Full Text
Columbia County Title VI Plan Date Adopted: October 19, 2021 ---PAGE BREAK--- Title VI Plan Columbia County iii Table of Contents 1.0 Title VI/Nondiscrimination Policy Statement and Management Commitment to Title VI Plan 1-1 2.0 Introduction & Description of Services 2-1 2.1 First Time Applicant Requirements 2-2 2.2 Annual Certifications and 2-2 2.3 Title VI Plan Concurrence and Adoption 2-3 3.0 Title VI Notice to the Public 3-1 3.1 Notice to Public 3-1 3.2 Notice Posting Locations 3-1 4.0 Title VI Procedures and Compliance 4-1 4.1 Complaint Procedure 4-1 4.2 Complaint Form 4-1 4.3 Record Retention and Reporting Policy 4-2 4.4 Sub-recipient Assistance and Monitoring 4-2 4.5 Contractors and Subcontractors 4-2 5.0 Title VI Investigations, Complaints, and Lawsuits 5-1 6.0 Public Participation Plan 6-1 7.0 Language Assistance Plan 7-1 8.0 Transit Planning and Advisory Bodies 8-1 9.0 Title VI Equity Analysis 9-1 10.0 System-Wide Service Standards and Service Policies 10-1 11.0 Appendices 11-1 APPENDIX A FTA CIRCULAR 4702.1B REPORTING REQUIREMENTS FOR TRANSIT PROVIDERS APPENDIX B CURRENT SYSTEM DESCRIPTION APPENDIX C TITLE VI PLAN ADOPTION MEETING MINUTES AND GDOT CONCURRENCE LETTER APPENDIX D TITLE VI NOTICE TO PUBLIC APPENDIX E TITLE VI COMPLAINT FORM APPENDIX E-1 SUMMARY OF LAWSUITS, INVESTIGATIONS, AND COMPLAINTS APPENDIX F PUBLIC PARTICIPATION PLAN APPENDIX G LANGUAGE ASSISTANCE PLAN APPENDIX H OPERATING AREA LANGUAGE DATA: COLUMBIA COUNTY SERVICE AREA APPENDIX I DEMOGRAPHIC MAPS APPENDIX J TITLE VI EQUITY ANALYSIS APPENDIX K TEXT FORMATTING PALETTE ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- Title VI Plan Columbia County 2-1 2.0 Introduction & Description of Services Columbia County submits this Title VI Plan in compliance with Title VI of the Civil Rights Act of 1964, 49 CFR Part 21, and the guidelines of FTA Circular 4702.1B, published October 1, 2012. Columbia County is a sub-recipient of FTA funds and provides service in Columbia County, GA. A description of the current Columbia County system is included in Appendix B. Title VI Liaison Jeff Asmann Columbia County Board of Commissioners Management and Internal Services Division, Public Transit Department [PHONE REDACTED] 5913 Euchee Creek Drive, Grovetown, GA 30813 Alternate Title VI Contact Don Barrow Columbia County Board of Commissioners Engineering Division, Road Construction Department [PHONE REDACTED] P O Box 498, Evans, GA 30809 Columbia County must designate a liaison for Title VI issues and complaints within the organization. The liaison is the focal point for Title VI implementation and monitoring of activities receiving federal financial assistance. Key responsibilities of the Title VI Liaison include: Maintain knowledge of Title VI requirements. Attend training on Title VI and other nondiscrimination authorities when offered by GDOT or any other regulatory agency. Disseminate Title VI information to the public including in languages other than English, when necessary. Develop a process to collect data related to race and national origin of service area population to ensure low income, minorities, and other underserved groups are included and not discriminated against. Implement procedures for the prompt processing of Title VI complaints. ---PAGE BREAK--- Title VI Plan Columbia County 2-2 2.1 First Time Applicant Requirements Columbia County is not a first time applicant for FTA/GDOT funding. The following is a summary of Columbia County’s current and pending federal and state funding. Current and Pending FTA Funding None Current and Pending GDOT Funding 1. Transportation Operating Assistance, FY2021, $619,144, Current 2. Transportation Operating Assistance, FY2020, $213,656, Pending 3. UMTA/Transit Operating Assistance, FY2019, $562,320, Current 4. Green Space, FY2019, $250,000, Current Current and Pending State Funding (non-GDOT) 1. DHR Coordinated Transportation, FY2021, $21,300, Current During the previous three years, GDOT did complete a Title VI compliance review of Columbia County. Columbia County has not been found to be in noncompliance with any civil rights requirements. 2.2 Annual Certifications and Assurances In accordance with 49 CFR Section 21.7(a), every application for financial assistance from FTA must be accompanied by an assurance that the applicant will carry out the program in compliance with Title VI regulations. This requirement shall be fulfilled when the applicant/recipient submits its annual certifications and assurances. Primary recipients will collect Title VI assurances from sub-recipients prior to passing through FTA funds. Columbia County will remain in compliance with this requirement by annual submission of certifications and assurances as required by GDOT. FTA Circular 4702.1B, Chapter III, Paragraph 3: Entities applying for FTA funding for the first time shall provide information regarding their Title VI compliance history if they have previously received funding from another Federal agency. ---PAGE BREAK--- Title VI Plan Columbia County 2-3 2.3 Title VI Plan Concurrence and Adoption This Title VI Plan received GDOT concurrence on 08/23/2021. The Plan was approved and adopted by Columbia County’s Board of Directors during a meeting held on 10/19/2021. A copy of the meeting minutes and GDOT concurrence letter is included in Appendix C of this Plan. ---PAGE BREAK--- Title VI Plan Columbia County 3-1 3.0 Title VI Notice to the Public 3.1 Notice to Public Recipients must notify the public of its rights under Title VI and include the notice and where it is posted in the Title VI Plan. The notice must include: A statement that the agency operates programs without regard to race, color and national origin A description of the procedures members of the public should follow in order to request additional information on the grantee’s nondiscrimination obligations A description of the procedure members of the public should follow in order to file a discrimination complaint against the grantee A notice is included in Appendix D of this Plan. The Title VI notice is translated to both Spanish and Korean. 3.2 Notice Posting Locations The Notice to Public will be posted at many locations to apprise the public of Columbia County’s obligations under Title VI and to inform them of the protections afforded them under Title VI. At a minimum, the notice will be posted in public areas of Columbia County Transit’s office including the reception desk and meeting rooms, and on the Columbia County’s website at Additionally, Columbia County Transit will post the notice at stations, stops and on transit vehicles. A version of this notice is included in Appendix D of this Plan along with translated versions of the notice, in both Spanish and Korean as necessary. FTA Circular 4702.1B, Chapter III, Paragraph 5: Title 49 CFR 21.9(d) requires recipients to provide information to the public regarding the recipient’s obligations under DOT’s Title VI regulations and apprise members of the public of the protections against discrimination afforded to them by Title VI. ---PAGE BREAK--- Title VI Plan Columbia County 4-1 4.0 Title VI Procedures and Compliance 4.1 Complaint Procedure Any person who believes he or she has been discriminated against on the basis of race, color or national origin by Columbia County may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form (refer to Appendix Columbia County investigates complaints received no more than 180 days after the alleged incident. Columbia County will process complaints that are complete. Once the complaint is received, Columbia County will review it to determine if our office has jurisdiction. The complainant will receive an acknowledgement letter informing him/her whether the complaint will be investigated by our office. Columbia County has ninety (90) days to investigate the complaint. If more information is needed to resolve the case, Columbia County may contact the complainant. The complainant has ten (10) business days from the date of the letter to send requested information to the investigator assigned to the case. If the investigator is not contacted by the complainant or does not receive the additional information within ten (10) business days, Columbia County can administratively close the case. A case can also be administratively closed if the complainant no longer wishes to pursue their case. After the investigator reviews the complaint, she/he will issue one of two letters to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed. A LOF summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff member or other action will occur. If the complainant wishes to appeal the decision, she/he has seven days to do so from the time he/she receives the closure letter or the LOF. The complaint procedure is available to the public on Columbia County’s website 4.2 Complaint Form A copy of the complaint form in English, Spanish and Korean is provided in Appendix E and on Columbia County’s website FTA Circular 4702.1B, Chapter III, Paragraph 6: All recipients shall develop procedures for investigating and tracking Title VI complaints filed aginst them and make their procedures for filing a complaint available to member of the public. ---PAGE BREAK--- Title VI Plan Columbia County 4-2 4.3 Record Retention and Reporting Policy FTA requires that all direct and primary recipients (GDOT) document their compliance by submitting a Title VI Plan to their FTA regional civil rights officer once every three years. Columbia County will submit Title VI Plans to GDOT for concurrence on an annual basis or any time a major change in the Plan occurs. Compliance records and all Title VI related documents will be retained for a minimum of three years and reported to the primary recipient annually. 4.4 Sub-recipient Assistance and Monitoring Columbia County does not have any sub-recipients to provide monitoring and assistance to. As a sub- recipient to GDOT, Columbia County utilizes the sub-recipient assistance and monitoring provided by GDOT, as needed. In the future, if Columbia County has sub-recipients, it will provide assistance and monitoring as required by FTA Circular 4702.1B. 4.5 Sub recipients and Subcontractors Columbia County is responsible for ensuring that subcontractors (TPOs) are in compliance with Title VI requirements. Sub recipients may not discriminate in the selection and retention of any subcontractors. Subcontractors also may not discriminate in the selection and retention of any subcontractors. Columbia County, subcontractors, and/or TPOs may not discriminate in their employment practices in connection with federally assisted projects. Subcontractors and TPOs are not required to prepare or submit a Title VI Plan. However, the following nondiscrimination clauses will be inserted into every contract with contractors and subcontractors subject to Title VI regulations. Nondiscrimination Clauses During the performance of a contract, the contractor, for itself, its assignees and successors in interest (hereinafter referred to as the “Contractor”) must agree to the following clauses: 1. Compliance with Regulations: The Contractor shall comply with the Regulations relative to nondiscrimination in Federally-assisted programs of the U.S. Department of Transportation (hereinafter, “USDOT”) Title 49, Code of Federal Regulations, Part 21, as they may be amended from time to time, (hereinafter referred to as the Regulations), which are herein incorporated by reference and made a part of this Agreement. 2. Nondiscrimination: The Contractor, with regard to the work performed during the contract, shall not discriminate on the basis of race, color, or national origin in the selection and retention of subcontractors, including procurements of materials and leases of equipment. The Contractor shall not participate either directly or indirectly in the discrimination prohibited by section 21.5 of the Regulations, including employment practices when the contract covers a program set forth in Appendix B of the Regulations. 3. Solicitations for Subcontractors, including Procurements of Materials and Equipment: In all solicitations made by the Contractor, either by competitive bidding or negotiation for work to be performed under a subcontract, including procurements of materials or leases of equipment; each potential subcontractor or ---PAGE BREAK--- Title VI Plan Columbia County 4-3 supplier shall be notified by the Contractor of the subcontractor’s obligations under this contract and the regulations relative to nondiscrimination on the basis of race, color, or national origin. 4. Information and Reports: The Contractor shall provide all information and reports required by the Regulations or directives issued pursuant thereto, and shall permit access to its books, records, accounts, other sources of information, and its facilities as may be determined by the Georgia Department of Transportation and/or the Federal Transit Administration, to be pertinent to ascertain compliance with such Regulations, orders and instructions. Where any information required of a Contractor is in the exclusive possession of another who fails or refuses to furnish this information the Contractor shall so certify to the Georgia Department of Transportation, and/or the Federal Transit Administration, as appropriate, and shall set forth what efforts it has made to obtain the information. 5. Sanctions for Noncompliance: In the event of the Contractor’s noncompliance with the nondiscrimination provisions of this contract, Columbia County shall impose contract sanctions as appropriate, including, but not limited to: a. withholding of payments to the Contractor under the contract until the Contractor complies, and/or b. cancellation, termination or suspension of the contract, in whole or in part. 6. Incorporation of Provisions: The Contractor shall include the provisions of paragraphs through in every subcontract, including procurement of materials and leases of equipment, unless exempt by the Regulations, or directives issued pursuant thereto. The Contractor shall take such action with respect to any subcontract or procurement as the Columbia County, Georgia Department of Transportation, and/or the Federal Transit Administration, may direct as a means of enforcing such provisions including sanctions for noncompliance. Disadvantaged Business Enterprise (DBE) Policy As a condition of your agreement with GDOT, Columbia County and its contractors and subcontractors agree to ensure that Disadvantaged Business Enterprises as defined in 49 CFR Part 26, as amended, have the opportunity to participate in the performance of contracts. Columbia County and its contractor and subcontractors shall not discriminate on the basis of race, color, national origin, or sex in the performance of any contract. The contractor shall carry out applicable requirements of 49 CFR Part 26 in the award and administration of GDOT-assisted contracts. Failure by the contractor to carry out these requirements is a material breach of this contract, which may result in the termination of the contract or such other remedy as the recipient deems appropriate. E-Verify As a condition of your agreement with GDOT, vendors and contractors of Columbia County shall utilize the U.S. Department of Homeland Security’s E-Verify system to verify the employment eligibility of all new employees hired by the vendor or contractor while contracted with Columbia County. Additionally, vendors and contractors shall expressly require any subcontractors performing work or providing services pursuant to work for Columbia County shall likewise utilize the U.S. Department of Homeland Security’s E-Verify system to verify the employment eligibility of all new employees hired by the subcontractor while working for Columbia County. ---PAGE BREAK--- Title VI Plan Columbia County 5-1 5.0 Title VI Investigations, Complaints, and Lawsuits In accordance with 49 CFR 21.9(b), Columbia County must record and report any investigations, complaints, or lawsuits involving allegations of discrimination. The records of these events shall include the date the investigation, lawsuit, or complaint was filed; a summary of the allegations; the status of the investigation, lawsuit, or complaint; and actions taken by Columbia County in response; and final findings related to the investigation, lawsuit, or complaint. The records for the previous three years shall be included in the Title VI Plan when it is submitted to GDOT. Columbia County has had no investigations, complaints, or lawsuits involving allegations of discrimination on the basis of race, color, or national origin over the past three years. A summary of these incidents is recorded in Table 1. Table 1: Summary of Investigations, Lawsuits, and Complaints Date (Month, Day, Year) Summary (include basis of complaint: race, color, or national origin) Status Action(s) Taken Investigations N/A N/A N/A N/A Lawsuits N/A N/A N/A N/A Complaints N/A N/A N/A N/A FTA Circular 4702.1B, Chapter III, Paragraph 7: In order to comply with the reporting requirements of 49 CFR 21.9(b), FTA requires all recipients to prepare and maintain a list of any of the following that allege discrimination on the basis of race, color, or national origin: active investigations….; lawsuits, and complaints naming the recipient. ---PAGE BREAK--- Title VI Plan Columbia County 6-1 6.0 Public Participation Plan The Public Participation Plan (PPP) for Columbia County was developed to ensure that all members of the public, including minorities and Limited English Proficient (LEP) populations, are encouraged to participate in the decision making process for Columbia County. Policy and service delivery decisions need to take into consideration community sentiment and public opinion based upon well-executed outreach efforts. The public outreach strategies described in the PPP are designed to provide the public with effective access to information about Columbia County services and to provide a variety of efficient and convenient methods for receiving and considering public comment prior to implementing changes to services. The PPP is included as Appendix F to this Title VI Plan. Current Outreach Efforts Columbia County is required to submit a summary of public outreach efforts made over the last three years. The following is a list and short description of Columbia County’s recent, current, and planned outreached activities. Columbia County actively advises the public of opportunities to influence policy by participation in regularly scheduled Commission meetings held throughout the year Commission meetings are regularly publicized in local media and through public service announcements, Commission meetings are advertised in local radio and television outlets as well as posted on the County Website, Columbia County actively schedules meetings at times and locations that are convenient and accessible for minority and LEP communities and employs both different meeting sizes and formats Columbia County has established and maintained a local 311 call service center to allow for public input and information gathering through a formal system of incident tracking and complaint resolution, 311 staff are trained to access interpretive services as needed FTA Circular 4702.1B, Chapter III, Paragraph 4.a.4: Every Title VI Plan shall include the following information: A public participation plan that includes an outreach plan to engage minority and limited English proficient populations, as well as a summary of outreach efforts made since the last Title VI Plan submission. A recipient’s targeted public participation plan of minority populations may be part of efforts that extend more broadly to include constituencies that are traditionally underserved, such as people with disabilities, low-income populations, and others. ---PAGE BREAK--- Title VI Plan Columbia County 7-1 7.0 Language Assistance Plan Columbia County operates a transit system within Columbia County, GA. The Language Assistance Plan (LAP) has been prepared to address Columbia County’s responsibilities as they relate to the needs of individuals with Limited English Proficiency (LEP). Individuals, who have a limited ability to read, write, speak or understand English are LEP. In Columbia County’s service area there are 3,447 Spanish speaking residents or 2.2% of the population who describe themselves as not able to communicate in English very well (Source: US Census, 2019 American Community Survey). Latino and Hispanic residents make up the largest single identifiable group of LEP individuals within the county. Approximately 2,478 households speak Spanish within our county. Of these 2,478 households, approximately 451 or 18% report as being LEP. The second largest group of identifiable LEP populations is Korean. Approximately 1,001 Columbia county residents identify as speaking Korean at home. Of these 1,001 individuals, 731 or 73% report not speaking English very well (LEP). In order to address this population of residents, Columbia County offers Title VI materials in Spanish, Korean and English. Columbia County is federally mandated (Executive Order 13166) to take responsible steps to ensure meaningful access to the benefits, services, information and other important portions of its programs and activities for individuals who are LEP. Columbia County has utilized the U.S. Department of Transportation (DOT) LEP Guidance Handbook and performed a four factor analysis to develop its LAP. The LAP is included in this Title VI Plan as Appendix G. FTA Circular 4702.1B, Chapter III, Paragraph 9: Recipients shall take reasonable steps to ensure meaningful access to benefits, services, information, and other important portions of their programs and activities for individuals who are limited English proficient (LEP). ---PAGE BREAK--- Title VI Plan Columbia County 8-1 8.0 Transit Planning and Advisory Bodies Columbia County does not have a transit-related committee or board, therefore this requirement does not apply. FTA Circular 4702.1B, Chapter III, Paragraph 10: Recipients that have transit-related, non-elected planning boards, advisory councils or commitees, or similar committess, the membership of which is selected by the recipient, must provide a table depicting the racial breakdown of the membership of those committees, and a description of efforts made to encourage the participation of minorities on such committees. ---PAGE BREAK--- Title VI Plan Columbia County 9-1 9.0 Title VI Equity Analysis Title 49 CFR, Appendix C, Section (3)(iv) requires that “the location of projects requiring land acquisition and the displacement of persons from their residences and business may not be determined on the basis of race, color, or national origin.” For purposes of this requirement, “facilities” does not include bus shelters, as they are considered transit amenities. It also does not include transit stations, power substations, or any other project evaluated by the National Environmental Policy Act (NEPA) process. Facilities included in the provision include, but are not limited to, storage facilities, maintenance facilities, operations centers, etc. In order to comply with the regulations, Columbia County will ensure the following: 1. Columbia County will complete a Title VI equity analysis for any facility during the planning stage with regard to where a project is located or sited to ensure the location is selected without regard to race, color, or national origin. Columbia County will engage in outreach to persons potentially impacted by the siting of the facility. The Title VI equity analysis must compare the equity impacts of various siting alternatives, and the analysis must occur before the selection of the preferred site. 2. When evaluating locations of facilities, Columbia County will give attention to other facilities with similar impacts in the area to determine if any cumulative adverse impacts might result. Analysis should be done at the Census tract or block group level where appropriate to ensure that proper perspective is given to localized impacts. 3. If Columbia County determines that the location of the project will result in a disparate impact on the basis of race, color, or national origin, Columbia County may only locate the project in that location if there is a substantial legitimate justification for locating the project there, and where there are no alternative locations that would have a less disparate impact on the basis of race, color, or national origin. Columbia County must demonstrate and document how both tests are met. Columbia County will consider and analyze alternatives to determine whether those alternatives would have less of a disparate impact on the basis of race, color, or national origin, and then implement the least discriminatory alternative. Columbia County has not recently constructed any facilities nor does it currently have any facilities in the planning stage. Therefore, Columbia County does not have any Title VI Equity Analysis reports to submit with this Plan. Columbia County will utilize the demographic maps included in Appendix I for future Title VI analysis. FTA Circular 4702.1B, Chapter III, Paragraph 4.a.8: If the recipient has constructed a facility, such as vehicle storage, maintenance facility, operation center, etc., the recipient shall include a copy of the Title VI equity analysis conducted during the planning stage with regard to the location of the facility. ---PAGE BREAK--- Title VI Plan Columbia County 10-1 10.0 System-Wide Service Standards and Service Policies Columbia County is not a fixed route service provider. FTA Circular 4702.1B, Chapter III, Paragraph 10: All fixed route transit providers shall set service standards and policies for each specific fixed route mode of service they provide. ---PAGE BREAK--- Title VI Plan Columbia County 11-1 11.0 Appendices APPENDIX A FTA CIRCULAR 4702.1B REPORTING REQUIREMENTS FOR TRANSIT PROVIDERS APPENDIX B CURRENT SYSTEM DESCRIPTION APPENDIX C TITLE VI PLAN ADOPTION MEETING MINUTES AND GDOT CONCURRENCE LETTER APPENDIX D TITLE VI NOTICE TO PUBLIC APPENDIX E TITLE VI COMPLAINT FORM APPENDIX E-1 SUMMARY OF LAWSUITS, INVESTIGATIONS, AND COMPLAINTS APPENDIX F PUBLIC PARTICIPATION PLAN APPENDIX G LANGUAGE ASSISTANCE PLAN APPENDIX H OPERATING AREA LANGUAGE DATA: COLUMBIA COUNTY SERVICE AREA APPENDIX I DEMOGRAPHIC MAPS APPENDIX J TITLE VI EQUITY ANALYSIS APPENDIX K TEXT FORMATTING PALETTE ---PAGE BREAK--- Title VI Plan Columbia County A-1 Appendix A FTA Circular 4702.1B Reporting Requirements for Transit Providers ---PAGE BREAK--- Title VI Plan Columbia County A-2 Every three years, on a date determined by FTA, each recipient is required to submit the following information to the Federal Transit Administration (FTA) as part of their Title VI Program. Sub-recipients shall submit the information below to their primary recipient (the entity from whom the sub-recipient receives funds directly), on a schedule to be determined by the primary recipient. General Requirements All recipients must submit: Title VI Notice to the Public, including a list of locations where the notice is posted Title VI Complaint Procedures instructions to the public regarding how to file a Title VI discrimination complaint) Title VI Complaint Form List of transit-related Title VI investigations, complaints, and lawsuits Public Participation Plan, including information about outreach methods to engage minority and limited English proficient populations (LEP), as well as a summary of outreach efforts made since the last Title VI Program submission Language Assistance Plan for providing language assistance to persons with limited English proficiency (LEP), based on the DOT LEP Guidance A table depicting the membership of non-elected committees and councils, the membership of which is selected by the recipient, broken down by race, and a description of the process the agency uses to encourage the participation of minorities on such committees Primary recipients shall include a description of how the agency monitors its sub-recipients for compliance with Title VI, and a schedule of sub-recipient Title VI Program submissions A Title VI equity analysis if the recipient has constructed a facility, such as a vehicle storage facility, maintenance facility, operation center, etc. A copy of board meeting minutes, resolution, or other appropriate documentation showing the board of directors or appropriate governing entity or official(s) responsible for policy decisions reviewed and approved the Title VI Program. For State DOTs, the appropriate governing entity is the State’s Secretary of Transportation or equivalent. The approval must occur prior to submission to FTA. Additional information as specified in Chapters IV, V, and VI, depending on whether the recipient is a transit provider, a State, or a planning entity (see below) ---PAGE BREAK--- Title VI Plan Columbia County B-1 Appendix B Current System Description ---PAGE BREAK--- Title VI Plan Columbia County B-2 Current System Description 1. Columbia County’s current and long-term focus as a transportation provider is on maintaining the best-coordinated transportation system possible for this community. Our goal is to create a coordinated system with the objective of providing safe, reliable, timely and efficient transportation services to county residents. 2. Columbia County is a non-profit 509(a)(1) organization. Our organization is made up of 12 full-time employees, 1 part-time employee, and no volunteers. Our Transit Department Manager is responsible for all of the day-to-day operations of our organization and reports directly to our Board of County Commissioners (BCC). Our BCC is committed to this program and has, therefore, incorporated our service within the County’s Public Transportation Program. Transportation services are provided in accordance with the BCC’s approved Operations and Policy Manual. We will continue to operate at previous year 2020 service hours averaging 64 total fleet service hours per day or approximately 15,360 annual service hours (assuming 240 operating days). 3. Columbia County operates as a non-profit 509(a)(1) under the direct oversight of the BCC. 4. Columbia County’s manager is responsible for training and management of our transportation program. All safety sensitive employees are required to complete GDOT approved safety and security training course as part of their new hire orientation. All new employees are also required to complete 40 hours of on-the-road driver’s training, which includes riding with a training driver, behind-the- wheel training, and training on proper use of wheel chair lifts and securement devices. The Risk Management Services Manager is responsible for annual renewal of all liability insurance for both GDOT and agency owned vehicles, as well as vehicle registration renewal. It is the Transportation Manager’s responsibility to administer all aspects of the transportation program and to control access and usage of all agency vehicles. 5. Maintenance on all agency vehicles is provided by Columbia County Fleet Services Department. Columbia County Fleet Services employs only ASE certified technicians with experience in working on commercial passenger vehicles like the type our agency uses. All maintenance is performed using the Preventative Maintenance Plan, which conforms to the State Vehicle Maintenance Guidelines set forth in the GDOT Preventative Maintenance Guidelines document. All vehicle files and driver files are kept on-site at our operations base located at 5913 Euchee Creek Drive, Grovetown GA and are maintained by the manager. All records are maintained and retained for a minimum of four years. 6. Our transportation department has a total of 13 employees that include: 9 full-time drivers, 1 part- time driver, 1 manager and 2 support staff. ---PAGE BREAK--- Title VI Plan Columbia County B-3 7. Only transportation employees that have completed all of the required safety and driver’s training requirements will be allowed to drive the agency vehicles. 8. Transportation services provided through our program are available to all county residents and the general public. We provide a wide range of trip purposes that include: medical, nutrition, shopping, social service, training, employment, social and recreation. Approximately 90% of the medical trips we provide are to medical facilities out of the county; therefore, our out of county services are directed to the nearby highway corridors that surround this community for optimum efficiency of trip duration and the most convenient route. Currently, we use a variety of vehicles to provide passenger services. Our fleet includes eleven shuttle buses. Six of our vehicles are equipped for wheelchair service. We prioritize grouping trips and multi-loading to the maximum extent possible. We make 90 passenger trips per day on average and leverage our fleet resources so that all vehicles are used in a responsible manner to provide full coverage and retire the vehicles at a consistent pace and appropriate age and mileage. ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- Title VI Plan Columbia County E-1 Appendix D Title VI Notice to Public ---PAGE BREAK--- Title VI Plan Columbia County E-2 Title VI Notice to the Public Columbia County, Georgia hereby gives public notice that it is its policy to assure full compliance with Title VI of the Civil Rights Act of 1964 and all related regulations and directives. Columbia County assures that no person shall on the grounds of race, color, or national origin as provided by Title VI of the Civil Rights Act of 1964 be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity, whether such programs and activities are federally assisted or not. Any person who believes they have been aggrieved by an unlawful discriminatory practice under Title VI has a right to file a formal complaint with Columbia County. Any such complaint must be in writing and filed with the Columbia County Title VI Administrator within 180 calendar days following the date of the alleged discriminatory occurrence. Title VI Complaint Forms may be obtained from the Title VI Administrator's office at no cost to the complainant by calling (706) 868-3300 or in person at: Columbia County Government Center 630 Ronald Reagan Drive Building B - 1st Floor P. O. Box 498 Evans, GA 30809 ---PAGE BREAK--- Title VI Plan Columbia County E-3 Título VI aviso Al Público El Condado de Columbia, Georgia, da a conocer públicamente que su política es asegurar el pleno cumplimiento del Título VI de la ley de derechos Civiles de 1964 y todas las regulaciones y directivas relacionadas. El Condado de Columbia garantiza que ninguna persona, por motivos de raza, color, sexo, origen nacional, discapacidad o edad, conforme a lo dispuesto en el Título VI De la ley de derechos Civiles de 1964, la ley de Autopistas de la ayuda Federal de 1973, la ley de Rehabilitación de 1973, la ley De discriminación por Edad de 1975 y la ley de Restauración de los Derechos Civiles de 1987, quedará excluida de la participación en programas o actividades, ni se le negarán los beneficios ni será objeto de discriminación de ningún tipo, si tales programas y actividades reciben asistencia Federal o no. Toda persona que considere que ha sido perjudicada por una práctica discriminatoria ilícita con arreglo al Título VI tiene derecho a presentar una denuncia formal ante el Condado de Columbia. Toda denuncia de este tipo deberá presentarse por escrito y ante el Administrador del título VI del Condado de Columbia dentro de los 180 días naturales siguientes a la fecha de la presunta ocurrencia discriminatoria. Los formularios de Reclamación del título VI pueden Obtenerse en la oficina del Administrador del Título VI sin costo alguno llamando al (706) 868-3300 o en persona al: Centro De Gobierno Del Condado De Columbia 630 Ronald Reagan Drive Edificio B-1ª Planta Box 498 Evans, GA 30809 ---PAGE BREAK--- Title VI Plan Columbia County E-4 대중에게 제목 VI 알림 이를 통해 조지아 주 컬럼비아 카운티는 1964 년 민권법의 타이틀 VI 및 모든 관련 규정 및 지침을 완전히 준수하는 것이 정책이라는 것을 공표합니다. 컬럼비아 카운티는 1964 년 민권법의 타이틀 VI 가 제공한 인종, 피부색 또는 국적을 이유로 인종, 피부색 또는 국적을 이유로 어떠한 사람도 참여에서 제외되거나, 그러한 프로그램 및 활동이 연방 정부의 지원이든 아니든, 어떤 프로그램이나 활동에 따라 차별을 당하지 않을 것을 보장합니다. 타이틀 VI 에 따라 불법적인 차별 행위에 시대한 것으로 믿는 사람은 컬럼비아 카운티에 공식 적인 불만을 제기 할 권리가 있습니다. 이러한 불만 사항은 서면으로 작성되어야하며 차별 발생 이발생 일로부터 180 일 이내에 컬럼비아 카운티 타이틀 VI 관리자에게 제출해야 합니다. 제목 VI 불만 양식은 (706) 868-3300 또는 직접 전화하여 신고자에게 무상으로 타이틀 VI 관리자의 사무실에서 얻을 수 있습니다. 컬럼비아 카운티 정부 센터 630 로널드 레이건 드라이브 건물 B - 1 층 P. O. 박스 498 에반스, GA 30809 ---PAGE BREAK--- Title VI Plan Columbia County E-1 Appendix E Title VI Complaint Form ---PAGE BREAK--- Title VI Plan Columbia County E-2 Columbia County Discrimination Complaint Form Section I: Name: Address: Telephone (Home): Telephone (Work): Electronic Mail Address: Accessible Format Requirements? Large Print Audio Tape TDD Other Section II: Are you filing this complaint on your own behalf? Yes* No *If you answered "yes" to this question, go to Section III. If not, please supply the name and relationship of the person for whom you are complaining: Please explain why you have filed for a third party: Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party. Yes No Section III: I believe the discrimination I experienced was based on (check all that apply): [ ] Race [ ] Color [ ] National Origin [ ] Other (explain) Date of Alleged Discrimination (Month, Day, Year): Explain as clearly as possible what happened and why you believe you were discriminated against. Describe all persons who were involved. Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. If more space is needed, please use the back of this form. Section IV Have you previously filed a Title VI or ADA complaint with this agency? Yes No ---PAGE BREAK--- Title VI Plan Columbia County E-3 Section V Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court? [ ] Yes [ ] No If yes, check all that apply: [ ] Federal Agency: [ ] Federal Court [ ] State Agency [ ] State Court [ ] Local Agency Please provide information about a contact person at the agency/court where the complaint was filed. Name: Title: Agency: Address: Telephone: Section VI Name of agency complaint is against: Contact person: Title: Telephone number: You may attach any written materials or other information that you think is relevant to your complaint. Signature and date required below Signature Date Please submit this form in person at the address below, or mail this form to: Columbia County Title VI Liaison 630 Ronald Reagan Drive Evans, GA 30809 ---PAGE BREAK--- Title VI Plan Columbia County E-4 Condado de Columbia Formulario de denuncia por discriminación Sección I: nombre: dirección: Teléfono (Inicio): Teléfono (Trabajo): Dirección de correo electrónico: ¿Requisitos de formato accesible? Letra grande Cinta de audio Tdd Otro Sección II: ¿Está presentando esta queja en su propio nombre? Sí* No *Si respondió "sí" a esta pregunta, vaya a la Sección III. Si no es así, por favor proporcione el nombre y la relación de la persona por la que se queja: Por favor, explique por qué ha presentado una solicitud para un tercero: Por favor, confirme que ha obtenido el permiso de la parte agraviada si está presentando en nombre de un tercero. Sí No Sección III: Creo que la discriminación que experimenté se basó en (compruebe todo lo que se aplica): [ ] Raza [ ] Color [ ] Origen Nacional [ ] Otros (explicar) Fecha de la presunta discriminación (mes, día, año): Explique lo más claramente posible lo que sucedió y por qué cree que fue discriminado. Describa a todas las personas que estuvieron involucradas. Incluya el nombre y la información de contacto de la(s) persona(s) que lo discriminaron (si se conoce), así como los nombres e información de contacto de cualquier testigo. Si se necesita más espacio, utilice la parte posterior de este formulario. Sección IV ¿Ha presentado previamente una queja del Título VI o ADA ante esta agencia? Sí No ---PAGE BREAK--- Title VI Plan Columbia County E-5 Sección V ¿Ha presentado esta queja ante cualquier otra agencia federal, estatal o local, o ante cualquier tribunal federal o estatal? [ ] Sí [ ] No En caso afirmativo, compruebe todo lo que se aplica: [ ] Agencia Federal: [ ] Tribunal Federal [ ] Agencia Estatal [ ] Tribunal Estatal [ ] Agencia Local Sírvase proporcionar información sobre una persona de contacto en la agencia o tribunal donde se presentó la queja. nombre: título: agencia: dirección: teléfono: Sección VI El nombre de la queja de la agencia es contra: Persona de contacto: título: número de teléfono: Puede adjuntar cualquier material escrito u otra información que crea que es relevante para su queja. Firma y fecha requeridas a continuación Fecha de firma Por favor, envíe este formulario en persona a la siguiente dirección, o envíe este formulario por correo a: Enlace del Título VI del Condado de Columbia 630 Ronald Reagan Drive Evans, GA 30809 ---PAGE BREAK--- Title VI Plan Columbia County E-6 컬럼비아 카운티 차별 신고서 섹션 I: 이름: 주소: 전화(홈): 전화(업무): 전자 메일 주소: 액세스 가능한 형식 요구 사항? 대형 인쇄 오디오 테이프 TDD 다른 섹션 II: 이 불만 사항을 직접 제출하고 있습니까? 예* 아니요 *이 질문에 "예"라고 대답한 경우 섹션 III 로 이동하십시오. 그렇지 않은 경우, 당신이 불평하는 사람의 이름과 관계를 제공하시기 바랍니다 : 제3 자에 신청한 이유를 설명해 주십시오. 제3 자 대신 신청하는 경우 상대방의 허가를 받은 경우 확인하시기 바랍니다. 예 아니요 섹션 III: 내가 경험한 차별이 (적용되는 모든 것을 확인)에 근거했다고 믿습니다. 【 】 레이스 [ [ [ 색상 ] [ [ 내셔널 오리진] [ 장애 ] 기타 (설명) 차별 혐의 일자(월, 일, 연도): 무슨 일이 있었는지, 그리고 왜 당신이 차별을 받았다고 믿는지 가능한 한 명확하게 설명한다. 관련된 모든 사람을 설명합니다. 귀하를 차별한 사람의 이름과 연락처 정보와 (알려진 경우) 증인의 이름과 연락처 정보를 포함합니다. 더 많은 공간이 필요한 경우 이 양식의 뒷면을 사용하십시오. 섹션 IV 이전에 이 기관에 타이틀 VI 또는 ADA 불만을 제기했습니까? 예 아니요 ---PAGE BREAK--- Title VI Plan Columbia County E-7 섹션 V 다른 연방, 주 또는 지방 기관 또는 연방 또는 주 법원에 이 불만을 제기했습니까? [ 】 예 [ 아니오] 그렇다면 적용된 모든 것을 확인하십시오. [ ] 연방 기관: 연방 법원 [ ] 주 정부 기관 주 법원 [ ] 지방 기관 불만이 제기된 기관/법원에서 연락처에 대한 정보를 제공하십시오. 이름: 타이틀: 기관: 주소: 전화: 섹션 VI 대행사 불만 의 이름은 다음과 같은 것입니다. 담당자: 타이틀: 전화번호: 귀하는 불만 사항과 관련이 있다고 생각되는 서면 자료 또는 기타 정보를 첨부할 수 있습니다. 서명 및 날짜 는 아래에 필요합니다. _ 서명 날짜 아래 주소로 직접 본 양식을 제출하거나 다음 양식을 우편으로 보내주십시오. 컬럼비아 카운티 타이틀 VI 연락 630 로널드 레이건 드라이브 에반스, GA 30809 ---PAGE BREAK--- Title VI Plan Columbia County F-1 Appendix F Public Participation Plan (PPP) ---PAGE BREAK--- Title VI Plan Columbia County F-2 Introduction The Public Participation Plan (PPP) for Columbia County was developed to ensure that all members of the public, including minorities and Limited English Proficient (LEP) populations, are encouraged to participate in the decision making process for Columbia County. Policy and service delivery decisions need to take into consideration community sentiment and public opinion based upon well-executed outreach efforts. The public outreach strategies described in the PPP are designed to provide the public with effective access to information about Columbia County services and to provide a variety of efficient and convenient methods for receiving and considering public comment prior to implementing changes to services. Columbia County also recognizes the importance of many types of stakeholders in the decision-making process, including other units of government, metropolitan area agencies, community-based organizations, major employers, passengers and the general public, including low-income, minority, LEP, and other traditionally underserved communities. Public Participation Goals The main goal of the PPP is to offer meaningful opportunities for all interested segments of the public, including, but not limited to, low-income, minority and LEP groups, to comment, about Columbia County and its operations. The goals for this PPP include: Inclusion and Diversity: Columbia County will proactively reach out and engage low-income, minority, and LEP populations for the Columbia County service area so these groups will have an opportunity to participate. Accessibility: All legal requirements for accessibility will be met. Efforts will be made to enhance the accessibility of the public’s participation – physically, geographically, temporally, linguistically and culturally. Clarity and Relevance: Issues will be framed in public meetings in such a way that the significance and potential effect of proposed decisions is understood by participants. Proposed adjustments to fares or services will be described in language that is clear and easy to understand. Responsive: Columbia County will strive to respond to and incorporate, when possible, appropriate public comments into transportation decisions. Tailored: Public participation methods will be tailored to match local and cultural preferences as much as possible. Flexible: The public participation process will accommodate participation in a variety of ways and will be adjusted over time as needed. Public Participation Methods The methods of public participation included in this PPP were developed based upon best practices in conjunction with the needs and capabilities of Columbia County. Columbia County intends to achieve meaningful public participation by a variety of methods with respect to service and any changes to service. ---PAGE BREAK--- Title VI Plan Columbia County F-3 Columbia County will conduct community meetings and listening sessions as appropriate with passengers, employers, community based organizations, and advisory committees to gather public input and distribute information about service quality, proposed changes or new service options. The public will be invited to provide feedback on the Columbia County website (www.columbiacountyga.gov) and all feedback on the site will be recorded and passed on to Columbia County management. The public will also be able to call the Columbia County office at [PHONE REDACTED] or 311 during its hours of operation. Feedback collected over the phone will be recorded and passed on to Columbia County management. Formal customer surveys to measure performance, and listening sessions to solicit input, will be conducted periodically. The comments recorded as a part of these participation methods will be responded to as appropriate. Meeting formats will be tailored to help achieve specific public participation goals that vary by project or the nature of the proposed adjustment of service. Some meetings will be designed to share information and answer questions. Some will be designed to engage the public in providing input, establishing priorities, and helping to achieve consensus on a specific recommendation. Others will be conducted to solicit and consider public comments before implementing proposed adjustments to services. In each case, an agenda for the meetings will be created that work to achieve the stated goals and is relevant to the subject and not overwhelming for the public. For all public meetings, the venue will be a facility that is accessible for persons with disabilities and, preferably, is served by public transit. If a series of meetings are scheduled on a topic, different meeting locations may be used, since no one location is usually convenient to all participants. For community meetings and other important information, Columbia County will use a variety of means to make riders and citizens aware, including all of the following methods: In-vehicle advertisement Posters or flyers in transit center Posting information on website Press releases and briefings to media outlets Multilingual flyer distribution to community based organizations, including the Columbia County Health Department, Columbia County DFACS, and Columbia County Cares Food Bank Flyers and information distribution through various libraries and other civic locations that currently help distribute timetables and other information Communications to relevant elected officials All information and materials communicating proposed and actual service adjustments will be provided in English and any other language that meets the “safe harbor” criteria. ---PAGE BREAK--- Title VI Plan Columbia County F-4 Public Hearing Columbia County conducts public meetings allowing for public comment and participation with the calendar set by the Columbia County Board of Commissioners. All meetings dates are released in advance to local media and posted at and-committee-meetings ) website. ---PAGE BREAK--- Title VI Plan Columbia County G-1 Appendix G Language Assistance Plan (LAP) ---PAGE BREAK--- Title VI Plan Columbia County G-2 I. Introduction Columbia County operates a transit system within Columbia County, GA. The Language Assistance Plan (LAP) has been prepared to address Columbia County’s responsibilities as they relate to the needs of individuals with Limited English Proficiency (LEP). Individuals, who have a limited ability to read, write, speak or understand English are LEP. In Columbia County service area there are 1,182 residents in either Spanish speaking or Korean speaking groups who describe themselves as not able to communicate in English “very well” (Source: 2019 American Community Survey, US Census Columbia County is federally mandated (Executive Order 13166) to take responsible steps to ensure meaningful access to the benefits, services, information and other important portions of its programs and activities for individuals who are LEP. Columbia County has utilized the U.S. Department of Transportation (USDOT) LEP Guidance Handbook and performed a four factor analysis to develop its LAP. The U.S. Department of Transportation Handbook, titled “Implementing the Department of Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Persons: A Handbook for Public Transportation Providers, (April 13, 2007)“ (hereinafter “Handbook”), states that Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and its implementing regulations provide that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity that receives Federal financial assistance (Handbook, page The Handbook further adds that Title VI prohibits conduct that has a disproportionate effect on LEP persons because such conduct constitutes national origin discrimination (Handbook, page Executive Order 13166 of August 16, 2000 states that recipients of Federal financial assistance must take reasonable steps to ensure meaningful access to their programs and activities by LEP persons (Handbook, page Additionally recipients should use the DOT LEP Guidance to determine how best to comply with statutory and regulatory obligations to provide meaningful access to the benefits, services, information and other important portions of their programs and activities for individuals who are LEP (Handbook, page These provisions are included in FTA Circular 4702.1B in Paragraph 9 of Chapter III (pages III-6 to III- For many LEP individuals, public transit is the principal transportation mode available. It is important for Columbia County be able to communicate effectively with all of its riders. When Columbia County is able to communicate effectively with all of its riders, the service provided is safer, more reliable, convenient, and accessible for all within its service area. Columbia County is committed to taking reasonable steps to ensure meaningful access for LEP individuals to this agency’s services in accordance with Title VI. This plan will demonstrate the efforts that Columbia County undertakes to make its service accessible to all persons without regard to their ability to communicate in English. The plan addresses how services will be provided through general guidelines and procedures including the following: Identification: Identifying LEP populations in service areas Notification: Providing notice to LEP individuals about their right to language services Interpretation: Offering timely interpretation to LEP individuals upon request Translation: Providing timely translation of important documents ---PAGE BREAK--- Title VI Plan Columbia County G-3 Staffing: Identifying Columbia County staff to assist LEP customers Training: Providing training on LAP to responsible employees. II. Four Factor Analysis The analysis provided in this report has been developed to identify LEP population that may use Columbia County services and identify needs for language assistance. This analysis is based on the “Four Factor Analysis” presented in the Implementing the Department of Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Persons, dated April 13, 2007, which considers the following factors: 1. The number and proportion of LEP persons in the service area who may be served or are likely to encounter a Columbia County program, activity or service. 2. The frequency with which LEP persons come in contact with Columbia County programs, activities or services. 3. The nature and importance of programs, activities or services provided by Columbia County to the LEP population. 4. The resources available to Columbia County and overall costs to provide LEP assistance a. Factor 1: The Number and Proportion of LEP Persons Serviced or Encountered in the Eligible Service Population Of the 141,111 residents in the Columbia County service area 2,983 residents meeting the safe harbor requirement who either speak Spanish or Korean describe themselves as speaking English less than “very well”. People of Hispanic descent are the primary LEP persons likely to utilize Columbia County services constituting apporximately 6,056 residents within the county. For the Columbia County service area, the 2019 American Community Survey of the U.S. Census Bureau shows that among the area’s population 62.5% speak English “very well”. For groups meeting the safe harbor requirement who speak English “less than very well”, 37.4 % speak Spanish and 71.2% speak Korean. Appendix H contains a table which lists the languages spoken at home by the ability to speak English for the population within the Columbia County service area. b. Factor 2: The Frequency with which LEP Individuals Come into Contact with Your Programs, Activities, and Services The Federal guidance for this factor recommends that agencies should assess the frequency with which they have contact with LEP individuals from different language groups. The more frequent the contact with a particular LEP language group, the more likely enhanced services will be needed. Columbia County has assessed the frequency with which LEP individuals come in contact with the transit system. The methods utilized for this assessment include analysis of Census data, examining phone inquiries, requests for translated documents, and staff survey. As discussed ---PAGE BREAK--- Title VI Plan Columbia County G-4 above, Census data indicates that there is a less than 4 percent probability of routine encounters or service requests from LEP individuals within the service population who speak Spanish or Korean. Phone inquiries and staff survey feedback indicated that Columbia County dispatchers and drivers interact infrequently with LEP persons. The majority of these interactions have occurred with LEP persons who mainly spoke Spanish. c. Factor 3: The Nature and Importance of the Program, Activity, or Service Provided by the Recipient to People’s Lives Public transportation and regional transportation planning is vital to many people’s lives. According to the Department of Transportation’s Policy Guidance Concerning Recipient’s Responsibilites to LEP Persons, providing public transportation access to LEP persons is crucial. A LEP person’s inability to utilize public transportation effectively, may adversely affect his or her ability to access health care, education, or employment. An analysis of ridership and trip data was conducted to asses the areas of greatest use and to identify areas of potential growth or underserved populations. The majority of Columbia County’s ridership is over the age of 60 and the majority of Columbia County’s ridership uses our services for medical appointments. No requests from LEP individuals has been documented during the past three years of services. d. Factor 4: The Resources Available to the Recipient and Costs Columbia County assessed its available resources that are currently being used, and those that could be used, to provide assistance to LEP populations. These resources include the following: LanguageLine Solutions and LanguageLine Interpretor services. Columbia County provides a reasonable degree of services for LEP populations in its service area. Language interpretations services have no direct cost to consumers and are funded through the county general fund. III. Language Assistance Plan In developing a Language Assistance Plan, FTA guidance recommends the analysis of the following five elements: 1. Identifying LEP individuals who need language assistance 2. Providing language assistance measures 3. Training staff 4. Providing notice to LEP persons 5. Monitoring and updating the plan The five elements are addressed below. a. Element 1: Identifying LEP Individuals Who Need Language Assistance Federal guidance provides that there should be an assessment of the number or proportion of LEP individuals eligible to be serviced or encountered and the frequency of encounters pursuant to the first two factors in the four-factor analysis. ---PAGE BREAK--- Title VI Plan Columbia County G-5 Columbia County has identified the number and proportion of LEP individuals within its service area using United States Census data from the 2019 American Community Survey (see Appendix As presented earlier, 90.5% of the service area population speaks English only. The largest non-English spoken language in the service area is Spanish Of those whose primary spoken language is Spanish, approximately 37.5% identify themselves as speaking english less than “very well”. Residents who speak primarily Korean now meet the safe harbor criteria with 1,001 residents. Of these Korean speakers approximately 731 or 73.1% report speaking english less than “very well”. Those residents whose primary language is not English or Spanish or Korean and who identify themselves as speaking English less than “very well” account for 2% of the service area population. Columbia County may identify language assistance need for an LEP group by: 1. Examining records to see if requests for language assistance have been received in the past, either at meetings or over the phone, to determine whether language assistance might be needed at future events or meetings. 2. Having Census Bureau Language Identification Flashcards available at Columbia County Public Transit meetings. This will assist Columbia County Transit in identifying language assistance needs for future events and meetings. 3. Having Census Bureau Language Identification Flashcards on all transit vehicles to assist operators in identifying specific language assistance needs of passengers. If such individuals are encountered, vehicle operators will be instructed to obtain contact information to give to Columbia County management to follow-up. 4. Vehicle operators and front-line staff (i.e. Dispatchers, Transit Operation Supervisors, etc.) will be surveyed on their experience concerning any contacts with LEP persons during the previous year. b. Element 2: Language Assistance Measures Federal Guidance suggests that an effective LAP should include information about the ways in which language assistance will be provided. This refers to listing the different language services an agency provides and how staff can access this information. For this task Federal Guidance recommends that transit agencies consider developing strategies that train staff as to how to effectively deal with LEP individuals when they either call agency centers or otherwise interact with the agency. Columbia County has undertaken the following actions to improve access to information and services for LEP individuals: 1. Provide Language Identification Flashcards onboard transit vehicles and in the Columbia County offices. 2. When an interpreter is needed in person or on the telephone, staff will attempt to access language assistance services from a professional translation service or qualified community volunteers. Columbia County will utilize the demographic maps provided in Appendix I in order to better provide the above efforts to the LEP persons within the service area. ---PAGE BREAK--- Title VI Plan Columbia County G-6 c. Element 3: Training Staff Federal guidance states staff members of an agency should know their obligations to provide meaningful access to information and services for LEP persons and that all employees in public contact positions should be properly trained. Suggestions for implementing Element 3 of the Language Assistance Plan, involve: identifying agency staff likely to come into contact with LEP individuals; identifying existing staff training opportunities; providing regular re-training for staff dealing with LEP individual needs; and designing and implementing LEP training for agency staff. In the case of Columbia County, the most important staff training is for Customer Service Representatives and transit drivers. The following training will be provided to Customer Service Representative: 1. Information on Title VI Procedures and LEP responsibilities 2. Use of Language Identification Flashcards 3. Documentation of language assistance requests 4. How to handle a potential Title VI/LEP complaint d. Element 4: Providing Note to LEP Persons Columbia County will make Title VI information available in English, Spanish and Korean on the Agency’s website. Key documents are written in English, Spanish and Korean. Notices are also posted in Columbia County Transit office lobby, and on buses. Additionally, when staff prepares a document or schedules a meeting, for which the target audience is expected to include LEP individuals, then documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population. e. Element 5: Monitoring and Updating the Plan The plan will be reviewed and updated on an ongoing basis. Updates will consider the following: The number of documented LEP person contacts encountered annually How the needs of LEP persons have been addressed Determination of the current LEP population in the service area Determination as to whether the need for translation services has changed Determine whether Columbia County’s financial resources are sufficient to fund language assistance resources needed Columbia County understands the value that its service plays in the lives of individuals who rely on this service, and the importance of any measures undertaken to make the use of system easier. Columbia County is open to suggestions from all sources, including customers, Columbia County staff, other transportation agencies with similar experiences with LEP ---PAGE BREAK--- Title VI Plan Columbia County G-7 communities, and the general public, regarding additional methods to improve their accessibility to LEP communities. IV. Safe Harbor Provision DOT has adopted the Department of Justice’s Safe Harbor Provision, which outlines circumstances that can provide a “safe harbor” for recipients regarding translation of written materials for LEP population. The Safe Harbor Provision stipulates that, if a recipient provides written translation of vital documents for each eligible LEP language group that constitutes five percent or 1,000 persons, whichever is less, of the total population of persons eligible to be served or likely to be affected or encountered, then such action will be considered strong evidence of compliance with the recipient’s written translation obligations. Translation of non-vital documents, if needed, can be provided orally. If there are fewer than 50 persons in a language group that reaches the five percent trigger, the recipient is not required to translate vital written materials but should provide written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of those written materials, free of cost. Columbia County service area does have LEP populations which qualify for the Safe Harbor Provision. As shown in Appendix H, Columbia County does have LEP groups which speak English less than “very well” which exceed either 5.0% or 1,000 person The Safe Harbor Provision applies to the translation of written documents only. They do not affect the requirement to provide meaningful access to LEP individuals through competent oral interpreters where oral language services are needed and are reasonable. Columbia County may determine, based on the Four Factor Analysis, that even though a language group meets the threshold specified by the Safe Harbor Provision, written translation may not be an effective means to provide language assistance measures. ---PAGE BREAK--- Title VI Plan Columbia County H-1 Appendix H Operating Area Language Data: Columbia County Service Area ---PAGE BREAK--- Title VI Plan Columbia County H-2 Language Spoken At Home For The Populations 5 Years and Over Columbia County, Georgia Label Estimate Total: 141,111 Speak only English 127,742 Spanish: 6,056 Speak English "very well" 3,786 Speak English less than "very well" 2,270 French, Haitian, or Cajun: 310 Speak English "very well" 239 Speak English less than "very well" 71 German or other West Germanic languages: 846 Speak English "very well" 668 Speak English less than "very well" 178 Russian, Polish, or other Slavic languages: 558 Speak English "very well" 271 Speak English less than "very well" 287 Other Indo-European languages: 1,420 Speak English "very well" 799 Speak English less than "very well" 621 Korean: 1,001 Speak English "very well" 288 Speak English less than "very well" 713 Chinese (incl. Mandarin, Cantonese): 488 Speak English "very well" 180 Speak English less than "very well" 308 Vietnamese: 749 Speak English "very well" 277 Speak English less than "very well" 472 Tagalog (incl. Filipino): 330 Speak English "very well" 225 Speak English less than "very well" 105 Other Asian and Pacific Island languages: 748 Speak English "very well" 481 ---PAGE BREAK--- Title VI Plan Columbia County H-3 Speak English less than "very well" 267 Arabic: 405 Speak English "very well" 234 Speak English less than "very well" 171 Other and unspecified languages: 458 Speak English "very well" 255 Speak English less than "very well" 203 ---PAGE BREAK--- Title VI Plan Columbia County I-1 Appendix I Demographic Maps ---PAGE BREAK--- Title VI Plan Columbia County I-2 ---PAGE BREAK--- Title VI Plan Columbia County I-3 ---PAGE BREAK--- Title VI Plan Columbia County I-4 ---PAGE BREAK--- Title VI Plan Columbia County I-5 ---PAGE BREAK--- Title VI Plan Columbia County I-6 ---PAGE BREAK--- Title VI Plan Columbia County I-7 ---PAGE BREAK--- Title VI Plan Columbia County J-1 Appendix J Title VI Equity Analysis ---PAGE BREAK--- Title VI Plan Columbia County J-2 Columbia County is not required at this time and has not performed Title VI Equity Analysis ---PAGE BREAK--- Title VI Plan Columbia County K-1 Text Formatting Palette