Ms. Brenda Armstead, Investigations & Adjudication Team Director FHWA Office of Civil Rights 1200 New Jersey Avenue, SE Suite E-81 Washington, DC 20590 City of Middletown, Office of the General Counsel Office of Mayor Drew T. Daniel 245 deKoven Street Middletown, CT 06457 ‘Thursday, June 22, 2017 Re: Title VI ComplaintTitle V1 Complaint Middletown Transit District ‘Complainant(s) Name: Mayor Daniel T. Drew. on behalf of the City of Middletown Complainant(s) Addvess: 245 deKoven Drive, Middletown, CT, 06457 ‘Complainant(s) Phone Number: Work: (860) 638-4801. Complainant's Representatives Name: Brig Smith Adress; 245 deKoyen Drive, Middletown, CT 06457 Phone Number: Work: (860) 638-4820 Relationship to Complainant; General Counsel to the City of Middletown Ageney that discriminated against you: Middletown Area Transit ‘Name: Middletown Area Transit Address: 340 Main Street, Middletown, CT 06457 ‘Telephone Number: 860-346-0212, 860-347-7657 Discrimination on the basis of: Disability and income status ig Status: This complaint was filed with the State Agency: Conneoticut Department of ‘Transportation and the Local Agency: Middictown Transit Authority Division of Contract Compliance, Manager Connectient Depariment of Transportation 2800 Berlin Turnpike Newington, Cl 06111 Andrew Chiaravallo, Admi Middle 340 Main Street Middletown, CT 06475 Previous ‘Title VI Complaints Filed with this Agency? NoDates that discrimination took place: June 3, 2017 through present day June 22, 2017 Explanation: Under the theory of Disparate/Adverse Impact, Middletown Area ‘Transit (“MAT”) discriminated against Middletown residents. According to the Conneeticut Department of ‘Transportation (*CTDOT™), elements of Proof for Disparate/Adverse Impact include: © Facially neutral poliey or practice that has affected the complainant © The policy or practice operates to disprop. 1y exclude members of the protected group © The policy or practice is a business necessity; or © There is an effective business altemative with a fess adverse impact According to MAT bylaws, Article XIII “Public Hearings”, whenever MAT shall abandon am routes, MAT shall hold a hearing on its intention to proceed according to the following procedures: 1) the change shall be embodied in a resolution: 2) Notice of the hearing shall be posted in a newspaper between ten (10) and fourteen (14) days prior to the hearing: and 3) MAT. shall act upon the resolution after the hearing, MAT cancelled Night Owl and evening paratransit services on Saturdays starting June 3, 2017. MAT di 1 to cancelling these services. not hold a public hearing pri Bederal Transit Administration C*FTA”) Circular 4702.18, Chapter IV-14(f) states that the ‘Transit provider shall evaluate the impacts of a proposed service change on minority populations which include comparisons of those included and excluded from the protected class that are affected by the service change, The analysis is performed to determine whether there is ¢ disparate impact on the basis of Race, Color, National Origin, or Low-Income Populations. To my knowledge, no such survey was performed. ‘The service cut affects citizens who ride at night as well as paratransit bus riders. Paratransit bus service provides individ ies a level of service similar to that of individuals without disabilities. Cancellation of this service without a study and public hearing is Disparate/Adverse Impact Discrimination, Attached please find: © MAT website announcing service cancellation © MAT By-laws © Federal ‘Transit Administration (“FTA”) Circular 4702.1B, Chapter IV-14(f).