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HomeMy WebLinkAbout2016-03-28 16-117 ORDERCOUNCIL ACTION Item No. 16-117 Date: March 28, 2016 Item/Subject: Order, Approving and Adopting Title VI Environmental Justice Non - Discrimination Plan for Community Connector Public Transit Service. Responsible Department: Executive Commentary: This Order would approve and adopt a Title VI / Non -Discrimination Plan for the Community Connector transit system. This Plan is required by the Federal Transit Administration (FTA) for entities that are direct recipients of federal funds. The City is required to adopt a Title VI / Non -Discrimination Plan and submit to the FTA for approval. The Governmental Operations Committee reviewed and recommended approval and adoption of the Plan to the City Council at its March 21, 2016 meeting. Manager's Comments: Recommend Approval Associated Information: Order, Non -Discrimination Plan Budget Approval: Legal Approval: Introduced for X Passage (Consent Agenda) First Reading Referral Department Head slYl � City Manager Page _of_ Finance Director City golicitor 16-117 MARCH 28, 2016 Assigned to Councilor Nichols RA r. CI`T'Y OF BANGOR gTED,f (TITLE.) ORDER, Approving and Adopting Title VI/Environmental Justice Non -Discrimination Plan for Community Connector Public Transit Service. WHEREAS, the City of Bangor operates Community Connector serving six communities and the University of Maine; and WHEREAS, federal funding to assist with operational and capital costs; and WHEREAS, federal funding will be received and administered by Community Connector is a Direct Recipient; and WHEREAS, all Direct Recipients of Federal Transit Administration (FTA) funding must approve and adopt a Title VI Environmental Justice Non -Discrimination Plan in order to remain eligible to receive federal funding. By tfae O?ty Couna/ of #re City of Bangor. ORDERED, That the attached Title VI Environmental Justice Non -Discrimination Plan dated March 31, 2616 is hereby approved and adopted for purposes of meeting the requirements of, and submission to, the Federal Transit Administration IN CITY COUNCIL MARCH 28, 2016 PASSED CITY CLERK 16-117 MARCH 28, 2016 To: Government Operations Committee From: Laurie Linscott, Community Connector Superintendent Subject: Title VI / Non -Discrimination Plan Date: March 15, 2016 City of Bangor, Community Connector is required by Federal Transit Administration (FTA) to have a Title VI / Non -Discrimination Plan as part of being a direct recipient of federal funding. The VI program refers to a document developed by an FTA recipient to demonstrate how the recipient is complying with Title VI requirements. Direct and primary recipients must submit their Title VI programs to FTA every three years. The Title VI program must be approved by the recipient's board of directors or appropriate governing entity or officials responsible for policy decisions prior to submission to FTA. Our first plan was approved Dec 26, 2012 and expires May 31, 2016. The Title VI plan needs to be submitted to FTA 60 days before it expires. Our plan is due to FTA April 1, 2016. The City of Bangor, Community Connector is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin. This plan was developed pursuant to FTA Circular 4702.113 to guide Community Connector and its administration and management of Title VI -related activities. Our Title VI Plan outlines in detail how Community Connector will address certain issues related to discrimination, such as public outreach , public participation, LEP Analysis and LEP Plan, Title VI Complaints, Public Notification, Title VI Investigations, Service Standards, and Service Policies. Staff recommends that the Committee endorse our updated Title VI Plan and forward to the City Council with a recommendation to approve as written. After City Council approval, the plan will be submitted to FTA for review. At that point, the FTA will either approve the Plan as submitted, or recommend modifications so that the Plan will be in compliance. 16-117 MARCH 28, 2016 Service stand Title VI/Environmental Justice Non -Discrimination Plan For Discrimination based on Race, Color, National Origin City of Bangor Community Connector 481 Maine Avenue Bangor, Maine 04401 207-992-4670 March 31, 2016 Contents 16-117 MARCH 28, 2016 Page Introduction........................................................................................................1 1. Community Connector Public Outreach Plan ....................................................... 2 2. Community Connector LEP Analysis and Plan ..................................................... 3 3. Title VI Complaint Procedure................................................................................ 6 Discrimination Complaint Form............................................................................. 7 4. Notifying the Public of Rights under Title VI .......................................................... 9 5. Community Connector Title VI Investigations..................................................... 10 6. Racial Breakdown of Board............................................................................... 10 7. Efforts of Primary Recipient to Ensure Title VI Compliance of Sub recipients .... 10 8. Title VI Analysis for Facility Construction............................................................ 10 9. Service Standards.............................................................................................. 11 10. Service Policies.................................................................................................. 14 Introduction Plan Statement 16-117 MARCH 28, 2016 Title VI of the Civil Rights Act of 1964 as amended 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 ground of race, color, or national origin, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance" (FTA) 42 U.S.C. Section 2000d). The City of Bangor's transit system, Community Connector, is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin. This plan was developed pursuant to FTA Circular 4702.1 B to guide Community Connector (CC) and its administration and management of Title VI -related activities. Title VI Coordinator Contact Information Laurie Linscott, Superintendent, Community Connector, 481 Maine Avenue, Bangor, Maine, 04401, 992-4672. Subcontractors and Vendors All subcontractors and vendors who receive funding originates from any federal assistance Civil Rights Act of 1964 as amended. Wrift language, either directly or through the bic associated component of the contract. Record Keeping payments from Community Connector where are subject to the provisions of Title VI of the an contracts shall contain non-discrimination I specification package which becomes an The Title VI Coordinator shall maintain permanent records which include, but are not limited to, copies of Title VI complaints or lawsuits and related documentation, and records of correspondence to and from complainants, and Title VI investigations. 16-117 MARCH 28, 2016 1. Community Connector Public Outreach Plan Public outreach is essential to the success of Community Connector, the public transit system operated by the City of Bangor that serves Bangor, Brewer, Old Town, Orono, Veazie and Hampden. Community Connector's ongoing public outreach efforts extend beyond maintaining a website and marketing its services through brochures and schedules to include public workshops. These workshops benefit both Community Connector officials and the general public in a number of ways: • They provide users of the transit system with an opportunity to describe what they like about the system and what they would like to see changed; • They introduce potential riders of Community Connector with basic information about how the system works and how it can meet their needs; • They engender a sense of ownership among people, especially those who are often at the mercy of their surroundings; • They help Community Connector officials design a transit system that meets the needs of the public within the constraints of available funding; • They help Community Connector officials gauge the success of the transit system; and • They provide Community Connector officials with new ideas and alert them to potential environmental justice issues. The following is a summary of public outreach efforts undertaken by Community Connector during calendar year 2013-2015. These outreach efforts are aimed at helping these organizations understand the transit services provided by Community Connector. While all of the meetings are open to the public, some of the meetings are focused on smaller groups with a unique interest. Participation at meetings of groups that target either minority, elderly or low income populations are underlined. Presentations were made to the following organizations: Brewer Affordable Housing Local Schools University of Maine —Student Orientations University of Maine — Commuter Day University of Maine — International Students Husson University - International Students Eastern Maine Community College City of Bangor Council — Government Operations Committee Veazie Town Council Hampden Town Council Transportation for All Committee Bangor House Ellen Leach Home -Brewer Community Connector makes available one-on-one training to help all passengers to learn how to navigate the transit system. The Bus Ambassador Program was started in 2015. This is a group of trained volunteers who want to teach people how to ride the transit bus. Call the Community Connector office or The Bus Ambassador office to reach a trained volunteer who is 16-117 MARCH 28, 2016 will assist you. Community Connector's Public Outreach Plan is to continue efforts similar to those listed above into the future. 2. Community Connector LEP Analysis and Plan Introduction On August 11, 2000, President Clinton signed Executive Order 13166: Improving Access to Service for Persons with Limited English Proficiency, which requires meaningful access to all federally assisted programs and activities by persons with limited English proficiency (LEP). Executive Order 13166 states that individuals who do not speak English well and who have a limited ability to read, write, speak or understand English are entitled to language assistance under Title VI of the Civil Rights Act of 1964 with respect to a particular type of service, benefit or encounter. It reads in part: Each Federal agency shall prepare a plan to improve access to its federally conducted programs and activities by eligible LEP persons. Each plan shall be consistent with the standards set forth in the LEP Guidance, and shall include the steps the agency will take to ensure that eligible LEP persons can meaningfully access the agency's programs and activities. In addition to the requirement that federal agencies prepare LEP plans, all recipients of federal financial assistance have to comply with Title VI and LEP guidelines of the federal agency from which funds are provided. The Federal Highway Administration has mandated that all "...recipients must take reasonable steps to ensure that such persons have meaningful access to the programs, services and information those recipients provide, free of charge..." Who is an LEP Individual? According to FTA Circular 4702.113, "Limited English Proficient (LEP) persons refers to persons for whom English is not their primary language and who have a limited ability to read, write, speak or understand English. It includes people who reported to the U.S. Census that they speak English less than very well, not well, or not at all." The Four Factor Analysis Under the provisions of FTA Circular 4702.1 B, Community Connector is obligated to determine the extent of its obligation to provide LEP services to its transit -dependent population. This determination must be based on an analysis of four factors as described in the paragraphs below. Factor #1: The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient. The 2010-2014 American Community Survey 5 -Year Estimates shows that the number and percentage of persons who speak English less than very well within four major groups in each of the six municipalities served 3 16-117 MARCH 28, 2016 by Community Connector falls below the 1,000 person/5% threshold, as shown in the table below. Table 1 Summary of Limited English Proficiency (LEP) Persons 5 Years and Older Community Connector Service Area 2010-2014 Census Estimates Total 5% Persons Threshold Persons S akin En lish Less than Very Well Spanish Indo- European Asian or Pacific Other Bangor 31,230 1,562 57 128 268 6 Brewer 8,899 445 0 63 0 0 Hampden 7,041 352 0 23 17 0 Old Town 7,244 362 01 59 83 0 Orono 10,252 513 0 1 531 83 1 0 Veazie 1,902 95 01 51 01 0 Source: 2010-2014 American Community Survey 5 -Year Estimates, Table DP02 a. How LEP persons interact with the Agency. LEP persons can potentially interact with Community Connector when they telephone the agency, when they board or exit a transit vehicle, or when they attend a meeting sponsored by Community Connector. b. Identify LEP communities by language group and assess the number of proportion of LEP persons from each language group to determine the appropriate language services for each language group. As shown in Table 1, the number and percentage of persons within each of the four major language groups falls well below the 1,000 person/5% threshold. Based on these relatively small numbers, Community Connector's use of a language poster, the use of "I Speak" cards, and the potential to use one of the translator services in Maine, is an appropriate level of service. c. The literacy skill of LEP populations in their native languages, in order to determine whether translation documents will be an effective practice. Community Connector has no data that suggests that the literacy skills of LEP persons are a barrier to using Community Connector's services. There have been no requests for translation services, and no requests for documents in another language. d. Whether LEP persons are underserved by Community Connector due to language barriers. Community Connector has no data that suggests that LEP populations are underserved in our programs and services. Factor #2: The frequency with which LEP persons come in contact with programs, activities or services. Language barriers have not been an issue. 4 16-117 MARCH 28, 2016 a. Buses. Community Connector has no data that suggests that LEP populations are using its buses. Although LEP persons connected with the University of Maine, Husson University, and Eastern Maine Medical Center do use the buses. b. Public meetings. Community Connector has no data that suggests that LEP populations are attending its meetings. c. Customer service interactions. There have been few customer services interactions with LEP persons during the last three years. d. Surveys. Community Connector has no data that suggests that LEP populations have participated in any customer surveys during the past three years. Factor #3: The nature and importance of programs, activities or services to the LEP population. The bus service may be important to some LEP individuals. Community Connector is not aware of any LEP population in its service area that is unable to use the bus system because of language barriers. Factor #4: The resources available to the recipient for LEP outreach, and overall costs to provide LEP assistance. Community Connector bus drivers and administrative staff have "I speak" language identification cards for use in the event that they encounter an LEP person who needs language assistance. In the event that an LEP person requires language assistance, Community Connector would utilize one of the translation services identified by MaineDOT at a cost of about $50 - $65/hour. Language Assistance Plan a. Results of the Four Factor Analysis, including a description of the LEP Population(s) served. The 2010-2014 American Community Survey 5 -Year Estimates shows that the number and percentage of persons who speak English less than very well within four major groups in each of the six municipalities served by Community Connector falls below the 1,000 person/5% threshold. There are no known LEP communities in Community Connector's service area. b. How Community Connector provides language assistance services by language. Community Connector has "I Speak" language identification cards available on its buses and at public meetings. Should the need arise, Community Connector can utilize translation services identified by MaineDOT. c. How Community Connector provides notice to LEP persons about the availability of language assistance. Community Connector has "I Speak" language identification cards available on its buses and at public meetings. Community Connector also posts Title VI posters in its offices and at other prominent places. d. How Community Connector monitors, evaluates and updates the language assistance plan. On a yearly basis, Community Connector's title VI Coordinator will review the Title VI plan in conjunction with Census data, FTA requirements, and any developments that would impact the plan including complaints and requests for 6 16-117 MARCH 28, 2016 language assistance services. Based on this review, Community Connector's Language Assistance Plan will be updated accordingly. e. How Community Connector trains employees to provide timely and reasonable language assistance to LEP populations. Periodically, Community Connector includes Title VI training and one of its training sessions. Training includes providing a copy of the Title VI plan to employees, and highlighting key features of the Plan including a definition of LEP persons, and the steps that Community Connector has agreed to take to assist LEP persons, including the use of "I Speak" cards. 3. Title VI Complaint Procedure Any person who believes she or he has been discriminated against on the basis of race, color, or national origin by the City of Bangor Community Connector (hereinafter referred to as "the agency") may file a Title VI complaint by completing and submitting the agency's Title VI Complaint Form. The agency investigates complaints received no more than 180 days after the alleged incident. The Authority will process complaints that are complete. Once the complaint is received, the agency will review it to determine if Community Connector has jurisdiction. The complainant will receive an acknowledgement letter informing her/him whether the complaint will be investigated by the agency. The agency has 30 days to investigate the complaint. If more information is needed to resolve the case, the agency 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, the agency can administratively close the case. A case can also be administratively closed if the complainant no longer wishes to pursue her/his 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 summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff member, or other action will occur. If the complainant wishes to appeal the decision, she/he has 30 days after the date of the letter of the LOF to do so. A person may also file a complaint directly with the Federal Transit Administration, at FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590. C9 16-117 MARCH 28, 2016 DISCRIMINATION COMPLAINT FORM Community Connector Title VI/Environmental Justice and Related Statutes I Ilk Name: Address: Telephone (Home): Telephone (Work): Electronic Mail Address: Accessible Format Requirements? Large Print Audio Tape TDD Other Section If: Are you filing this complaint on your own behalf? Yes* No *If you answered "yes" to this question, go to Section Ill. If not, please supply the name and relationship of the person for whom you are complaining: Please explain why you have filed for a third party: Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party. Yes No Section fit: 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 y6u filed this complaint with any other Federal, State, or local agency, or with an 16-117 MARCH 28, 2016 Federal or State court? []Yes []No If yes, check all that apply: [ ] Federal Agency: [ ] Federal Court [ ] State Agency [ ] State Court [ ] Local Agency Please provide information about a contact person at the agency/court where the complaint was filed. Name: Title: Agency: Address: Telephone: Section VII Name of agency complaint is against: Contact person: Title: Telephone number: 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: City of Bangor Community Connector 481 Maine Avenue Bangor, Maine 04401 9 16-117 MARCH 28, 2016 4. Notifying the Public of Rights under Title VI City of Bangor Community Connector • The City of Bangor operates Community Connector without regard to race, color and national origin in accordance with Title VI of the Civil Rights Act. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with Community Connector. • For more information on Community Connector's civil rights program, and the procedure to file a complaint, contact 207-992-4670, or visit our administrative office at 481 Maine Avenue, Bangor, Maine 04402. • A complainant may file a complaint directly with the Federal Transit Administration by filing a complaint with the Office of Civil Rights, Attention: Title VI Program Coordinator, East Building, 5th Floor -TCR, 1200 New Jersey Avenue., SE, Washington, D.C. 20590. • If information is needed in another language, contact 207-992-4670. Note: this notice will be prominently and publicly displayed at the Community Connector dispatch center, and on transit buses. This notice will also be posted on Community Connector's website and will be distributed whenever specialized training or assistance is provided to disabled or visually impaired customers. Additional information relating to nondiscrimination can be obtained from the Title VI Coordinator. Title VI information shall be disseminated to Community Connector employees annually. During new employee orientation, new employees shall be informed of the provisions of Title Vl, and Community Connector's expectations that they will perform their duties accordingly. 10 16-117 MARCH 28, 2016 5. Community Connector Title VI Investigations There have been no Title VI investigations, complaints or lawsuits filed with the agency during the past three calendar years (2013, 2014 and 2015). In the event that there are any investigations, complaints or lawsuits in the future, Community Connector plans to use the following form for documenting them. 6. Minority Representation on Governing Board Community Connector is governed by the Bangor City Council, an elected body consisting of nine members. The requirement in FTA Circular 4702.1 B to include a table showing the racial breakdown of the governing board does not apply to boards consisting of elected officials. 7. Efforts of Primary Recipient to Ensure Title VI Compliance by Sub -recipients Community Connector is a primary recipient of FTA funds and does not have sub -recipients. 8. Title VI Analysis for Facility Construction Community Connector has not constructed a facility such as a vehicle storage facility in the last two years. In the future, construction of any such facility will require a Title VI analysis with regard to the location of the facility. 11 Date Summary (include basis (Month, of complaint; race, color, Status Action(s) Taken Day, Year) or national origin) Investigations 1. 2. Lawsuits 1. 2. Complaints 1. 2. 6. Minority Representation on Governing Board Community Connector is governed by the Bangor City Council, an elected body consisting of nine members. The requirement in FTA Circular 4702.1 B to include a table showing the racial breakdown of the governing board does not apply to boards consisting of elected officials. 7. Efforts of Primary Recipient to Ensure Title VI Compliance by Sub -recipients Community Connector is a primary recipient of FTA funds and does not have sub -recipients. 8. Title VI Analysis for Facility Construction Community Connector has not constructed a facility such as a vehicle storage facility in the last two years. In the future, construction of any such facility will require a Title VI analysis with regard to the location of the facility. 11 9. Service Standards Vehicle Loads 16-117 MARCH 28, 2016 The average of all loads during the peak operating period should not exceed the vehicles' achievable capacities which are shown in the table below. BUS NO. Run Assignment High Floor Low Floor Seating Standees Total Load Factor ORION 0202 Brewer North X 29 26 55 1.9 0209 Capehart - 2 X 29 26 55 1.9 0203 Capehart -3 X 29 26 55 1.9 0207 Brewer South X 29 26 55 1.9 0210 Capehart -1 X 29 26 55 1.9 GILLIG 1046 Old Town - 1 X 31 23 54 1.75 1047 Old Town - 2 X 31 23 54 1.75 1048 Mt Hope X 31 23 54 1.75 1049 Hammond St X 31 23 54 1.75 1050 Stillwater X 31 23 54 1.75 ORION 43 Spare X 29 25 54 1.9 44 ISpare X 29 25 54 1.9 ELDORADO 0725 University X 28 20 48 1.7 0726 University X 26 18 44 1.7 CHEV. GOSHE 0924 IHampden X 24 15 39 1.6 CHAMPION 0722 Spare X 22 15 37 1.7 0723 Spare X 22 15 37 1.7 BLUEBIRD 0621 Spare X 32 24 56 1.75 NEW FLYER 0027 Spare X 25 18 43 1.72 0028 Center St X 25 18 43 1.72 0029 Mall Hopper X 25 18 43 1.72 12 16-117 MARCH 28, 2016 Vehicle Headway The Community Connector provides service every 30 minutes on four of the routes (Capehart, Center Street, Hammond Street, Orono Black Bear Express) and every 60 minutes on the remaining routes, as shown in the table below. Service begins and ends at different times on different routes, as shown in the table below. Scheduling involves consideration of a number of factors including contract financial support, cost, ridership productivity, and the density of transit population densities and activities. Community Connector — Headway and Service Hours Weekday Service Route Headway Service Hours Beginning Ending Ca ehart 30 minutes 6:06 am 6:27 prn Hammond Street 30 minutes 5:55 am 6:15 pm Center Street 30 minutes 6:15 am 6:08 pm Black Bear Orono Express 30 minutes 6:55 am 9:55 pm Brewer South 60 minutes 6:45 am 6:30 pm Brewer North 60 minutes 7:15 am 6:00 prn Hampden 60 minutes 6:15 am 6:15 pm Mall Hopper 60 minutes 6:55 am 6:45 pm Old Town 60 minutes 5:45 am 7:05 pm Stillwater 60 minutes 6:45 am 6:45 pm Mount Hoe 60 minutes 6:15 am 6:15 pm Saturday Service Route Headway Service Hours Beginning Ending Ca ehart 30 minutes 7:06 am 6:15 prn Hammond Street 60 minutes 9:15 am 6:15 prn Center Street 60 minutes 8:45 am 6:15 pm Black Bear Orono Express 30 minutes 12:13 pm 4:55 pm Brewer South 60 minutes 6:45 am 6:30 pm Brewer North 60 minutes 7:15 am 6:00 pm Mall Hopper 60 minutes 6:55 am 6:45 pm Old Town 60 minutes 6:15 am 7:05 pm Stillwater 60 minutes 6:45 am 6:45 pm Mount Hope 60 minutes 6:15 am 6:15 pm Note: hampaen is the only route that doesn't have Saturday service. 13 16-117 MARCH 28, 2016 On -Time Performance • Ninety-five (95) percent of Community Connector transit vehicles will complete their established runs no more than 5 minutes early or late in comparison to the published timetables. The exception will be inclement weather such as a major snowstorm. • A transit vehicle is considered on time if it departs a scheduled time -point no more than 1 minute early and no more than 5 minutes late. The Community Connector's on- time performance objective is 90% or greater. The exception will be inclement weather such as a major snowstorm. Community Connector continuously monitors on-time performance. Service Availability • Community Connector distributes transit service so that 98% of all residents in the City of Bangor's urbanized area are within a 3/ mile walk of bus service. Community Connector distributes transit service to other communities on a contract basis. The extent of service is based on the amount of financial support from these communities as well as federal and state financial support. Service to residents in the urbanized area of these communities within a 3/ mile walk of bus service is: Brewer: 100% Veazie: 100% Old Town: 100% Orono: 98% Hampden: 100% • Buses will stop at any safe intersection. 14 10. Service Policies Vehicle Assignment Policy 16-117 MARCH 28, 2016 • Bus assignments take into account the operating characteristics of buses of various lengths and loading capacity, which are matched to the operating characteristics of the route. Routes with lower ridership may be assigned smaller buses with lower loading capacities. Buses are assigned to routes on a more permanent basis. • Buses are replaced on a rotating basis, based on bus conditions and the availability of funds. Replacement buses will be assigned to all routes on an equitable, rotating basis such that no route will be favored by newer buses. Transit Amenities. All transit vehicles will continue to have equal amenities such as air conditioning and all routes will have equal amenities such as signs to the extent that permission to install signs can be obtained. 15