Agenda 06/09/2020 Item #16D11 (Submittal of CAT's Title VI Program)06/09/2020
EXECUTIVE SUMMARY
Recommendation to approve the submittal of Collier Area Transit's Title VI Program to the
Federal Transit Administration (FTA) ensuring equal access to any person without regard to race,
color, or national origin.
OBJECTIVE: To make certain that transit services made available are equitably distributed, and
provides equal access and mobility to any person, without regard to race, color, or national origin.
CONSIDERATIONS: The Collier County Board of County Commissioners (Board) has received
Federal financial assistance from the FTA, and as a condition of receiving this assistance, the Board must
comply with Title 49 of the Code of Federal Regulations (C.F.R.), part 43. The Board is required to have
a Title VI Program in accordance with the regulations of the U.S. Department of Transportation, as
provided in Title 49 of the C.F.R. The Title VI Program ensures equal access to any person without
regard to race, color, or national origin, provides procedures for investigating complaints and informs the
public of their rights under Title VI. This program is updated every three (3) years and was last submitted
in 2017. Updates are required to comply with statutes and FTA requirements. Updates to the 2020 Title
VI plan include updated maps and new bus routes and bus stop amenities since the last Title VI
submission in 2017.
A copy of Resolution 2014-57 that adopts the Transit Title VI Program and authorizes the Transit
Manager to sign all documents required in connection with the program is attached to this summary for
the Board's reference.
The Title VI Program Update is going through the Collier Area Transit (CAT) Public Participation Plan,
which includes an endorsement from the Public Transit Advisory Committee. At the development of this
Executive Summary, the 30-day public comment period for the Title VI Plan had not yet completed but
will expire on June 1st, 2020 in accordance with the Collier Area Transit Public Participation Plan. The
document attached to this Item will be considered the final Title VI Program Update unless substantive
public comments are received during the public comment period. Any substantive changes will be
presented to the Board during the public hearing.
With the approval of the attached plan update, the Transit Title VI Plan will be submitted to FTA and will
be valid through 2023.
FISCAL IMPACT: There is no Fiscal impact associated with the approval of this plan.
GROWTH MANAGEMENT IMPACT: There is no Growth Management impact associated with this
Item.
LEGAL CONSIDERATIONS: This Item is approved for form and legality and requires a majority vote
for Board action. -JAB
RECOMMENDATION: To approve the Collier Area Transit Title VI Program Update and authorize its
submittal to the Federal Transit Administration.
Prepared By: Omar De Leon, Public Transit Manager, Public Transit & Neighborhood Enhancement
Division
16.D.11
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06/09/2020
ATTACHMENT(S)
1. [linked] Title VI Program 2020 Update Final (PDF)
2. Signed Resolution 2014-057 (PDF)
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06/09/2020
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.D.11
Doc ID: 12448
Item Summary: Recommendation to approve the submittal of Collier Area Transit's Title VI
Program to the Federal Transit Administration (FTA ) ensuring equal access to any person without regard
to race, color, or national origin.
Meeting Date: 06/09/2020
Prepared by:
Title: Planner, Senior – Public Transit & Neighborhood Enhancement
Name: Omar Deleon
05/19/2020 6:11 PM
Submitted by:
Title: Division Director - Pub Tran & Nbrhd Enh – Public Transit & Neighborhood Enhancement
Name: Michelle Arnold
05/19/2020 6:11 PM
Approved By:
Review:
Public Transit & Neighborhood Enhancement Caroline Soto Additional Reviewer Completed 05/20/2020 8:53 AM
Public Transit & Neighborhood Enhancement Michelle Arnold Additional Reviewer Completed 05/21/2020 3:19 PM
Operations & Veteran Services Kimberley Grant Level 1 Reviewer Completed 05/22/2020 12:25 PM
Public Services Department Todd Henry Level 1 Division Reviewer Completed 05/22/2020 1:35 PM
Public Services Department Steve Carnell Level 2 Division Administrator Review Completed 05/23/2020 10:50 AM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 05/26/2020 8:14 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 05/27/2020 11:52 AM
Budget and Management Office Ed Finn Additional Reviewer Completed 06/01/2020 9:57 AM
County Manager's Office Sean Callahan Level 4 County Manager Review Completed 06/02/2020 11:38 AM
Board of County Commissioners MaryJo Brock Meeting Pending 06/09/2020 9:00 AM
16.D.11
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RESOLUTION No. 2014 57
RESOLUTION NO. 2014 - 5 ADOPTING THE
COLLIER AREA TRANSIT TITLE VI PROGRAM
WHEREAS, the Board of County Commissioners of Collier County, Florida (the
Board") receives Federal financial assistance from the Federal Transit Administration (FTA),
and as a condition of receiving this assistance, the Board must comply with Title 49 of the Code
of Federal Regulations (CFR), part 53.
NOW, THEREFORE BE IT RESOLVED BY THE BOARD OF COUNTY
COMMISSIONERS OF COLLIER COUNTY, FLORIDA THAT:
1. That it is the policy of the Board to ensure that transit services are equitably distributed
and provide equal access and mobility to any person, without regard to race, color or
national origin.
2. That the policies and procedures set forth in the County's Title VI Program presented on
the below-referenced is approved.
3. That the Public Transit Manager is authorized to sign any and all assurances,
certifications and other documents that may be required in connection with the Program
or subsequent Programs.
4. That the Public Transit Manager is authorized to make necessary modifications to the
Title VI Program to ensure compliance with 49 C.F.R., part 53.
This Resolution adopted this day ofV-\<_r Ae,_2014 after motion, second and
majority vote in favor of passage.
ATTEST BOARD OF COUNTY COMMSSIONERS
DWIGHT E. BROCK,CLERK COLLIER COUNTY, FLORIDA
I3 Bye ' D`___
Deputy Cie rlc eet aS to Char an s Commissioner Tom } ginning, Chairman
signature only. U
Approved as to form and legality:
By: .. ,
Scott R. Teach
Deputy County Attorney
I)
16.D.11.b
Packet Pg. 1253 Attachment: Signed Resolution 2014-057 (12448 : Title VI Program Update 2020)
COLLIER COUNTY BOARD OF COUNTY
COMMISSIONERS
COLLIER AREA TRANSIT (CAT)
TITLE VI PROGRAM
2020 - 2023
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TITLE VI PROGRAM 2020 - 2023
Table of Contents
Introduction 4
Background 5
Title VI Program Policy Statement 7
Major Accomplishments Since 2017 Submittal 9
General Reporting Requirements 10
Pending Applications for Financial Assistance to FTA and Agencies Other than the FTA 10
FTA Civil Rights Assurance, DOT Title VI Assurance 12
Program Specific Requirements 12
Title VI Notice to the Public 12
Title VI Complaint Procedures 13
List of Transit-Related Title VI Investigations, Complaints or Lawsuits 15
Public Participation Plan 15
Limited English Proficiency 17
Membership Non-Elected Committees 34
Title VI Equity Analysis for New Facility Construction 36
Title VI Plan Approval 38
Requirements of Transit Providers 38
System Wide Service Standards and Policies 38
Other Areas of Title VI Considerations 45
Assessment of Compliance 46
List of Tables
Table 1: CAT Budget Fiscal Years 2015-2019 5
Table 2: CAT Fares 10
Table 3: CAT Active Federal Grant Assistance 11
Table 4: Percent of Limited English Proficiency Persons by Census Block Group 17
Table 5: Summary of Limited English Proficiency Persons within the CAT Service Area 24
Table 6: Percentage of Limited English Proficiency Students within Collier County Public Schools 26
Table 7: Service Changes Since the Last Title VI Update through March 2020 33
Table 8: Racial Composition of Bodies that Provide Input to Decision-Making Bodies 34
Table 9: Vehicle Load Standards 39
Table 10: CAT Service Levels by Routes 40
Table 11: On Time Performance 42
Table 12: CAT Minority Routes 42
Table 13: Annual Update of HHS Poverty Guidelines 60
Table 14: Fixed Route Capacities 61
Table 15: Demand Response Capacities 61
Table 16: Total Capacity Analysis and Total Vehicle Counts 62
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Table 17: Peer System Characteristics 65
Table 18: CAT’s Performance Review Measures 65
Table 19: CAT’s General Indicator Peer Comparison 65
Table 20: Summary of Collier County’s Peer and Trend Analysis (2013-2018) 78
List of Maps
Map 1: Limited English Proficiency 19
Map 2: Bus Stop Amenity Locations for Low Income & Minority Populations Areas 45
Map 3: Minority Census Tracts and CAT Fixed Route & ADA Service Areas 48
Map 4: Low-Income Census Tracts and CAT Fixed Route & ADA Service Areas 49
List of Figures
Figure 1: Distribution of Limited English Proficiency Persons within the CAT Service Area 25
Figure 2: CAT Operations and Maintenance Facility 37
Figure 3: Recent Conceptual Site Plan of the Immokalee Transfer Facility 38
Figures 4-25: Transit Development Plan (TDP) Peer Review 66-77
Appendix
A: Title VI Complaint Form 50-51
B: Certifications and Assurances 52-54
C: Sub-Recipient Monitoring Form 54-56
D: CAT Route Fare or Service Change Policy 57-60
E: Transit Development Plan Capacity Analysis 61-63
F: Transit Development Plan Peer Review 64-78
G: Ridership Survey 79-82
H: Community Agencies 83-84
I: Transit Manager Resolution 85-86
J: Fare Study 87
K: Latest TDP 88
L: Title VI Training 89
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Introduction
Collier Area Transit, (d.b.a. “CAT”) began its fixed route service in February 2001, offering service in Collier
County, to include the cities of Naples, Marco Island and the Immokalee area. Collier Area Transit (CAT)
operates under the supervision of the Collier County Division of Public Transit and Neighborhood
Enhancement (PTNE) for the Collier County Public Services Department. CAT provides public transit
service including fixed-route bus, express bus, Americans with Disabilities (ADA) and Transportation
Disadvantaged (TD) paratransit service. CAT coordinates through the State of Florida Commission for the
Transportation Disadvantage with the transportation vendor providing public transportation services to
Medicaid individuals.
CAT is submitting this report to the Federal Transit Administration, (FTA), providing a program to ensure
that transit services made available is equitably distributed, and provides equal access and mobility to any
person, without regard to race, color, or national origin. This program is updated every three (3) years
and received approval by FTA through March 31, 2023.
This program update for 2020-2023 has been prepared pursuant to Title VI of the Civil Rights Act of 1964;
Title 49, Chapter 53, Section 5332 of the United States Code; and the FTA Circular 4702.1B, “Title VI
Requirements and Guidelines for Federal Transit Administration Recipients,” (October 1, 2012).
Additionally, this update summarizes the CAT transit service provisions since the last program was
approved. This update will provide compliance with all parameters of the FTA Title VI Program Checklist
for all applicable requirements of Transit Providers.
The objectives of this Title VI Program include the following:
1. Ensure that federally-assisted benefits and related services are made available and are equitably
distributed.
2. Ensure that the level and quality of federally-assisted services are sufficient to provide equal
access and mobility to all persons.
3. Ensure adequate opportunities for all to participate in the planning and decision-making
processes.
4. Ensure that placement of transit services and facilities are equitable.
5. Ensure that corrective and remedial actions are taken for all applications and receipts of federal
assistance to prevent discriminatory treatment of any beneficiary.
6. Provide procedures for investigating Title VI complaints.
7. Take responsible steps for ensuring that meaningful access to programs and activities is
provided for persons with Limited English Proficiency.
8. Inform the public of their rights under Title VI.
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Background
Collier County, like most jurisdictions, has been drastically impacted by the downward housing market
and the economy over the past several years, which increased ridership but limited funding. Although the
economy and housing has recovered in recent years, the strong economy has too made it a challenge to
continue to provide public transportation services as disposable income has increase thus private cars
have become much more of an affordable mode of transportation. The challenge is now that with a
reduction in ridership, CAT’s budget has remained stagnant only seeing a very slight increase to cover
inflation. Consequently, those truly needing public transit are not seeing an increase in bus frequency or
fixed-route coverage. The low frequency and coverage issues are also affecting CAT’s ability to attract
choice riders which too hurts CAT’s revenue earning potential.
The ridership trends coupled with budget constraints has prompted service restructuring and adjustments
for efficiency purposes. The CAT staff conducted annual planning and evaluation of the routes and
implemented route modifications in 2018 to maximize utilization of the available budget, increase
efficiency and increase ridership. Table 1 presents the CAT budget over the past five years. Despite these
budgetary changes, CAT continues to provide public transit service aimed at serving the maximum number
of persons in the most efficient and equitable manner.
Table 1: CAT Budget
Fiscal Years 2015 - 2019
Fiscal Year FY 2015 FY 2016 FY 2017 FY 2018 FY 2019
Fixed Route
Budget
$6,181,900 $6,642,500 $5,727,700 $6,063,500 $6,281,200
Paratransit
Budget
$3,451,700 $3,916,200 $4,222,800 $4,036,500 $4,242,200
Total $9,633,600 $10,558,700 $9,950,500 $10,100,000 $10,523,400
Percent
Change
4% 9% -6% 1.5% 4%
Over the past three years, CAT has participated in a number of compliance reviews with the Collier
Metropolitan Planning Organization (MPO), FDOT, and the FTA with regard to ensuring federal and state
guidelines are adhered to in transportation planning and service delivery.
Over the past three years, CAT has completed three (3) Minor Transit Development Plan (TDP) Updates
and is currently in the middle of a Major Transit Development Plan (TDP) Updates. The previous TDP Minor
updates have allowed ample opportunity for public input into the planning, service delivery, and capital
investment program process. The current Major TDP Update is doing the same but has been impacted
with the challenge of reaching the public amidst a pandemic (Coronavirus – COVID-19). CAT and its
consultants have improvised and are conducting several surveys, utilized social media and conducted
virtual meetings in response to stay at home and social distancing orders. In addition to the public
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participation efforts, planning resources have also provided CAT with significant data on its customers and
the surrounding area that can be used for identification of service area populations and any necessary
equity analysis prior to proceeding with decision-making activities. From the TDP on-board survey, CAT
was able to identify its typical rider and determine its customers’ qualitative and quantitative opinions of
the service provided and focus areas for future service and capital purchases. The TDP also provides an
in-depth analysis of how CAT performs in comparison with peer agencies. Many aspects of the TDP will
be utilized to support compliance with Title VI guidelines and the full documents can be found on the CAT
website at http://www.rideCAT.com.
The public transit services in Collier County, provided by CAT, are governed by the Collier County Board of
County Commissioners. The commissioners are elected in accordance with the State of Florida District
Designations as follows:
• District 1 – Donna Fiala
• District 2 – Andy Solis
• District 3 – Burt Saunders
• District 4 – Penny Taylor
• District 5 – William L. McDaniel Jr.
The Collier County Board of County Commissioners is the official decision-making body for Collier County
and, because they are elected by the general public, CAT has no ability to ensure that there is adequate
representation of minorities on this body.
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Title VI Program Policy Statement
CAT operates under the Public Transit & Neighborhood Enhancement (PTNE) Division which is one of Nine
(9) Divisions within the Public Services Department of Collier County Government. CAT is the provider of
public transportation; whose purpose is to deliver quality public transportation services to the general
public. CAT’s employees who have extensive daily contact with the public, recognize its responsibility to
the community it serves and is committed to a policy of non-discrimination. Governed by the Collier
County Board of County Commissioners and serving the cities of Naples, Marco Island, Everglades City,
the Immokalee community, and other areas of unincorporated Collier County, CAT complies with Title VI
of the Civil Rights Act. It is CAT’s policy to ensure non-discriminatory transportation practices throughout
Collier County.
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin
in programs and activities receiving Federal financial assistance. Specifically, Title VI 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 subjected to discrimination under any program or activity
receiving federal financial assistance.
The Environmental Justice (EJ) component of the Title VI requirements guarantees fair treatment for all
people regardless of race and income. The requirements under EJ include CAT identifying and addressing,
as appropriate, any potential disproportionate and/or adverse impact of its programs, policies, and
activities on minority and low-income populations. In addition to EJ considerations in the administration
of public transit, CAT will undertake reasonable steps to ensure that Limited English Proficiency (LEP)
persons have meaningful access to programs, services, and information.
The three fundamental Environmental Justice concepts are to:
1. Avoid, minimize, or mitigate disproportionately high and adverse human health or environmental
effects, including social and economic effects, on minority and low-income populations.
2. Ensure the full and fair participation by all potentially affected communities in the transportation
decision-making process.
3. Prevent a denial, reduction, or significant delay in the receipt of benefits by minority and low-
income populations.
The Public Transit Manager has been designated as the CAT Civil Rights Officer responsible for civil rights
compliance and monitoring to ensure the nondiscriminatory provision of transit services and programs.
In addition to the Transit Manager, the PTNE Director and all Transit agency staff share in the responsibility
of making CAT’s Title VI program a success. Title VI compliance is given the utmost importance by CAT and
its governing board.
To request a copy of the agency’s Title VI Program, contact the Public Transit & Neighborhood
Enhancement (PTNE) Division at the phone number, e-mail, or physical address provided below or access
it on the CAT website at http://www.rideCAT.com. Any person who believes that they have been denied
a benefit, excluded from participation in, or discriminated against under Title VI has the right to file a
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TITLE VI PROGRAM 2020 - 2023
formal complaint in writing to the Public Transit Manager, responsible for civil rights compliance and
monitoring to ensure non-discriminatory provision of transit services and programs. File your formal
complaint in writing, via e-mail, or by phone using the following contacts:
By Mail: Public Transit & Neighborhood Enhancement Division
8300 Radio Road
Naples, FL 34104
By Phone: CAT - (239) 252-4996
Email : rideCAT@colliercountyfl.gov
Online: https://www.colliercountyfl.gov/your-government/divisions-f-r/public-transit-
neighborhood-enhancement/our-services/collier-area-transit-cat/title-vi-program
Form: https://www.colliercountyfl.gov/home/showdocument?id=90136
Please be sure to include your name, address, and how to contact you (physical address, phone number,
and/or e-mail address, etc.). Complaints are documented in the County’s database, logged and tracked
for investigation. Once the investigation is completed, the customer is notified of the outcome of the
investigation.
The Title VI Policy statement is disseminated to all staff and is available on CAT’s website. The Title VI
Notice can be found in this Plan; posted at each transfer Station and on each bus. Implementation of the
Title VI Program is considered a legal obligation accepted as part of the financial assistance agreement
entered into with the U.S. Department of Transportation’s Federal Transit Administration.
Individuals and organizations also have the right to file a complaint with the Federal Transit
Administration’s Office of Civil Rights by obtaining the complaint form from:
https://www.transit.dot.gov/regulations-and-guidance/civil-rights-ada/fta-civil-rights-complaint-form.
To file a complaint directly to FTA complete the FTA complaint form (PDF). The complaint form must be
signed and mailed to:
Federal Transit Administration
Office of Civil Rights
Attention: Complaint Team
East Building, 5th Floor – TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
_____________________________________________________ ____________________
Omar De Leon Date
Transit Manager
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TITLE VI PROGRAM 2020 - 2023
Major Accomplishments since the 2017 Title VI Submittal
Collier Area Transit has made the following improvements to the system to better the operations and
services provided to its passengers in accordance with FTA regulations since the last Tittle VI submittal:
• Passenger Transfer Station - located at 8300 Radio Road has been further enhanced with the
construction of ADA accessible hallways to allow better passenger accessibility to the mobility
manager for their paratransit interviews in a private setting.
• Route Changes and Improvements – In FY2018 in response to public input, operational changes
were made to Route 22 and 23 so they no longer circulate on the same route. This change allowed
CAT to service key destinations such as the Immokalee Technical College, Salvation Army, retail
and medical offices, as well as the Department of Children and Families. Existing revenue hours
were utilized to increase frequency and reduce wait time as well as provide later service hours.
• Frequency Improvements - In April 2018, 3 extra loops were added to the most utilized route,
Route 11. This route 11 is incredibly important, because it services the major corridor where most
of the businesses are located, providing employment opportunity to the transit dependent
population. This route is also a major connection between Northern and Southern Collier County.
• Bus Shelter Construction – 13 bus shelters were installed within Collier County. In addition, the
newly installed shelters incorporate solar lighting to enhance security measures.
• ADA Bus Stop Improvements - CAT obtained grant funding for the design and construction of bus
stop improvements to meet ADA accessibility standards. 17 ADA bus stops were designed and
constructed in FY2018.
• New transit route Extension - Route 24 was reevaluated and it was revealed that the San Marco
Stop was completely unneeded, so route changes were made to better service the farm worker
population within the area. Three new stops were added to Six L’s Farm Rd, one stop in particular
is now servicing a farm worker housing community. The housing community has approximately
400 residents with limited vehicular access and transit options to basic needs such as medical
care, grocery stores, and general goods. Bus frequency was also added to this region to again
better assist the farm workers.
• New Beach Access Route – In 2019 the CAT’s Beach Bus was realigned to provide direct access
to the beach. The route was shortened, running along Bluebill Ave between Delnor Wiggins State
Park and Creekside, a major connection point to three other routes within the system. Fares
were also eliminated to expand access to the community. These were very popular alterations
with passengers.
• Fare Study – In March 2018 CAT conducted a Fare Study which resulted in the following changes
to the Fixed Route fares:
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Table 2: CAT Fares
The paratransit fare struct was also modified to consolidate the Transportation Disadvantaged
(TD) fare structure from five to three income-based categories. The maximum pre trip fare was
capped at $4 rather than $7 under the old fare structure.
General Reporting Requirements
Pending Applications for Financial Assistance to FTA and Agencies Other than the FTA
As of May 31, 2017, CAT had the following pending grant applications:
The pending grants are listed below:
1032-2020-1 / FHWA Flex Funds Bus Shelters
1032-2020-2 / FY20 FHWA Flex Funds Bus Shelter
1032-2020-3 / 5307 and 5339 Funds; Capital, ADA, Planning
1032-2020-4 / FY20 FTA Section 5307 CARES Act Capital and Operating
FDOT USC 5311 Non-Urbanized Formula Grant
FDOT USC 5310 Transportation for Elderly Persons
FDOT USC 5339 Rural Capital Assistance Grant
CAT utilizes the active grants listed in Table 2 to support public transit services in Collier County. Some
of these grants cover multiple fiscal years.
Fare Category Previous Newly Adopted
Full Fare Reduced Fare Full Fare Reduced Fare
One-way Fare $1.50 $0.75 $2.00 $1.00
Children 5 years of age & under Free Free Free Free
Transfer $0.75 $0.35 Free/90 min. Free/90 min.
Day Pass $4.00 $2.00 $3.00 $1.50
7-Day Pass $15.00 $7.50 NA NA
15-Day Pass NA NA $20.00 $10.00
30-Day Pass $35.00 $17.50 $40.00 $20.00
Marco Express One-way Fare $2.50 $1.20 $3.00 $1.50
Marco Express 30-Day Pass $70.00 $35.00 $70.00 $35.00
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Table 3: CAT Active Federal Grant Assistance
GMS Grant Number Grant Program Award Amount Balance to Expend
33172-01 FTA Section 5307 - FY11 $2,989,875 $9,234
33243-01 FTA Section 5307 FLEX-XU $336,872 $186,203
33369-01 FTA Section 5307 FLEX-XU $287,124 $175,069
33371-01 FTA Section 5307 - FY14 $3,464,582 $227,457
33372-01 FTA Section 5307 FLEX-XU $294,000 $173,707
33425-01 FTA Section 5339 RURAL (G0015) $217,600 $2,898
33441-01 FTA Section 5307 - FY15 $3,355,215 $14,025
33447-01 SDTS State Discretionary G0575 $100,000 $1,362
33474-01 FTA Section 5339 RURAL $210,400 $263,000
33482-01 FTA Section 5307 - FY16 $2,843,559 $29,439
33483-01 FTA Section 5307 FLEX-XU $497,000 $30,997
33510-01 FTA Section 5339 - FY16 $299,327 $251,846
33511-01 FTA Section 5307 FLEX-XU $80,000 $13,402
33518-01 FTA Section 5339 RURAL $202,400 $202,400
33526-01 FTA Section 5307 - FY17 $2,888,070 $653,466
33549-01 FTA Section 5310 17/18-SFY18 $285,518 $356,898
33551-01 FTA Section 5339 RURAL $82,875 $103,594
33552-01 FTA Section 5339 - FY17 $299,889 $299,889
33555-01 FTA Section 5307 FLEX-XU $274,000 $274,000
33556-01 FTA Section 5307 FLEX-XU $316,250 $316,250
33570-01 FTA Section 5307 - FY18 $3,397,820 $174,936
33590-01 FTA Section 5324 Emergency Relief $226,327 $226,327
33591-01 FTA Section 5339 - FY18 $411,466 $260,272
33607-01 SBG State Block Grant G1577 $940,849 $22,998
33614-01 FTA Section 5311 $379,787 $759,574
33615-01 FTA Section 5310 18/19-SFY19 $281,382 $351,728
33623-01 FTA Section 5307 FLEX-XU $286,180 $286,180
33634-01 FTA Section 5307 - FY19 $3,410,514 $2,249,135
33635-01 T&E Trip and Equipment (G1A20) $910,405 $0
33642-01 FTA Section 5307 FLEX-XU $545,068 $545,068
33664-01 FTA Section 5339 - FY19 $372,752 $313,272
33648-01 SC - Shirley Conroy (G1A93) $71,206 $0
33652-01 Public Transit Block Grant Program $982,792 $1,965,584
33665-01 FTA Section 5310 FY19-20 $398,726 $448,567
$31,939,830 $11,188,776
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FTA Civil Rights Assurance, DOT Title VI Assurance
CAT submitted the Fiscal Year 2020 Certifications and Assurances in FTA’s Transit Award Management
System (TrAMS). A copy of the signed Certifications and Assurances is provided in Appendix A, including
the 01 Assurance required for each applicant, which incorporates the following sections:
D. Non-Discrimination Assurance
E. Assurance of Non-Discrimination on the basis of disability
The Certifications and Assurances were electronically signed and submitted on March 3rd, 2020. CAT has
a process in place that staff follows to prepare for the annual execution of the FTA Annual Certifications
and Assurances. Transit staff prepares a request to the County Attorney’s Office for review and approval.
Upon review, the Public Service Department Head is notified of the County Attorney’s approval and the
Department Head executes the document. The Collier County Board of County Commissioners has
delegated the Public Services Department Head with the obligation to review and execute the
Certifications and Assurances. Upon review and acceptance, the County Attorney, and the Public Service
Department Head complete the requirements for execution of the Certifications and Assurances.
Program Specific Requirements
The following information addresses Title VI general reporting requirements as described in FTA Circular
4702.1B.
Title VI Notice to the Public
A Title VI Notice to the Public must be displayed to inform a recipient’s customer of their rights under Title
VI. At a minimum, recipients must post the notice on the agency’s website, in public areas of the agency’s
office(s), and on fixed routes.
The following Title VI Notice to the Public is posted in the Collier Area Transit’s administrative offices, on
the buses, website, and terminals.
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Title VI Complaint Procedures
As a recipient of federal financial assistance, Collier Area Transit (CAT) has the following Title VI complaint
procedures in place.
Filing a Discrimination Complaint
Collier County has provided procedures for filing complaints alleging discrimination on the basis of race,
color, or national origin. Information on how to file a complaint is provided through the County Manager’s
Office of Equal Employment Opportunity, on CAT’s website, and appears routinely on publications,
interior bus cards, schedules, and on other materials available at public facilities. The information is also
posted at the CAT administrative facility, at the Transfer terminals, and at other public facilities frequented
by transit users such as libraries and community health centers.
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TITLE VI PROGRAM 2020 - 2023
Any person who believes that he or she, individually or as a member of any specific class of persons, has
been subjected to discrimination on the basis of race, color, or national origin may file a written complaint
with the FTA or the Secretary of Transportation. Persons are encouraged to first notify Collier County and
file a complaint through the local office.
Any person who believes that he, or she, or any specific class of persons, has been subjected to
discrimination or retaliation prohibited by the Title VI of the Civil Rights Act of 1964, as amended, and
related statutes, under CAT’s program of transit service delivery or related services or programs is
encouraged to file a report with Public Transit and Neighborhood Enhancement at:
Public Transit and Neighborhood Enhancement Division
8300 Radio Road Naples, Fl 34104
Telephone (239) 252-4996, fax (239) 252-6534
www.rideCAT.com
CAT encourages the filing of a complaint in writing and includes a name, addresses, and other information
so that the individual may be contacted regarding the matter. A copy of the Title VI Complaint Form is
provided to document all pertinent information regarding the complaint.
All complaints received within 180 days of the incident are processed and investigated by CAT. A
preliminary review to determine jurisdiction is conducted and if within CAT’s authority and investigation
is conducted. The complainant will receive an acknowledgement letter informing her/him whether the
complaint will be investigated by CAT or the OEO.
CAT has 30 days to investigate the complaint. If more information is needed to resolve the case, CAT may
contact the complainant. The complainant has 30 business days from the date of the letter to send
requested information to the investigator assigned to the case. If the investigator is not contacted by the
complainant or does not receive the additional information within 30 business days, CAT can
administratively close the case. A case can also be administratively closed if the complainant no longer
wishes to pursue their case.
After the investigator reviews the complaint, she/he will issue one of two letters to the complainant: a
closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there
was not a Title VI violation and that the case will be closed. An LOF summaries that the allegations and
the interviews regarding the alleged incident, and explains whether any disciplinary action, additional
training of the staff member, or if any other action will occur. If the complainant wishes to appeal the
decision, she/he has 30 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
File a complaint by completing the FTA complaint form (PDF). The complaint form must be signed and
mailed to:
Federal Transit Administration
15
TITLE VI PROGRAM 2020 - 2023
Office of Civil Rights
Attention: Complaint Team
East Building, 5th Floor – TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
Title VI Complaint Form
The CAT Title VI complaint form and associated procedures are available in English, Spanish, and Creole
in Appendix A of this plan as well as on the CAT website. If the information is needed in other languages
spoken by LEP populations CAT will accommodate that request.
List of Transit-Related Title VI Investigations, Complaints or Lawsuits
Members of the public and staff who believe that they have been discriminated against based on race,
color, national origin, age, gender, or disability are afforded the opportunity to have their concern
documented. The public has the option to convey their concern via direct phone communication with a
customer service representative, face to face during regular business hours, via the internet in the form
of an email, or written correspondence. Complaints are documented and tracked for investigation. Once
the investigation is completed, the customer is notified of the outcome of the investigation. If the
customer is not satisfied with the outcome of the investigation, they are then referred to the Public Transit
Director for escalation. Internal files have been reviewed to determine whether there were and
complaints filed or concluded between submittal of the last Title VI Plan in June 2017 through March 2020
that raised to the level of a Title VI complaint.
There were no external complaints or internal complaints filed by management during this time period.
During this period the County changed from a two-vendor system to a single vendor, consolidating transit
operation services. The contract with Medical Transportation Management (MTM) Inc. was terminated
and MV Contract Transportation, Inc. assumed full service for Collier County in January 2019. There have
been no complaints registered to the vendors during their contract period with Collier County., Inc.
Had there been any complaints received they would have been given the highest priority and thoroughly
investigated to ensure that any substantiated complaint is addressed and that appropriate follow-up
actions are taken to correct discriminatory actions and prevent future discriminatory policies, practices,
and environments.
Public Participation Plan
The following section includes information about CAT’s Public Participation plan, including information
about outreach methods to engage minority and limited English proficient populations (LEP), as well as a
summary of outreach efforts made since the last Title VI Program submission
16
TITLE VI PROGRAM 2020 - 2023
Public Involvement
CAT’s public involvement process is two-fold in that the CAT has its own Public Participation Plan (PPP)
but the agency also participated in the Collier Metropolitan Planning Organization (MPO) public
involvement activities to ensure that a wider range of opportunities are available for all persons to provide
feedback on public transit service. The CAT process has been designed to obtain a wide range of input
from the community of both users and non-users. The CAT PPP can be reviewed in its entirety on the CAT
website at www.rideCAT.com and additional details on the public involvement activities are found in the
Limited English Proficiency section of this Plan.
Through participation with the community, CAT can gather public input on a daily basis. As part of the
public involvement, the general public is provided an opportunity to comment on CAT’s services and
capital investments through the Public Transit Advisory Committee (PTAC), the MPO Committees and
MPO Board Meetings. They also are provided an additional opportunity when those same items viewed
through the MPO process are taken to the Collier County Board of County Commissioners.
CAT recognizes that in compliance with Title VI, public involvement activities must focus on low-income
and minority populations and thereby ensures access to the transportation planning process for low-
income and minority populations through its public involvement process.
As part of CAT’s public outreach process all meeting notices, press releases, and public service
announcements are translated into other languages as requested or needed based on documentation of
previous requests. CAT staff refreshes the printed materials monthly or as needed and monitors the
frequency of requests for other than English materials. In addition, whenever possible, CAT utilizes
pictographs to display information and instructions. Bus cards and printed schedules are also utilized to
convey information on CAT’s Title VI requirements.
Future service planning efforts often include the dissemination of customer demographic and opinion
surveys to collect information about who is using the service and how the service could be improved for
those persons. CAT disseminates on-board surveys in English, Spanish and Creole to ensure that non-
English speaking customers have meaningful access to provide input in the planning process. This process
also reaches out to obtain input from low-income and minority persons who may not attend a formal
public meeting.
As a result of the public outreach process implemented by CAT, portions of the Golden Gate Estates and
other low-income and minority areas in the eastern most portion of the county have been identified by
the public as areas in need of transportation options. CAT, through its upcoming Transit Development
Plan (TDP) will be defining ways to efficiently provide transportation service to these areas.
17
TITLE VI PROGRAM 2020 - 2023
Limited English Proficiency
Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency (LEP),
was signed by President Clinton in August 2000. The Executive Order directs each federal agency to
examine the services it provides and develop and implement a system by which LEP persons can
meaningfully access those services. Failure to ensure opportunities for LEP persons to effectively
participate in or benefit from federally-assisted programs may constitute national origin discrimination.
As a public transportation provider receiving federal funding from the U.S. Department of Transportation
(DOT), CAT has a responsibility, under Title VI of the Civil Rights Act of 1964, to take reasonable steps to
ensure that LEP persons have meaningful access to benefits, services, information, and other important
programs and activities provided by CAT. LEP persons include individuals who have a limited ability to
read, write, speak, or understand English. Many LEP persons rely on public transit services to achieve
greater mobility and access to employment. Creating a positive environment for LEP persons may help to
retain existing riders and attract new riders who otherwise would be excluded based on language barriers.
The DOT developed LEP guidance to assist public transit agencies in determining the best ways to comply
with the statutory and regulatory LEP obligations. Transit agencies should conduct an LEP needs
assessment based on the four-factor framework.
Four-Factor Framework
The four-factor framework includes four steps that assist transit agencies in developing a cost-effective
mix of language assistance measures. The factors that should be considered during the LEP needs
assessment include:
1. The number and proportion of LEP persons served or encountered in the eligible service
population;
2. The frequency with which LEP persons come into contact with the agency’s programs,
activities, and services;
3. The importance of the programs, activities, and services to LEP persons; and
4. The cost and resources available.
Collier Area Transit (CAT) Service Area
CAT provides approximately 800,000 Fixed Route trips each year within the Collier County area. CAT is
continually providing information to LEP residents of the community. Approximately 15% percent of the
population residing in the CAT service area who are five years of age or older speak a language other than
English. Due to the number of persons speaking a language other than English, CAT has translated the
system maps into Spanish and provides instructive information to the public on its website in Spanish and
Creole. The County website also has a device that allows viewers to translate the information on the
18
TITLE VI PROGRAM 2020 - 2023
website into Spanish, Creole, French and German. In addition, CAT provides printed information in
Spanish at all stations and public locations disseminating CAT information.
CAT has developed this LEP Plan to document the steps being taken to provide assistance for LEP persons
seeking meaningful access to CAT programs and to identify any additional LEP needs that are not being
met through the existing information dissemination processes.
The number and proportion of LEP persons within the CAT service area was assessed using the 2018
American Community Survey (ACS) 5-year estimates. The ACS data were reviewed to determine the
number of people who speak English “very well” and “less than very well” for each Census tract within
the CAT service area. Collier County Public Schools (CCPS) enrollment data were also assessed to
determine the percentage of LEP children who may encounter CAT services. In addition, community
organizations that serve LEP persons can provide input that confirms the data collected from other
sources.
The geographic boundaries of the CAT service area and the existing routes that have been modified based
on recent recommendations from the CAT staff are presented in Map 1. All Census Block Groups with an
LEP population percentage above the Collier County average (15%) are depicted in the two darkest brown
colors.
Public Participation Plan Performance Measures and Objectives
I. Goals and Objectives
• To provide updates on current and future services
• To obtain community feedback on services provided
• To educate on the benefits of public transportation
II. Performance Measures and Monitoring
To measure Customer Relation and Communications effectiveness in meeting the goals
and objectives the following performance measures will be monitored on a continual
basis:
• Average Monthly Website Visits
• Goal: 17,000
• Latest Measure: 14,782
• Evaluation: CAT is currently not meeting the measure, however with current
decreases in transit demand as a result of Covid-19 this is expected. CAT also
has begun a large social media blitz which is beginning result in an increase in
website visits.
• Community Outreach Presentations
• Goal: Average 5+ per quarter
• Latest Measure: 6.75
• Evaluation: CAT is currently meeting our established goal for presentations.
19
TITLE VI PROGRAM 2020 - 2023
• Assist in Languages other than English at Public outreaches and events.
• Goal: Assist 80% of LEP customers
• Latest Measure: 100%
• Evaluation: CAT is currently meeting our established goal for assisting LEP
customers.
• Percentage of Outreach Events and Presentation in Low-Income or Minority Census
Tracts
• Goal: 40%
• Latest Measure: 50%
• Evaluation: CAT is currently meeting this goal.
20
TITLE VI PROGRAM 2020 - 2023
Map 1: Limited English Proficiency
Table 4 presents the total population and LEP populations for all Census Block Groups within the CAT
service area. In addition, Table 4 details the number of persons in each of the four major language
categories who speak English “less than very well.” These four major language categories include Spanish,
Indo-European, Asian-Pacific Island, and all other populations.
Table 4: Percent of Limited English Proficiency Persons by Census Block Groups
Block Group
Spanish
LEP
Population
Other
Indo-
European
languages
LEP
Population
Asian and
Pacific
Island LEP
Population
Other
Languages
LEP
Population
Total LEP
Population
5 Years
and Over
LEP
Percentage
of Total
Population
120210104191 618 231 0 0 849 41.7%
120210003021 0 8 0 0 8 0.9%
120210004011 11 68 0 0 79 3.8%
21
TITLE VI PROGRAM 2020 - 2023
120210102102 175 18 0 0 193 9.2%
120210104202 851 132 0 0 983 35.3%
120210112013 290 81 32 0 403 7.9%
120210003012 0 20 0 0 20 2.3%
120210101102 138 9 39 0 186 15.8%
120210003013 0 42 31 0 73 4.4%
120210106012 582 69 0 0 651 39.9%
120210109031 1 0 110 0 111 6.0%
120210113021 419 97 0 0 516 21.5%
120210107012 126 9 0 0 135 15.6%
120210106043 254 27 0 0 281 12.8%
120210103002 215 0 0 0 215 23.4%
120210114001 368 60 0 0 428 33.2%
120210101104 13 47 0 0 60 5.3%
120210102084 0 0 0 0 0 0.0%
120210112051 337 273 0 7 617 45.9%
120210111023 0 0 0 0 0 0.0%
120210111051 69 25 0 0 94 8.6%
120210102091 0 17 10 0 27 4.0%
120210114002 403 343 9 0 755 44.0%
120210104141 100 32 0 0 132 10.9%
120210102052 17 17 0 0 34 2.9%
120210111031 0 0 0 0 0 0.0%
120210113011 117 0 0 0 117 16.3%
120210102101 25 19 0 0 44 3.1%
120210113022 304 114 0 0 418 34.0%
120210105072 19 0 0 0 19 2.1%
120210109052 0 25 0 0 25 2.4%
120210111032 425 361 0 0 786 46.1%
120210111053 38 0 0 0 38 5.0%
120210104172 225 144 54 0 423 16.7%
120210105093 0 30 0 0 30 1.0%
120210105103 0 0 0 0 0 0.0%
120210101061 0 0 0 0 0 0.0%
120210101072 0 12 0 0 12 0.5%
120210105092 0 0 0 0 0 0.0%
120210105081 428 32 102 0 562 23.8%
120210004021 0 0 0 0 0 0.0%
120210110011 0 0 0 0 0 0.0%
120210113023 720 104 0 0 824 32.7%
120210104152 636 251 63 0 950 6.6%
120210108031 69 127 0 0 196 7.4%
22
TITLE VI PROGRAM 2020 - 2023
120210101022 131 16 28 0 175 5.6%
120210111052 55 9 0 0 64 8.0%
120210102092 0 78 0 0 78 7.4%
120210104161 0 0 29 0 29 1.3%
120210101021 13 0 0 0 13 1.2%
120210112023 555 0 0 0 555 6.8%
120210104132 599 42 0 0 641 28.8%
120210114003 1454 0 0 0 1454 68.0%
120210101023 0 0 0 0 0 0.0%
120210112022 401 422 123 0 946 13.3%
120210104203 753 48 0 0 801 39.9%
120210112011 31 0 0 0 31 1.3%
120210002001 20 18 0 0 38 3.8%
120210107011 309 7 0 0 316 19.3%
120210101071 107 11 29 0 147 8.1%
120210112021 626 6 7 0 639 7.0%
120210001021 13 6 0 0 19 2.3%
120210104144 253 53 0 0 306 18.4%
120210104143 367 16 0 0 383 18.1%
120210102131 12 8 0 0 20 3.1%
120210112012 33 16 0 0 49 1.8%
120210101062 0 0 0 0 0 0.0%
120210111062 30 41 0 0 71 12.0%
120210108032 0 0 0 0 0 0.0%
120210002002 14 5 0 0 19 1.6%
120210106062 32 0 11 0 43 3.1%
120210105091 61 0 16 0 77 10.3%
120210102151 0 10 0 75 85 8.1%
120210104052 0 0 0 0 0 0.0%
120210102152 0 0 0 0 0 0.0%
120210104081 95 38 14 0 147 8.4%
120210109022 0 0 0 0 0 0.0%
120210004022 0 0 0 0 0 0.0%
120210108021 575 597 0 0 1172 19.0%
120210104121 345 9 0 0 354 9.2%
120210001022 13 0 0 0 13 2.3%
120210106022 541 54 0 0 595 28.9%
120210111022 4 0 0 0 4 0.5%
120210109054 0 0 0 0 0 0.0%
120210102081 0 0 0 0 0 0.0%
120210104151 88 27 0 0 115 6.9%
120210101053 42 0 0 0 42 2.5%
23
TITLE VI PROGRAM 2020 - 2023
120210005001 0 14 28 0 42 2.3%
120210107021 567 0 58 0 625 26.5%
120210105102 0 0 0 0 0 0.0%
120210104103 1906 17 0 0 1923 53.4%
120210105062 13 43 65 0 121 7.4%
120210104123 303 0 0 0 303 12.7%
120210113013 375 0 0 0 375 32.8%
120210101091 0 0 0 0 0 0.0%
120210101065 0 36 0 0 36 7.6%
120210109033 212 51 0 0 263 16.8%
120210104173 325 37 11 0 373 32.1%
120210105052 675 37 24 0 736 26.1%
120210104112 311 0 0 0 311 17.2%
120210105051 392 113 0 0 505 12.7%
120210111021 1003 160 12 0 1175 16.4%
120210101063 0 0 20 0 20 5.0%
120210101092 0 0 0 0 0 0.0%
120210104122 87 14 0 0 101 10.4%
120210104162 183 139 0 0 322 13.7%
120210104102 847 174 0 0 1021 42.2%
120210105082 0 0 0 0 0 0.0%
120210103003 83 55 0 0 138 12.6%
120210107022 68 109 0 4 181 15.6%
120210101093 73 22 8 0 103 8.9%
120210104053 24 0 0 0 24 1.3%
120210104051 860 25 42 0 927 21.0%
120210101103 247 0 0 9 256 23.7%
120210102111 0 39 73 0 112 11.0%
120210006001 0 0 0 0 0 0.0%
120210104131 617 35 87 12 751 14.2%
120210104181 60 28 98 113 299 8.7%
120210101052 0 11 0 0 11 0.8%
120210110021 0 58 0 0 58 2.5%
120210104113 1053 79 0 0 1132 40.4%
120210104082 3 0 19 0 22 1.6%
120210105061 14 13 0 0 27 2.1%
120210106051 74 20 0 0 94 9.6%
120210102112 19 18 0 0 37 4.8%
120210001011 6 24 0 0 30 3.1%
120210111061 171 91 0 0 262 10.1%
120210004023 0 8 0 0 8 1.5%
120210101081 101 15 0 0 116 5.8%
24
TITLE VI PROGRAM 2020 - 2023
120210103001 335 15 0 0 350 17.3%
120210106011 94 5 0 0 99 10.0%
120210101051 0 38 10 0 48 3.9%
120210104111 1404 0 0 0 1404 43.4%
120210112041 292 165 0 0 457 31.9%
120210106052 76 0 0 0 76 6.4%
120210106061 69 37 63 0 169 13.9%
120210107014 115 102 0 0 217 22.7%
120210104012 72 56 0 0 128 5.1%
120210104124 9 171 14 0 194 8.9%
120210105071 652 266 27 0 945 29.4%
120210106041 0 0 0 0 0 0.0%
120210104011 74 58 42 0 174 10.2%
120210109021 378 57 0 0 435 15.6%
120210007001 194 200 0 0 394 27.4%
120210113012 1122 236 0 0 1358 32.3%
120210101082 357 0 0 0 357 31.2%
120210104171 48 0 0 34 82 4.8%
120210105063 716 14 0 0 730 30.3%
120210108022 735 0 0 0 735 38.1%
120210102132 37 0 0 0 37 2.4%
120210102153 0 3 0 0 3 0.2%
120210104182 18 0 53 0 71 2.7%
120210102083 19 10 0 0 29 3.1%
120210109042 49 94 0 0 143 11.4%
120210003011 14 0 0 0 14 1.9%
120210102093 0 0 0 0 0 0.0%
120210112052 233 328 0 0 561 43.5%
120210101064 9 8 0 0 17 2.2%
120210109053 0 0 0 0 0 0.0%
120210104192 592 163 0 7 762 45.2%
120210112043 171 260 0 0 431 46.4%
120219900000 0 0 0 0 0 0.0%
120210104054 112 37 17 0 166 4.2%
120210109032 0 18 0 0 18 0.9%
120210106053 73 89 0 0 162 15.1%
120210109051 0 12 0 0 12 1.5%
120210102123 336 0 0 0 336 9.7%
120210110012 8 22 9 0 39 3.5%
120210104163 15 10 0 0 25 1.6%
120210108011 12 0 0 0 12 1.1%
120210107013 40 7 0 0 47 11.0%
25
TITLE VI PROGRAM 2020 - 2023
120210101101 21 0 0 8 29 4.1%
120210102082 0 20 0 0 20 2.8%
120210108033 120 100 0 0 220 20.2%
120210108013 70 69 0 0 139 9.1%
120210102122 0 0 0 0 0 0.0%
120210102051 18 9 0 0 27 2.2%
120210003022 0 0 0 0 0 0.0%
120210104101 1238 94 0 0 1332 48.1%
120210109041 16 11 0 0 27 4.8%
120210108012 4 0 0 0 4 0.5%
120210106042 0 19 0 0 19 5.5%
120210102133 11 0 0 0 11 0.6%
120210104201 672 0 0 0 672 27.0%
120210105101 0 16 0 0 16 0.8%
120210102121 32 12 0 0 44 5.2%
120210001012 0 0 0 0 0 0.0%
120210108024 628 0 0 0 628 37.4%
120210104142 303 0 41 0 344 14.5%
120210106021 7 0 0 0 7 0.6%
120210004012 0 0 0 0 0 0.0%
120210112042 1220 156 0 0 1376 65.8%
120210108023 747 167 0 0 914 35.2% Table 5 presents a summary of the total number and percentage of LEP persons for all Census Block
Groups located within the CAT service area. The LEP population accounts for approximately 15 percent
of the total population. Figure 1 illustrates the distribution of all populations within the CAT geographic
boundaries.
Table 5: Summary of Limited English Proficiency
Persons within the CAT Service Area
Total
Population 5
Years and
Over
Spanish
LEP
Population
Other Indo-
European
languages
LEP
Population
Asian and
Pacific Island
LEP
Population
Other
Languages
LEP
Population
Total LEP
Population
347,226 39,824 9,020 1,528 269 50,641
100% 11.5% 2.6% 0.4% 0.1% 14.6%
26
TITLE VI PROGRAM 2020 - 2023
Figure 1: Distribution of Limited English Proficiency Persons within the CAT Service Area
CAT Se rvi ce Area Population Dis tribution
The School District of Collier County enrollment data were assessed to determine the percentage of LEP
children who may encounter CAT services. According to the latest statistics provided by Collier County
Public Schools, English is not the first language for 16 percent of the students with more than 7,500
students enrolled in the English Language Learners (ELL) program. Collectively, these students speak 104
different heritage languages and hail from 76 different countries of origin.
More than 46% percent of the students live in non-English homes, where English is not the first language
and sometimes is not even spoken. The percentage increases to more than 56 percent in grades Pre-K
through 3, where learning to read is so critical. These students and their parents may rely on public transit
for transportation to school and other activities. The table below presents the percentage of LEP students
enrolled at the School District of Collier County. Also shown, is the distribution of diversity for the student
population.
Table 6: Percentage of Limited English Proficiency Students
within Collier County Public Schools
Total CCPS
Student
Total LEP
Student
Percentage of
LEP Students
48,000 7,680 16%
27
TITLE VI PROGRAM 2020 - 2023
Diversity of Student
Population
Hispanic 52%
White 32%
Black 11%
Mixed 2%
Asian <2%
Indian <1%
Hawaiian/Pacific Islander 0%
The information shown above is from the Collier County Public Schools Data Warehouse, updated 1/14/2020.
The number of CCPS Limited English Proficiency students very closely mirrors that of the overall
population in Collier County over the age of five.
Language Assistance Measures
The frequency with which LEP persons could or have come into contact with CAT programs, activities,
and services can be measured based on the analysis presented in the previous section. The more
frequent the contact with LEP persons, the greater the need to provide language enhanced services. The
following measures were implemented by CAT to provide assistance to LEP persons and to document and
measure the frequency of contact with LEP individuals.
Implemented Measures
CAT Website – Collier County’s website had previously included the capability to translate information on
the website into Spanish. As of October 2013, the Collier County website was enhanced to allow the text
to be translated to German, French, and Creole by clicking on the preferred language. In addition, the
website provides customers with general information about CAT, including fares and passes,
announcements, ADA and TD services, and “How to Ride.”
CAT Transfer Stations – Paper materials provided at CAT Transfer stations, including “How to Ride” guides,
fares, and schedules are available in both English and Spanish versions. CAT documents the number of
printed materials requested in languages other than English to determine the frequency of LEP persons
using the system.
In addition to schedules and route maps, rider alerts and notices posted at the stations are translated to
Spanish and placed next to the English versions in visible locations.
Printed Materials – Spanish translations of the “How to Ride” guide and other notices and information
are provided at all locations where bus passes are sold, including libraries and other public places that
post CAT information. CAT staff refreshes the printed materials monthly or as needed and monitors the
frequency of requests for other than English materials. In addition, whenever possible, CAT utilizes
pictographs to display information and instructions.
28
TITLE VI PROGRAM 2020 - 2023
Announcements – Safety and security announcements are provided in both English and Spanish. Radio
announcements, including public service messages, rider alerts, and ads promoting transit are broadcast
on both English and Spanish stations. CAT staff continues to monitor the need to provide safety and
security announcements in other languages and opportunities to provide public announcements on radio
stations of other languages.
Press and Public Relations – All meeting notices, press releases, and public service announcements are
translated into other languages as requested or needed based on documentation of previous requests.
On-board Surveys – Future service planning efforts often include the dissemination of customer
demographic and opinion surveys to collect information about who is using the service and how the
service could be improved for those persons. CAT disseminates on-board surveys in both English and
Spanish to ensure that Spanish-speaking customers have meaningful access to provide input in the
planning process. During the early part of the 2020 Major Transit Development Plan, a total of 1,091 on-
board surveys were distributed in English, Spanish and Creole. A total of 1,091 completed surveys were
analyzed.
CAT also completes periodic surveys to explore the need for providing surveys in languages other than
English and Spanish. CAT staff is made available to assist with completing surveys and taking public
comment.
Planning Meetings – According to the Collier MPO LEP Plan, the MPO advertises the availability of Spanish
interpreter services, free of charge, at least seven (7) days prior to MPO Board and Committee meetings,
workshops, forums, or events that will be noticed on the MPO website, in meeting notices (packets), and
using the following additional tools as appropriate:
• Signage
• Public outreach materials
• Community-based organizations
• Local newspapers
• Collier County Library System
CAT representatives are members of many of the MPO Committees, including the Technical Advisory
Committee, the Congestion Management System/ Intelligent Transportation Systems (CMS/ITS), the Local
Coordinating Board, and the Pathways Advisory Committee. Therefore, Spanish interpreter services are
available at many of the meetings where CAT staff may participate in the transportation planning process.
Customer Service – CAT drivers complete the driver training program as new employees and participate
in refresher training courses annually. As part of the training, drivers are reminded of the importance of
conveying information to passengers, particularly assisting passengers with using the transit system,
especially those with language or other barriers. CAT also makes every effort to ensure that its customer
service telephone lines are staffed with persons who speak other languages. All CAT personnel complete
customer service training with periodic refreshers to underscore the importance of providing assistance
to persons with language and other barriers.
29
TITLE VI PROGRAM 2020 - 2023
Community Outreach – CAT makes available persons who can serve as translators at all community
outreach meetings. CAT strives to ensure the competency of interpreters and translation services per the
DOT LEP guidance.
Social Media – CAT uses various social media feeds (Facebook, YouTube, and Instagram) to make
announcements regarding service delays, service proposals, upcoming events, and public outreach
activities.
Cell Phone App – CAT is currently, with the help of Masabi in the process of developing a mobile ticketing
application for cellular devices. This is not only a much easier and more convenient way to pay for
passenger as other methods of payments will be accepted compared to the old cash only system, but it is
yet another source of system information and notifications. The app will be translated into multiple
prominent languages allowing for the greatest passenger inclusion.
Electronic Signage – CAT uses electronic signs at both transfer locations to provide service and public
information in multiple languages.
Additional Language Assistance
CAT recognizes that based on the LEP population shown as part of the Census and CCPS analysis, special
effort is necessary to communicate important transit information to some of its riders in languages other
than English. In order to meet this need, CAT will continue to conduct the activities listed previously and
enhance its LEP outreach by taking the additional steps listed below.
Community Outreach – Community organizations that serve LEP persons within the CAT service area
Census tracts where the LEP populations are greater than the county average have the ability to confirm
the statistical analysis completed using the Census data. During various transit planning processes,
community organizations will be asked to provide information pertaining to the population(s) that they
serve. The questions will focus on the number of people served, the languages spoken, age, gender,
education levels, expectations for public services, public transportation inquiries, most frequently
traveled destinations, locations that are difficult to access, transit needs, and travel patterns. The key
concerns mentioned by the community organizations will be reviewed by CAT in an effort to improve the
provision of service to LEP persons. A listing of community agencies in Collier County is presented in
Appendix F.
CAT will also present outreach materials to schools in an effort to provide transit service information to
LEP students and their parents who may rely on public transportation to access school and other activities.
Staff Training and Development – CAT will continue to train staff on the importance of assisting LEP
persons with obtaining information and accessing the transit system. Staff will be provided with LEP
policies and procedures. In addition, all CAT staff will complete customer service training and be provided
guidance on working effectively with in-person and telephone interpreters.
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TITLE VI PROGRAM 2020 - 2023
Signage – CAT will continue to post signs to communicate language services available at initial customer
contact points. As additional resources permit, CAT will enhance the availability of outreach documents,
brochures, booklets, and recruitment materials in multiple languages.
Planning – CAT will participate in annual updates to the County’s evacuation and disaster preparedness
plans to ensure that the plans include the needs of all community members and especially those in
minority populations.
LEP Resources
Based on the current resources available, CAT is providing the most cost-effective means of delivering
competent and accurate language services within its service area. CAT will continue to monitor the need
for additional language assistance, including the need for greater dissemination of information in the
existing languages provided and/or translation to new languages. If additional services are needed, CAT
will determine which additional language assistance measures are cost-effective and feasible for
implementation based on the current and projected financial resources.
CAT will continue to monitor the costs associated with the existing language assistance measures and the
costs associated with implementing enhanced language assistance measures, including an estimate of the
number of staff and the percentage of staff time necessary to provide the current and proposed LEP
resources.
Project Level Public Involvement and Outreach Activities Since Last Title VI Plan
Submission
Transit Development Plan (TDP)
CAT, as part of the process for planning services and determining its capital program, develops a Transit
Development Plan (TDP). The TDP is a requirement of the FDOT. Statute requires Florida transit agencies
to complete a major update every five years and in the interim years provide annual progress reports on
any changes and accomplishments in implementing the Plan. The TDP is a requirement to receive block
grant operating assistance from the FDOT. Since the last Title VI update CAT completed its Major TDP
Update in September 2015 for fiscal years 2016-2025 with annual updates in 2016 through 2019. CAT is
currently completing the 2020 Major TDP for fiscal years 2020-2030. A simple, yet key ingredient, of any
good public outreach effort is the effectiveness of listening and how that information is incorporated into
the study process. The most effective plans include activities and methods oriented specifically to the
project study area and an understanding of the local and regional character. Collier Metropolitan Planning
Organization (MPO), Collier Area Transit (CAT), and the Consultant Team recognize the importance of
public engagement and have developed strategies to engage the public, stakeholders and agencies
involved in the development of the Transit Development Plan (TDP). The Public Participation Plan (PPP)
for this project includes proven outreach efforts that go beyond “the minimum requirements”. The team
has identified a menu of opportunities to provide the public information, listen to their concerns and
suggestions, and find ways to incorporate solutions into the TDP.
Public participation activities have been designed to encourage participation throughout the entire TDP
process. Our Team has identified methods of communication that best serve the needs of Collier County,
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TITLE VI PROGRAM 2020 - 2023
but are flexible enough to make changes, if necessary, to ensure maximum feedback. Our goal is to reach
and hear from as many people and organizations as possible to ensure that their voices are heard. The
2020 – 2030 TDP Major Update public involvement activities will include the following:
• Public Workshops - Two public workshops will be held at key milestones in the study process,
first early in the process, to educate attendees about the TDP effort and collect input on gaps
and unmet needs. The second public workshop will focus on obtaining feedback on the
proposed improvements.
The meeting will be planned and scheduled to maximize opportunities for citizen participation by
selecting venues in areas that have bus access and we will piggyback these workshops with other
community events to ensure a good turnout. The meeting will be held at times to best
accommodate a variety of work and personal schedules. There will be a comment period open for
one week before and one week after each public meeting (7 days) where the public can submit
comments, questions, and concerns via email, phone call, social media, and written letters
without being required to attend the public workshops.
• On-Board Passenger Survey - A passenger survey has been conducted of the fixed-route patrons
on-board CAT vehicles to obtain information related to the demographics, attitudes, preferences,
and habits of current riders as part of the current Major Transit Development Plan research. To
allow for enough valid survey responses to support statistical rigor of the results, the survey effort
covered 100% of CAT’s scheduled fixed-route bus routes. The surveys too were conducted by
individuals riding the buses. The survey efforts resulted in 1,091 responses.
• Online Survey - The Team will conduct a regional online survey of the general public in Lee and
Collier Counties to help better understand their needs and concerns and, especially, persons who
do not currently use the CAT services. The online survey will be posted on the County website
and distributed via any current email/social media outlets and mailing lists available to Collier and
Lee Counties, including opportunities to use relevant social media platforms.
• Stakeholders Interviews - To assess the attitudes of key local officials and community leaders
regarding the transit system, a series of stakeholder interviews were conducted during the TDP
development process. The interview purpose was to assess political and community leaders’
views on transit’s current and future role in the community, transit funding, and other issues
relevant to mobility needs and the transit services. Stakeholder interviews were conducted with
representatives from the Collier County Board of County Commissioners, City Council members
from the municipalities with the County, City and County Managers, and representatives from the
Greater Naples and Immokalee Chambers of Commerce.
• Discussion Group Workshops – Two Discussion Group meetings were held on March 31st, 2020.
The sessions were conducted virtually, due to the Coronavirus restrictions and were structured in
smaller groups (10-12 persons) to permit more in-depth and candid discussion about issues and
needs. The focus will be on mobility needs and interests of the business community, tourists and
tourism, health care access, community services, social services, Department of Labor, seniors,
and students.
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TITLE VI PROGRAM 2020 - 2023
• Ongoing Social Media - In conjunction with the method of notices described above, leveraging
the use of social media is cost-effective and can reach a large segment of population who are
younger, trendy, and more prone to becoming involved in an issue that affects their community.
Both social media and the County and MPO websites will be used appropriately to raise awareness
about the project and to provide opportunities for the public to comment and used as a means to
provide information and notice of the public meetings and community workshops.
• Collier MPO and Committees - The TDP methodologies and document are taken to the MPO for
feedback and approval. All MPO Board and Committee meetings are open to the public.
• Collier County Board of County Commissioners - Prior to submittal to the FDOT, the CAT governing
board must adopt the TDP. The meeting for adoption of the TDP is a regular County Commission
meeting noticed in accordance with the Florida Sunshine Law and open to the general public.
CAT recognizes that its operators have the majority of contact with customers who provide them with
input on the system; therefore, during the update to the TDP, CAT also gathered public input through
operators. Bus operators are a valuable source of information as they reflect the eyes and ears on the
road for CAT’s daily operation. Operator insight into public opinion and need can also supplement
information that cannot be collected through other means. Information can include safety and security
issues, an understanding of travel characteristics on specific routes, and representation of needs for those
who may not be willing to participate in other public outreach activities.
The first year of the TDP financial plan is used as the agency’s POP (Program of Projects). The POP is also
provided to the Collier MPO for use in the development of the Transportation Improvement Plan (TIP).
Through the Collier MPO’s TIP process, the POP is available for additional public comment. CAT publishes
the POP, annually at the time of grant application.
Fare Study
In 2018 CAT conducted a fare analysis to evaluate the fare structure for the bus system and determine
whether a fare change would be warranted. The study met the FTA Title VI requirement.
Public Outreach
As part of this fare study, a rider intercept survey and public workshops were conducted to gather input
on potential fare changes from both fixed-route and paratransit riders.
• Rider Intercept Surveys - CAT staff conducted an intercept survey via tablet of 80 riders at the CAT
Transfer Center on January 18–19, 2018.
• Public Workshops - Two public workshops were held on January 30, 2018, to solicit feedback from
the public on potential fare changes for CAT’s fixed-route and paratransit services. The workshops
were noticed on CAT buses in English, Spanish, and Creole.
The first workshop was held at the CAT Transfer Center in Naples from 10:00 AM–2:00 PM, and
the second was held at CareerSource Southwest Florida in Immokalee from 4:00–7:00 PM.
Workshop participants were asked to complete an exercise sheet to provide feedback on
potential fixed-route and paratransit fare change scenarios.
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TITLE VI PROGRAM 2020 - 2023
Fare Increases and Service Changes
Fare Increases
The Collier County Board of County Commissioners, in its efforts to ensure Title VI Compliance, established
local guidelines for service changes and fare increases as part of the Transit Development Plan. Major
service changes require a public hearing announcement in a newspaper of general circulation (the Naples
Daily News) and Board of County Commissioners approval. Determination as to whether or not a
modification constitutes a major change is determined on a case-by-case basis, with the exception of total
elimination of a specific route service which is automatically considered a major service reduction. The
CAT Route Fare or Service Change Policy is provided in Appendix C of this plan.
In accordance with FTA Circular 4702.1B, minority and low-income populations will be examined to
determine whether any disproportionate impacts would occur with a potential fare change. In addition,
if a disproportionate impact is identified, justification on how an alternate action would result in an even
greater impact to these populations or actions to mitigate the potential impacts will be identified.
Service Changes
CAT completes minor service changes on a regular basis related to running time adjustments to improve
the efficiency and effectiveness of service. Ridership and stop-level automatic passenger counter (APC)
data along with supervisor and operator input are utilized when making these minor service changes.
Prior to a service change, CAT posts notices on-board its vehicles to notify customers of the impending
change. Customers are always able to comment on services and proposed changes using the CAT
customer service or by through the County website by clicking on the link “Contact Us” and send their
comments by email to rideCAT@colliercountyfl.gov All comments are tracked and responded to, if
warranted.
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TITLE VI PROGRAM 2020 - 2023
Table 7: Service Changes Since the Last Title VI Update (July 2017 –March 2020)
Route Type of Change
FY2017 -2020
Route
11
In April 2018, three (3) loops were added to the peak hours of the route to increase
frequency to encourage ridership and access to employment/shopping opportunities.
Route
12
In April 2018, one (1) loop was added within the identified peak hours of the route.
Route
22
In November of 2017, Routes 22 was modified to serve the southeastern portion of the
Immokalee community, connecting with Route 23 at the State Health Department Facility.
Due to the split of a singular circulation pattern, a decline in ridership was initially noted
and this past year has slightly rebound. This move to increase the serviceable area. Further
education is necessary to the public within the area to provide information about the
newly created routes to increase the usage of the route.
Route
23
In November of 2017, Routes 22 was modified to serve the southeastern portion of the
Immokalee community, connecting with Route 23 at the State Health Department Facility.
Due to the split of a singular circulation pattern, a decline in ridership was initially noted
and this past year has slightly rebound. This move to increase the serviceable area. Further
education is necessary to the public within the area to provide information about the
newly created routes to increase the usage of the route.
Route
24
In March of 2020, the stop at San Marco Road was removed and three stops on Six L’s
Farm Rd was added increasing coverage in a transit dependent area of migrant farm
workers. A Route alignment was adjusted to service Regal Acres. The change was
incorporated as a result of a request made by the community. Staff conducted a survey
within the community to evaluate the potential use of the service prior to the route
alignment. Although a decline in the ridership was noted, the overall percentage of
ridership loss was reduced with only a 7% decline in 2018 as compared to 10% in 2017 and
15% in 2016.
Route
26
In April 2018, an unproductive loop was eliminated from the route. With the modifications
made, the route continues to experience ridership decline.
Route
29
The beach bus service was added into service in FY17 to increase access to Delnor Wiggins
State Park. The original service in FY17 was a singular route with two buses. The second
year was two different routes and two buses, and the third year, due to financial
constraints routes were reduced as well as the number buses. The third year the service
only utilized a single bus on a single route. All route modification implemented each year
was done to accommodate the public and their mobility needs which resulted in ridership
dramatically increased each year.
Major service changes, which represent modification to a route or a route’s ridership without elimination
of the route, are reviewed through CAT’s internal meeting process, where managers, the Division Director
review the impact of the potential route modifications. These types of service changes occur when a route
is deemed to be a consistent low performer with regard to ridership, farebox recovery, and latent demand
from the service area of the route (evaluated using APC data) or when the agency’s budget has been cut
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TITLE VI PROGRAM 2020 - 2023
requiring service reductions. For these route changes, the public has an opportunity to comment
consistent with the adopted CAT PPP.
Service elimination is the final type of service change that might have an adverse impact to Title VI
populations. Extensive analysis and public input is required for the elimination of a route. To ensure
compliance with Title VI requirements, public meetings are to be conducted in locations that are
convenient and accessible for minority and LEP communities. Coordination with community- and faith-
based organizations, educational institutions, and other organizations to implement public engagement
strategies that reach out specifically to members of affected minority and/or LEP communities. Multiple
means of communication will be offered to the public and notices of such communication efforts will be
consistent with the adopted CAT PPP.
Service increases may be implemented with approval of the Division Director with final decision to
implement any major service changes (as defined Appendix D of this report) made by the Collier County
Board of County Commissioners.
Membership of Non-Elected Committees
CAT utilizes an appointed Public Transit Advisory Committee (PTAC) as well as the Collier MPO and its
committees to assist in decision-making. The MPO has a Technical Advisory Committee (TAC), a Citizen’s
Advisory Committee (CAC) and the Local Coordinating Board (LCB) who are consulted for transit decisions.
The racial composition of the committees is provided below in Table 7.
Minority Representation on Decision-Making Bodies
CAT will continue to utilize the Collier Public Transit Advisory Committee (PTAC) and if applicable,
supplement with the Collier MPO process for decision-making and will encourage diversity on these
committees. Efforts to encourage the participation of minorities on the committee include outreach to
social service agencies and existing member promotion of vacancies to the general public including
minorities and posting public notices through the County’s Communication Division.
Table 8: Racial Composition of Bodies that Provide Input to Decision-Making Bodies
PTAC Racial Composition TAC Racial Composition CAC Racial Composition LCB Racial Composition
White Male - 5 White Male - 8 White Male - 8 White Male - 4
White Female - 1 White Female - 5 White Female - 4 White Female - 9
Black Male - 0 Black Male - 0 Black Male - 1 Black Male - 0
Black Female - 0 Black Female - 1 Black Female - 0 Black Female - 1
Hispanic Male - 0 Hispanic Male - 0 Hispanic Male - 1 Hispanic Male -
Hispanic Female - 0 Hispanic Female - 0 Hispanic Female - 0 Hispanic Female - 0
Other Male - 0 Other Male - 0 Other Male - 0 Other Male - 0
Other Female - 0 Other Female - 0 Other Female - 0 Other Female - 0
Vacancy - 1 Vacancy - 0 Vacancy - 0 Vacancy - 2
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TITLE VI PROGRAM 2020 - 2023
Description of the Agency’s Criteria for Selecting Transit Providers to Participate in any FTA Grant
Program
The Collier County Public Transit & Neighborhood Enhancement (PTNE) Division is responsible for planning,
operating, and managing CAT public transportation services through a contract operator. CAT utilized the
Collier County procurement process to ensure that the procurement process is fair and open to all
providers. CAT transit services have always been contracted since its inception in 2001 and have not
affected the level of service for the system. If any changes in the contracted provision of service results
in a change to the level of service provided, an analysis of such change on Title VI populations will be
conducted and submitted to FTA as an addendum to this plan. If any adverse impact is found through the
analysis, appropriate and swift action will be taken to remedy or mitigate the impact. In addition, the CAT
Disadvantaged Business Enterprise Program is incorporated into the procurement to allow disadvantaged
businesses an opportunity to provide service. There have been no Transit providers that receives grant
funding through CAT however in the event that occurs CAT requires Transit providers to complete CAT’s
customer service and ADA training course and agree to the same FTA Certifications and Assurances as
CAT. Having the Certifications and Assurances as well as the sub-recipient monitoring allows CAT to ensure
that contract transit providers are delivering service in an equitable and non-discriminatory manner. Final
approval of any selected transit provider is completed by the Collier County Board of County
Commissioners at County Commission meetings, which are advertised and open to the public.
Process for Ensuring that all Sub-recipients are Complying with the General Reporting Requirements of
this Circular
As previously stated, CAT will complete sub-recipient training and monitoring to ensure that sub-
recipients are complying with all Certifications and Assurances, including those regarding
nondiscrimination.
The monitoring would be randomly scheduled for all sub-recipients to ensure compliance.
A Description of the Procedures the Agency uses to Pass-through FTA Financial Assistance in a Non-
Discriminatory Manner
The following procedure has been established to be utilized when FTA funds are pass-through to sub-
recipients. CAT utilizes an independent selection committee comprised of various racial backgrounds to
assist in the decision making regarding FTA financial assistance. CAT will confirm that the agency is valid
to operate in the state and is registered with the Central Contractor Registration (CCR). Applications for
assistance from CAT are then provided to the independent selection committee for review and comment.
The selection committee is provided a form for rating contractors and guidance on each rating category.
The selection committee is not allowed to discuss the applications until the advertised selection
committee meeting, which is open to the public. For all uses of FTA financial assistance the Collier County
procurement process and federal purchasing guidelines are utilized. Whenever, there is a conflict
between the Collier County Procurement Policy and the Federal Procurement Guidelines and FTA funding
is being utilized the Federal Procurement Guidelines are utilized throughout the purchasing process.
Collier County provides vendor of all procurement opportunities to allow open and non-discriminatory
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TITLE VI PROGRAM 2020 - 2023
access on its website. The full procurement policies for Collier County can be found on their website at:
http://www.colliergov.net/index.aspx?page=762
Title VI Equity Analysis for New Facility Construction
Construction Projects
CAT Operations and Transfer Station – 8300 Radio Road
In 2017, the CAT Operations and Maintenance Facility was severely damaged by hurricane Irma. Although
Irma was a strong hurricane, a majority of the damage could be directly related to the age and material
integrity of the facility. As a result of the damage and the continual aging of the structure, CAT along with
other responsible County staff believe that it is time to upgrade to ensure that the facility will remain
operational for the foreseeable future. For the facility upgrades to take place CAT has to secure grant
funds to help facilitate this need. CAT staff is currently pursuing the needed funds by applying for a grant.
The upgraded facility will ensure an efficient and effective transit service to meet the needs of passengers.
In addition to construction projects, CAT staff is amending the current conditional use (CU) on the 8300
Radio Road Facility which currently limits the total number of allowable routes to converge at this location.
The amendment is to eliminate the limit on the number of allowable routes. The elimination of the cap
will open the CAT system up to connect with regional bus companies, allowing greater regional access for
transit dependent populations.
Figure 2: CAT Operations and Maintenance Facility
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TITLE VI PROGRAM 2020 - 2023
CAT Intermodal Transfer Facility
Collier County is planning to construct a transfer facility in the Immokalee Community on a vacant parcel
owned by Collier County. The proposed project site is a grassed field adjacent to a green wooded area
with an asphalt/concrete driveway providing vehicular access to the Health Department and a
maintenance shed. The property is approximately 1.7 acres in size and is zoned Residential Single Family-
3 with a conditional use providing for governmental facilities. The facility does not meet the requirement
for an equity analysis because it will not require land acquisition and the displacement of persons from
their residences and businesses.
The bus transfer station will include passenger and transit efficiency enhancements including new bays
for the buses to pull off the street; canopy cover for the sheltered transfer of passengers; waiting platform
with benches and trash receptacles; vending machines for food and possible fare media; restroom
facilities for drivers; cover for passengers; and ADA improvements. Figure 3 below depicts the site plan
for the proposed improvements. Currently passengers transferring at this location are using a shelter that
is located in the parking lot shared by visitors to the Health Department, County Library and the David
Lawrence Center.
Figure 3: Recent Conceptual Site Plan of the Immokalee Transfer Facility
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TITLE VI PROGRAM 2020 - 2023
Title VI Plan Approval
The Title VI Program Update has been approved by the Transit Manager who is responsible for ensuring
that CAT policies are developed and followed accordingly. The Transit Manager has been granted the
authority by the governing body, to sign any and all assurances, certifications and other documents that
may be required in connection with the Title VI Program. The Transit Manager is also granted authority
to make necessary modifications to the Title VI Program to ensure compliance with 49 C.F.R., part 53. The
resolution granting such authority is provided in Appendix H of this document.
Requirements of Transit Providers
Chapter IV of FTA Circular 4702.1B provides program specific guidance for recipients that provide public
transportation that that operate fixed route and demand response service. Additionally, the circular
provides specific requirements for transit providers that operate 50 or more fixed-route vehicles in peak
service and are located in a geographic area with a population of 200,000 or greater. CAT meets the
requirements for a transit provider that operates with fewer than 50 fixed route vehicles, therefore only
the system-wide standards and policies are required.
System-wide Service Standards and Policies
Service standards and policies have been set for each mode of service operated by CAT, including local
fixed-route bus, express bus service (service between Immokalee and Marco Island), Beach Bus service
(service along Bluebill Avenue for the Vanderbilt Beach area), and CAT Connect paratransit demand
response service. Quantitative standards for vehicle loads, vehicle headways, on-time performance, and
service availability are listed below. These standards are the desired targets for CAT and any deviation
from the standard will be reviewed in accordance with the monitoring program to ensure adequate and
equitable system performance.
Vehicle Load
Vehicle load is defined as the ratio of passengers to the total number of seats on a vehicle with a standard
established for peak and off-peak times.
Routes which are experiencing capacity issues for three consecutive trips, at least two days per week may
be candidates for increased frequency or a larger vehicle with additional seating capacity.
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TITLE VI PROGRAM 2020 - 2023
Table 9: Vehicle Load Standards
Vehicle
Type/Service
Seating
Capacity
Standing
Capacity
Maximum
Vehicle
Load –
Off-Peak
Maximum
Vehicle
Load –
Peak
Maximum
Load
Factor –
Off-Peak
Maximum
Load
Factor -
Peak
Low-Floor
40’ Bus
(Fixed-
Route)
38 41 79 79 2.08 2.08
Low-Floor
40’ Bus
(Express-
Route)
38 41 79 79 2.08 2.08
Low Floor
35’ Bus
(Fixed-
Route and
Trolley)
31 44 75 75 2.38 2.38
Low Floor
30’ Bus
26 17 43 43 1.61 1.61
Low Floor
24’ Bus
(Paratransit)
12 0 12 12 1.00 1.00
Low Floor
23’ Bus
(Paratransit)
12 0 12 14 1.00 1.00
Vehicle Headways
Vehicle headway is the amount of time between two vehicles traveling in the same direction on a given
line or combination of lines. A shorter headway corresponds to more frequent service. Vehicle headways
are measured in minutes (e.g., every 15 minutes); service frequency is measured in vehicles per hour (e.g.,
4 buses per hour). Headways and frequency of service are general indications of the level of service
provided along a route. Vehicle headway is one component of the amount of travel time expended by a
passenger to reach his/her destination.
Local bus service should be scheduled with headways of not more than 60 minutes during the peak
periods and 90 minutes during off-peak. The current CAT service span is shown in Table 9 below.
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TITLE VI PROGRAM 2020 - 2023
Table 10: CAT Service Levels by Routes
Route Route
Description/Geo
graphic Location
Monday - Saturday Sunday
Service Span Frequency Service Span Frequency
Route 11 US 41 to Creekside
Park of Commerce
6:00 AM-8:52 PM 90 minutes 7:30 AM-5:56 PM 90 minutes
Route 12 Airport Rd. to
Creekside Park of
Commerce
6:05 AM-7:20 PM 90 minutes 7:30 AM-5:50 PM 90 minutes
Route 13 NCH & Coastland
Mall
6:05 AM-7:50 PM 60 minutes 7:05 AM-5:50 PM 60 minutes
Route 14 Bayshore Dr. &
Coastland Mall
6:35 AM-6:25 PM 60 minutes No service N/A
Route 15 Golden Gate City via
Santa Barbara Blvd.
5:35 AM-8:28 PM 90 minutes 6:58 AM-5:28 PM 90 minutes
Route 16 Golden Gate City via
Golden Gate Pkwy
4:35 AM-5:58 PM 90 minutes No service N/A
Route 17 Rattlesnake &
Florida
Southwestern
College
6:00 AM-7:22 PM 90 minutes 7:30 AM-5:52 PM 90 minutes
Route 18 US 41 & Naples
Manor
6:30 AM-6:20 PM 90 minutes No service N/A
Route 19 Golden Gate Estates
to Immokalee City
4:45 AM-8:27 PM 60 minutes 7:50 AM-9:25 AM 1 run
Route 20 Pine Ridge Road to
Goodlette-Frank Rd.
6:00 AM-6:00 PM 90 minutes 7:30 AM-6:00 PM 90+ minutes
Route 21 Marco Circulator* 7:40 AM-4:50 PM 90 minutes 7:40 AM-4:50 PM 90 minutes
Route 22 Immokalee
Circulator*
5:45 AM-8:52 PM 90 minutes 9:00 AM-5:52 PM 120 minutes
Route 23 Immokalee
Circulator*
7:00 AM-7:50 PM 90 minutes 8:00 AM- 6:50 PM 120 minutes
Route 24 US 41 East to
Charlee Estates
6:45 AM-6:47 PM 90 minutes 8:45 AM-4:42 PM 90 minutes
Route 25 Golden Gate Pkwy &
Goodlette-Frank Rd.
6:00 AM-6:00 PM 90 minutes 12:05 AM-4:29 PM 180 minutes
Route 26 Pine Ridge Rd. to
Clam Pass Beach
9:05 AM-4:23 PM 90 minutes 9:05 AM-4:23 PM 90 minutes
Route 27 CR 951 & Immokalee
Rd to Creekside POC
6:00 AM-7:50 PM 90 minutes 7:30 AM-6:22 PM 90 minutes
Route 28 Golden Gate Estates
to Immokalee City
via Everglades Blvd.
3:35 AM-7:35 PM 3 runs 5:05 PM-7:51 PM 90+minutes (1 run)
Seasonal Route(s)
Route 29 Bluebill Avenue
Beach Bus 9:00 AM-3:00 PM 60 minutes 9:00 AM-3:00 PM 60 minutes
Express Route(s)
Route 121 Immokalee to Marco
Island (Express)
5:30 AM-6:48 PM 2 runs 5:30 AM-6:48 PM 2 runs
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TITLE VI PROGRAM 2020 - 2023
On-Time Performance
On-time performance is a measure of runs completed as scheduled. Fixed Route trips are measured by
both its early departure and late arrival. Paratransit On- time Performance is defined as the percent of
trip late as defined by the trip timing preference. Certain trips provided on the paratransit demand
response service also are evaluated based on the early arrival time (work and medical trips cannot be
dropped off earlier than 30-minutes of the scheduled time).
The on-time performance standard for all bus modes operated by CAT is measured by the arrival time not
exceeding 5 minutes later that the schedule time. The goal for CAT is to achieve 95 percent on-time
performance for all bus transit. Routes performing with an on-time performance of less than 85 percent,
which is not the direct impact of weather, traffic incidents, detours, and/or events over a consistent period
of two or more weeks, will be reviewed to determine if schedule modifications are necessary to meet the
on-time performance standard. The paratransit mode on-time performance goal is 95 percent.
Passengers are offered “negotiated times” or options of pick up times based on vehicle availability, the
distance of the trip, and passengers requested pick-up or drop-off time. These scheduling windows are
dependent on the trip length of the pick-up and drop-off points. Trips lengths that are less than 9 miles
will have a 60-minute scheduling window. Trips lengths that are between 9 miles to 18 miles will have a
75-minute scheduling window and trip lengths of over 18 miles will have a scheduling window of up to
120-minutes. Once the passenger accepts one of the “negotiated times” this will serve as an estimated
arrival time with a 30-minute window. Medical appointments and employment must follow the “30
minutes early to zero minutes late” policy. Table 10 provides the quantitative on-time performance
standards.
Table 11: On-Time Performance
Mode On-Time
Performance
Measure
(Percent)
On-Time
Performance
Measure
(Time)
Local Bus 95 % Up to 5
minutes late
Express
Bus
95% Up to 5
minutes late
Trolley Bus 95% Up to 5
minutes late
Paratransit
Bus
90% 0 minutes
late
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TITLE VI PROGRAM 2020 - 2023
Service Availability
Service availability is a general measure of the distribution of routes within a service area. The basis
of providing public transportation is to ensure access to those who need the service and attract choice
riders. In an effort to reach the maximum number of users, within the available budget, CAT provides
service from 3:45 a.m. to 8:52 p.m., Monday through Saturday and 5:30 a.m. until 7:51 p.m. on Sundays.
CAT determines service availability based on financial resources, public input, performance of existing
routes, transit orientation index (population and employment density, income, age, and zero-car
households), safety guidelines, and development patterns. CAT minority routes are shown in Table 11
and are those routes that have at least 1/3 of their revenue miles in a minority census block group. CAT
service is available as shown in Table 9. Routes are concentrated in the urban area to allow the highest
level of access to community resources, with additional routes providing linkages to suburban and rural
areas.
Paratransit service for ADA customers is provided within ¾-mile of a fixed-route bus line. The current
service including the ¾-mile ADA paratransit service buffer is displayed in Map 2.
Table 12: CAT Minority Routes
Route Total Route
Miles
(Round
Trip)
Total Route
Miles (one-
Way)
Route Miles
within Minority
Block Group
(Round Trip)
Route Miles
within Minority
Block Group
(One-Way)
Percent Route
within Minority
Block Group
11 25.0 12.5 6.8 3.4 27.2
12 24.6 12.3 9 4.5 36.6
13 26.8 13.4 18.4 9.2 68.7
14 27.0 13.5 16.8 8.4 62.2
15 48.6 24.3 36.8 18.4 75.7
16 48.6 24.3 29.8 14.9 61.3
17 43.0 21.5 30.8 15.4 71.6
18 42.4 21.2 30.4 15.2 71.7
19 168.2 84.1 61.4 30.7 36.5
20 24.2 12.1 7.2 3.6 29.8
21 56.0 28 13.6 6.8 24.3
22 42.6 21.3 42.6 21.3 100
23 42.4 21.2 42.4 21.2 100
24 24.0 12 17.6 8.8 73.3
25 28.6 14.3 10.2 5.1 35.6
26 23.4 11.7 7.2 3.6 30.8
27 61.6 30.8 27.4 13.7 44.4
28 169.0 84.5 58.2 29.1 34.4
121 A 138.6 69.3 57.8 28.9 41.7
121 B 129.4 64.7 51.8 25.9 40.0
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All of CAT routes serve a minority census block group, while approximately 45 percent of the service
provided has the majority (50 percent or more) of the service within minority census block groups.
Based on the urbanized area characteristics service could be extended to major commercial/ employment
uses based on overall square footage and/or number of employees/patrons, including the following
thresholds.
• Individual businesses of 200 or more employees
• Shopping centers of more than 1,000 square feet of leased retail space
• Medical facilities with more than 100 beds
• Academic institutions with an enrollment of 1,000 full time students
• Government agencies that attract substantial daily patrons
The bus stop spacing standards for the network will be implemented based on population density along
the route and based on roadway speed as listed below.
• An average of 4 bus stops per mile where roadway speeds are 35 miles per hour or lower.
• An average of 2 bus stops per mile where roadway speeds are 45 miles per hour or higher.
The roadway speed impacts customer safety when accessing stops and also the safety of vehicles when
the bus is entering and exiting the travel lane to pick up and drop off customers. Stops will also be placed
closest to signalized intersections, as appropriate on higher speed roadways.
Service policies
Transit Amenities for Each Mode
CAT currently provides fixed-route service throughout the urban area, one express route, and paratransit
service. Paratransit service does not provide shelter and stop amenities since it is a door-to-door
reservation based service and stops may be made throughout the ADA and Transportation Disadvantages
(TD) paratransit service area. The bus service stops and shelters are provided throughout the service area
to give the greatest level of access to the majority of system users. CAT currently has 591 bus stops
throughout their service area. Shelter placement is largely based on funding available, accessible land,
and passenger boardings and alightings. CAT provides amenities related to service along each route based
on the following:
• Fixed-route bus stops are provided based on the number of passengers boarding and alighting at
stops; availability of right of way, and provision of ADA access. Stops are placed approximately
every two blocks on lower speed roadways and in more population dense areas and every ¼-mile
along higher speed roadways. Shelters are placed at locations in the same manner as bus stops,
but geared toward stops with higher patronage as identified through the use of automatic
passenger counter (APC) data.
• Express bus stops and shelters are located at the origin, midpoint, and destination of the express
bus route.
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Map 2 identifies the current bus stop locations for CAT bus and express bus, along with the locations of
the CAT transfer centers.
Vehicle Assignment for Each Mode
Vehicles are randomly assigned on a daily basis. The only caveat to random vehicle assignment is a
determination based on vehicle size to ensure that the vehicles can handle the passenger capacity and
navigate the operating environment. Within the size category vehicles still receive random assignment.
Map 2: Bus Stop Amenities Locations for Low Income and Minority Population Areas
Other Areas of Title VI Considerations
Transit Security
CAT makes every effort to ensure that its vehicles and facilities are safe for the general public and staff.
As a division of Collier County, CAT works with the Collier County’s Security Personnel on campaigns and
efforts that increase the safety and security of the transit system. Other transit security efforts completed
by CAT include regular training sessions with the Collier County Emergency Management Staff in
coordination with local Fire and Law Enforcement Departments on Tabletop sessions, and the installation
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of cameras on buses. CAT also maintains a preventative maintenance schedule in accordance with FTA
guidelines to ensure the safe performance of vehicles. Newly installed shelters contain solar lighting and
CAT is in the process of retrofitting shelters with lighting to enhance security at bus stops.
Assessment of Compliance
Monitoring
As stated earlier in this Plan, CAT conducts several efforts to monitor the quality of the service it provides.
Regular monitoring efforts including service review and amenities placement, are conducted by CAT.
Quarterly monitoring efforts to review service for Title VI compliance include, but are not limited to,
various planning studies such as the TDP and COA. As part of the monitoring activities, CAT also reviews
travel patterns and journey to work characteristics of the County population. CAT utilizes staff input and
public feedback to monitor performance as well as conduct a review of statistical data reported to the
National Transit Database. As part of its monitoring, CAT also reviews the performance of peer agencies
to ensure that it is on par with the performance of similarly-sized or adjacent area transit systems. The
peer review is included as Appendix E.
As part of CAT’s monitoring process, the following procedures and guidelines are carried out to monitor
compliance with Title VI. Periodic compliance assessments are undertaken to determine whether transit
service provided by CAT to minority communities and minority users is consistent with the objectives of
this Plan. The assessments will identify possible areas of noncompliance and implement corrective actions
to include the following:
• Establish procedures for developing and maintaining standards for compliance with Title VI.
• Establish internal guidelines for making determinations of compliance with Title VI as part of the
local decision-making processes and continue project management and contract administration
responsibilities.
• Establish internal guidelines for making determinations.
• Evaluate system-wide service changes and proposed improvements at the planning and
programming stages to determine whether the overall benefits and costs of such changes or
improvements are distributed equitably and are not discriminatory.
• Conduct compliance assessments of transit services and benefits to assure compliance with the
spirit and intent of Title VI.
• Take action on findings and recommendations made by review officials to remedy such findings.
Information Dissemination
CAT will continue to provide information to minority communities and the general public using its website,
public notices, meetings, workshops, hearings, presentations, and posting information on vehicles.
Additional public information dissemination to minority and low-income populations is covered in the LEP
section of this Plan. CAT staff will also continue to participate at various community events throughout
Collier County to disseminate information.
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Customer Service Surveys
CAT from time to time will conduct customer surveys to assess its performance and gather information
on market demands. Customer survey information can be a useful tool in assessing performance and
guiding future direction.
Incorporating Corrective Action
Upon identification of the need for corrective action by the FTA, CAT will commence corrective actions to
remedy identified deficiencies and incorporate the corrective actions into the Transportation
Improvement Plan to assure compliance with Title VI.
Procedures
CAT will maintain procedures identified in this Plan to assure continued compliance with Title VI. These
procedures will allow for comparing the level and quality of transit services against overall system
averages. These procedures will document both the Level of Service Methodology and the Quality of
Service Methodology used.
Public Information
In compliance with the requirement of the U.S. Department of Justice, the Department of Transportation,
and the FTA, the following information will be disseminated and made available to the public upon
request.
1. This plan and its requirements will be made available to the public upon request and will be
available for review from the CAT website or in the CAT offices during regular business hours.
2. CAT will maintain records and submit compliance reports and assessments as required and
make available such information to the general public upon request.
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Map 3: Minority Census Tract and CAT Fixed Route and ADA (3/4 Mile) Service Area
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Map 4: Low Income Census Tract and CAT Fixed Route and ADA (3/4 Mile) Service Area
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Appendix A
Title VI Complaint Form
Section I:
Name:
Address:
Telephone (Home/Cell): Telephone (Work):
Email Address:
Large Print Audio Tape
TDD Other
Section II:
Are you filing this complaint on your own behalf? Yes* No
If you answered “yes” to this question, go to Section III.
If not, please supply the name and relationship of the
person for whom you are complaining:
Name:
Relationship:
Please explain why you have filed for a third party:
Please confirm that you have obtained the permission to file this complaint
on behalf of the aggrieved party. Yes No
Section III:
I believe the discrimination I experienced was based on (check all that apply):
Race Color National Origin
Date of Alleged Discrimination (Month, Day, Year):
Explain as clearly as possible what happened and why you believe you were discriminated against.
Describe all persons who were involved. Include the name and contact information of the person(s)
who discriminated against you (if known) as well as names and contact information of any witnesses.
If more space is needed, please use the back of this form.
Section IV:
Have you previously filed a Title VI complaint with this agency? Yes No
Section V:
Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or
State court?
Yes No
If yes, check all that apply:
Federal Agency: ________________________ State Agency: _______________________
Federal Court: _________________________ State Court: ________________________
Local Agency: __________________________ Equal Opportunity Commission
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Section VI:
Name of Agency complaint is against:
Contact person:
Title: Telephone:
Email: Other:
You may attach any written materials or other information that you think is relevant to your
complaint.
Signature and date required below:
__________________________________________________ __________________________
Signature Date
Please submit this form in person at the address below, or mail this form to:
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Appendix B
Certifications and Assurances
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Appendix C
Sub-recipient Monitoring Form
Sub-recipient Monitoring Form
Agency Name: _____________________________________________
Date: _____________________________________________________
Funding: (Place an “” next to the appropriate grant source and type of funding.)
Capital _____________ Operating_____________ Both_____________
1. Verify Sub-recipient has registered with the SAM (System for Award Management) to determine
whether sub-recipients were registered before the award?
a. Registered ______________
b. Not Registered___________ date by which registration will be completed _______________. Access
site at https://www.sam.gov/portal/public/SAM/
2. Is Sub-recipient aware of the following:
a. CFDA title and number Yes_______ No_______
b. Award name and number Yes_______ No_______
c. The name of the Federal awarding agency Yes_______ No_______
d. Requirements imposed by laws, regulations Yes_______ No_______
e. Provisions of grant agreements Yes_______ No_______
3. Can Sub-recipient show proof of matching funds? Yes_______ No_______
4. Does Sub-recipient have documentation that shows how the grant award was utilized?
a. Copies of expenses Yes_______ No_______
b. Copies of payment (may need to show electronic transfers to document payment from CAT)
Yes_______ No_______
c. If not available date that documentation can be produced_____________
5. Does sub-recipient have a completed audit? Yes_______ No_______
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a. Are there audit findings? Yes_______ No_______
b. If yes, have findings been addressed? Yes_______ No_______
6. If Sub-recipient has a vehicle, verify the following:
a. Sub-recipient has manifest or system to separately track grant related trips?
Yes_________ No________
b. Sub-recipient has preventative maintenance policy? Yes_______ No_______
c. Sub-recipient has valid vehicle insurance? Yes_______ No_______
d. Sub-recipient has accident reporting policy? Yes_______ No_______
7. How does Sub-recipient notify the public or customers about the vehicle, program, or resource?
_________________________________________________________
8. Is a follow-up visit needed to verify compliance with above required items?
Yes_________ No___________
Agency Signature: ___________________________________ Print Name: ______________________
Signature of Monitor: ________________________________ Print Name: ______________________
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Appendix D
Collier Area Transit
Route Fare or Service Change Policy
In accordance with the Federal Transit Administration (FTA) Circular 4702.1A Title VI of the Civil Rights
Act of 1964, Transit providers within service areas containing more than 200,000 residents to evaluate
service and fare changes and their corresponding impacts to ensure transit service is planned operated
and distributed in an equitable manner without regard to race, color or national origin. The required
policies fall in the following three categories:
• Major Service Change Policy
• Disparate Impact Policy
• Disproportionate Burden Policy
Major Service Change Policy
The FTA requires that funding recipients prepare and submit service and fare equity analyses for public
comment in consideration of proposed major service or fare changes. The purpose of this policy is to
establish thresholds that define a “major service change”, and the definition of an adverse impact created
by a “major service change”.
As contained within this policy, a major service change is defined as meeting one of the following criteria:
1. Proposed service expansions and reductions including all routing and timetable changes
remaining in effect after 12 months that exceed 25 percent of the current configurations.
2. Total elimination of service on a specific route.
3. All proposed fare changes, excluding ride free promotional events and temporary fare reductions,
that in effect after 6 months.
If a proposed major service change falls within one of the three categories above, CAT will conduct a Title
VI service and/or fare equity analysis for review and consideration by the Board of County Commissioners
and the public prior to implementing changes.
An adverse effect is defined as a major geographical or time-based reduction in service which may include,
but is not limited to, span of service changes, frequency changes, route segment elimination, re-routing,
or route elimination. CAT shall consider the degree of adverse effects in the form of an equity analysis
when planning major service changes.
The following types of service changes are exempt:
• Minor route alignment, frequency, span, or time point adjustments;
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• Routing or bus stop changes due to temporary road detours caused by construction,
maintenance, closures, emergencies, labor disruptions or strikes, fuel shortages, or safety
concerns;
• Any temporary service addition, change, or discontinuation of a route with less than twelve
months of operation;
• Changes on special service routes serving sporting events, special events, or service contracted
through other cities or agencies;
• Any service change that does not meet the definition of a major service change described above.
Disparate Impact Policy
The purpose of this policy is to establish a threshold which identifies when adverse effects of a major
service or fare change are borne disproportionately by minority populations. For the purpose of this
policy, a minority population is defined as any readily identifiable group of minority persons who live in
geographical proximity, and if circumstances warrant, geographically dispersed/transient populations
(such as migrant workers or Native Americans) who will be similarly affected by a proposed program,
policy, or activity.
A “disparate impact” is defined as occurring when an adverse effect of a major service or fare change on
minority populations is at least 20 percent greater than the adverse effect on the average minority
population of CAT’s service area. In order to identify a potential impact, CAT will follow the process
illustrated within the flow chart below.
Collier County utilizes Remix Software Title VI Analysis tool to ensuring equitable public service for
protected populations
Should a proposed major service change result in a disparate impact, CAT will consider modifying the
proposed change to avoid, minimize, or mitigate the disparate impact of the change. The modified
proposed change due to potential disparate impacts will then be reanalyzed in order to determine
whether the modifications actually removed the potential disparate impacts of the changes.
If the CAT chooses not to alter the proposed changes, they may implement the service or fare change if
there is substantial legitimate justification for the change and it can be shown that there are no
alternatives that would have less impact on the minority population and would still accomplish program
goals.
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Title VI Service and Fare Equity Analysis Process
to Identify Potential Disparate Impacts
Potential Disparate
Impacts?
No Yes
Analysis Complete
Take Action to avoid,
minimize, mitigate.
(Revise Proposal)
Reanalyze changes for
potential Disparate
Impact
Does the agency have a substantial legitimate
justification for the action or policy? Has the agency
analyzed alternatives and determined that the
selected action or policy is the least discriminatory
alternative?
Analysis Complete
No to one or both
questions.
Analysis Complete
No Yes
Potential Disparate
Impacts?
Consider revising
proposal due to
possible Title VI
violation.
Yes
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Disproportionate Burden Policy
The purpose of this policy is to establish a threshold which identifies when adverse effects of a major
service or fare change are borne disproportionately by low-income populations. For purposes of this
policy, low-income population is defined as any readily identifiable group or households who are at or
below 150 percent of the U.S. Department of Health and Human Services Poverty Guidelines listed below.
Table 13: Annual Update of the HHS Poverty Guidelines
Source: Department of Health and Human Services, Office of the Secretary, Annual Update of the
HHS Poverty Guidelines
A “disproportionate burden” is defined as occurring when the low-income population adversely affected
by a major service or fare change is 20 percent more than the average low-income population of CAT’s
service area.
Similar to the approach in identifying a potential disparate impact, should a proposed major service or
fare change result in a disproportionate burden, CAT will consider modifying the proposed change to
avoid, minimize, or mitigate the disproportionate burden of the change. The modified proposed change
due to a potential disproportionate burden will then be reanalyzed in order to determine whether the
modifications actually removed the potential disproportionate burden of the changes.
If the CAT chooses not to alter the proposed changes, they may implement the service or fare change if
there is substantial legitimate justification for the change and it can be shown that there are no
alternatives that would have less impact on the low-income population and would still accomplish
program goals.
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Appendix E
Transit Development Plan (TDP) Capacity Analysis
Table 14: Fixed Route Capacities
Table 15: Demand Response Capacities
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Table 16: Total Capacity Analysis and Total Vehicle Counts
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Fixed-Route Capacity Analysis Summary
Based on the estimated capacity analysis, CAT was using approximately 14 percent of its possible capacity
in FY2019. This shows that the existing bus service has substantial capacity remaining. Routes with the
least amount of excess capacity include Routes 11, 12, 13, 14, and 15. Routes with the largest amount of
excess capacity include Routes 20,21, 23, 25, 26, and 29. Excess capacities for these routes range between
96 percent to 93 percent. It should be noted that the NTD reported average trip length is used to
determine excess capacity and Route 121,19, and 28 operate as routes from Immokalee to Marco Island
and Naples; therefore, these routes travel a greater distance than 7.25 miles per trip. When calculating
excess capacity using a greater average trip length, the excess capacity would be much less on Routes 19,
28, and 121.
Excess capacity is not necessarily a weakness in the system. The ridership-to-capacity ratio should be
monitored over time as part of future major updates to the TDP. In addition, route-by-route average trip
length estimates are needed in order to provide a more accurate reflection of unused capacity along fixed-
routes.
Demand Response Service Capacity Analysis Summary
Based on the estimated capacity analysis, CAT is using approximately 9 percent of the possible capacity.
This shows that demand response service has substantial capacity remaining. Excess capacity is not
necessarily a weakness in the system, given the nature of the requested trips. Expecting full paratransit
vans is unrealistic since the service operates on the basis of advanced trip reservations, and multiloading
is often difficult to accommodate given the often diverse nature of origins and destinations for each
patron.
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Appendix F
Transit Development Plan (TDP) Peer Review
Peer Review Analysis
This section presents the results of the peer and trend analysis conducted as part of Collier County’s
10-year TDP to examine transit system performance. The evaluation was conducted using data
available from the Florida Transit Information System (FTIS), which derives its data from the National
Transit Database (NTD). As part of the overall performance review of the system, this analysis assists
with assessing the extent to which CAT’s service is meeting its goals and objectives. Analyses include
statistical tables and graphs that summarize selected performance indicators and effectiveness and
efficiency measures. These measures are designed to review various trend components, as follows:
• Performance measures report absolute data for the selected categories; these tend to be key
indicators of overall system performance.
• Effectiveness measures refine the data further and indicate the extent to which various
service-related goals are being achieved.
• Efficiency measures involve reviewing the level of resources required to achieve a given level
of output; it is possible to have very efficient service that is not effective or to have highly
effective service that is inefficient.
Seven peer systems were selected for the peer analysis that represent transit systems with service
areas characteristics and services similar to CAT. The peer selection methodology is described in the
The peer systems are:
• City of Montgomery – Montgomery Area Transit System, AL
• Tri-State Transit Authority – Huntington, WV
• The Wave Transit System – Mobile, AL
• ART (Asheville Redefines Transit) – Asheville, NC
• Gwinnett County – Lawrenceville, GA
• Pasco County Public Transportation – Port Richey, FL
• Cape Fear Public Transit Authority – Wilmington, NC
Table 17shows the peer system sizes in terms of the number of routes and route miles compared to
CAT. As shown, CAT has the highest number of routes compared to the peer group and falls above the
peer average of 14 routes. CAT also has the highest number of route miles of compared to the peer
systems and supplies 57.1% more route miles than the peer average of 278 route miles.
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Table 17: Peer System Characteristics
Source: Agency websites for number of routes, 2018 NTD data for route miles
Table 18 reflects the measures used in this performance peer and trend analysis. A review of the
trend and peer analysis for each measure is presented, followed by highlights of the analyses.
Table 18: CAT’s Performance Review Measures
Table 19: CAT’s General Indicator Peer Comparison
Indicator CAT Peer Group
Minimum
Peer Group
Maximum
Peer Group
Mean
CAT %
from Mean
Service Area Population 262,699 88,512 920,260 320,228 -18.0%
Service Area Pop. Density
(persons/sq. mile)
847 654 2,106 1,534 -44.8%
Passenger Trips 896,201 654,474 2,125,214 1,102,154 -18.7%
Revenue Miles 1,285,354 1,017,879 1,724,047 1,220,154 5.3%
Revenue Hours 72,018 63,524 85,636 74,035 -2.7%
Average Speed (RM/RH) 17.85 14.04 20.75 16.47 8.4%
Operating Expenses $5,557,686 $5,148,844 $9,143,524 $6,495,939 -14.4%
Vehicles Operated in Max. Service 18 17 27 23 -21.7%
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Selected performance indicators for the peer review are presented in the above table, table 19. Categories
of performance indicators include service area population, population density, ridership, revenue and
vehicle miles, revenues hours, operating expense, fuel consumption, and the number of vehicles operated
in maximum service. Table 19 and Figures 4 through 25 present the performance indicators for CAT’s peer
review analysis.
Passenger trips, or ridership, are the number of passengers who board public transit vehicles and are
counted each time they board the vehicles, no matter how many vehicles they transfer to. It is a
measure of the market demand for the service. A higher number of passenger trips is a positive
metric. The total number of passenger trips in Collier County decreased from approximately 1.3
million in 2013 to 0.84 million in 2018, a 38% decrease. Ridership decline has been seen consistently in
the transit industry since the end of the Great Recession. CAT ridership is 19.3% below the peer mean
of about 1.0 million trips.
Figure 4: Peer and Trend Comparison for Passenger Trips
Passenger miles is a measure of passengers served over miles of service operated. Passenger miles
are calculated through randomized and statistically-valid survey sampling that counts elapsed miles
traveled for each passenger boarding and alighting. Higher passenger miles is a positive metric. For
CAT, passenger miles decreased since 2013, from 11.4 million in 2013 to 6.1 million in 2018. Overall,
passenger miles decreased by 46.7% from 2013 to 2018. CAT compares favorably to the peer mean,
ranking second in the peer group.
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Figure 5: Peer and Trend Comparison for Passenger Miles
Vehicle miles are the miles that transit vehicles travel while in revenue service plus deadhead miles.
This is a measure of how much service coverage is provided or the supply of service. Vehicle miles as a
metric by itself is not positive or negative but should be viewed in relation to productivity and cost
effectiveness measures. CAT’s total vehicle miles of service increased 6.4% overall, from 1.3 million in
2013 to 1.4 million in 2018. CAT’s vehicle miles are 9% higher than the peer mean.
Figure 6: Peer and Trend Comparison for Vehicle Miles
Revenue miles are the total number of miles for which the public transit service is scheduled or that
are operated while in revenue service. This excludes miles traveled when passengers are not on board
(deadhead travel), training operations, and charter services. Revenue miles increasing faster than
total vehicle miles generally indicates a positive operational trend and points to a decreasing
proportion of deadhead miles over time relative to total miles. Revenue miles as a metric by itself is
not positive or negative but should be viewed in relation to productivity and cost-effectiveness
measures. Revenue miles is a measure of service provided and should be slightly lower than vehicles
miles to reflect efficiency in service. CAT experienced an increase in revenue miles of 3.5% for 2013-
2018. CAT’s revenue miles were 5.6% higher than the peer mean and ranks third in the peer group.
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Figure 7: Peer and Trend Comparison for Revenue Miles
Vehicle hours are the total hours of travel a transit vehicle is being operated, including both revenue
service and deadhead travel and are a measure of service provided. Vehicle hours as a metric by itself
is not positive or negative but should be viewed in relation to productivity and cost-effectiveness
measures. CAT had a plateauing increase in vehicle hours, with an overall 10.6% increase in vehicle
hours from 2013 to 2018. CAT’s vehicle hours metric was 5.6% lower than the peer mean.
Figure 8: Peer and Trend Comparison for Vehicle Hours
Route miles represent the total length of all routes in the network and are a measure of the linear
extent of the transit network. Route miles for CAT increased from 279 to 436 miles in 2013 to 2018,
respectively, representing a 15% increase overall. CAT ranked the highest in the peer group for the route
miles metric.
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Figure 9: Peer and Trend Comparison for Route Miles
Total operating expense includes all costs associated with operating the transit agency (i.e., vehicle
operations, maintenance, and administrative costs). CAT’s total operating expense increased by 6% in
2013 to 2018. However, when considering the effects of inflation, the actual total operating expense
measured in 2013 dollars increased by only 2% in the six-year period, indicating that overall operating
expenses increased annually. CAT had the third lowest total operating expense in the peer group, 9%
below the peer mean.
Figure 10: Peer and Trend Comparison for Operating Expenses
Vehicles operated in maximum service (VOMS) are a measure of the fleet required to operate at the
peak of full service and are an important metric when assessing fleet size, as it is directly related to
the network structure, number of routes, and frequency of service of each transit agency. CAT
increased its supply of vehicles operating in maximum service from 23 vehicles in 2013 to 28 in 2018, an
approximate 22% increase. CAT is below the group mean of 30 vehicles.
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Figure 11: Peer and Trend Comparison for Vehicle Available for Maximum Service Maximum
Generally, fuel consumption is tied to vehicle miles of service and type of vehicle power employed.
CAT’s gas consumption fluctuated since 2013, but overall decreased by 11% in the six-year period. For
this performance measure, CAT is 11.3% above the group mean.
Figure 12: Peer and Trend Comparison for Fuel Consumption
Effectiveness measures indicate the extent to which service-related goals are being met and include
service supply, service consumption, and quality of service and are represented by variables such as
vehicle miles per capita, passenger trips per revenue hour, and average age of fleet.
Vehicle miles per capita are derived from the total system vehicle miles divided by the service area
population within a ¾-mile distance of service provided and measure the supply of service provided
based on the population of the service area. For CAT, vehicle miles per capita experienced an increase
from a low of 4.0 miles per capita to 5.2 in 2018, a growth of 31%. Vehicle miles per capita for CAT are
close to the peer group mean of 5.7, an indication that the supply of service is similar to what is
typically experienced by peer agencies.
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Figure 13: Peer and Trend Comparison for Vehicle Miles per Capita
Note: 2017 and 2018 updated using service area population manually calculated using TBEST 2019 Land Use Model.
Passenger trips per capita are calculated by dividing the total transit boardings by service area
population. This measure of service effectiveness quantifies transit utilization within the service area.
It is desirable that trips per capita are high, meaning greater utilization of the service. Passenger trips
per capita in Collier County experienced a 24% decrease between 2013 and 2018. CAT ranks sixth in the
peer group, 46% below the peer mean, suggesting a need for service consumption improvement.
Figure 14: Peer and Trend Comparison for Passenger Trips per Capita
Note: 2017 and 2018 updated using service area population manually calculated using TBEST 2019 Land Use Model.
Passenger trips per revenue hour are a measure used to quantify productivity and service
consumption and can help evaluate the amount of resources consumed in providing service. It is
desirable for this metric to be high, reflecting greater utilization of the service per unit of service
provided. From 2013 to 2018, CAT’s passenger trips per revenue hour decreased by 43%. The decline
in passenger trips per revenue hours is consistent with the increase in revenue miles and hours of
service and the decrease in ridership. CAT is 15% below the peer mean for this metric.
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TITLE VI PROGRAM 2020 - 2023
Figure 15: Peer and Trend Comparison for Passenger Trips per Revenue Hour
Passenger trips per revenue mile are calculated by dividing transit boardings by revenue miles and
are a measure of the productivity of the revenue service provided. It is desirable for this metric to be
high, meaning greater utilization of the service per unit of service supplied. In Collier County, passenger
trips per revenue mile experienced a decrease of 41% during the six-year period, indicating that the
agency experienced lessening ridership productivity during the time period. The decreasing trend is
driven by the decrease in ridership during that time period. CAT is 27% below the peer mean for this
metric, indicating a need for improvement in service consumption.
Figure 16: Peer and Trend Comparison for Passenger Trips per Revenue Mile
Efficiency measures focus on costs and other measures of efficiency. Figure 3-16 through Figure 3-24
present the efficiency measures for CAT’s peer review and trend analysis. Similarities between CAT
and the peers in this category may be related to the peer selection process, which is largely based on
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TITLE VI PROGRAM 2020 - 2023
transit service characteristics. The following section summarizes the trend and peer analysis by
efficiency measure type.
Operating expense per passenger trip measures the investment in providing public transport relative to
the population within the service area. This metric is more complex, in that although a higher cost
reflects a greater investment in transit, it must be viewed in context of direct costs per unit of service
relative to peers. When excluding inflation, the operating expense per capita for Collier County
increased from $17.51 in 2013 to $22.89 in 2018, an increase of 31%. CAT is 25% below the peer group
mean, suggesting that it is achieving a greater cost efficiency compared to its peer group.
Figure 17: Peer and Trend Comparison for Operating Expense per Capita
Note: 2017 and 2018 updated using service area population manually calculated using TBEST 2019 Land Use Model.
Operating expense per passenger trip measures the efficiency of transporting riders and the cost of
operations relative to the resulting ridership and reflects on how service is delivered and the market
demand for the service. The goal is to minimize cost per passenger trip. The operating expense per
passenger trip in Collier County increased from $14.17 in 2013 to $6.86 (2013$) in 2018, an increase of
65% overall. The decline in this is metric is driven primarily by the declining trend in passenger trips
during that time period. CAT is performing just above the the peer mean of $7.01 (2019$).
Figure 18: Peer and Trend Comparison for Operating Expense per Passenger Trip
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TITLE VI PROGRAM 2020 - 2023
Operating expense per passenger mile measures the impact of ridership, average trip length, and
operating cost. The goal is to minimize cost per passenger miles. CAT’s operating expense per
passenger mile nearly doubled between 2013 and 2018. Despite this trend, CAT is 28% below the peer
mean for this measure and is performing more efficiently than the peer group.
Figure 19: Peer and Trend Comparison for Operating Expense per Passenger Mile
Operating expense per revenue mile indicates how efficiently a transit service is delivered. The goal is
to minimize cost per revenue mile. Overall, the metric has remained stable, with an overall increase of
3%. CAT is 15% below the peer mean, indicating more efficient transit service delivery than its peers for
this measure.
Figure 20: Peer and Trend Comparison for Operating Expense per Revenue Mile
The farebox recovery ratio is a measure of the percentage of the transit system’s total operating
expenses that are funded with fares paid by passengers and is calculated by dividing the total fare
revenue collected by the total operating expenses. The goal is to increase farebox recovery, meaning
more of the costs are absorbed by users. CAT’s farebox recovery declined from 21% in 2013 to 33.4% in
2018, 34% overall. The farebox recovery ratio for CAT is at the peer group mean.
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TITLE VI PROGRAM 2020 - 2023
Figure 21: Peer and Trend Comparison for Farebox Recovery Ratio
Revenue miles per vehicle miles are a measure of vehicle utilization. A higher ratio of revenue miles
traveled to total vehicle mile generally indicates higher system productivity. The goal is to maximize
the ratio of operations in revenue service to total operations. For CAT, the revenue miles per vehicle
mile remained stable, with a slight decrease of 3% over the six-year period. Revenue miles per vehicle
mile for CAT is 3.5% below the peer group mean, which indicates a near-average use of fixed-route bus
vehicles within the peer group mean.
Figure 22: Peer and Trend Comparison for Revenue Miles per Vehicle Mile
Revenue miles per total vehicles are another measure of vehicle utilization. Interpretation of this
metric is complex, as it must be taken in context of the fleet size, revenue miles, and age of the fleet.
CAT experienced an overall decrease of approximately 15% over the six-year period and ranks 9% above
the peer mean of 41,207 revenue miles per total vehicles.
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TITLE VI PROGRAM 2020 - 2023
Figure 23: Peer and Trend Comparison for Revenue Miles per Total Vehicle
Vehicle miles per gallon, the ratio between fuel consumed and distance traveled, are an indication of
fuel efficiency and apply only to diesel- and gasoline-powered vehicles. It is desirable to maintain a
higher fuel economy, i.e., more miles per gallon. For CAT, vehicle miles per gallon (or fuel efficiency)
remained relatively constant, from 5.02 in 2013 to 4.8 in 2018, a decrease of 4% overall. CAT is 4%
below the peer mean.
Figure 24: Peer and Trend Comparison for Vehicle Miles per Gallon
Average fare is calculated by dividing total passenger fare revenue collected by ridership. The average
can be lowered by systems that offer free transfers or discounted/free rides. CATS’s average fare
increased from $0.88 in 2013 to $0.99 in 2018, 12% overall. The mean average fare for the peer
systems is $0.95. This means that, on average, CAT riders pay close to the mean fare of the peers.
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Figure 25: Peer and Trend Comparison for Average Fare
The trend analysis is only one aspect of transit performance evaluation. When combined with the peer
review analysis (summarized later in this section), the results provide a starting point for
understanding the transit system’s operating environment over time when compared to other
systems with similar characteristics. Key trends observed from 2013 to 2018 are summarized as
follows:
• The amount of service has increased with respect to total vehicle miles, revenue miles, vehicle
hours and route miles, and vehicle miles per capita. CAT placed above average for passenger
miles, vehicle miles, revenue miles, and route miles.
• Passenger trips and passenger miles have declined over the six-year period, which mirrors the
national trend in transit ridership decline. CAT performed 19.3% below the peer mean for
passenger trips and 19.6% above the peer mean for passenger miles.
• Total operating expenses have increased moderately by 6% over the six-year period.
Operating expense per passenger trip and operating expense per passenger mile have seen
dramatic increases that were driven largely by decreasing passenger trips and passenger
miles, suggesting a decline in efficiency. CAT performed better than the peer mean with
respect to total operating expenses, operating expense per passenger mile, and operating
expense per revenue mile, suggesting that CAT has a better cost efficiency compared to its
peer group. Operating expense per revenue mile fluctuated between 2013 and 2018, but only
with a slight increase of 2.6% overall.
• Passenger trips per capita, passenger trips per revenue mile, and passenger trips per revenue
hour have decreased over the six-year period, indicating a negative trend in service
consumption. CAT performed below the peer group mean for these measures.
• The farebox recovery ratio decreased 34% but, compared to the peer group, CAT is performing
near the peer mean.
Table 20 summarizes the peer and trend analysis showing the positive and negative trends identified
in the analysis.
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Table 20: Summary of Collier County’s Peer and Trend Analysis (2013–2018)
*2017-2018 service area population calculated using TBEST
Source: FTIS
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Appendix G: Ridership Survey
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Appendix H
List of Community Agencies
Leadership Council, LCA
Mayflower Congregational Church,
2900 County Barn Road,
Naples, Florida
www.collierseniorresources.org
Healthy Communities Program Consultant
Florida Department of Health in Collier County
Deborah Chesna
Phone: (239) 252-2594
Fax: (239) 774-5653
www.healthycollier.org
Jewish Family and Community Services (JFCS)
Dr. Jaclynn Faffer, President/CEO
5025 Castello Drive, Suite 101
Naples FL 34103
Phone: 239-325-4444
Fax: 239-330-7947
www.jfcsswfl.org
Catholic Charities, Diocese of Venice, Inc.
P.O. Box 2116
Venice, Florida 34284
www.catholiccharitiesdov.org
Refugee Coalition
Department of Children and Families
Hiram A. Ruiz, Director, Refugee Services
401 NW 2nd Ave., Suite N-812
Miami, Fl 33128
Office: (786) 257-5189
Cell: (305) 763-9040
hiram_ruiz@dcf.state.fl.us
Collier 211
Phone: 211 (IN FL) or (239)-263-4211
www.collier211.org
Lighthouse of Collier, Inc.
2685 Horseshoe Drive South, Suite 211
Naples, FL 34104
Phone: 239-430-3934
Fax: 239-430-9213
www.lighthouseofcollier.org
Neighborhood Health Clinic
121 Goodlette Road North
Naples, FL 34102
Phone: 239-261-6600
Fax: 239-261-6582
Email: info@neighborhoodhealthclinic.org
www.neighborhoodhealthclinic.org
Senior Friendship Center Health Clinic
2171 Pine Ridge Rd Suite F
Naples, FL 34109
Phone: 239.566.7425
Fax 239.593.3430
www.friendshipcenters.org/Locations/Collier.aspx
Physician Led Access Network (PLAN) of Collier
County
2500 Tamiami Trail North, Suite 212
Naples FL 34103
Phone: (239) 776-3016
FAX: (239) 435-1297
E-mail: info@plancc.org
www.plancc.org
United Way of Collier County
9015 Strada Stell Ct. #204
Naples, FL 34109
Phone: (239) 261-7112
Fax: (239) 261-3955
www.unitedwayofcolliercounty.org
Harry Chapin Food Bank
2221 Corporation Blvd
Naples, FL 34109
Phone: (239) 334-7007
fighthunger@harrychapinfoodbank.org
Collier Area Transit Title VI Program Update – 2017-2020 Page 85
United Cerebral Palsy (UCP) of Southwest FL
(Sunrise Community)
4277 Exchange Ave
Naples, FL 34104
Phone: (239) 643-5338 ext 101
FAX: (239) 643-4937
E-Mail: Naples@sunrisegroup.org
Collier Area Transit Title VI Program Update – 2017-2020 Page 86
Appendix I
Transit Manager Resolution
Collier Area Transit Title VI Program Update – 2017-2020 Page 87
Collier Area Transit Title VI Program Update – 2017-2020 Page 88
Appendix J
Fare Study
The link below is the recently completed fare study.
http://sp16/sites/PSD/Operations/PTNE%20Files/CAT%20Fare%20Study%20Final%20Report.pdf
Appendix K
Latest TDP
The link below is a link to the recently completed TDP.
http://sp16/sites/PSD/Operations/PTNE%20Files/CAT%20FY16-25%20TDP_6%2015%2015_Red.pdf
Collier Area Transit Title VI Program Update – 2017-2020 Page 89
Appendix L
Staff Training Documents on Title VI
Title VI Program CAT’s 2020-2023 Revision
List of Contents
•Title VI Overview
•Introduction
•Requirements
•Public Participation Plan (PPP)
•Limited English Proficiency (LEP)
•Environmental Justice
•System Wide Service Standards
•Minority Routes
•Title VI Complaint Procedures
•Questions and Comments
Title VI Program Revision 2020-2023
Title VI Overview
Statue Based on Civil Rights Act of 1964
Nondiscrimination Statement:
"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 subjected to discrimination under any program or activity receiving federal financial assistance.”
Title VI:
•Updated every three years
•Applies to CAT as a recipient of federal funding and its subrecipients
•Federal Transit Administration (FTA) regulating agency for CAT
Introduction
The objectives of this Title VI Program include the following:
1.Ensure that federally-assisted benefits and related services are made available and are equitably distributed.
2.Ensure that the level and quality of federally-assisted services are sufficient to provide equal access and mobility to all persons.
3.Ensure adequate opportunities for all to participate in the planning and decision-making processes.
4.Ensure that placement of transit services and facilities are equitable.
5.Ensure that corrective and remedial actions are taken for all applications and receipts of federal assistance to prevent discriminatory treatment of any beneficiary.
6.Provide procedures for investigating Title VI complaints.
7.Take responsible steps for ensuring that meaningful access to programs and activities is provided for persons with Limited English Proficiency.
8.Inform the public of their rights under Title VI.
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns ** This one I’m not sure about**
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Requirements
Notice of rights under Title VI
•A Title VI Notice to the Public must be displayed to inform a recipient’s customer of their rights under Title VI.
List of Title VI investigations and complaints or lawsuits
•CAT has no investigations, complaints or lawsuits.
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Public Participation Plan
The Public Participation Plan (PPP):
•CAT has its own PPP, and also participated in the Collier Metropolitan Planning Organization (MPO) public involvement activities to ensure that a wider range of opportunities are available for all persons
•Designed to engage both transit users and non-transit users
•Staff regularly gathers input via online surveys in multiple languages, English, Spanish, and Creole
•General Public can comment on CAT’s services and capital investments through the Public Transit Advisory Committee (PTAC), the MPO Committees and MPO Board Meetings.
•As part of CAT’s public outreach process all meeting notices, press releases, and public service announcements are translated into other languages as requested or needed based on documentation of previous requests.
•CAT utilizes pictographs to display information and instructions.
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Limited English Proficiency (LEP)
CAT has a responsibility, under Title VI of the Civil Rights Act of 1964, to take
reasonable steps to ensure that LEP persons have meaningful access to
benefits, services, information, and other important programs and activities
provided by CAT.
•Vital Documents are readily translated from English to Spanish as well as
Creole, and upon request other languages.
•CAT’s website provides translation to other languages: Spanish, Creole,
German, and French
•CAT also provides translation for public meetings
Limited English Proficiency (LEP)
Four Factor Framework Analysis
1.The number and proportion of LEP persons served or encountered in the
eligible service population;
2.The frequency with which LEP persons come into contact with the agency’s
programs, activities, and services;
3.The importance of the programs, activities, and services to LEP persons; and
4.The cost and resources available.
Limited English Proficiency (LEP)
Total Population
5 Years and
Over
Spanish LEP
Population
Other Indo-European languages
LEP Population
Asian and
Pacific Island
LEP Population
Other
Languages LEP
Population
Total LEP
Population
347,226 39,824 9,020 1,528 269 50,641
100%11.5%2.6%0.4%0.1%14.6%
Limited English Proficiency By Census BlockDistributionofLimited English Pro ficiency
Persons within the CAT Service Area LEP Population
=
15% of the Total
Service Area
Population
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Requirements
Racial breakdown of non-elected advisory boards/councils
Narrative describing sub-recipient monitoring
•CAT is required to complete sub-recipient training and monitoring to ensure compliance with all Certifications and Assurances, including those regarding non-discrimination.
•The monitoring would be randomly scheduled to capture the everyday operations.
PTAC Racial Composition TAC Racial Composition CAC Racial Composition LCB Racial Composition
White Male -5 White Male -8 White Male -8 White Male -4
White Female -1 White Female -5 White Female -4 White Female -9
Black Male -0 Black Male -0 Black Male -1 Black Male -0
Black Female -0 Black Female -1 Black Female -0 Black Female -1
Hispanic Male -0 Hispanic Male -0 Hispanic Male -1 Hispanic Male -0
Hispanic Female -0 Hispanic Female -0 Hispanic Female -0 Hispanic Female -0
Other Male -0 Other Male -0 Other Male -0 Other Male -0
Other Female -0 Other Female -0 Other Female -0 Other Female -0
Vacancy -1 Vacancy -0 Vacancy -0 Vacancy -2
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
System-Wide Service Standards
Vehicle Load Standards
Vehicle Type/Service Seating Capacity Standing Capacity Maximum Vehicle Load
–Off-Peak
Maximum Vehicle Load
–Peak
Maximum Load Factor
–Off-Peak
Maximum Load Factor -
Peak
Low-Floor 40’ Bus
(Fixed-Route)38 41 79 79 2.08 2.08
Low-Floor 40’ Bus
(Express-Route)38 41 79 79 2.08 2.08
Low Floor 35’ Bus
(Fixed-Route and
Trolley)
31 44 75 75 2.38 2.38
Low Floor 30’ Bus 26 17 43 43 1.61 1.61
Low Floor 24’ Bus
(Paratransit) 12 0 12 12 1.00 1.00
Low Floor 23’ Bus
(Paratransit)12 0 12 14 1.00 1.00
System-Wide Service Standards
Vehicle Headways
•Average of 90 minute Frequencies on both Monday –Saturday and
Sunday
•Route 13, 14, 19 are the only routes with 60 minute frequencies
System-Wide Service Standards
On-Time Performance
Mode On-Time Performance Measure Goal
(Percent)
On-Time Performance Measure
(Time)
Local Bus 95 %Up to 5 minutes late
Express Bus 95%Up to 5 minutes late
Trolley Bus 95%Up to 5 minutes late
Paratransit Bus 90%0 minutes late
System-Wide Service Standards
Service Availability
CAT provides service from 3:45 a.m. to 8:52 p.m., Monday through Saturday
and 5:30 a.m. until 7:51 p.m. on Sundays.
Service Delivery Factors:
1.Financial resources
2.Public input
3.Performance of existing routes
4.Transit Orientation Index (population and employment density, income, age, and
zero-car households)
5.Safety guidelines
6.Development patterns
Policies
Ensure Transit Amenities are provided equitably for each Mode
•591 bus stops throughout their service area.
Vehicle Assignments are distributed among all routes
•Randomized Vehicle Selection
Fare or Service Change are evaluated so to not adversely impact any
group and are categorized as follows:
•Major Service Change Policy
•Disparate Impact Policy
•Disproportionate Burden Policy
Minority Routes
All of CAT routes serve a
minority census block
group, while
approximately 45 percent
of the service provided
has the majority (50
percent or more) of the
service within minority
census block groups.
Route Total Route
Miles
(Round
Trip)
Total Route
Miles (one-
Way)
Route Miles
within Minority
Block Group
(Round Trip)
Route Miles
within
Minority Block
Group (One-
Way)
Percent Route
within Minority
Block Group
11 25.0 12.5 6.8 3.4 27.2
12 24.6 12.3 9 4.5 36.6
13 26.8 13.4 18.4 9.2 68.7
14 27.0 13.5 16.8 8.4 62.2
15 48.6 24.3 36.8 18.4 75.7
16 48.6 24.3 29.8 14.9 61.3
17 43.0 21.5 30.8 15.4 71.6
18 42.4 21.2 30.4 15.2 71.7
19 168.2 84.1 61.4 30.7 36.5
20 24.2 12.1 7.2 3.6 29.8
21 56.0 28 13.6 6.8 24.3
22 42.6 21.3 42.6 21.3 100
23 42.4 21.2 42.4 21.2 100
24 24.0 12 17.6 8.8 73.3
25 28.6 14.3 10.2 5.1 35.6
26 23.4 11.7 7.2 3.6 30.8
27 61.6 30.8 27.4 13.7 44.4
28 169.0 84.5 58.2 29.1 34.4
121 A 138.6 69.3 57.8 28.9 41.7
121 B 129.4 64.7 51.8 25.9 40.0
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Environmental Justice
Executive Order 12898 passed in February 1994
Department of Transportation EJ Order 5610.2 (a) May
2012
Executive branch internal management to protect minority
and low-income populations
Environmental Justice
Bus Stop Amenities Locations
for Low Income and Minority
Population Areas
Environmental Justice
Minority Census Tract and
CAT Fixed Route and ADA
(3/4 Mile) Service Area
Environmental Justice
Low Income Census Tract
and CAT Fixed Route and
ADA (3/4 Mile) Service
Area
Requirements
CAT’s Title VI Program must contain the following:
•Notice of rights under Title VI
•List of Title VI investigations and complaints or lawsuits
•Public Participation Plan
•Language Assistance Plan (Limited English Proficiency)
•Racial breakdown of non-elected advisory boards/councils
•Narrative describing subrecipient monitoring
•Service Standards and Policies
•Demographic Analysis
•Customer Demographics and Travel Patterns
•Major Service Change Policy
•Board Resolution or Meeting minutes demonstrating board approval of Title VI Program
•How to file a complaint and copy of complaint form
Title VI Complaint Procedures
As a recipient of federal financial assistance, CAT has Title VI Complaint
procedures in place.
Any person who believes that he or she, individually or as a member of any
specific class of persons, has been subjected to discrimination on the basis of
race, color, or national origin may file a written complaint with the FTA or the
Secretary of Transportation.
Persons are encouraged to first notify Collier County and file a complaint
through the local office.
The CAT Title VI complaint form and associated procedures are available in
English, Spanish, and Creole and any other language upon request.
Comments & Questions?