Boston Region MPO 2014 Title VI Report

 

 

Project Manager

Alicia Wilson

 

Project Principal

Pam Wolfe

 

GIS

Mary McShane

Paul Reim

 

Graphics

Jane Gillis

 

Cover Design

Jane Gillis

 

 

The preparation of this document was supported

by the Federal Highway Administration through

MassDOT 3CPL contract #78890 and the Federal Transit Administration through MassDOT 5303 contract #78922.

 

Central Transportation Planning Staff

Directed by the Boston Region Metropolitan

Planning Organization. The MPO is composed of

state and regional agencies and authorities, and

local governments.

 

 

June 19, 2014

 

map page

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


 

 

            ABSTRACT

Title VI of the Civil Rights Act of 1964 (42 United States Code (USC) §2000d) provides that “no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subject to discrimination under any program or activity receiving federal financial assistance.” To fulfill this basic civil rights mandate, each federal agency that provides financial assistance for any program is authorized and directed by the United States Department of Justice to apply provisions of Title VI to each program by issuing applicable rules, regulations, or requirements. As federal agencies, the Federal Transit Administration (FTA) and the Federal Highway Administration (FHWA) require that funding recipients have Title VI programs and document their programs and activities.

 

As a subrecipient of funding from both FTA and FHWA, the Boston Region Metropolitan Planning Organization (MPO) has prepared this report that explains its Title VI program. The program, conducted in cooperation with the Massachusetts Department of Transportation (MassDOT), is consistent with the principles of Title VI, federal guidelines, and related requirements and is responsive to the needs of Title VI beneficiaries.

 

 

 

 

 

 


 

 

Table of Contents                                                                                                                Page

ABSTRACT

Chapter 1—Introduction

Background

Chapter 2—General Reporting Requirements

2.1 Annual Title VI Certifications and Assurances

FFY 2014 FTA Certifications and Assurances

FFY 2014 FHWA Certifications and Assurances

2.2 Notice of Nondiscrimination Rights and Protections to Beneficiaries

Federal “Title VI/Nondiscrimination” Protections

State Nondiscrimination Protections

Additional Information

Complaint Filing

Translation

2.3 Boston Region Metropolitan Planning Organization 2014 TITLE VI Program Member Endorsement

2.4 Complaint Procedures

2.5 Title VI Investigations, Complaints and Lawsuits

2.6 Meaningful Access for Persons with Limited English Proficiency (LEP)

Chapter 3—General Reporting Requirements

3.1 INTRODUCTION

3.2 BOSTON REGION MPO PUBLIC PARTICIPATION PLAN

3.3 Activities

3.4 Outreach Methods

3.5 MPO TRANSPORTATION EQUITY PROGRAM

3.5.1 Outreach Methods

Summary of Concerns and Issues

Feedback to Community Partners

Public Forums

3.5.2 MPO Coordinated Public Transit Human-Services Transportation Plan

3.6 Access Advisory Committee to the MBTA (AACT)

3.7 Regional Transportation Advisory Council

Chapter 4—Assessment of the Metropolitan Planning Process

4.1 INTRODUCTION

4.2 MPO POLICY AND PLANS

4.2.1 Transportation Equity

Vision

Policies

4.2.2 Mobility.

Vision

Policies

4.3 THE TRANSPORTATION PLANNING PROCESS

4.4 DEMOGRAPHIC PROFILE

4.4.1 Definitions

4.4.2 Data Used for Title VI Purposes

Race and Income

Language

Age

4.4.3 Transportation Equity (Environmental Justice) Outreach to Underserved Populations

Identification of Needs of Low-Income and Minority Populations

Identification of Benefits and Burdens

4.5 TIP Projects In or Near Environmental Justice (EJ) Zones

Appendix A—Complaint Procedures

Appendix B—Boston Region MPO Language-Assistance Plan (February 2014)

B.1 INTRODUCTION

B.1.1 Boston Region MPO Policy

B.2 DETERMINATION OF NEED

Factor 1: Number and Proportion of LEP People in the Boston Region MPO Area

Factor 2: Frequency of Contact

Factor 3: The Importance of the Service Provided by the Program

Factor 4: Resources Available to the Recipient

B.3 PLAN IMPLEMENTATION

B.3.1 Oral Language Assistance

B.3.2 Written Language Assistance

B.3.3 MPO Website

B.4 MONITORING AND UPDATING THE PLAN

B.5 Training staff

Appendix C—Boston Region MPO Draft Public Participation Plan

Appendix D—Boston Region MPO Memorandum of Understanding and Advisory Council Bylaws

Appendix E—Boston Region MPO Notice Samples

Appendix F—Boston Region MPO Public Meeting Summary

Appendix G—Environmental Justice Invitation to Participate

Appendix H—Human Services and Equity in Transportation Forum Prospectus and Invitation

Appendix I—Unified Planning Work Program Studies Sensitive to Title VI, Environmental JUSTICE, and/or ADA Adherence

I.1 Transportation Equity/Environmental Justice Support (funded on an ongoing basis)

I.2 Analysis of JARC and New Freedom Projects (funded in FFY 2012)

I.3 MetroWest RTA Transit Planning Assistance (funded in FFY 2013)

I.4 Disability Access Support (funded on an ongoing basis)

I.5 Priority Corridors for LRTP Needs Assessment (funded in FFY 2012)

I.6 Methodology for Evaluating the Potential for Limited-Stop Service on Transit Routes (funded in FFY 2013)

I.7 Environmental Justice and Title VI Analysis Methodology  Review
(Funded in FFY 2014)

I.8 Impacts of Walking Radius/Transit Frequency and Reliability
(funded in FFY 2012)

I.9 MBTA Bus Route 1 Transit Signal Priority (funded in FFY 2011)

I.10 Sullivan Square/Rutherford Avenue Land Use Visioning
(Funded in FFY 2013)

Appendix J—Long-Range Transportation Plan Development

Appendix K—Transportation Improvement Program Process

K.1 Transportation Improvement Program—Development

K.2 Outreach and Data Collection (December–February)

K.3 Evaluation of Projects (February–March)

K.4 Staff Recommendation and Draft TIP (March–April)

K.5 Public Review and Endorsement (April–June)

Appendix L—Long-Range Transportation Plan Benefits and Burdens Analysis

 

Table of Tables and Figures                                                                                              Page

TABLE 1 Boston Region MPO FHWA Title VI Complaints.......................................................

Table 2 RACIAL CHARACTERISTICS* OF THE BOSTON REGION MPO AREA

Figure 1 Low-income and Minority Populations

Table 3 NON-ENGLISH SAFE HARBOR LANGUAGES IN THE BOSTON REGION MPO

Table 4 NON-ENGLISH SAFE HARBOR LANGUAGES IN THE BOSTON REGION MPO*

Figure 2 Environmental Justice Areas of Concern

Table 5 Federal Fiscal Years 2012-2017 TIP Project Information

Figure 3 FEDERAL FISCAL YEARS 2012-2017 TIP PROJECT INFORMATION

Figure 4 FEDERAL FISCAL YEARS 2012-2017 TIP PROJECT COSTS

TABLE B.1 NON-ENGLISH SAFE HARBOR LANGUAGES IN THE BOSTON REGION MPO.

Figure B-1 Populations with Limited-English Proficiency

Figure B-2 Limited-English Proficiency: Spanish Speakers

Figure B-3 Limited-English Proficiency: Chinese Speakers

Figure B-4 Limited-English Proficiency: Portuguese Speakers

Figure B-5 Limited-English Proficiency: French Creole Speakers

Figure B-6 Limited-English Proficiency: Vietnamese Speakers

Figure B-7 Limited-English Proficiency: Russian Speakers

 

 


 

 

Chapter 1—Introduction

 

            Background

Title VI of the Civil Rights Act of 1964 (42 United States Code (USC) §2000d) provides that “no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subject to discrimination under any program or activity receiving federal financial assistance.” To fulfill this basic civil rights mandate, each federal agency that provides financial assistance for any program is authorized and directed by the United States Department of Justice to apply provisions of Title VI to each program by issuing applicable rules, regulations, or requirements. The Federal Transit Administration (FTA) of the United States Department of Transportation issued guidelines on May 26, 1988, FTA C 4702.1, describing the contents of Title VI compliance programs to be adopted and maintained by recipients of FTA-administered funds for transit programs. The latest FTA guidance, FTA C 4702.1B, was issued on October 1, 2012.

 

The Federal Highway Administration (FHWA) issued guidance in U S Code Title 23, Section 200 on April 1, 2011 and updated it on April 1, 2013.

 

Although Title VI is the focal point of nondiscrimination law in this country, FHWA incorporates a broader application of nondiscrimination statutes, regulations, and Executive Orders into its Title VI program requirements for states and their subrecipients. For example, Section 324 of the Federal-Aid Highway Act of 1973 prohibits discrimination based on sex; Section 504 of the Rehabilitation Act of 1973 prohibits discrimination on the basis of disability status, as does the Americans with Disabilities Act of 1990; and the Age Discrimination Act of 1975 prohibits age discrimination. In addition, the Civil Rights Restoration Act of 1987 (FHWA Notice 4720.6) clarified the original intent of Congress with respect to Title VI by restoring the broad, institution-wide scope and coverage of the nondiscrimination statutes to include all programs and activities of federal-aid recipients, whether or not such programs and activities are federally assisted; and it enforced application of the laws that include nondiscrimination on the basis of race, color, national origin, age, gender, or disability.

 

In addition, the principles of Executive Order 13166 on limited English proficiency (LEP) are incorporated to ensure that meaningful access is provided to persons who are not proficient in the English language. This guidance is based on the prohibition against national origin discrimination in Title VI of the Civil Rights Act of 1964, as it affects the LEP population.

 

This document explains the Boston Region MPO’s Title VI program, which—conducted in cooperation with the Massachusetts Department of Transportation (MassDOT)—is consistent with the principles of Title VI, federal guidelines, and related requirements, and is responsive to the needs of Title VI beneficiaries.

 

Chapter 2 of this report addresses the MPO’s general reporting requirements under the circular including FTA and FHWA certifications and assurances; certification that the MPO as a body has approved this document; the MPO’s notice to the public regarding Title VI protections; a description of the procedures for filing civil rights complaints; a list of Title VI discrimination complaints, investigations and lawsuits; and the MPO’s plan to provide meaningful access to persons with limited English proficiency. Chapter 3 describes the MPO’s public outreach and public participation activities and highlights how the MPO reaches out to minority, LEP, and low-income populations. Chapter 4 provides an assessment of the MPO’s planning process, a demographic profile of the MPO region, and a description of the strategies used to identify the needs of minority and low-income residents.

 

Chapter 2—General Reporting Requirements

 

2.1      Annual Title VI Certifications and Assurances

The MPO’s Title VI assurances for federal fiscal year 2014 are cited beginning on page 9 of this report. Please note that the text of these assurances is not accessible to individuals with low or no vision who use a screen reader.

This page and the following page contain materials taken directly from the Federal Transit Administration (FTA), called “Federal Fiscal Year 2014 Certifications and Assurance for Federal Transit Administration Programs.” The first page is a form sent to the applicant that checks of which provisions the applicant needs to comply with. On this form, the first two provisions (of the 24 listed) are checked: “Required Certifications and Assurances for Each Applicant” and “Lobbying.” The second page has places for the applicant’s representative and its attorney to sign, indicating that they agree to comply with those provisions.

These 12 pages contain a document from the Federal Highway Administration (FHWA) titled “Title VI/Nondiscrimination Agreement and Sub-Recipient Assurances.” The first four pages list the regulations with which the Boston Region MPO, as the recipient of federal financial assistance from the US Department of Transportation and the FHWA, needs to comply in order to receive federal financial assistance from USDOT and the FHWA. The next page is a signature page that the secretary of the Massachusetts Department of Transportation needs to sign, and the following page is a signature page for the Boston Region MPO representative. The next two pages are Appendix A of the Assurances document; it lists in detail the provisions with which the grantee (the Boston Region MPO) needs to comply. The following page is Appendix B of the Assurances document, titled “Clauses for Deeds Transferring United States Property,” and the next page is Appendix C, “Clauses for Transfer of Real Property Acquired or Improved under the Federal Highway Programs.” The next two pages are Appendix D, titled “Clauses for Construction/Use/Access to Real Property Acquired under the Federal Highway Program.”

2.2      Notice of Nondiscrimination Rights and Protections to Beneficiaries

Title 49 CFR Section 21.9(d) requires recipients to provide information to the public regarding the recipient’s obligations under the United States Department of Transportation’s (US DOT) Title VI regulations and apprise members of the public of the protections against discrimination afforded to them by Title VI. The MPO notice, adapted from a MassDOT prototype, follows:

 

Federal “Title VI/Nondiscrimination” Protections

The Boston Region Metropolitan Planning Organization (MPO) operates its programs, services, and activities in compliance with federal nondiscrimination laws including Title VI of the Civil Rights Act of 1964 (Title VI), the Civil Rights Restoration Act of 1987, and related statutes and regulations. Title VI prohibits discrimination in federally assisted programs and requires that no person in the United States of America shall, on the grounds of race, color, or national origin (including limited English proficiency), be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity receiving federal assistance. Related federal nondiscrimination laws administrated by the Federal Highway Administration, the Federal Transit Administration, or both prohibit discrimination on the basis of age, sex, and disability. These protected categories are contemplated within the Boston Region MPO’s Title VI Program consistent with federal interpretation and administration. Additionally, the Boston Region MPO provides meaningful access to its programs, services, and activities to individuals with limited English proficiency, in compliance with US Department of Transportation policy and guidance on federal Executive Order 13166.

 

State Nondiscrimination Protections

The Boston Region MPO also complies with the Massachusetts Public Accommodation Law, M.G.L. c 272 §§ 92a, 98, 98a, prohibiting making any distinction, discrimination, or restriction in admission to or treatment in a place of public accommodation based on race, color, religious creed,  national origin, sex, sexual orientation, disability, or ancestry. Likewise, the Boston Region MPO complies with the Governor's Executive Order 526, section 4 requiring all programs, activities, and services provided, performed, licensed, chartered, funded, regulated, or contracted for by the state shall be conducted without unlawful discrimination based on race, color, age, gender, ethnicity, sexual orientation, gender identity or expression, religion, creed, ancestry, national origin, disability, veteran's status (including Vietnam-era veterans), or background.

 

Additional Information

To request additional information regarding Title VI and related federal and state nondiscrimination obligations, please contact:

 

Title VI Specialist -

Boston Region MPO

10 Park Plaza, Suite 2150

Boston, MA 02116

617-973-7100

TTY: 617-973-7089

publicinformation@ctps.org

 

Complaint Filing

To file a complaint alleging a violation of Title VI or related federal nondiscrimination law, contact the Title VI Specialist (above) within 180 days of the alleged discriminatory conduct. To file a complaint alleging a violation of the state's Public Accommodation Law, contact the Massachusetts Commission Against Discrimination within 300 days of the alleged discriminatory conduct at:

 

Massachusetts Commission Against Discrimination (MCAD)

One Ashburton Place, 6th Floor

Boston, MA 02109

617-994-6000

TTY: 617-994-6196

 

Translation

English: If this information is needed in another language, please contact the Boston Region MPO’s Title VI Specialist at 617-973-7100.

 

(The above phrase will be repeated in four additional languages.)

 

Once MassDOT completes the translations, this statement will be posted on the MPO’s website along with the procedures for filing a complaint described in Appendix A of this report. This notice also will be posted at the entrance to the MPO office and a shorter version will be included in all public-outreach materials and on MPO meeting agendas. (A different version of this notice is currently posted on the MPO website, on outreach materials and MPO meeting agendas.)

 


 

 

2.3      Boston Region Metropolitan Planning Organization 2014 TITLE VI Program Member Endorsement

 

 

1)

2)

3)

Massachusetts Department of Transportation


Massachusetts Bay Transportation Authority


MBTA Advisory Board


Massachusetts Port Authority


Metropolitan Area Planning Council


Regional Transportation Advisory Council


City of Beverly

1)

2)

City of Boston


City of Everett


City of Newton

 

(Continued)

 


 

 

Program Member Endorsement (Cont’d.)

 

 


City of Somerville


City of Woburn


Town of Arlington


Town of Bedford


Town of Braintree


Town of Framingham


Town of Lexington


Town of Medway


Town of Norwood

 

 

 

 

 

 

 


 

 

2.4      Complaint Procedures

In order to comply with both FTA and FHWA requirements, the MPO has developed procedures for receiving, investigating, addressing, and tracking Title VI complaints, which are included in Appendix A. MassDOT is in the process of revising its complaint procedures. The MPO will adopt these procedures when they are finalized.

 

2.5      Title VI Investigations, Complaints and Lawsuits

The MPO has not been the recipient of any Title VI complaints or lawsuits as defined by the Department of Justice and FTA, and no investigations have been initiated. However, FHWA includes those with disabilities as a protected class in its Title VI nondiscrimination definition. The following is pertinent information concerning an ADA complaint.

 

TABLE 1

Boston Region MPO FHWA Title VI Complaints

 

Date Filed with FHWA

Summary of Allegations

Status

Findings

March 28, 2012

MPO did not provide an auxiliary hearing aid; failed to address attitudinal issues regarding people with disabilities; failed to train staff; failed to provide an effective alternative accommodation; retaliated against complainants.

Closed

The Boston MPO did not violate the ADA and Section 504 by failing to provide reasonable accommodations for persons with disabilities.

 

2.6      Meaningful Access for Persons with Limited English Proficiency (LEP)

It is the policy of the MPO that people with limited English proficiency be neither discriminated against nor denied meaningful access to and participation in the programs and services provided by the MPO. The MPO has developed a Language Assistance Plan (LAP) to be sure that it employs appropriate strategies in assessing needs for language services and in implementing language services that provide meaningful access to the planning process and to published information without placing undue burdens on the MPO’s resources. The LAP, included in Appendix B, will be reviewed and revised periodically based on demographic changes, changes in the frequency of encounters with LEP persons, feedback from LEP groups, and changes in technology.

 


 

 

Chapter 3—General Reporting Requirements

 

3.1      INTRODUCTION

The MPO facilitates and encourages the involvement of minority, low-income, elderly, persons with disabilities, and LEP persons in its activities. As described in this chapter, it reaches out to these populations through its Public Participation Program (including its process for developing the metropolitan transportation certification documents), its Transportation Equity Program, its Coordinated Public Transit-Human Services Transportation planning, and the Access Advisory Committee to the MBTA.

 

3.2      BOSTON REGION MPO PUBLIC PARTICIPATION PLAN

The MPO utilizes a variety of approaches to providing for communication and consultation with interested parties and members of the public and is continually working to improve its outreach. This section will summarize the activities conducted and the outreach methods used by the MPO in implementing its public participation program. The MPO has recently updated its public participation plan (the Plan)—which describes all of the activities in its public participation program (the Program)—to be consistent with MassDOT’s plan, particularly regarding Title VI requirements. The Plan was revised following public outreach and research on MPO public participation needs and desires. The plan will be adopted in the fall, subsequent to a public-comment period on the draft and any changes that may need to be made as a result. The Draft Public Participation Plan is included in Appendix C.

 

3.3      Activities

The MPO conducts a varied and ongoing program for gathering information and views from all sectors of the public for its transportation planning and programming work. Some activities are focused specifically on the development of the certification documents. Others are ongoing and provide input year-round. All activities are open to the public and all MPO-sponsored activities are held at locations accessible for people with disabilities. The locations are well dispersed through the region, include environmental justice communities, and are almost always served by public transportation. In conducting its activities, the MPO strives to meet the needs of people requiring special services such as translation for LEP populations, American Sign Language interpreters, large-format printed materials, audiotapes, Braille materials, and escorts. Meeting materials are available in accessible formats and in other languages, upon request. Assistive-listening devices and microphones are provided at all public meetings.

 

Listed below are MPO activities that provide opportunities for the public to learn about metropolitan transportation planning and programming processes and provide input to decision making.

 

 

4.2.2   Mobility

Vision

 

Policies

 

These policies were applied in assessing projects for inclusion in the LRTP, in developing MPO criteria for evaluation and selection of projects for the TIP; in selecting and defining studies for the UPWP, which includes MPO staff support for the MBTA’s Title VI reporting work; and in supporting the MPO’s ongoing transportation equity/environmental justice program.

 

The MPO is currently updating and recasting its visions and policies as goals and objectives with quantifiable targets to reflect national goals for performance-based decision making under MAP-21.

 

4.3      THE TRANSPORTATION PLANNING PROCESS

The 3C process in the Boston region is the responsibility of the MPO, which has established the following objectives for the process:

 

 

The MPO is responsible for carrying out and completing all transportation plans, programs, and conformity determinations required by federal and state laws and regulations through the 3C process. This includes preparation of the major certification documents: the LRTP, the UPWP, the TIP, and all required air quality analysis. The MPO also initiates studies to identify transportation needs and solutions, and programs financial resources for the region’s multimodal transportation system. The following is a brief description of each of the certification documents:

 

 

4.4.     DEMOGRAPHIC PROFILE

For planning purposes, it is essential to understand who lives in the MPO region. Entities that receive federal funds are required to develop and use demographic profiles to ensure that the rights of people protected under various civil rights laws and presidential executive orders are not ignored during planning, selection, and implementation of various projects and services.

 

The FTA’s Title VI and environmental-justice circulars (FTA C4702.1B and FTA C 4703.1, respectively) require demographic profiles of the area encompassed by the MPO. The MPO uses these demographic data for several purposes: to identify geographic areas where minority populations exceed the MPO average; identify LEP populations, for the purpose of ascertaining potential transportation project benefits and burdens on low-income and minority populations, help evaluate TIP projects, and conduct outreach to engage low-income, minority, and LEP populations in the MPO planning process.

 

Except where otherwise noted, the following demographic profile was developed in 2012, based on the 2010 Census and the 2006-2010 American Community Survey (ACS).

 

4.4.1   Definitions

The Boston Region MPO has defined and continues to define a low-income threshold for an individual as a person living in a household whose median income is 60% or less than the median household income in the MPO area. Research indicates that this is in line with thresholds used by comparable MPOs. According to the 2010 ACS Summary File, the median MPO household income is $70,829, and the MPO’s low-income threshold is $42,497. This income threshold is used for all of the MPO’s Title VI reporting and for all of the environmental-justice analyses conducted for the LRTP and the TIP.

 

The Title VI circular defines a predominantly minority area as a geographic area, such as a neighborhood, census tract, or transportation analysis zone (TAZ ), where the proportion of minority persons residing in that area exceeds the average proportion of minority persons in the recipient’s service area.  

 

For Title VI purposes, when identifying benefits and burdens of proposed transportation projects included in its LRTP and when evaluating TIP projects, the MPO has defined a minority TAZ as one whose minority population is greater than the overall MPO region’s average of 27.8%. For transportation equity (environmental justice) outreach purposes, the MPO continues to use the minority threshold of 50% or greater as it focuses on the areas of the MPO region that are most heavily defined as “minority.”

 

Federal regulations define LEP persons as those for whom English is not the primary language and who have a limited ability to read, write, speak, or understand English. It includes people who reported in the US census that they speak English ‘not well’ or ‘not at all.’ FTA, in its latest Title VI circular, includes those who speak English ‘less than well’ in its LEP definition. As such, FTA’s new definition doubles the number of people who are considered to be LEP.

 

4.4.2   Data Used for Title VI Purposes

Race and Income

Analysis reveals that the Boston Region MPO is home to approximately 3.2 million residents, 27.8% of whom are minorities. Table 2 shows the distribution of the population by race and the changes between 2000 and 2010. The total population increased by 3%. This growth is primarily a result of an approximately 34% increase in the minority population. The Asian population, which is the fastest-growing minority population, increased by 46%. The Hispanic population, which can include people in all racial groups, increased by 48%. Figure 1 shows the location of low-income and minority TAZs within the MPO.

Table 2

Racial Characteristics* of the Boston Region MPO Area

 

Appendix A

Appendix A is titled “Complaint Procedures.” This appendix includes a description of the Boston Region MPO’s Title VI and Civil Rights Nondiscrimination Complaint Procedure, and complaint forms.

 

Appendix B—Boston Region MPO Language-Assistance Plan (February 2014)

 

B.1      INTRODUCTION

On August 11, 2000, President Clinton signed Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency.” This Executive Order requires federal agencies to examine the services they provide, identify those whose potential users could include persons with limited English proficiency, and develop and implement a system to provide those services in such a way that LEP persons have meaningful access to them.

 

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of national origin and, in consideration of Executive Order 13166, requires that recipients of federal funds assess and address the needs of LEP individuals seeking assistance. The US Department of Transportation (USDOT) developed guidance titled Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient Persons to ensure that people in the United States are not excluded from participation in DOT-assisted programs and activities because they face challenges communicating in English. This guidance clarifies funding recipients’ responsibilities to provide meaningful access for LEP people under existing law by describing the factors recipients should consider in fulfilling their responsibilities to LEP persons.

 

The Boston Region Metropolitan Planning Organization’s Language-Assistance Plan has been developed based on DOT guidance, which identifies the following four factors to consider when determining reasonable steps for ensuring that LEP people have meaningful access3 :

 

 

B.1.1 Boston Region MPO Policy

It is the policy of the Boston Region MPO that people with limited English proficiency be neither discriminated against nor denied meaningful access to and participation in the programs and services provided by the MPO. The MPO has developed this plan ensure that it employs appropriate strategies to assess needs for language services; and to implement language services that provide meaningful access to the planning process and to published information without placing undue burdens on the MPO’s resources.

 

B.2      DETERMINATION OF NEED

The MPO used the aforementioned four factors identified by USDOT to determine reasonable steps for providing meaningful access to the MPO’s activities for people LEP. These factors are described below.

 

Factor 1: Number and Proportion of LEP People in the Boston Region MPO Area

According to the USDOT’s definition, people are considered to have LEP if they speak English “not well” or “not at all.” However, FTA’s definition includes those who speak English “less than very well”. FTA’s definition is used in this analysis as it sets the upper bounds on the LEP population.

 

Data from the 2008-2012 five-year ACS public-use micro data sample (PUMS)4 were used to analyze the number of LEP persons five years of age and older in the Boston Region MPO. According to the ACS Summary file, 10.5% of this population (301,878 of the MPO area population of 2,865,258 who are five years of age and older) in the MPO region are considered to have limited English proficiency as they speak English “less than very well.” The largest proportion of LEP persons speak Spanish (34.2%), followed by Chinese (14.4%), and Portuguese (12.4%). Altogether, LEP speakers of these three languages represent almost two-thirds (61%) of the MPO’s LEP population five years old and older. LEP populations meeting the US Department of Transportation’s definition of LEP “safe harbor” thresholds (5% of the population or 1,000 individuals, whichever is less) include speakers of the languages in the following table. Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English may be entitled to language assistance under Title VI of the Civil Rights Act of 1964. Figures B1-B-7 (at the end of the appendix) show the distribution of those with limited-English proficiency and the distribution of speakers of the top six languages.

 

TABLE B.1

Non-English Safe Harbor Languages in the Boston Region MPOa

 




Languages Spoken




Total LEP



Pct. LEP Population



Pct. MPO Population

Spanish

103,147

34.2%

3.6%

Chinese

43,614

14.4

1.5

Portuguese

37,400

12.4

1.3

French Creole

19,061

6.3

0.7

Vietnamese

16,186

5.4

0.6

Russian

12,281

4.1

0.4

Italian

7,956

2.6

0.3

Arabic

7,534

2.5

0.3

French

6,302

2.1

0.2

Korean

5,296

1.8

0.2

Greek

4,315

1.4

0.2

Mon-Khmer, Cambodian

2,915

1.0

0.1

Albanian

2,888

1.0

0.1

Japanese

2,416

0.8

0.1

Armenian

1,856

0.6

0.1

Polish

1,821

0.6

0.1

Hindi

1,768

0.6

0.1

Gujarati

1,607

0.5

0.1

Amharic

1,402

0.5

0.0

Punjabi

1,398

0.5

0.0

Persian

1,247

0.4

0.0

Tamil

1,140

0.4

0.0

Bengali

1,076

0.4

0.0

Tagalog

1,057

0.4

0.0

Other Languages

16,195

5.4

0.6

Total

301,878

100.0%

10.5%

a Population that is five years of age and older.

b Includes those who self-identify as speaking English “less than very well,” “not well,” and “not at all.”

 

Factor 2: Frequency of Contact

The MPO has infrequent and unpredictable contact with LEP individuals, partly because of the nature of MPO programs and activities. The most frequent avenues for contact are the MPO website, flyers, and other announcements that are emailed to individuals and organizations, identified through the MPO’s transportation equity program.

 

Other likely occasions for contact with non-English-speaking people are events like the MPO’s public workshops, open houses, and transportation equity forums. The MPO has been making a concerted effort to identify and reach out to minority and LEP populations. Demographic maps are used to identify areas in which public outreach meetings may be needed to include LEP populations and determine the languages into which outreach materials might be translated.

 

To date, language interpreters have not been requested for any MPO meetings or events. The MPO will continue to monitor such requests to help inform future needs.

 

Factor 3: The Importance of the Service Provided by the Program

The MPO plans, and programs capital transportation funds for future transportation projects in the region. While the MPO is not a direct transportation-service provider, and denial or delay of access to the MPO’s programs and activities would not have immediate or life-threatening implications for a person with LEP, transportation improvements resulting from the MPO’s activities have an impact on the mobility and quality of life for all residents.

 

Input from all stakeholders is critical to the MPO’s process, so it invests considerable effort in inclusive public outreach. The MPO encourages and helps the public to understand the transportation planning process and provides many opportunities for the public to participate and comment through a variety of activities, which are described fully in the MPO's Public Participation Plan.

 

Three major documents and their related planning initiatives—an annual Unified Planning Work Program, a four-year Transportation Improvement Program, and a 20-plus-year Long-Range Transportation Plan—also are important to the planning process, and offer opportunities for the public to comment on the use of federal funds that are programmed

 

As a result of the regional transportation planning process, selected projects receive approval for federal funding and progress through project planning, design, and construction under the responsibility of local jurisdictions or state transportation agencies. These state and local organizations have their own policies in place to ensure opportunities for people with LEP to participate in the process that shapes where, how, and when a specific project is implemented.

 

Some MPO documents and outreach materials are of vital importance to the public for understanding and participating in the transportation planning process. To accommodate LEP individuals, the MPO routinely translates these into the three languages most widely spoken by LEP individuals: Spanish, Chinese, and Portuguese. Documents currently identified as vital are:

 

Factor 4: Resources Available to the Recipient

The cost of providing interpreters at meetings is high; however, although the MPO has advertised the availability of interpreters, none have been requested to date. The MPO’s current policy is to provide these services whenever they are requested.

 

Based on the number and type of meetings for which written materials need to be translated, the MPO has budgeted sufficient funds to translate vital documents into the three languages most widely spoken by LEP individuals (see section B.3.2 below). The budget also includes sufficient funds to translate documents into other languages, as needed, for public outreach or to accommodate requests. To date, only a few individuals have made such requests.

 

Although the MPO has been able to provide services with existing resources thus far, the region is dynamic and continues to attract diverse ethnic and cultural populations. Therefore, the MPO will continue to monitor the need for translating publications and documents and for interpretation at meetings/events, based on factors one through three of the four-factor analysis and the number of requests received, and will determine whether the current policy needs to be adjusted because of resource constraints.

 

B.3      PLAN IMPLEMENTATION

B.3.1   Oral Language Assistance

Notices for all MPO meetings state that translation services (including American Sign Language) are available at public meetings upon request. The current number of residents with limited English proficiency in the Boston region, and their infrequent interaction with the MPO, have resulted in the MPO’s rarely needing to provide language services. However, engaging the diverse population within the region is important, and the MPO takes the following measures to ensure meaningful access for the LEP population in the Boston region.

 

Key staff at the MPO office will utilize language identification “I speak” cards, developed by the US Census Bureau, when first encountering an LEP individual. On these cards appears the phrase “Mark this box if you read or speak [name of language]” in 38 different languages. Government and non-government agencies use these cards to identify the primary language of LEP individuals when face to face. To assist LEP individuals who might come to the MPO offices, language identification cards are available at the front desk, along with a list of staff members who are able and willing to serve as translators.

 

MPO staff that interact frequently with the public are familiar with the resources necessary to engage translators for meetings and use phone translators for one-on-one communication.

 

B.3.2   Written Language Assistance

The MPO’s public involvement activities seek to promote respect, provide opportunities for meaningful involvement, be responsive to participants, provide a predictable process, open new avenues of communication, and attract new constituencies. The MPO provides press releases for its workshops on the LRTP and TIP. Language interpreters will be provided upon request at public meetings. Press releases announcing public review of the certification documents or their amendments are placed in the El Mundo and La Semana (the region’s two major Spanish-language newspapers).

 

The MPO’s Transportation Equity Program includes outreach to areas with relatively high concentrations of people who may be limited in their ability to speak or understand English. The MPO regularly contacts representatives of community ethnic and cultural organizations as part of the transportation equity outreach process. These individuals have been resources for identifying the needs of LEP populations and informing their communities about MPO programs and activities.

 

As indicated above, the MPO currently translates vital documents into Spanish, Chinese, and Portuguese, the three primary non-English languages in the region. Material is translated into other languages, as needed, when outreach meetings or forums are conducted in areas where MPO demographic maps indicate the presence of LEP populations.

 

MPO staff that interact frequently with the public are familiar with the resources necessary to obtain written translations of materials whenever necessary.

 

B.3.3   MPO Website

Google Translates is available on the MPO website, which contains considerable information on the regional transportation-planning process and the MPO’s programs and activities. Google Translates allows visitors to translate any page of text into the following additional languages: simplified and traditional Chinese, French, Italian, Portuguese, Russian, Spanish, and Vietnamese. To meet accessibility requirements for individuals with low or no vision, MPO documents are posted as PDF files and in HTML, which can be read using Google Translates.

 

Vital documents posted on the website are formally translated into Spanish, Chinese, and Portuguese.

 

B.4      MONITORING AND UPDATING THE PLAN

The MPO will monitor the region’s changing language needs and update language-assistance services when appropriate. The MPO will track the number of requests (by language) for language assistance in its programs and activities and will look for ways to expand participation of LEP people. If the need for language-assistance services warrants, the MPO will revise its language-access plan.

 

B.5      Training staff

The CTPS Nondiscrimination Handbook describes a training program that is being developed to train MPO staff about the treatment and accommodation of those protected under various civil rights laws and regulations, including minority and LEP individuals. This training will be developed and implemented in collaboration with the MassDOT Office of Diversity and Civil Rights, the Massachusetts Office of Diversity, the Massachusetts Commission for the Deaf and Hard of Hearing, and the Massachusetts Commission for the Blind. Although key staff already know how to provide timely and reasonable language assistance to LEP populations, future training for all staff will include this information.

 

For face-to-face interactions with LEP individuals, training will include language identification “I speak” cards, developed by the US Census Bureau. The phrase “Mark this box if you read or speak [name of language]” appears on these cards in 38 different languages. These are kept at the front desk for use by the receptionist or any other staff member who needs to identify the primary language of an LEP individual. Also available is a list of staff members who speak languages other than English and are able and willing to serve as translators. Staff that have most frequent contact with the public through MPO and other public meetings, are taught to use phone translation services, how to engage translators for meetings, and obtain written translations.

 

The CTPS Nondiscrimination Handbook provides MPO staff with information about all types of accommodations and establishes protocols for using them.

Figure B-1 Populations with Limited-English Proficiency

 


 

Figure B-2 Limited-English Proficiency: Spanish Speakers

 


 

Figure B-3 Limited-English Proficiency: Chinese Speakers

 


 

 

Figure B-4 Limited-English Proficiency: Portuguese Speakers

 

 


 

 

Figure B-5 Limited-English Proficiency: French Creole Speakers

 

 

 

Figure B-6 Limited-English Proficiency: Vietnamese Speakers

 


 

Figure B-7 Limited-English Proficiency: Russian Speakers

 

 

 

3 FTA C4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, October 1, 2012, p Chap. III.7.

4 Geographic detail for this dataset is limited to the Public Use Micro data Area (PUMA). Each PUMA, with the exception of those overlaying the City of Boston, is made up of one or more municipalities and has a total population of at least 100,000. Boston is comprised of five PUMAs. The PUMA boundaries do not all nest within the limits of the Boston Region MPO. For those PUMAs that lie only partially within the MPO limits, the statistics were factored down in proportion to the percentage of the PUMA's 2010 five-year-and-older population residing in the MPO portion of the PUMA.

 

Appendix C—Boston Region MPO Draft Public Participation Plan

Appendix C—Boston Region MPO Draft Public Participation Plan. This appendix consists of the draft of the Boston Region MPO’s new Public Participation.

2014Pub_Part_Plan_Report_2

 

 

Appendix D

 

Appendix D is titled “Boston Region MPO Memorandum of Understanding and Advisory Council Bylaws.” It consists of those two documents. It consists of two documents: Memorandum of Understanding Relating to the Comprehensive, Continuing, and Cooperative Transportation Planning Process in The Boston

Metropolitan Area,” which was approved July 7, 2011, and “Bylaws Of The Regional Transportation Advisory Council, Adopted 5/8/2002 and Amended 10/14/2009.”

 

Appendix E

 

Boston Region MPO Notice Samples.” It includes examples of meeting and publications

 

Appendix F—Boston Region MPO Public Meeting Summary

 

Pub_Part_Plan_tables_2.html

 

Appendix G—Environmental Justice Invitation to Participate

This appendix contains various notices and an invitation to participate sent to Environmental Justice Contacts

 

 

Appendix H—Human Services and Equity in Transportation Forum Prospectus and Invitation

 

This appendix contains a forum prospectus and an invitation to attend the forum sent to various groups.

 

Appendix I—Unified Planning Work Program Studies Sensitive to Title VI, Environmental Justice, and/or ADA Adherence

 

The following describes current, upcoming and completed MPO UPWP initiatives for providing data collection and analysis that support MPO coordination of environmental justice issues and that help to address the transportation needs of minority, LEP, and low-income residents.

 

I.1       Transportation Equity/Environmental Justice Support (funded on an ongoing basis)

The primary purpose of this ongoing project is to integrate environmental justice issues and concerns into MPO planning and programming activities and support development of the LRTP, UPWP, TIP, Congestion Management Process (CMP), air quality conformity determinations, and project-specific work products. Another purpose is to foster awareness of the MPO in environmental justice populations and to facilitate their participation in MPO planning and programming. This has been done through continued outreach to minority, LEP, and low-income populations.

 

I.2       Analysis of JARC and New Freedom Projects (funded in FFY 2012)

Many MPO-recommended proposals for the FTA’s Job Access and Reverse Commute (JARC) and New Freedom grant programs were funded under SAFETE-LU, the previous surface transportation act. These proposals include: conducting studies on how to facilitate coordination of existing transportation resources, identifying resource gaps and developing strategies for closing them, enhancing consumers’ abilities to access and use transportation options, and planning for and operating paratransit.

 

The MPO determined which of these projects were effective and used this information to recommend future projects, to encourage the use of best practices, and to update the Coordinated Public-Transit Human Services Transportation Plan.

 

I.3       MetroWest RTA Transit Planning Assistance (funded in FFY 2013)

When the MWRTA was established, CTPS conducted a study that explored potential markets and provided service planning assistance. During its fifth year of service, CTPS evaluated existing transit service, identified potential improvements to routes and schedules, and proposed new services to meet untapped demand and relieve traffic congestion. (The MetroWest RTA is located in a community that has minority and LEP populations.)

 

I.4       Disability Access Support (funded on an ongoing basis)

CTPS supports the MBTA in meeting ADA requirements by providing ongoing support to the Access Advisory Committee to the MBTA (AACT), a user group representing people with disabilities. AACT advises the MBTA on all accessibility matters relating to the use of the MBTA’s systemwide fixed-route services and THE RIDE paratransit service by people with disabilities and ensures that users’ ideas concerning accessible transportation are heard.

 

One requirement of the 1990 Americans with Disabilities Act (ADA) is that government agency material that is distributed to the public be made available in accessible formats, in a timely manner, upon request. CTPS fulfills this requirement. Most materials prepared for the MPO are posted on the MPO website in PDF and HTML formats so that they can be read by contemporary screen reader technology. In addition to providing materials in accessible formats, CTPS has developed accessibility standards and guidelines for the conduct of MPO-sponsored meetings.

 

I.5       Priority Corridors for LRTP Needs Assessment (funded in FFY 2012)

Corridor analysis is a logical way to approach transportation studies in the region. Possible corridors of critical and strategic concern might best be viewed in a programmatic way. An arterial management roadway improvement effort would recommend conceptual improvements for corridors that the Congestion Management Process (CMP) and the Long-Range Transportation Plan (LRTP) identified as part of the needs assessment process. A particular corridor or several sections of multiple corridors could be selected. Candidate locations included:

 

Corridors are listed roughly in priority order according to traffic flow. Seven of the fifteen corridors are either entirely or partially in in communities with environmental justice populations.

 

I.6       Methodology for Evaluating the Potential for Limited-Stop Service on Transit Routes (funded in FFY 2013)

This project evaluates criteria and costs for establishing additional limited-stop bus services based on existing and future ridership demand, operating strategies, and equipment needs. This methodology could ultimately be used by regional transit authorities (RTAs) beyond the MBTA. This project then would analyze which Key Route corridors would be most likely to support both local and limited-stop service, as well as estimate the resources needed to provide both types of service. The results of the analysis could be used to justify additional operating funds at some point in the future. If additional MBTA operating resources become available, the results of this study could be used to prioritize the implementation of limited-stop service on Key Routes. Most of these routes operate in minority and/or low-income areas.

 

I.7       Environmental Justice and Title VI Analysis Methodology Review (Funded in FFY 2014)

As a recipient of Federal Transit Administration (FTA) and Federal Highway Administration (FHWA) funds, the MPO is required to comply with both Title VI of the Civil Rights Act of 1964 and the U. S. Department of Transportation’s environmental justice (EJ) policy. While there is significant overlap between the two, Title VI and EJ analyses are not interchangeable. Title VI is a federal statute that prohibits discrimination on the basis of race, color, or national origin and applies to all activities, while EJ is an executive order that requires the identification of disproportionately high and adverse human health or environmental effects of programs, policies, or activities on minority populations and low-income populations.

 

Title VI is one tool for achieving the principals of environmental justice, and although Title VI applies specifically to minority populations, the FTA Title VI Circular includes certain monitoring and reporting requirements for low-income populations as well. In addition, FTA published an EJ circular in 2012, and FHWA continues to include EJ in its Title VI Nondiscrimination Handbook.

 

The MPO carries out various activities to support the inclusion of Title VI and environmental justice principles in the transportation planning process and to identify the needs of Title VI and environmental justice communities within the Boston Region. This study would take an overall look at the way that Boston Region MPO staff conduct environmental justice and Title VI analyses and identify opportunities for improvement and standardization. These recommendations would support the MPO in meeting the Title VI and EJ requirements of both FTA and FHWA; they may also enhance the MPO implementation of performance-based planning. The study would consider four elements:

I.8       Impacts of Walking Radius/Transit Frequency and Reliability (funded in FFY 2012)

The current MBTA service delivery policy’s coverage guideline states that, in areas that are served by bus and/or rapid transit with a population density of greater than 5,000 persons per square mile, no individual should need to walk farther than 0.25 miles to access transit service. As part of this project, CTPS analyzed the potential and suggested possible system designs for local bus system consolidation if the 0.25-mile radius was relaxed to 0.33 miles, 0.4 miles, and 0.5 miles and the consolidated bus routes adhered to rapid-transit-service standards. This modeling-based effort was built on the MBTA Core Services Evaluation study and helped the MPO better understand the implications of the tradeoff between eliminating poor performing local bus routes and increasing service on a smaller number of transit corridors. It considered the best option for providing mobility and accessibility through the bus network. The ultimate goal was to increase transit mode shares. The study also considered the equity implications and potential tradeoffs of the potential systems.

 


 

 

I.9       MBTA Bus Route 1 Transit Signal Priority (funded in FFY 2011)

MBTA bus Route 1 from Harvard Square in Cambridge to Dudley Square in Roxbury is one of the busier routes in the system. The corridor along which this bus route travels, Massachusetts Avenue (Route 2A) is a multilane roadway with an on-street parking lane in both directions. Transit signal priority (TSP) could improve bus operations for the route by reducing travel times and improving schedule adherence. CTPS evaluated existing traffic and bus operations along the bus route or parts of the route and identified TSP and other traffic-signal recommendations to improve both bus and traffic operations. A traffic-simulation model was utilized to evaluate both the existing conditions and proposed improvements. CTPS was responsible for carrying out the project and worked in collaboration with MassDOT, the MBTA, and the cities of Boston and Cambridge.

 

I.10     Sullivan Square/Rutherford Avenue Land Use Visioning (Funded in FFY 2013)

MAPC worked closely with the City of Boston to study the potential for redevelopment of the Sullivan Square area into a transit-oriented, mixed-use center that will better connect the transit station to residential neighborhoods in Charlestown and interconnect existing and new open spaces. The land use planning study and rezoning also aimed to support the further development of a multimodal MBTA station at Sullivan Square that includes a commuter rail stop and future Urban Ring connections. As a corollary to the creation of a new street grid and development parcels, the study aimed to enhance the public realm by creating public sidewalks, new open spaces, and an appropriate mix and scale of residential and commercial development with active ground-floor uses. The transportation elements of this project are programmed in the Long-Range Transportation Plan in the 2016–20 time period.

 

 

 

 

Appendix J is titled “Long-Range Transportation Plan Development.” It consists of Chapter 1 of the LRTP.

 

 

Appendix K—Transportation Improvement Program Process

 

K.1      Transportation Improvement Program—Development

The Boston Region MPO develops a Transportation Improvement Program (TIP) each year. View the Development Schedule for an outline of the main activities of the FFYs 2015-18 TIP process. The process by which the MPO develops the TIP is described on this page.

 

K.2      Outreach and Data Collection (December–February)

The outreach process begins in December when MPO staff solicits a listing of priority projects to be considered for federal funding from each of the 101 cities and towns in the region. The MPO also seeks the input from interested parties and members of the general public. MPO staff compiles the project funding requests and relevant information into a Universe of Projects list for the MPO. The Universe of Projects list consists of all identified projects being advanced for possible funding and includes those projects only in the conceptual stage as well as those which are fully designed and ready to be advertised for construction.

 

New projects must be initiated through the MassDOT Highway Division before they can be considered for programming in the TIP. Municipal TIP Contacts and MPO staff coordinate to update each project´s Project Funding Application Form through the MPO’s Interactive TIP Database. The form provides information on each project´s background, infrastructure condition and needs, development status, and ability to help the region attain the visions established by the MPO.

 

K.3      Evaluation of Projects (February–March)

The MPO uses TIP project evaluation criteria to make the process of evaluating and selecting projects for programming in the TIP more logical and transparent. The criteria are a means of programming projects that will help the region attain the visions established by the MPO, which include, to maintain a state of good repair, focus investments on existing activity centers, improve mobility for people and freight, reduce the level of greenhouse gas (GHG) emissions, minimize environmental burdens from transportation facilities on low-income and minority populations, and provide safe transportation for all modes. Projects with components and outcomes that help attain the goals of the MPO receive higher scores. The project evaluation criteria consist of 35 questions across six policy categories.

MPO staff requires a Functional Design Report to conduct a complete evaluation. Projects with partial or no evaluation indicate that staff did not have enough information available to evaluate the project across all categories.

 

K.4      Staff Recommendation and Draft TIP (March–April)

The staff uses evaluation ratings and project readiness information to prepare a First-Tier List of Projects. This is a list of the projects with the highest ratings that could be made ready for advertising within the TIP’s time horizon (next four federal fiscal years). The staff relies on the MassDOT Highway Division to provide information about what year a project would be ready for advertising. In developing the staff recommendation for the draft TIP, MPO staff strongly considers the First-Tier List of Projects. MPO staff also factors in projects that are listed in the long-range transportation plan in order to implement the LRTP, considers geographic equity to help ensure that the list of projects addresses needs throughout the region, and accounts for cost to comply with fiscal constraint.

 

Also at about that point in the process, the transit agencies present their priority projects for inclusion in the draft TIP. The list of transit projects for the TIP draws from the MBTA’s Capital Investment Program (CIP) and authority priorities. The CIP is the MBTA’s rolling five-year plan, which outlines the transit system’s infrastructure needs and planned investments within this time frame. The list of projects selected for the TIP also draws from the projects being developed by the Cape Ann Transportation Authority (CATA) and the MetroWest Regional Transit Authority (MWRTA).

 

K.5      Public Review and Endorsement (April–June)

The MPO discusses the First-Tier List of Projects, the staff recommendation, and other information before voting on a draft TIP to release for a 30-day public review and comment period. After the comment period ends, the MPO reviews all comments and makes changes to the document as appropriate. It then endorses the TIP and submits it to the Federal Highway Administration and Federal Transit Administration to enable federal approval at the end of the federal fiscal year or September 30.

 

 

 

Appendix L—Long-Range Transportation Plan Benefits and Burdens Analysis