Route 9 Davidson County Business 85 Service Equity Analysis

Route 9 Davidson County Business 85 Service Equity Analysis Transportation is not an end in and of itself, but a means to providing access to opportunity. Source: LivingCities.org 1 P a g e

This analysis was conducted in compliance with Federal Transit Administration (FTA) Circular 4702.1A which requires that under Title VI of the Civil Rights Acts of 1964, the Piedmont Authority for Regional Transportation herein referred to as PART; shall evaluate significant system-wide service and fare changes and proposed improvements at the planning and programming stages to determine whether those changes have a discriminatory impact on minority and low income populations. In its Title VI Program Submittal to FTA, PART must provide a copy of the equity evaluation of any significant service changes and fare changes implemented since the last submission. Reinforced in the March 8, 2011 FTA Dear Colleague letter PART is subject to the following: Recipients to which this chapter applies shall evaluate significant system-wide service and fare changes and proposed improvements at the planning and programming stages to determine whether those changes have a discriminatory impact. For service changes, this requirement applies to "major service changes" only. The recipient should have established guidelines or thresholds for which it considers a "major" change to be. Often, this is defined as a numerical standard, such as the change that affects 25 percent of service hours of the route." i P a g e

Table of Contents Summary...... ii Existing Conditions...... 1 Route Analysis...... 2 Equity Analysis...... 8 Proposed Route Revisions...... 10 Methodology...... 11 Ridership Potential...... 11 Ridership Projections...... 12 Transit Propensity...... 12 Equity Analysis...... 13 Service Standards...... 14 Regional Demographics...... 16 ii P a g e

Summary Route 9 - Davidson Business 85 Express has experienced poor ridership since a service reduction occurred in July 2012 due to funding shortages. In the spring of 2015 the PART Planning Department began an analysis of the transit service within the Business 85 Corridor. The conclusions were: Ridership projections and potential indicate great ridership numbers if service could be expanded; Davidson County Transportation System (DCTS) had established successful circulators in Lexington and Thomasville and a connector service between the two cities. These successes support the view that there is a greater need and strong foundation for more transit service in the corridor; and Despite the fact that most of the very limited ridership traveled to Greensboro, the actual Davidson to Guilford County commuting patterns and out of county trips provided by DCTS were to High Point and not Greensboro. After reviewing all the available data the recommendations are to: 1. increase service in the corridor to four morning, two mid-day and four evening trips; 2. revise the route to go to downtown High Point eliminating Route 9 service to Greensboro; and 3. extend service into uptown Lexington and downtown Thomasville. Below is a comparison of the service characteristics of the existing and proposed route: Current Service Service Characteristics: Takes 1 bus to operate 98.57 miles in length 1,600 revenue hours / annually 4 trips daily (2 N. bound and 2 S. bound) Proposed Service Service Characteristics: Takes 1 bus to operate 50.5 miles in length 2,016revenue hours / annually 10 trips daily (5 N. and 5 S. bound) iii P a g e

Demographic Information within ¼ mile of Each Stop Current Service Proposed Service People 22,622 3,525 Jobs 44,761 7,277 Low Income Families 44.20% 60.8% Families in Poverty 28.30% 45.4% Minority Population 48.60% 61.7% Households with no Vehicles 13.00% 17.2% Persons with Limited English 3.70% 4.5% Status Persons 65 years Old or Older 8.95% 12.6% Persons 18 years Old or Younger 16.80% 29.4% Persons with Disabilities 11.75% 17.5% Historical Route 9 Ridership Calendar Year Annual Total Monthly Average 2014 6,126 511 2013 6,605 550 2012 7,023 585 2011 13,966 1,164 2010 14,066 1,172 2009 11,754 980 2008 7084 1,012 Based upon current monthly ridership for Route 9 factoring in the increased level of service the projected ridership for the proposed Route 9 is: Projected Monthly Ridership 930 Projected Annual Ridership - 11,160 Based upon all known factors the potential ridership for the proposed Route 9 is: Potential Monthly Ridership 8,268 Potential Annual Ridership 99,218 iv P a g e

Existing Conditions Davidson US 52 (Route 8) and Davidson Business 85 (Route 9) began service in June 2008. Their design followed the trend established by PART in 2002. The routes were designed to provide commuter express service from Lexington and Midway into Winston-Salem and from Lexington, Thomasville, and Archdale into Greensboro. Connections to High Point where made via a transfer at a Hi tran stop on the southern outskirts of High Point. Route 9 ridership averaged 511 trips per month in 2014. Currently there are two morning trips (a north and southbound) and two evening trips (again a north and southbound). The route serves several medical and educational institutions before arriving at the Greensboro rail/bus depot. At its peak the route averaged 1,172 trips per month in 2011. In July 2012 the route experienced a service reduction. Overall PART s ridership peaked in 2011 with a monthly average of 48,326 and annual total of 579,916. Route changes system-wide caused an overall reduction in ridership. The decrease system wide bottomed out in 2013 and began to rise in 2014, while Route 9 continued to decrease. Route 9 was established using PART s original service goal of providing commuters express bus service from rural/suburban areas into the urban areas. Those urban areas were Winston-Salem and Greensboro. At that time commuter data showed a strong out-commuter from Davidson into Guilford and Forsyth. In the case of Route 9 it was assumed that the majority of the Davidson out-commuters where headed to Greensboro. High Point was served by Route 9 via a transfer point with Hi tran at the edge of their service area. Service schedules were setup to benefit rural county out-commuters and not riders interested in the reverse commute. However, over time Route 9 served more people heading to Davidson County Community College from urban Guilford County than in the opposite direction. In 2010 Davidson County Transportation Services began to operate a circulator system in Thomasville. They added a Lexington to Thomasville route and a Lexington Circulator route. Ridership on all three routes has been strong, exposing the local need for transit service. The strong ridership on the Davidson County local routes and the low ridership on the PART express route prompted PART to conduct a corridor analysis. 1 P a g e

Route Analysis From 2002 to 2015, the primary data source for designing PART s routes was county to county commuting data. This was supplemented with zip code data from large employers in Winston-Salem and Greensboro. Service was established along major transportation corridors and Park-n- Ride Lots were constructed at the edge of the service area. As you can see from the map to the right, Davidson County has the greatest out commute into Guilford County with Forsyth second. Out commuting to these two counties is 69% higher than all in commuting to Davidson County. Then in 2006, the Brookings Institute published a report linking the cost of housing and transportation to location affordability. This led to the development of a tool by the Center for Neighborhood Technologies, referred to as H + T, to show that the further you live from an urban area the higher your transportation costs and lower your housing costs are likely to be. And the closer you lived to an urban area the lower your transportation costs, higher your housing costs are likely to be. The data also revealed that, in many parts of the country, families were spending 55% to 65% of their income on housing and transportation costs. Figure 1: 2010 Commuting Patterns The map to the right clearly shows a lower H+T percentage for people living in Lexington, Thomasville and High Point and along the entire I-85 Business Corridor. Figure 2: H + T in the Business I-85 Corridor 2 P a g e

Following the 2010 census more data and tools to analyze that data were released. One tool is the Longitudinal Employer-Household Dynamics Program or LEHD data for short. It is a robust tool that allows the user to see where people in a particular geographical area go to work and where people are coming from who work in a particular geographical area. The map below depicts where people who live in Davidson County work. With this refined view of the data we can see that a greater proportion of the 15,722 people who commute from Davidson to Guilford County work in High Point than work in Greensboro. 1 Figure 3: Where LEHD Data Davidson Depicting County where Residents Davidson Work County Residents Work To determine potential ridership, a Catchment Area Process was used. Two catchment areas were defined: a drive radius around park-n-ride lots (at 5- and 10-minute intervals) and a 5- minute walk radius around bus stops. These areas are depicted in the figure below. The analysis uses socio-economic data taken from the Piedmont Triad Regional Travel Demand Model. Data from the analysis is then applied to ridership projection formulas. There is very little empirical research on ridership projections for commute express services. PART designed a methodology through combining its own research in Park-n-Ride catchment areas, knowledge of ridership habits and industry standards for projecting urban fixed route ridership. The formulas are detailed in the Methodology section. 3 P a g e

PART forecasts ridership and potential ridership. The ridership projection takes the current ridership and applies a factor based on the increase or decrease in service. The potential ridership projection uses the total number of people and jobs in the catchment area and applies several factors to estimate the number of people who might access the service. The results of the ridership projection calculations are: Based upon current monthly ridership for Route 9 factoring in the increased level of service the projected ridership is: Projected Monthly Ridership 930 Projected Annual Ridership - 11,160 Based upon all known factors the potential ridership for Route 9 is: Potential Monthly Ridership 8,268 Potential Annual Ridership 99,218 The projected ridership is close to twice the current ridership. The potential ridership is in line with the current ridership of PART s Route 3, the High Point Express. Figure 4: Catchment Areas for Route 9 Analysis The final element that is examined is a measure of Transit Propensity. This calculation uses the same socio-economic data as discussed above and projects the level of service that could be supported by a given area or corridor. The formula is detailed under the Methodology section. The Transit Propensity shows areas within Lexington, Thomasville and downtown High Point that could support 60-minute to 30-minute frequencies. Refer to Figure 5. 4 P a g e

Table 1: Persons, Jobs and Students within a 5 and 10 minute drive of a Park-n-Ride Lot Socio-economic Data 2013 2020 5 min 1) 10 min 1) 5 min 1) 10 min 1) Population 86,363 194,512 89,652 201,311 Highway Retail 5,799 8,268 6,119 8,704 Industry 18,550 33,715 19,291 34,840 Employment 2) Students Retail 11,676 19,218 12,130 19,909 Service 15,533 24,267 17,740 27,454 Office 6,107 7,851 6,327 8,165 School/University 2,704 6,266 2,853 6,564 K12 13,098 35,279 13,356 36,035 College/University 6,102 10,234 6,892 11,559 5 P a g e

Employment FINAL / Route 9 Davidson County Business 85 Service Equity Analysis Table 2: Persons, Jobs and students within a 5-minute walk of a bus stop or Park-n-Ride Lot Socio-economic Data South Lexington Depot District Davidson Co. Transportation DCCC Thomasville GTCC High Point Hitran Terminal High Point Regional Hospital 2013 2020 2013 2020 2013 2020 2013 2020 2013 2020 2013 2020 2013 2020 2013 2020 2013 2020 Population 30 38 104 250 82 90 7 7 210 213 128 130 71 96 77 78 709 902 Hwy. Retail 0 3 35 41 9 10 0 0 3 3 2 2 89 90 5 5 143 154 Industry 85 91 64 74 3 4 0 0 7 8 5 9 612 614 3 3 779 803 Retail 1 4 54 57 3 4 0 0 15 16 18 19 799 808 22 23 912 931 Service 8 21 161 187 4 7 0 0 9 13 27 30 402 431 316 353 927 1042 Office - 1 60 62 30 31 0 0 4 4 0 1 128 133 15 17 237 249 School/ - - - - 41 6 703 793 14 14 65 71 2 2 - - 789 886 University Total Students K12 - - - - 41 42 2 2 104 106 233 237 14 15 - - 394 402 College/ University - - - - - - 4,100 4,632 - - 341 385 - - - - 4,441 5,017 6 P a g e

Figure 5: Transit Propensity for Route 9 Analysis 7 P a g e

Equity Analysis This analysis complies with Title VI of the Civil Rights Acts of 1964 and the Federal Transit Administration (FTA) Circular 4702.1A which requires transit systems to evaluate significant system-wide service and fare changes and proposed improvements at the planning and programming stages to determine whether those changes have a discriminatory impact. PART uses a tool called Remix for routing planning and title VI analyses. The methodology for the Equity Analysis is found at the end of the report. The results of the analysis are in the table below. Route Population (within 1/4 mi) Low Income Before Minority Trips (Annually) Existing Morning Run 6,751 44.2% 49.6% 252 Existing Evening Run 6,751 44.2% 49.6% 252 01 S. Lex P&R AM 0 0 02 Lex to HP 0 0 03 Lex to HP 0 0 04 Lex to HP 0 0 05 S. Lex P&R PM 0 0 All Changes 6,750 44.1% 49.6% 504 Route Population (within 1/4 mi) Low Income After Minority Trips (Annually) Existing Morning Run 0 0 Existing Evening Run 0 0 01 S. Lex P&R AM 3,409 61.1% 60.8% 252 02 Lex to HP 2,507 62.8% 61.7% 252 03 Lex to HP 2,507 62.8% 61.7% 252 04 Lex to HP 2,507 62.8% 61.7% 252 05 S. Lex P&R PM 2,868 60.6% 59.5% 252 All Changes 3,590 60.8% 60.8% 1,260 Difference People-Trips Route (Population * Trips) Low Income People-Trips Minority People-Trips Change Borne By Low Income Change Borne by Minorities Existing Morning Run -1,701,252-751,301-843,192 44.2% 49.6% Existing Evening Run -1,701,252-751,301-843,192 44.2% 49.6% 01 S. Lex P&R AM 859,068 524,613 522,396 61.1% 60.8% 02 Lex to HP 631,764 396,795 389,592 62.8% 61.7% 03 Lex to HP 631,764 396,795 389,592 62.8% 61.7% 04 Lex to HP 631,764 396,795 389,592 62.8% 61.7% 05 S. Lex P&R PM 722,736 437,702 429,912 60.6% 59.5% All Changes 74,592 650,099 434,700 871.5% 582.8% 8 P a g e

The route potentially serves fewer people overall, because it does not continue on into Greensboro. However it provides more service at a greater frequency to persons in poverty and persons who have no other means of transportation. Within ¼ mile of each stop there are: Existing Route Proposed Route People 22,622 3,525 Jobs 44,761 7,277 Low Income Families 44.20% 44.23% Families in Poverty 28.30% 44.23% Minority Population 48.60% 61.60% Households with no Vehicles 13.00% 16.50% Persons with Limited English Status 3.70% 4.73% Persons 65 years Old or Older 8.95% 12.60% Persons 18 years Old or Younger 16.80% 29.80% Persons with Disabilities 11.75% 17.37% The tool used to conduct the Title VI analysis also projects ridership based on people within a ¼ mile of a bus stop. The calculation is similar to the one conducted and detailed in this analysis. The difference is that it uses total population, and PART s methodology focuses on people working in the health and education industries and people likely to use transit. 9 P a g e

Proposed Route Revisions The data makes it clear that most of the commuters leaving Davidson and heading to Guilford are headed to High Point or farther north to the NC68/Airport area. Ridership potential is greater than current ridership and is capable of supporting hourly service. Through discussions with Davidson County officials and service providers, it was determined that connecting the PART route to transfer points for the existing DCTS circulator and connector services will provide better and less expensive connections to High Point. Therefore the following changes are recommended for Route 9: 1. Increase the number of trips from four to four morning, two mid-day and four evening; 2. Revise the route to go to downtown High Point eliminating the service to Greensboro; and 3. Extend service into uptown Lexington and downtown Thomasville. The proposed route is shown to the left and the schedule is shown below. The revised route will take 400 more revenue hours to operate and provide continuous service throughout the day. The schedule was structured to accommodate persons traveling north to downtown High Point in the mornings and south to Davidson County in the afternoon. This didn t allow optimal timing at transfer points with the circulators and PART Route 3 Express. The average wait time for transferring is 22 minutes. 10 P a g e

Methodology Ridership Potential The Ridership Potential Equation was developed by PART. It takes the total number of potential transit riders in a corridor and adjusts for the percentage of people who commute in and out of the county and factors in the regional percentage of people who currently use public transit. From Out-Commute: CA x OC% x RMS = TOCR 78,971 x 9.1% x 0.83% = 63.6 CA = Total Population within a 5-minute drive of a park-n-ride lot OC = Out of County Commuters RMS = Regional Mode Split for Transit Ridership TOCR = Total Riders from Out of County Commuters TOCR + TICR = TPR 63.6 + 133.3 = 196.9 TPR = Total Number of Potential Riders From In-Commute: AES x RMS = TICR 6,058 x 0.83% = 133.3 AES = Total number of employees and students with a 5-minute walk of a park-n-ride lot and stop, includes the entire college or hospital campus RMS = Regional Mode Split for Transit Ridership TICR = Total Riders from Into County Commuters TPR x TpD x DpM = TPM 196.9 x 2 x 21 = 8,268 TpR = Total Number of Potential Riders TpD = Trips per Day DpM = Days per Month TPM = Trips per Month 11 P a g e

Projected Ridership The Projected Ridership Formula takes the existing route ridership and applies an increase or decrease to ridership based upon the increase or decrease in the level of service. For example, the method assumes that an increase in service frequency from every 60 minutes to every 30 minutes would increase the ridership. CR x LOSF = PR 511 x 1.82% = 930 CR = Current Monthly Ridership LOSF = Level of Service Factor (elasticity rate applied based on increase/decrease of headway) PR = Projected Ridership Transit Propensity The Transit Propensity Measure is calculated as follows: Transit Propensity = Population + (2 x Employment) Employment projections are doubled based on guidance from the Transportation Research Board s (TRB) Transit Capacity and Quality of Service Manual. The employment projection is added to the population forecast to estimate the number of people that could support transit service (i.e. transit propensity). The combined employment and population figures were generated for Traffic Analysis Zones (TAZs) within the model area and for U.S. Census block groups outside the model area. The figures were then divided by the number of square miles for each TAZ or block group to generate transit-supportive densities for each county. The transit densities were then grouped into transit service classifications presented in TRB s Transit Capacity and Quality of Service Manual. These classifications, and their associated transit supportive densities, are listed in Figure 5 and illustrated in the graph below. 12 P a g e

Equity Analysis Data Sources Graph 1: Transit Supportive Densities and their associated service levels Census data is provided by the US American Community Survey, 2008 2013. Population is coded by table B03002, field B03002001. Low income status is set at 100%, 150% or 200% of the US poverty level, depending on your individual agency. This is coded by the appropriate fields in table C17002. Minority status is coded by table B03002, by subtracting the white, non-hispanic population (B03002003) from the total population (B03002001). Service area is a set of block groups determined by a shapefile your agency provides. Map and routing data is provided by OpenStreetMap, Mapbox, and Valhalla. Methodology 1. Determine the population near a route, including low income and minority %. For each route, build a shape that represents the area within quarter mile of any of its stops. Intersect the catchment area with 2013 ACS Census data. Get a list of block groups and the percentage overlap with each. For each block group, take the percentage of overlap and multiply it by the block group s statistics. Get the population, minority population, and low income population for each group and sum them together. This is the total population a route could serve. 2. Compare the number of people-trips, before and after. Multiply the population near a route times the number of trips it makes (per year) to get people-trips. Repeat for low-income and minority populations to get low income people-trips and minority people trips. 13 P a g e

Compare these numbers between the before and after versions of the route, to get a set of people-trip differences. We match before and after using routes that have the same name. 3. Determine the total difference in people-trips across the transit system. Repeat the process above for every route in the transit system. Sum together the difference in people trips. This will return three numbers: total difference in people-trips, total difference in low-income people-trips, and total difference in minority people trips. 4. Calculate the change borne by low-income and minority populations. Divide the total difference in low-income people trips by the total difference in people-trips to get the percentage of change borne by those with low incomes. Repeat for minority people-trips. 5. Compare the percentage change to the average in the service area. Calculate the average percentage of low-income and minority populations across the entire service area. Subtract from the change borne by those populations. Get two final numbers: the delta between the impact this set of transit changes had on low income and minority populations compared to any average change. Additional Raw Data In addition to the methodology outlined above, a set of raw data is attached that includes: A list of Census block groups in the service area with population, low-income, minority information for each. A before and after count of trips in each block group. A service-area-wide average of minority and low-income populations PART s Service Standards from Title VI Plan adopted September 13, 2013 Vehicle Load Standard PART operates regional express bus transportation services throughout a 10-county region. Due to work shifts that vary the Vehicle Load Standard is applied equally between peak and off-peak times. Also, with limited service for Saturday and Sunday PART applies the same standard for weekend service as well. The average of all loads during the peak and off-peak operating periods should not exceed a load factor of 1.4. With the 24 mini-bus this represents 18 seated, 7 standing for a total of 25 passengers. For the 35 low floor bus this represents 31 seated, 12 standing for a total of 43 passengers. For the 40 low floor bus this represents 39 seated, 15 standing for a total of 54 passengers. 14 P a g e

Vehicle Type Average Passenger Capacities Seated Standing Total Load Factor 24 mini-bus 18 7 25 1.4 35 low floor bus 31 12 43 1.4 40 low floor bus 39 15 54 1.4 Vehicle Headways Weekday PART service operates to and from four primary transportation centers. They include the Winston-Salem Transportation Center, the Greensboro Depot, the High Point Broad Ave. Terminal and the PART Hub near the PTI Airport. On the primary urban routes during peak hours the most frequent service is provided on 30 minute headways. For urban routes during off-peak times frequency is provided every 60 minutes. For the rural areas during peak hours the most frequent service is provided on 36 minute headways. During off-peak time for rural area routes service is provided at various times ranging from 180 minutes to no service during off-peak times. During weekday service PART also provides shuttle service from the PART Hub to businesses in and around the PTI Airport area on 30 minute headways. This service is provided during peak, off-peak and evening hours of operation. Weekend PART service is limited to one route traveling between Winston-Salem and High Point providing service to the Amtrak train station. Three round trips are provided each Saturday and Sunday with frequency every 5 hours. Headways and Periods of Operation Weekdays Peak Off-Peak Evening Urban Express 30 60 30 Rural Express 36 180 -- Shuttles 30 30 30 Peak 6 am 9 am, 3 pm 6 pm, Off-Peak 9 am 3 pm, Evening 6 pm 7 pm, no service. 15 P a g e

Headways and Periods of Operation Weekends AM Peak Mid-day PM Peak Amtrak Connector 1 trip 1 trip 1 trip On-Time Performance Standard PART Express routes are to be considered on time if they are no more than 1 minute early and no more than 5 minutes late. The on-time performance goal is set at 95% or greater. PART will continuously monitor the various routes throughout the system to maintain this standard. Service Availability Standard PART Express routes are designed to provide access to routes throughout a 10-county region. Access is made available through the use of Park & Ride Lots and direct stops along a route. Due to the nature of express service stops are limited along the routes due to the vehicles traveling on the highway system in the region. Major employment centers, central business districts, schools, universities and hospitals are target areas for the routes. Strategic corridors for the regions highway system are also used to enhance the efficiency of the service to the region. Regional Demographics From Title VI Plan Adopted September 13, 2013 The Piedmont Authority for Regional Transportation does not supersede, but compliments local transit services in the Piedmont Triad Region of North Carolina. The PART territory includes four metropolitan areas as defined by US Census metropolitan planning statistical areas, and ten counties. The following information is based on 2000 Census, local jurisdiction data, and state data center information compiled and maintained at PART. The PART territorial jurisdiction had a population (2011 American Community Survey 3 year data) of 1,591,511 individuals. The race and ethnic breakout is as follows: Race Total Percentage of Population White/Caucasian 1,160,452 72.9 African American 345,323 21.7 American Indian / Alaskan Native 15,499 1.0 Asian 37,708 2.4 Hawaiian / Pacific Islander 586 0.0 Other 64,288 4 Hispanic / Latino 138,624 8.7 Ninety percent of the region s population is White and African American ethnicity. The remaining 10% is broken out by all other recognizable ethnic cultures with the largest portion being Hispanic/Latino cultures; representing nearly 8%. 16 P a g e

6.98% of the population in the PART territory is foreign born, with 55% of those entering the region between 1990 and 2000. 10.7% of the population 5 years of age or older in the PART territory speaks a language other than English at home and of that group 49.6% speak English less than very well. The following information is based on the 2011 American Community Survey 5-year data sets for the PART territory. PART Service Area Population who are: Percentage Spanish speakers 7.5 Spanish speakers who speak English less than very well 54.3 Indo-European language speakers (other than English only speakers) 1.4 Indo-European speakers who speak English less than very well 28.2 Asian & Pacific Island (PI) languages speakers 1.3 Asian & PI language speakers who speak English less than very well 50.1 Speakers of languages not mentioned above 0.4 Other languages speakers who speak English less than very well 38.4 Data retrieved from the various school systems across the PART territory area reflects the highest concentration of Limited English Proficiency households within the urbanized area schools, and are ranked in order of highest to lowest: Spanish Vietnamese Arabic Urdu French Household Language by Linguistic Isolation Linguistic isolation describes a household as one in which no member 14 years and over speaks only English or speaks a non-english language and thereby speaks English very well. In simplistic terms, all members of the household 14 years and over have at least some difficulty with English. The data below is gathered from local human service agencies based on their interaction to communities from their jurisdiction. All households 4.5% Spanish 28.6% Other Indo-European languages 13.8% Asian and Pacific Island languages 17.6% Other languages 19.4% The data available from the sampling conducted for each of the jurisdictions within the PART territorial jurisdiction, 2000 census, 2009 census update and American Survey data combined; shows significant linguistically isolated households primarily in urbanized areas. In utilizing the data available from the sources identified above, PART, County school systems and human service agencies have been able to determine that the greatest non- English language need in the region is Spanish and a lower tier representation of Vietnamese / Asian dialect (Predominantly Korean). 17 P a g e