or national origin may submit a complaint to the U.S. Department of Transportation:
Federal Transit Administration’s Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor - TCR1200
New Jersey Ave., SE Washington, DC 20590
Further information, including the complaint form, is available at fta.dot.gov.