In Campaigns, DOT Complaint


Los Angeles County Metropolitan Transportation Authority

January 26, 2017

One Gateway Plaza,

Los Angeles, CA 90012-2952

Phillip A. Washington Chief Executi11e Officer 213.922.7555 Tel

213.922.7447 Fax 

Ms. Yvette Rivera Associate Director

Departmental Office of Civil Rights

Department of Transportation 1200 New Jersey Ave, SE

Suite W78-340 Washington, DC 20590

In Reply to Reference S-32 DOT #2017-0093


Subject: US DOT Letter of Title VI Complaint – Labor/Community Strategy Center Dear Ms. Rivera:

In your letter of December 1, 2016 regarding the Title VI complaint filed with your office from the Labor/Community Strategy Center (LCSC) it was advised that Metro engage with the LCSC in pursuit.of a voluntary resolution.

A first meeting between representatives of LCSC and me, Stephanie Wiggins, Deputy CEO, Daniel Levy, Chief Officer, Civil Rights Programs, and Alex Wiggins, Chief Officer, System Security and Law Enforcement was held in our office on January, 24, 2017. The meeting provided an opportunity for a full and frank exchange of views on the issues raised in the letter of complaint by the LCSC. We did find some common ground on the way forward, and Metro and LCSC agreed to keep the lines of communication open.

We explained to the LCSC representatives that our expectation in the past was that the Los Angeles Sheriffs Department (LASO) fare checkers enforced the law equally and did not engage in stop and frisk. If Metro were to have learned of such actions we would have put an immediate end to its implementation. The fare compliance staff now and in the past was directed to check all passengers at a given station, train or bus and no single race, gender or national origin would be targeted. Metro discussed the transition to a civilian (not sworn) fare compliance program now in progress. Metro explained the advantages of the administrative Transit Court over the previous processing of citations for adults at the Superior Court and explained our plan to also include young offenders in the program.

Metro provided a counter proposal in response to the four requests listed by the LSCS in their letter to Metro dated January 18, 2017 (attached). The first four elements of Metro’s proposal will ensure that fare compliance at Metro continues and honors the civil rights protections afforded to all Metro customers. Metro’s counter proposal contains these elements, several of which are underway:


  • Transition fare compliance function away from sworn law enforcement officers (Sheriff Deputies) to civilian fare compliance staff (now underway, transition scheduled to be complete by April, 2017).
  • Transfer the jurisdiction for young offender citations from the Superior Court to Metro’s non-criminal, administrative Transit Court with reduced penalties (Metro Board action to implement is scheduled for March 2017)
  • Implement Implicit Bias Training for all fare compliance staff
  • Implement a mystery shopper service for the fare compliance program to gather independent observations on the behavior of the fare compliance staff
  • As proposed by the LCSC, Metro will change the name of the program to”fare compliance” from “fare enforcement”
  • Conduct a review of the fare structure looking at the benefits or disbenefits of a variety of options including those advanced by the LCSC (i.e. reduced pass prices, free fares )

In addition, we were able to secure an opportunity for Mr. Eric Mann to address the Metro Board of Directors for three minutes as part of the response to my CEO report on January 26, 2017.

We look forward to continuing our shared dialogue with the LCSC and are hopeful that a voluntary and informal resolution of the complaint can be achieved. We will propose to the LCSC regular meetings to review fare compliance data beginning when the new system is fully in place (April, 2017)


Phillip A. Washington Chief Executive Officer

cc: Eric Mann, Director Labor/Community Strategy Center Jim McDonnell, Los Angeles County Sheriff

Courtney Wilkerson, Acting Associate Administrator FTA Bonnie Graves, Attorney-Advisor FTA

Dawn Sweet, Senior Equal Opportunity Specialist FTA Dan Levy, Chief Officer, Office of Civil Rights, Metro

Alex Wiggins, Chief Officer, System Security and Law Enforcement


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