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received ongoing updates, training, and a copy of the Title VI policies and that all postings are in place and in good condition. Program Monitoring The Town of Hamburg will monitor the effectiveness of the Title VI program through the feedback from clientele, employees, general public and other agencies (NYSDOT, FTA). Town of Hamburg seeks opportunities to continuously improve its Title VI plan, public participation outreach efforts and providing meaningful access of our services to LEP individuals. B10. Facility Location Equity Analysis As a subrecipient of federal funds, Town of Hamburg understands we are required to conduct a Title VI equity analysis when planning to acquire land to construct a new transportation facility or expand an existing transportation facility to ensure the location is selected without regard to race, color, or national origin. A facility includes storage facilities, maintenance facilities, and operations centers, but it does not include bus shelters, transit stations, or power substations. The equity analysis requirement applies even to land acquired to construct a new facility that do not receive direct federal funding (as long as Town of Hamburg receives federal financial assistance, Title VI requirements apply to all programs and activities). The equity analysis compares the equity impacts of various siting alternatives and must occur during the planning phase, prior to the selection of the preferred site, and must include the following: 1. A description of the outreach to persons potentially impacted. 2. A comparison of equity impacts of various siting alternatives. 3. An analysis about whether a disparate impact occurs on the basis of race, color or national origin (including potential cumulative adverse impacts from other facilities with similar impacts in the area) because of the location and construction of a facility. (If there is a disparate impact, the construction of the facility may only occur if there is a substantial legitimate justification, there are no alternative locations that would have a less disparate impact, and it is not a pretext for discrimination). For any land acquired to construct a new facility Town of Hamburg 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 Town of Hamburg was required to, completed, and included a Title VI equity analysis with this Title VI Plan update. Did Town of Hamburg acquire land to construct a transportation facility in the past three years? (check the box next to the appropriate response below) ☒ No. Town of Hamburg has not acquire land to construct a transportation facility. ☐ Yes. Town of Hamburg did acquire land to construct, a new transportation facility and completed a Title VI equity analysis to compare the equity impacts of various siting alternatives. Does Town of Hamburg plan to acquire land to construct a new transportation facility in the next three years? (check the box next to the appropriate response below) ☒ No. Town of Hamburg does not plan to acquire land to construct a new transportation facility. ☐ Yes. Town of Hamburg plans to acquire land to construct a new transportation facility. Town of Hamburg Title VI Plan Page 14 Open-Door Services 90