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legitimate justification, there are no alternative locations that would have a less disparate impact, and it is not a pretext for discrimination). For any new facility construction, expansion, or acquisition, Erie County Department for the Aging will work with NYSDOT to ensure that the equity analysis is completed and submitted to NYSDOT. The equity analysis will be provided upon request to NYSDOT, FTA and during the triennial review. The below is intended to provide direction to the reader as to whether Erie County Department for the Aging was required to, completed, and included a Title VI equity analysis with this Title VI Plan update. Did Erie County Department for the Aging construct, expand or acquired a facility in the past three years? (check the box next to the appropriate response below) ☒ No. Erie County Department for the Aging has not constructed, expanded or acquired a facility. Does Erie County Department for the Aging plan to construct, expand or acquire a facility in the next three years? (check the box next to the appropriate response below) ☒ No. Erie County Department for the Aging does not plan to construct, expand or acquire a facility. 84 | P a g e – E r i e C o u n t y G o i n g P l a c e s P o l i c y a n d P r o c e d u r e