GBNRTC's Title VI Policy

The Greater Buffalo-Niagara Regional Transportation Council (GBNRTC) assures that no person shall on the grounds of race, color, national origin, or gender, as provided in Title VI of the Civil Rights Act of 1964 and related statutes be excluded from participation in, or be denied the benefits of, or be otherwise subjected to discrimination under any program or activity for which the GBNRTC receives Federal financial assistance.

As the metropolitan planning organization (MPO) for the two-county region, the GBNRTC is committed to making Title VI and environmental justice a part of our planning process, integrated in all our programs and plans, and a guide for our public participation efforts. View our Environmental Justice and TItle VI Plan.

Title VI Complaint Procedures

Any person who believes them— or a specific class of persons—were subjected to discrimination on the basis of race, color, or national origin in the programs and activities of the Greater Buffalo Niagara Regional Transportation Council may file a Title VI complaint.

A complaint must be filed not later than 180 days after the date of the last instance of alleged discrimination, unless the time for filing is extended by the FHWA or FTA. You may contact the FHWA Headquarters Office of Civil Rights (HCR) office with questions by calling 202-366-0693. You may contact the Greater Buffalo Niagara Regional Transportation Council with questions at 716-856-2026 or staff@gbnrtc.org.

The complainant may use the Title VI complaint form, available through the following link: Complaint Form

Complaints may be sent to the Greater Buffalo Niagara Regional Transportation Council at:

For further information on filing a Title VI complaint visit FHWA Office of Civil Rights Questions and Answers

Legislation and Guidance

Presidential Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations”, directs federal agencies to identify and address the disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority and low-income populations.

Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency”, requires federal agencies to improve access to federally conducted and assisted programs and activities for persons who, as a result of national origin, are limited in their English proficiency.

Both executive orders are based on the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, sex, or national origin, by government agencies that receive federal funding.

Community Outreach and Participation

Meaningful participation of minority, low-income, limited English proficiency (LEP) populations and others is a critical component to implementing Title VI/Environmental Justice. Through effective public participation, the GBNRTC is able to identify and understand the needs of the community as a whole, and incorporate those needs into transportation plans and programs.

The GBNRTC Public Participation Plan outlines public participation policies and procedures the GBNRTC uses to develop transportation plans and programs and describes effective strategies for encouraging the public to participate in planning activities.

The Greater Buffalo Niagara Regional Transportation Council (GBNRTC), the metropolitan planning organization (MPO) for Erie and Niagara Counties, is continuing the process of updating the GBNRTC Public Participation Plan (PPP) with an additional round of public survey opportunity.

The PPP guides the GBNRTC’s efforts to ensure that everyone has access to the transportation planning process. The PPP covers a full range of opportunities for members of the public and stakeholders to engage in the transportation decision-making in the region, from in-person and virtual MPO meetings, social media posts, and other public engagement events.

Social Economic Environmental Justice Analysis and Assessment

As part of the objectives contained within the Transportation Equity Statement and Title VI Plan, GBNRTC uses Geographic Information Systems, other tools and data sources to determine the needs of traditionally underserved communities and to assess how regional transportation programs and plans impact different population groups in the region.

The criteria used to identify location and concentrations of Communities of Concern (EJ) includes the following American Community Survey (ACS) 2018-2022 variables above the Regional Thresholds values for each census tract:

RACE AND ETHNICITY POPULATION GROUP (REGIONAL THRESHOLD: 24.59%)

• This population group includes the following racial categories: Black or African American, American Indian and Alaska Native, Asian, Native Hawaiian and Pacific Islander, Some Other Race, Two or More Races, and Hispanic or Latino.

YOUTH POPULATION GROUP UNDER 18 (REGIONAL THRESHOLD: 20.06%)

• This population group includes the total population of those under 18 years.

ELDERLY POPULATION GROUP 75 & OLDER (REGIONAL THRESHOLD: 7.85%)

• This population group includes the total population of those 75 years and older.

LIMITED ENGLISH PROFICIENCY POPULATION GROUP (REGIONAL THRESHOLD: 3.72%)

• This population group refers to anyone above the age of 5 who speaks English less than “very well,” as classified by the U.S. Census Bureau.

DISABLED POPULATION GROUP (REGIONAL THRESHOLD: 13.98%)

• This population group includes total civilian noninstitutionalized population with a disability.

LOW INCOME POPULATION GROUP BY FEDERAL POVERTY LEVELS (REGIONAL THRESHOLD: 28.96%)

• This population group includes the total population for whom poverty is determined. Population with total income below the 200% Federal Poverty Levels (FPL). FPLs are used to determine eligibility for federal programs.

NATION OF BIRTH, ORIGIN POPULATION GROUP (REGIONAL THRESHOLD: 6.74%)

• This population group represents the total population of those who are foreign born.

ZERO CAR HOUSEHOLDS GROUP (REGIONAL THRESHOLD: 11.80%)

• This population group represents households with no vehicle available for use by household members.

FEMALE SINGLE PARENT HOUSEHOLDS GROUP (REGIONAL THRESHOLD: 6.23%)

• This population group represents female householder, with no husband present, family households, with children under 18 years of age.

COMMUNITIES OF CONCERN (COCs)

• The population groups are used to identify location and concentrations of Communities of Concern (COCs). They are combined into a single database and displayed showing census tracts that are above regional thresholds for each value.

Studies/Surveys

• Onboard Travel Survey 2021

• Coordinated Human Services Transportation Plan 2023-2027

Online Resources

• Environmental Data Mapping Tools

• USDOT Justice40

• An Overview of Transportation and Environmental Justice

• FHWA Environmental Guidebook

• FHWA Environmental Policy Statement (1994)

• FHWA Transportation Planning Capacity Building “Peer Program” Identifying and Engaging Low Literacy and Limited English Proficiency Populations in the Transportation Decisionmaking Process

• Transportation & Environmental Justice: Case Studies (December 2000)

• Transportation & Environmental Justice: Effective Practices

• Implementing Title VI Requirements in Metropolitan and Statewide Planning

• Environmental Justice in Transportation: Emerging Trends and Best Practices

General Questions and Concerns

Greater Buffalo-Niagara Regional Transportation Council, 438 Main Street Suite 503, Buffalo, NY 14202, 716.856.2026, staff@gbnrtc.org