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Civil Rights Policy

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Civil Rights Policy (EO 5) - Printable version

POLICY STATEMENT

The Los Angeles County Metropolitan Transportation Authority (LACMTA) is committed to ensuring that no person is excluded from participation in, or denied the benefits of its service on the basis of race, color or national origin under Title VI of the Civil Rights Act of 1964. In addition to Title VI of the Civil Rights Act of 1964, LACMTA also prohibits discrimination based on sex, age, disability, religion, medical condition, marital status or sexual orientation. 

PURPOSE

This policy ensures that LACMTA programs (including fares, routing, scheduling, and quality of transportation services) are operated without regard to race, color, national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation.  Frequency of service, age and quality of LACMTA vehicles assigned to routes, quality of LACMTA stations and location of routes will be determined solely on the basis of operational requirements. This policy will be updated annually. 

APPLICATION

This policy applies to all LACMTA employees, contractors, vendors, and customers.

1.0 GENERAL

LACMTA is committed to ensuring that no person is excluded from participation in its services, or subject to denial of LACMTA benefits on the basis of race, color, national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation. LACMTA is also committed to promoting environmental justice.  LACMTA will accomplish its goals by:

  • ensuring that the level and quality of transportation service is provided without regard to race, color, national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation;
  • promoting full and fair participation by all potentially affected populations in transportation decision making;
  • preventing denial, reduction or delay in the benefits of LACMTA programs and activities on the basis of race, color, national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation.
  • preventing denial, reduction, or delay of benefits related to programs and activities affecting minority and low-income populations; and
  • providing meaningful access to LACMTA services, programs, and activities by persons with limited English proficiency (LEP).

2.0 PROCEDURES

Any person who believes that he/she may have been discriminated against on the basis of race, color, national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation may file a complaint with LACMTA's Civil Rights Programs Compliance Department.

Patrons with limited English proficiency, who need assistance, may contact the Metro Customer Relations Department, located on the Plaza Level, One Gateway Plaza, Los Angeles, CA 90012-2932, or call 323.466.3876 (323.GO.METRO).

2.1  Reporting

The complaint must be filed within 180 days of the date of the alleged discrimination. Written complaints may be sent to LACMTA, One Gateway Plaza, Civil Rights Programs Compliance Department 99-21-4, Los Angeles, CA 90012, or an online Civil Rights Complaint Form (Attachment 1) may be accessed at LACMTA's website at www.metro.net.  Once completed, the complaint should be forwarded to LACMTA Customer Relations.

Any LACMTA employee who becomes aware of a discrimination complaint should immediately contact the Civil Rights Programs Compliance Department for handling.

In addition to utilizing the civil rights complaint process at LACMTA, a Complainant may file a complaint pertaining to race, color or national origin with the Federal Transit Administration (FTA), Office of Civil Rights, Region IX, 201 Mission Street, Suite 1650, San Francisco, California 94105-1839.

2.2   Reviewing

The Civil Rights Programs Compliance Department will review the complaint to determine whether it is within LACMTA jurisdiction based on the following criterion:  whether Complainant has alleged discriminatory treatment or harassment based on race, color, national origin, sex, age, disability, religion, medical condition, marital status or sexual orientation.

If the Civil Rights Programs Compliance Department determines it has jurisdiction, an investigator will be assigned to conduct an investigation within 24 hours of the review. The Complainant will receive an acknowledgement letter informing her/him whether the complaint will be investigated by the Civil Rights Programs Compliance Department.  All complaints will be investigated promptly and handled in a confidential manner. 

If jurisdiction is found not to exist in the Civil Rights Programs Compliance Department, but does exist in another department, the complaint will be forwarded to the appropriate department for resolution. The Civil Rights Programs Compliance Department will be notified of the steps taken to resolve the complaint.

2.3   Investigation Process

The investigator will take the followings steps to investigate the alleged discriminatory act:

  • contacting the department management where the alleged discrimination took place to determine if a departmental investigation has been initiated and the results of the investigation;
  • identifying and reviewing all relevant documents, practices and procedures to determine appropriate resolution; and
  • identifying and interviewing persons with knowledge of the alleged discrimination, such as the Complainant; witnesses; others identified by the Complainant; people who may have been subject to similar activity; or others with relevant information.

The investigation process and final investigative report is generally completed within 120 days. If no policy violation is found, and the Complainant wants to appeal the decision, he/she may appeal directly to LACMTA, Manager of Civil Rights Programs, One Gateway Plaza, 99-21-4, Los Angeles, CA 90012.

2.4  Subsequent Complaints and Amended Charges

Any subsequent complaint or amended charge should be filed utilizing the Civil Rights Complaint Form.  Amended charges can also be submitted via email or other written format. The Civil Rights Programs Compliance Department will review each subsequent complaint or amendment to determine whether the subsequent complaint should stand on its own or be incorporated into the original complaint and investigation.

2.5  Completion of Investigation

Upon completion of the investigation, the Investigator prepares a final investigative report for the Equal Employment Opportunity (EEO) Program Manager with a copy to County Counsel and the Manager of Civil Rights Programs. All principle parties receive written notification of the investigative findings.

2.6  Implementation of Remedial Actions

If a policy violation exists, appropriate remedial steps will be taken immediately.

3.0 DEFINITION OF TERMS

Title VI - Title VI of the 1964 Civil Rights Act prohibits discrimination on the basis of race, color, or national origin by recipients of federal financial assistance.

Equal Opportunity - requirement of non-discrimination in transit services with regard to race, color, or national origin in accordance with Title VI of the 1964 Civil Rights Act, as amended. LACMTA also prohibits discrimination based on sex, age and disability religion, medical condition, marital status, or sexual orientation.

Discrimination - any act or failure to act, whether intentional or unintentional, which has the purpose or effect of limiting, excluding, or denying a person transit services or benefits because of race, color, national origin, sex, age, disability, religion, medical condition, marital status, or sexual orientation.

Environmental Justice - efforts made to prevent minority communities and low-income communities from being subject to disproportionately high and adverse environmental effects. 

4.0 RESPONSIBILITIES

The Civil Rights Programs Compliance Department maintains a log of all complaints received. The log includes the date the complaint was filed; a summary of the allegations; the status of the complaint; and actions taken by LACMTA to resolve the complaint.

5.0  FLOWCHART

Not Applicable

6.0 REFERENCES

  • Title VI of the 1964 Civil Rights Act
  • FTA Circular 40702.1B
  • Unruh Civil Rights Act of 1959 

7.0 ATTACHMENTS

1.  Civil Rights Complaint Form 

8.0 PROCEDURE HISTORY

03/01/08        Policy memo.

01/08/09        Policy updated and revised into GEN 5 format template with the purpose of recognizing the importance of LACMTA's obligation regarding non-discrimination. Entire Procedure section revamped and streamlined to reflect current practices.

05/06/10        Policy updated to reflect administrative changes.

02/10/11        Revised to include protected classes sex, age and disability.

11/30/11        Policy renamed from Title VI Statement of Policy to Civil Rights Policy. Policy revised to reflect administrative changes. Updated § 6.0 References.  Under References: added the Unruh Civil Rights Act of 1959 and removed the Limited English Proficiency Outreach Plan.

10/17/12        Added more protected classifications; changed responsibility from EEO Manager to the Manager of Civil Rights Programs; expanded the investigation process from 90 to 120 days; updated FTA Circular reference; added Environmental Justice definition; added complaint form attachment

Policy Section Revision Reason

Throughout

Changed responsibilities from EEO Manager to the Manager of Civil Rights Programs

Administrative

Throughout

Added: religion, medical condition, marital status, sexual orientation

Expands protected class to conform w/state and federal practices

§3.0 Definition of Terms

Environmental Justice - efforts made to prevent minority communities and low-income communities from being subject to disproportionately high and adverse environmental effects. 

Works in tandem with Title VI

§7.0 Attachments

Added Civil Rights Complaint Form as Attachment 1

Administrative 

 

Summary of Policy Changes

Civil Rights Policy (EO 5)

NOTE:  THIS SUMMARY COVER SHEET IS INTENDED FOR REVIEW PURPOSES ONLY. IT IS NOT INTENDED FOR INTERPRETATION OF POLICY GUIDELINES. REFER TO POLICY DOCUMENT FOR ACTUAL GUIDELINES AND PROCEDURES.

Rev. 11/12


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