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HomeMy WebLinkAbout2024 Title VI Program revised1 Title VI Program Update GO Transit 926 Dempsey Trail Oshkosh, Wisconsin 54902 www.rideGOtransit.com (920)232-5340 Approved by the City of Oshkosh Transportation Committee on XXX XX, 2024 2 Table of Contents INTRODUCTION .......................................................................................................................... 3 A. Notice to the Public ............................................................................................................. 3 B. Complaint Form ................................................................................................................... 3 C. Active Lawsuits, Complaints or Inquiries Alleging Discrimination ............................... 4 D. Discrimination Complaint Procedure ................................................................................ 4 TITLE VI MONITORING PROCEDURES ................................................................................ 5 A. Levels of Service ................................................................................................................. 5 B. Quality of Service ................................................................................................................ 5 C. Corrective Action ................................................................................................................. 5 D. Monitoring Frequency ......................................................................................................... 5 PUBLIC PARTICIPATION PLAN ............................................................................................... 6 A. Process ................................................................................................................................. 6 SERVICE STANDARDS AND POLICIES ................................................................................ 8 A. Vehicle Capacity ............................................................................................................ 9 B. Route Headways ................................................................................................................. 9 C. On-Time Performance ........................................................................................................ 9 D. Service Availability .............................................................................................................. 9 E. Vehicle Assignment Policy ............................................................................................... 10 F. Transit Amenity Policy ...................................................................................................... 10 LANGUAGE ASSISTANCE PLAN .......................................................................................... 10 A. Background Information ................................................................................................... 10 B. Legal Basis for Language Assistance Requirements .................................................. 11 C. Evaluation - Four Factor Analysis .................................................................................. 11 D. Language Assistance Measures .................................................................................... 14 E. Monitoring and Updating GO Transit’s LAP Plan ......................................................... 14 NON-ELECTED BOARD........................................................................................................... 15 TITLE VI EQUITY ANALYSIS FOR CONSTRUCTION PROJECTS ................................. 15 3 INTRODUCTION This update of GO Transit’s Title VI Program has been prepared to ensure that the level and quality of GO Transit’s fixed-route and demand response transportation services are provided in a non-discriminatory manner and that the opportunity for full and fair participation is offered to GO Transit riders and other community members. Additionally, this document examines GO Transit’s need for services and materials for persons for whom English is not their primary language and who have a limited ability to read, write or understand English. GO Transit does not pass-through funds to sub-recipients. A. Notice to the Public To make GO Transit’s riders aware of its commitment to Title VI compliance, the following statement is posted on vehicles, website, brochures and main sales office: Title VI Notice: GO Transit is committed to ensuring that no person is excluded from participation in, or denied benefits of its services on the basis of race, color or national origin as protected by Title VI of the Civil Rights Act of 1964, as amended. If you believe you have been subjected to discrimination, you may file a written complaint with GO Transit – Attn: Title VI Complaints, 926 Dempsey Trail, Oshkosh, WI 54902. Please feel free to contact GO Transit for more info. B. Complaint Form Any person who believes that she or he has been discriminated against on the basis of race, color or national origin by GO Transit may file a Title VI complaint by completing and submitting the form below. This form is available at our administration offices or on our website (www.rideGOtransit.com). 4 C. Active Lawsuits, Complaints or Inquiries Alleging Discrimination There are no current complaints against GO Transit which allege discrimination on the grounds of race, color or national origin. D. Discrimination Complaint Procedure Each complaint which is received that alleges discrimination on the basis of race, color, or national origin will be investigated using the procedure below, whether it specifically references Title VI or not. The complainant will be notified within 7 days that their complaint has been received and is being investigated. This notice may include a request for additional information necessary to investigate the complaint (e.g., date or specific time of an incident). A written response of the determination will be provided to the complainant within 30 days whenever possible. If the investigation and determination cannot be completed within 30 days, the complainant will be provided with written notice including an explanation of the reason a longer time is required, and a deadline for a determination. If the allegation concerns a specific incident involving a driver or service representative, a preliminary investigation of the facts will be conducted by GO Transit’s Supervisory Staff. It should be noted that the downtown transit center and all of GO Transit’s buses and facilities are equipped with cameras. These cameras have proved to be extremely useful in resolving complaints about specific incidents. Supervisory Staff will make a preliminary determination about the facts, recommend any disciplinary measures, and transmit the complaint to the Transportation Director. For more general allegations – e.g., regarding GO Transit service design or fares – the Transportation Director will determine the appropriate member of senior staff to conduct the preliminary investigation and report the findings and recommendations for corrective action to the Transportation Director. The Transportation Director will review all complaints alleging discrimination on the basis of race, color, or national origin and the results of the preliminary investigation. The Transportation Director will make a determination as to whether the allegation of discrimination on the basis of race, color, or national origin was valid, and any corrective action that will be taken. Note that even if the allegation of discrimination is determined to be invalid, corrective action may still be warranted in some cases. The Transportation Director will provide his or her findings in writing to the complainant, include whether the allegation of discrimination was found to be valid, and corrective actions that the GO Transit has taken or promises to take. The letter will inform the complainant of the opportunity to provide additional information that may lead GO Transit to reconsider its conclusions and of the complainant’s right to file a complaint with the Federal Transit Administration (FTA). 5 A person may also file a complaint directly with the Federal Transit Administration, at: Federal Transit Administration Office of Civil Rights 1200 New Jersey Avenue SE Washington, DC 20590 Title VI Complaint Form TITLE VI MONITORING PROCEDURES The following procedure will be followed in monitoring the level and quantity of transit service provided to minorities in the Oshkosh area in compliance with Title VI regulations. For monitoring purposes, minority areas will be defined at the census tract level since more disaggregate data is not available. All minority tracts will be monitored. A. Levels of Service To assess level of transit service to minority areas, headways, vehicle loads, vehicle assignment, service access, and distribution of amenities will be compared with service policies and standards for the entire system. The standards will be as defined in the most recent Transit Development Plan (TDP). All bus routes are comprehensively evaluated approximately every 5 years as part of the TDP process. The level of service provided to minority areas is also analyzed during the TDP process. Census and service data is presented in the final TDP document. The final TDP document is available at GO Transit’s office and on our regional planning commission’s website. TDP documents are also available on GO Transit’s website. B. Quality of Service Quality of service is currently monitored through public comments and passenger surveys designed to provide information about passenger demographics, trip purposes, and service ratings. For purposes of monitoring the quality of transit service in minority tracts, passenger surveys are analyzed by route in order to identify responses from these areas for comparison with responses from non-minority areas. C. Corrective Action Where inequities in service are identified or perceived by transit users in minority areas, a review of corrective action will be undertaken. Actions involving service level changes will be addressed through the existing decision-making structure. This structure includes public notification of and involvement through Transportation Committee meetings. D. Monitoring Frequency An assessment of service level, vehicle assignment, load factors, distribution of facilities, and service access in minority areas was done in the original Title VI Documentation for the Oshkosh Area in 1978 and updated in subsequent submissions. Future monitoring reviews will be undertaken when major service changes occur, upon publication of new census information, and during the Transit Development Plan process. 6 PUBLIC PARTICIPATION PLAN A. Process The GO Transit’s public participation process includes meaningful access during monthly board meetings, written materials (route maps & pamphlets), transit center information stations, GO Transit’s website and social media (Facebook, Instagram, & X (formerly known as Twitter)). The GO Transit’s Transportation Committee meets monthly, with all meetings open to the public. Time is provided for the public to comment on any issues at each meeting. Board meetings are held during the operating hours of GO Transit buses and paratransit vehicles to improve access for riders. Service and fare change notices are sent directly to persons and organizations that may be impacted (including service changes and fare increases). Persons and organizations can request notification of future meetings and there is no charge. An archive of Transportation Committee (formerly the Transit Advisory Board (TAB)) agendas and meeting minutes are posted on the City of Oshkosh’s website. Beyond monthly Transportation Committee meetings, several other methods are used to communicate with riders. The GO Transit Route Map/Rider Guide is a printed map with guidance for using GO Transit services and includes information on how to contact GO Transit, as well as the web address and social media. Each year, 20,000 route maps are printed and distributed throughout the community. Maps are available at several key destinations in the City, on all transit vehicles, at the main office, and are mailed at no cost to requestors. GO Transit also publishes brochures that describe specific programs and services. These materials are available to riders at GO Transit’s main office, www.rideGOtransit.com, and are distributed to local agencies. GO Transit’s downtown transit center located at 110 Pearl Avenue provides another communication avenue with riders. The center is staffed one day a week. The transit center contains two outdoor informational stations. Each station contains travel information, notices to the public, contact information, and other communications applicable to the service. The transit center is centrally located in the City and many routes pulse into the center for transfers between runs. Each GO Transit bus contains an info display area. Maps, brochures, flyers and notices are placed on buses for display to riders. GO Transit’s website (www.rideGOtransit.com), X (formerly known as Twitter) and Facebook page also provide information to the public. The web content includes information on trip planning, paratransit programs, contact info, detours, news, and more. Public input is welcomed via the website and visitors are provided several options for contacting GO Transit (fax, mail, email, or phone). The website is designed to be clear and easy to use. 7 Proposed fare and service changes are announced to the public by the means described above, and public input is solicited far enough in advance for GO Transit to consider the comments, and make revisions based on the comments. In soliciting public input, GO Transit provides opportunities for interaction. Persons and organizations are afforded an opportunity to provide input in several ways: • Email • Telephone • Fax • In writing • GO Transit phone App • In person at public meetings located at City Hall or face-to-face meetings at GO Transit’s main office GO Transit’s ongoing public participation outreach methods to engage minority and Limited English Proficiency (LEP) populations include partnerships with community-based organizations, use of digital media and public participation techniques implemented during our transit development plan process. GO Transit has continuing partnerships with community-based organizations. We’ve provided travel training resources to World Relief, Lakeland Care District, the Winnebago Area Literacy Council and Oshkosh Housing Authority. We have ongoing meetings and contact with these groups to invite participation and communicate transit issues. GO Transit participates in community events that help us to engage minority and LEP populations. We attend an annual Back to School Fair that is designed to help families and children prepare for the upcoming school year. We also attend other public events, like the State of the City Address, that are designed to promote public participation and information sharing. GO Transit uses digital media as another avenue to engage participation. Our Facebook, X (formerly known as Twitter) and website pages all provide any member of the community the ability to contact us on their schedule. We post all information that is applicable to our riders (news, meetings notices, and planning events) to help notify all populations. We realize that not all community members have access to a computer. However, a 2020 rider survey showed that 75% of our riders have a smart phone and 83.8% of riders in Winnebago County, Wisconsin have access to the internet at home. GO Transit’s transit planning process (Transit Development Plan - TDP) contains its own Public Participation Plan. The PPP is developed by our MPO and identifies outreach efforts and public involvement opportunities. Techniques used to gain input from minority and LEP populations include involving stakeholders in the steering committee. This helps to disseminate information to populations that can be hard to reach. The MPO uses public notices in appropriate non-English languages and maintains contacts with local translators. TDP meetings are held at locations that are accessible and reasonably welcoming to all residents. Our 2023 TDP steering committee is made up of organizations and advocacy groups that represented a variety of community interests. The participant list 8 includes Making the Ride Happen (non-profit), UW-Oshkosh, Oshkosh Common Council, WisDOT and Winnebago County. We also identified other stakeholder groups and are engaging them. This list includes the Oshkosh Area School District, Fox Valley Technical College, Oshkosh Housing Authority, ESTHER (Empowerment Solidarity Truth Hope Equity Reform), Lutheran Social Services, Greater Oshkosh, Advocate Aurora Heath, Options for Independent Living, World Relief, ADVOCAP, Oshkosh Chamber, UW Heath, Boys and Girls Club and Lakeside Packaging Plus (sheltered workshop). The TDP process occurs approximately every 5 years. The results of the TDP drive GO Transit planning and policy decisions, so we place added effort to engage public participation during this critical process. GO Transit will continue to work with our MPO to develop and implement public engagement techniques for each planning process. Below is a summary of outreach efforts made since the last Title VI submission: • Facebook, Instagram, X (formerly known as Twitter) and website maintenance of information, as well as including opportunities for input • Start of new TDP and new customer survey • Annual attendance at community events (Back to School Fair, State of the City Address, etc.). Riders and community members visit booth to have informal discussions, ask questions and provide feedback • TDP plan process, included public participation plan with some efforts described above • Monthly Transportation Committee meetings, noticed to the public • Multiple group and individual travel trainings, where riders can provide feedback and ask questions SERVICE STANDARDS AND POLICIES GO Transit has developed the following service standards and policies: • Vehicle Capacity • Route Headways • On-Time Performance • Service Availability • Vehicle Assignment Policy • Transit Amenity Policy 9 A. Vehicle Capacity The table below lists standard capacity by the types of vehicles in GO Transit’s fleet Vehicle Type # in Fleet Seated Capacity Standing Capacity Total Capacity Wheelchair Capacity Total Capacity w/ wheelchairs 40’ New Flyer (XD40) 5 40 30 70 2 63 35’ New Flyer (XD35) 9 32 25 57 2 50 40’ New Flyer (DE40LF) 2 39 30 69 2 60 B. Route Headways Vehicle headway is the length of time it takes between two buses traveling in the same direction on a particular route. GO Transit’s fixed-routes are scheduled with 30-minute headways. All headway is consistent for the entire service day and week. GO Transit does add an additional bus specifically on routes 1 and 2 to accommodate increased demand related to North High School before school and at dismissal. These buses are available to all riders Routes Frequency for all Service 1, 2, 3, 4, 5, 6, 7, 8 & 9 30 Minutes Route 9 service to YMCA 30 Minutes – Upon Request C. On-Time Performance One of the most important service standards for GO Transit is on-time performance or adherence to published schedules. Reliability is one of the main characteristics of the GO Transit brand. A GO Transit bus is considered on-time if it departs a scheduled time point no more than 1 minute early or less than 5 minutes late. GO Transit’s on-time performance goal is 90%. D. Service Availability GO Transit currently provides service to all major destinations and most large employment centers within the City of Oshkosh. The majority of the City of Oshkosh’s 10 residents are within one quarter mile of bus service. GO Transit optimizes the funding and resources it receives to maximize its route coverage within the City of Oshkosh. Currently, over 85% of the dwelling units in the city are within ¼ mile of a bus stop. GO Transit frequently reviews its level of service and service coverage. Further opportunities to expand service coverage will be discussed when resources become available. E. Vehicle Assignment Policy Vehicles are rotated between routes daily and are not assigned to specific routes or areas of the City of Oshkosh. GO Transit frequently reviews the ridership of its routes and assigns the larger and smaller capacity buses to the areas with geographical / physical route limitations, and to whose ridership best matches these capacities. F. Transit Amenity Policy GO Transit has nearly 250 formal bus stops. GO Transit places bus stops every 2-3 blocks (approximately) and near major trip generators. There are also information displays placed at key locations along each route that provide stop times throughout the service day. GO Transit has a number of bus benches and shelters located throughout the service area. New shelters or bench installations are dependent on the ability to obtain the necessary right of way to locate the shelter, ridership activity and public requests. On private property, they are dependent upon a sponsoring business or other entity to provide maintenance and snow removal. LANGUAGE ASSISTANCE PLAN A. Background Information Limited English Proficiency (LEP) persons are defined as persons for whom English is not their primary language and who have a limited ability to read, write, speak, or understand English. Public transit is a key means of achieving mobility for many people with Limited English Proficiency (LEP). According to 2022 U.S. Census Data for Winnebago County, Wisconsin, 0.49% of transit-dependent riders aged 16 years and older were LEP persons. In comparison, 92.9% of transit-dependent riders aged 16 years and older spoke English as their primary language. Agencies that provide language assistance to persons with limited English proficiency in a competent and effective manner will help ensure that their services are safe, reliable, convenient, and accessible to those persons. These efforts may attract riders who would otherwise be excluded from participating in the service because of language barriers. Catering to LEP persons may also help increase and retain ridership among the agency’s broader immigrant communities in two important ways. 11 1) Agencies that reach out to recent immigrant populations in order to prepare a language implementation plan send a positive message to these persons that their business is valued; and 2) Community outreach designed to identify appropriate language assistance measures can also assist the agency in identifying the transportation needs of immigrant populations. B. Legal Basis for Language Assistance Requirements Title VI of the Civil Rights Act of 1964, as amended (42 U.S.C. 2000d), and its implementing regulations provide 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 otherwise subjected to discrimination under any program or activity that receives Federal financial assistance. The Supreme Court, in Lau v. Nichols, 414 U.S. 563 (1974), interpreted Title VI regulations to hold that Title VI prohibits conduct that has a disproportionate effect on LEP persons because such conduct constitutes national origin discrimination. Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency,” reprinted at 65 FR 50121 (August 16, 2000), 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. The Executive Order states that recipients must take reasonable steps to ensure meaningful access to their programs and activities by LEP persons. The U.S. Department of Transportation (USDOT) requires that recipients of USDOT funding take responsible steps to ensure meaningful access to the benefits, services, information, and other important portions of their programs and activities for individuals who are Limited English Proficient (LEP). USDOT recommends that recipients use the USDOT LEP Guidance to determine how best to comply with statutory and regulatory obligations to provide meaningful access to the benefits, services, information, and other important portions of their programs and activities for individuals who are LEP. C. Evaluation - Four Factor Analysis Recipients are required to take reasonable steps to ensure meaningful access to their programs and activities by LEP persons. While designed to be a flexible and fact- dependent standard, the starting point is an individualized assessment that balances the following four factors: 1. The number or proportion of LEP persons eligible to be served or likely to encounter an agency program, activity, or service; 2. The frequency with which LEP individuals come in contact with an agency program, activity, or service; 3. The nature and importance of the program, activity, or service provided by an agency to people's lives; and 12 4. The resources available to an agency and the cost to provide LEP Assistance. A summary of the results of GO Transit’s four-factor analysis is as follows: Factor #1: The number or proportion of LEP persons eligible to be served or likely to encounter a GO Transit program, activity, or service. GO Transit examined the US Census data from 2022 and was able to determine that approximately 4,475 or 7.1% of people (age 5 and older) within the City of Oshkosh spoke a language other than English. Of the 4,475 people reporting they speak a language other than English, less than 2.79% of total respondents speak English less than “very well.” LANGUAGE SPOKEN AT HOME (OSHKOSH, WI) Population 5 years and over 63,002 63,002 English only 58,527 92.90% Language other than English 4,475 7.10% Speak English less than "very well" 1,757 2.79% Spanish 1,225 1.94% Speak English less than "very well" 521 0.83% Other Indo-European languages 786 1.25% Speak English less than "very well" 266 0.42% Asian and Pacific Islander languages 1,950 3.10% Speak English less than "very well" 750 1.19% Other languages 514 0.82% Speak English less than "very well" 220 0.35% GO Transit surveyed transit riders in the Summer of 2023. In order to provide assistance to riders while completing the survey, there were survey administrators on board every bus and at our downtown transit center. According to this rider survey results, 11% of respondents said that English was not their primary spoken language. 0% of these riders responded that they did not speak English at all. Factor #2: The frequency with which LEP individuals come in contact with a GO Transit program, activity, or service. GO Transit assesses the frequency with which LEP individuals come in contact with services by communicating with staff and drivers that have or could possibly have contact with LEP persons. This includes documenting phone inquiries and discussions with drivers. In the previous four years, GO Transit has had no requests for interpreters or for translated documents. Each summer, drivers have contact with international students attending the University of Wisconsin Oshkosh. These students are supported by UWO staff and faculty until 13 they can independently use GO Transit services. Our experience with this population has shown that they tend to know enough English to communicate on the phone or with drivers. Additionally, GO Transit attends regional and local transportation coordination meetings where unmet transportation needs and solutions are discussed by various stakeholders. Beyond the communications and observations above, it is difficult to determine with certainty which LEP individuals require transit services and are also served by GO Transit programs. The map in Appendix 1 shows GO Transit bus routes and the location of the minority population in Oshkosh. GO Transit’s next Transit Development Plan (TDP) process will include an in-depth LEP study according to service area. Information gathered during the next TDP process will be included as an update to this plan. Factor #3: The nature and importance of the program, activity, or service provided by GO Transit to people's lives. Most customer service requests received by GO Transit personnel are for schedules, route information and for the sale of tickets and passes. Most transit riders are regular users who use only a portion of the bus system for their daily travel, making routine trips with little need for complex information. Requests for information about routes and schedules are most likely to be made by infrequent or new passengers to the system. This population could include recent immigrants, including those that are transit dependent, in non-English speaking households. Therefore, it is important to have language resources ready to enable service for these clients. GO Transit’s website, www.rideGOtransit.com, contains a language translator (Google Translate) where LEP passenger and potential riders can access basic information on routes and fares. Information about GO Transit and policies can be obtained and translated for LEP visitors through several agencies who translate on behalf of the Oshkosh community. These agencies include: ADVOCAP – Oshkosh Office 920.426.0150 2929 Harrison Street Oshkosh, WI 54901 Oshkosh Police Department 920.236.5700 420 Jackson Street Oshkosh, WI 54903 Oshkosh Area United Way 920.235.8560 36 Broad Street, Ste 100 Oshkosh, WI 54901 University of Wisconsin Oshkosh Office of International Education 920.424.0775 800 Algoma Blvd. Oshkosh, WI 54901 World Relief Fox Valley – Oshkosh Office 920.231.3600 404 N. Main St. Suite 302 Oshkosh, WI 5490 14 Factor #4: The resources available to GO Transit and the cost to provide LEP Assistance. GO Transit is a small urban public transit operator receiving Federal funds for transit operation under Section 5307. It is a sub-recipient of the Governor’s Apportionment from the Wisconsin Department of Transportation. Due to limited resources, GO Transit partners with local agencies, including those listed above, to address the needs of the LEP persons in our community. These agencies have been integral in helping students, refugees and other minority populations navigate the public transportation system that is currently provided by GO Transit. Because Oshkosh has a small population of LEP persons likely to use transit, the most cost-effective language assistance appears to be through the use of verbal and oral interpretation services. At this time, there have been no requests and it does not appear to be cost-effective to engage in translating and publishing route and schedule information into other languages. D. Language Assistance Measures GO Transit has or will implement the following LEP measures. • Provide picture cards to drivers with destination information for LEP riders; • Work with the United Way, Winnebago Area Literacy Council, and World Relief when refugees are located in our service area; • Notify drivers and other staff to continue to immediately communicate experiences involving contact with LEP individuals that may require language assistance; • Engage attendees at GO Transit public information meetings or hearings to ascertain the attendee’s ability to understand English by having a staff member greet and briefly speak to each attendee; • Include Google Translate feature on website • All staff computers (including dispatch) will bookmark Google Translate; • GO Transit will utilize Spanish and Hmong speaking interpreters provided by the Oshkosh Police Department and ADVOCAP as sources of assistance. • Incorporate the community’s language assistance resources into travel training program. E. Monitoring and Updating GO Transit’s LAP Plan GO Transit will update the LAP plan as required by U.S. DOT. At a minimum, the plan will be reviewed and updated when it is clear that higher concentrations of LEP individuals are present in the service area or when contact with LEP individuals becomes more frequent. Updates will include the following: 15 • The number of documented LEP person contacts encountered annually. • How the needs of LEP persons have been addressed. • Determination of the current LEP population in the service area. • Determine whether local language assistance programs have been effective and sufficient to meet the need. • Determine whether GO Transit’s financial resources are sufficient to fund language assistance resources needed. • Determine whether GO Transit has fully complied with the goals of this LAP Plan. • Determine whether complaints have been received concerning the agency’s failure to meet the needs of LEP individuals. Information gathered in the review will be used to update the LAP Plan, no less than every three years to coincide and be integrated with GO Transit’s submission of its Title VI Update to regulatory agencies. NON-ELECTED BOARD GO Transit is guided by a Transportation Committee. The Transportation Committee reviews fare changes, route revisions and policies. They provide a recommendation to the Common Council and advise GO Transit. Major route and fare changes are decided by the City of Oshkosh’s Common Council (elected officials). Recent board openings were publicized on buses, website and on GO Transit’s facebook page. Board openings were also shared during local advocacy coalition and Transportation Committee meetings. The City of Oshkosh encourages all community members to apply for and serve on advisory boards and committees. The table below shows the Transportation Committee’s membership by race. Body Caucasian Latino African American Asian American Native American Transportation Committee 7 0 0 0 0 Attached is the board approval of this submission. TITLE VI EQUITY ANALYSIS FOR CONSTRUCTION PROJECTS The current downtown facility was renovated in 2023 and further improvements are planned for 2024/2025. These improvements will not impact demographics within the service area. 16 Appendix 1