Document Jeffersoncountyga_doc_efd79a60a2

Jefferson County Transit Title VI Plan Date Adopted: 12/11/2018 ---PAGE BREAK--- Title VI Plan Jefferson County Transit i Preface This template has been developed by the Georgia Department of Transportation (GDOT) Transit division in order to assist transit agencies with the development of their Title VI Plan. Although each agency is different in size, organization structure, operations, etc., minimum Title VI compliance requirements are common to all. This template document is intended to assist smaller transit agencies that often do not have adequate resources to develop a Title VI Plan in accordance with the minimum requirements of Section 49 Code of Federal Regulations, Part 21 and Federal Transit Administration (FTA) Circular 4702.1B. It should be noted that this template covers the Title VI requirements for sub-recipient transit providers that operate less than 50 vehicles in peak service and are located in urbanized areas (UZA) of less than 200,000 population and rural transit providers. While the development, adoption, and implementation of a Title VI Plan that complies, at a minimum, with the requirements set forth by FTA Circular 4702.1B is mandatory, the agencies have the prerogative to either utilize this template or enhance their existing Title VI Plan with the information contained in this document. If an agency decides to utilize this template, they will have to customize this document to fit their agency ensuring compliance with FTA Circular 4702.1B, adopt the document, and implement and comply with the Title VI Plan. It is important to note that the Department is not requiring transit agencies to adopt this template. Transit agencies must, however, adopt a Title VI Plan which addresses all of the requirements of FTA Circular 4702.1B which apply to their agency. The intent of the Department was to develop a document which addresses the provisions of the circular and provide it to local transit agencies as a means of helping them reduce their administrative burden in preparing or updating their Title VI Plans. We believe this document will be invaluable to you in this regard. In developing this document, it was understood that some transit agencies may elect to adopt the template document in whole with little customization. This decision is up to the local transit agency. It must be understood, however, that future compliance reviews will examine your policies and observed practices to ensure that they are consistent with the Title VI Plan you have adopted, and also compliant with FTA Circular 4702.1B. To use this template, open the electronic file and save the file with an appropriate name (e.g. “Jefferson County Transit Bus System Title VI Plan.doc”). You will quickly note that the Template Document has been color coded to help you distinguish between the actual requirements of FTA Circular 4702.1B, and optional language we have provided that might assist you in developing your plan, or elaborating on how your agency is addressing the requirements of FTA Circular 4702.1B. Text Any text highlighted in yellow color should be replaced with your agency’s information. Text Any text highlighted in blue color are instructions for completion of the template. Please delete all blue highlighted text prior to completion of the Plan. Text appearing within the blue shaded boxes is informational only and may provide instructions or other information that will help you in customizing your Title VI Plan. ---PAGE BREAK--- Title VI Plan Jefferson County Transit ii Text Any text appearing in green color represents optional or suggested language that may assist you in explaining or elaborating on how you are meeting the intent of the requirement. Text appearing within the bordered boxes as well as the black text found within the section descriptions which follow, represent the actual requirements as stated in FTA Circular 4702.1B, or provides information directly related to the requirements. Certain FTA Circular 4702.1B requirements are very prescriptive and the requirements are defined in great detail. Under these circumstances, it would be redundant to explain the requirements twice (once in the bordered box and then restate again within the general text that would follow). When such circumstances occur, it will be noted within the bordered box and the general text will be deferred to in summarizing the requirement. Remember, in the context of FTA Circular 4702.1B, some requirements are not always prescriptive and detailed. Some portions of FTA Circular 4702.1B simply obligate the agency to define or develop a policy or procedure to explain how the agency will meet the intent of the requirement. The language the Department has developed in the green colored text is optional or example language crafted to assist you in these instances. You are not required to use it. Whether you elect to use the optional green text is entirely up to you, but please ensure that any green text utilized applies precisely to your agency. Regardless, your policy or procedure must comply with the requirements set forth by FTA Circular 4702.1B. Also, note that this Template is geared towards satisfying the requirements of FTA Circular 4702.1B only. You may have to incorporate additional policies and procedures to meet the requirements of other regulatory agencies, as appropriate. You can also customize the Appendices as needed to supplement the Title VI Plan. The document is provided in a format that is easily editable by the Agencies, a text formatting palette has been provided in the Appendix of the document specifying font type, text size, etc. This template was created by the Florida Department of Transportation, modified and adopted for use by the Georgia Department of Transportation. ---PAGE BREAK--- Title VI Plan Jefferson County Transit iii Title VI Plan Activity Log Date Activity (Review/Update/Addendum/ Adoption/Distribution) Concerned Person (Signature) Remarks 12/09/2014 Board of Commissioners adopted Title VI Plan 12/2018 Board of Commissioners adopted draft Title VI Plan ---PAGE BREAK--- Title VI Plan Jefferson County Transit iv Title VI Plan Activity Log (Continued) Date Activity (Review/Update/Addendum/ Adoption/Distribution) Concerned Person (Signature) Remarks ---PAGE BREAK--- Title VI Plan Jefferson County Transit v 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 2-3 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 Sub recipients and Subcontractors 4-3 5.0 Title VI Investigations, Complaints, and Lawsuits 5-1 6.0 Public Participation Plan 6-2 7.0 Language Assistance Plan 7-3 8.0 Transit Planning and Advisory Bodies 8-1 9.0 Title VI Equity Analysis 9-2 10.0 System-Wide Service Standards and Service Policies 10-3 11.0 Appendices 11-4 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 SAMPLE NOTICE TO PUBLIC APPENDIX E TITLE VI COMPLAINT FORM APPENDIX F PUBLIC PARTICIPATION PLAN APPENDIX G LANGUAGE ASSISTANCE PLAN APPENDIX H OPERATING AREA LANGUAGE DATA: JEFFERSON COUNTY TRANSIT SERVICE AREA APPENDIX I DEMOGRAPHIC MAPS APPENDIX J TITLE VI EQUITY ANALYSIS ---PAGE BREAK--- Title VI Plan Jefferson County Transit 1-1 1.0 Title VI/Nondiscrimination Policy Statement and Management Commitment to Title VI Plan Jefferson County Transit assures the Georgia Department of Transportation that no person shall on the basis of race, color, national origin, age, disability, family or religious status, as provided by Title VI of the Civil Rights Act of 1964, Federal Transit Laws, 49 CFR Part 21 Unlawful Discrimination, Nondiscrimination In Federally-Assisted Programs Of The Department Of Transportation and as per written guidance under FTA Circular 4702.1B, dated October 2012, be excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination or retaliation under any program or activity undertaken by the agency. Jefferson County Transit further agrees to the following responsibilities with respect to its programs and activities: 1. Designate a Title VI Liaison that has a responsible position within the organization and access to the recipient’s Chief Executive Officer or authorized representative. 2. Issue a policy statement signed by the Executive Director or authorized representative, which expresses its commitment to the nondiscrimination provisions of Title VI. The policy statement shall be circulated throughout the Recipient’s organization and to the general public. Such information shall be published where appropriate in language other than English. 3. Insert the clauses of Section 4.5 of this plan into every contract subject to the Acts and the Regulations. 4. Develop a complaint process and attempt to resolve complaints of discrimination against Jefferson County Transit. 5. Participate in training offered on the Title VI and other nondiscrimination requirements. 6. If reviewed by GDOT or any other state or federal regulatory agency, take affirmative actions to correct any deficiencies found within a reasonable time period, not to exceed ninety (90) days. 7. Have a process to collect racial and ethnic data on persons impacted by the agency’s programs. 8. Submit the information required by FTA Circular 4702.1B to the GDOT. (refer to Appendix A of this plan) THIS ASSURANCE is given in consideration of and for the purpose of obtaining any and all federal funds, grants, loans, contracts, properties, discounts or other federal financial assistance under all programs and activities and is binding. The person whose signature appears below is authorized to sign this assurance on behalf of the agency. Signature: Printed Name: Mitchell McGraw Chairman, Jefferson County Board of Commission - Jefferson County Transit, Date: Dec. 11, 2018 49 CFR Part 21.7(a): Every application for Federal financial assistance to which this part applies shall contain, or be accompanied by, an assurance that the program will be conducted or the facility operated in compliance with all requirements imposed or pursuant to [49 CFR Part 21]. ---PAGE BREAK--- Title VI Plan Jefferson County Transit 2-1 2.0 Introduction & Description of Services Jefferson County Transit 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. Jefferson County Transit is a sub-recipient of FTA funds and provides service in Jefferson County. A description of the current Jefferson County Transit system is included in Appendix B. Title VI Liaison Teresa C. Snider, Supervisor Employed by Jefferson County Board of Commissioners [PHONE REDACTED] P.O. Box 658, Louisville, GA 30434 Alternate Title VI Contact Eloise Smith, Dispatcher Employed by Jefferson County Board of Commissioners [PHONE REDACTED] P.O. Box 658, Louisville, GA 30434 Jefferson County Transit 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, gender 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. This is a section of the plan which covers general information about the transit agency. ---PAGE BREAK--- Title VI Plan Jefferson County Transit 2-2 2.1 First Time Applicant Requirements Jefferson County Transit is not a first time applicant for FTA/GDOT funding. The following is a summary of Jefferson County Transit’s current and pending federal and state funding. Current and Pending FTA Funding 1. Operating Assistance Contract # T006264, FY 2019, $165,063.00, Current 2. Capital Contract, FY 2019, $37,231.94, Current Current and Pending GDOT Funding 1. Capital Contract, FY 2019, $4,653.99, Current Current and Pending Federal Funding (non-FTA) 1. Dept. of Human Services, Contract # 42700-362-[PHONE REDACTED], FY 2019, $98,246.57, Current Current and Pending State Funding (non-GDOT) None During the previous three years, GDOT did complete a Title VI compliance review of Jefferson County Transit. Jefferson County Transit has not been found to be in noncompliance with any civil rights requirements. The following is a summary of the compliance review a. Date of compliance review - March 13, 2018 b. The purpose or reason for the review – Part of overall compliance review c. Agency or organization that performed the review – GDOT, Kristy Pettit d. Summary of the findings and recommendations of the review – no findings e. Report on the status of the findings and recommendations – N/A f. Current status of the compliance review - Complete 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 Jefferson County Transit 2-3 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. Jefferson County Transit will remain in compliance with this requirement by annual submission of certifications and assurances as required by GDOT and/or Department of Human Services. 2.3 Title VI Plan Concurrence and Adoption This Title VI Plan received GDOT concurrence on June 11, 2019. The draft plan was approved and adopted by Jefferson County Transit’s Board of Directors during a meeting held on Dec. 11, 2018. The final plan was adopted at the ______July 2019 BOC meeting. A copy of the meeting minutes and GDOT concurrence letter is included in Appendix C of this Plan. FTA Circular 4702.1B, Chapter III, Paragraph 2: Every application for financial assistance from FTA must be accompanied by an assurance that the applicant will carry out the program in compliance with the Title VI regulations. ---PAGE BREAK--- Title VI Plan Jefferson County Transit 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 sample of the notice is included in Appendix D of this Plan. The sample notice should be translated into other languages, as necessary. 3.2 Notice Posting Locations The Notice to Public will be posted at many locations to apprise the public of Jefferson County Transit’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 Jefferson County, Transit office lobby, county commission office, and on the Jefferson County Transit’s website at www.jeffersoncountyga.gov. Additionally, Jefferson County Transit will post the notice on transit vehicles. A sample version of this notice is included in Appendix D of this Plan along with any translated versions of the notice, as necessary. The public notice must be provided in any other language which meets the Safe Harbor threshold (See Appendix 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 Jefferson County Transit 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 Jefferson County Transit may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form (refer to Appendix Jefferson County Transit investigates complaints received no more than 180 days after the alleged incident. Jefferson County Transit will process complaints that are complete. Once the complaint is received, Jefferson County Transit 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. Jefferson County Transit has ninety (90) days to investigate the complaint. If more information is needed to resolve the case, Jefferson County Transit 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, Jefferson County Transit 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 will be made available to the public on Jefferson County’s website www.jeffersoncountyga.gov. 4.2 Complaint Form A copy of the complaint form in English is provided in Appendix E and on Jefferson County’s website www.jeffersoncountyga.gov. 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 Jefferson County Transit 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. Jefferson County Transit will submit Title VI Plans to GDOT for concurrence on an annual basis or any time a major change in the Plan occurs. Since we receive part of our funding from the Dept. of Human Services, a copy of our Title VI Plan will be submitted to them as well. 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 Jefferson County Transit does not have any sub-recipients to provide monitoring and assistance to. As a sub-recipient to GDOT, Jefferson County Transit utilizes the sub-recipient assistance and monitoring provided by GDOT, as needed. In the future, if Jefferson County Transit has sub-recipients, it will provide assistance and monitoring as required by FTA Circular 4702.1B. FTA Circular 4702.1B, Chapter III, Paragraph 11: Primary recipients should assist their sub-recipients in complying with DOT’s Title VI regulations, including the general reporting requirements. ---PAGE BREAK--- Title VI Plan Jefferson County Transit 4-3 4.5 Sub recipients and Subcontractors Jefferson County Transit 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. Jefferson County Transit, 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, national origin, sex, age, disability, religion or family status 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 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, national origin, sex, age, disability, religion or family status. 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, Jefferson County Transit shall impose contract sanctions as appropriate, including, but not limited to: ---PAGE BREAK--- Title VI Plan Jefferson County Transit 4-4 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 Jefferson County Transit, 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, Jefferson County Transit agrees 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. Jefferson County Transit 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 Jefferson County Transit 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 Jefferson County Transit. Additionally, vendors and contractors shall expressly require any subcontractors performing work or providing services pursuant to work for Jefferson County Transit 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 Jefferson County Transit. ---PAGE BREAK--- Title VI Plan Jefferson County Transit 5-1 5.0 Title VI Investigations, Complaints, and Lawsuits In accordance with 49 CFR 21.9(b), Jefferson County Transit 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 Jefferson County Transit 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 and Dept. of Human Services. Jefferson County Transit 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 1. 2. Lawsuits n/a n/a n/a n/a 1. 2. Complaints n/a n/a n/a n/a 1. 2. 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 Jefferson County Transit 6-2 6.0 Public Participation Plan The Public Participation Plan (PPP) for Jefferson County Transit 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 Jefferson County Transit. 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 Jefferson County Transit 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 Jefferson County Transit 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 Jefferson County Transit’s recent, current, and planned outreached activities.  Posted flyer on Facebook personal page, Jefferson County Yard sale page, and County Commissioners page  Put flyers on Bulletin Boards in the following areas: Ingles in Louisville and Wrens, IGA grocery in Louisville, Wadley and Wrens, Jefferson County Food Pantry, Jefferson County DFACS, Jefferson County Health Department, Jefferson County Commission Office, Jefferson County Sheriff’s Complex and local laundromats These flyers have been posted around the county as listed above for the last 3 years. 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 Jefferson County Transit 7-3 7.0 Language Assistance Plan Jefferson County Transit operates a transit system within Jefferson County. The Language Assistance Plan (LAP) has been prepared to address Jefferson County Transit’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 Jefferson County Transit service area there are 180 residents or 1.18% who describe themselves as not able to communicate in English very well (Source: US Census). Jefferson County Transit 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. Jefferson County Transit 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 Jefferson County Transit 8-1 8.0 Transit Planning and Advisory Bodies Jefferson County Transit 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 Jefferson County Transit 9-2 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, Jefferson County Transit will ensure the following: 1. Jefferson County Transit 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. Jefferson County Transit 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, Jefferson County Transit 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 Jefferson County Transit determines that the location of the project will result in a disparate impact on the basis of race, color, or national origin, Jefferson County Transit 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. Jefferson County Transit must demonstrate and document how both tests are met. Jefferson County Transit 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. Jefferson County Transit has not recently constructed any facilities nor does it currently have any facilities in the planning stage. Therefore, Jefferson County Transit does not have any Title VI Equity Analysis reports to submit with this Plan. 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 Jefferson County Transit 10-3 10.0 System-Wide Service Standards and Service Policies Jefferson County Transit 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 Jefferson County Transit 11-4 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 SAMPLE NOTICE TO PUBLIC APPENDIX E TITLE VI COMPLAINT FORM APPENDIX F PUBLIC PARTICIPATION PLAN APPENDIX G LANGUAGE ASSISTANCE PLAN APPENDIX H OPERATING AREA LANGUAGE DATA: JEFFERSON COUNTY TRANSIT SERVICE AREA APPENDIX I DEMOGRAPHIC MAPS APPENDIX J TITLE VI EQUITY ANALYSIS APPENDIX K TEXT FORMATTING PALETTE ---PAGE BREAK--- Title VI Plan Jefferson County Transit A-1 Appendix A FTA Circular 4702.1B Reporting Requirements for Transit Providers ---PAGE BREAK--- Title VI Plan Jefferson County Transit 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 Jefferson County Transit B-1 Appendix B Current System Description Current System Description 1. An overview of the organization including its mission, program goals and objectives. Jefferson County Transit’s current and long-term focus as a transportation provider is on maintaining the best-coordinated transportation system possible for this county. Our goal is to create a coordinated system with the objective of providing safe, reliable, timely and efficient transportation services to county residents. 2. Organizational structure, type of operation, number of employees, service hours, staffing plan and safety and security plan. Jefferson County Transit is a governmental organization. Our organization is made up of 6 full-time employees and 7 part-time employees. Our Supervisor 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. We will continue to operate at previous year (2018) service hours averaging 60 total fleet service hours per day or approximately 15,060 annual service hours (assuming 251 operating days). 3. Indicate if your agency is a government authority. Jefferson County Transit operates as a governmental organization. 4. Who is responsible for insurance, training and management, and administration of the agency’s transportation programs? Jefferson County Transit’s supervisor is responsible for training coordination 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 drivers 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 County Board of Commissioners 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 Supervisor’s responsibility to administer all aspects of the transportation program and to control access and usage of all agency vehicles. 5. Who provides vehicle maintenance and record keeping? Maintenance on all agency vehicles is provided by Jefferson County Board of Commissioners. Jefferson County Board of Commissioners 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 1841B Hwy. 24 West, ---PAGE BREAK--- Title VI Plan Jefferson County Transit B-2 Louisville, GA and are maintained by the Supervisor. All records are maintained and retained for a minimum of four years. 6. Number of current transportation related employees Our transportation department has a total of 13 employees that include: 5 full-time drivers, 6 part- time drivers, 1 Dispatcher and 1 Supervisor. 7. Who will drive the vehicle, number of drivers, CDL certifications, etc.? Only transportation employees that have completed all of the required safety and drivers training requirements will be allowed to drive the agency vehicles. 8. A detailed description of service routes and ridership numbers Transportation services provided through our program are available to all residents of Jefferson County. Our service incorporates transportation services. We provide a wide range of trip purposes that include: medical, nutrition, shopping, social service, training, employment, social and recreation. Approximately 10% 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. Our GDOT fleet includes 5 vans, 2 of which are equipped for wheelchair service. Jefferson County Board of Commissioners also owns 1 standard van and 1 wheelchair van that the county purchased from GDOT that can supplement any services that GDOT vans are unable to accommodate. We prioritize grouping trips and multi-loading to the maximum extent possible. We make 110 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--- Title VI Plan Jefferson County Transit C-1 Appendix C Title VI Plan Adoption Meeting Minutes and GDOT Concurrence Letter ---PAGE BREAK--- Title VI Plan Jefferson County Transit C-2 Insert a copy of the Title VI Plan adoption meeting minutes and the GDOT concurrence letter. ---PAGE BREAK--- Title VI Plan Jefferson County Transit D-1 Appendix D Title VI Sample Notice to Public ---PAGE BREAK--- Title VI Plan Jefferson County Transit D-2 Notifying the Public of Rights Under Title VI Jefferson County Transit  Jefferson County Transit operates its programs and services without regard to race, color, and national origin in accordance with Title VI of the Civil Rights Act. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with Jefferson County Transit.  For more information on Jefferson County Transit’s civil rights program, and the procedures to file a complaint, contact [PHONE REDACTED]; email [EMAIL REDACTED]; or visit our administrative office at 217 East Broad Street, Louisville, GA 30434. For more information, visit www.jeffersoncountyga.gov and click on the link for Jefferson Transit.  If information is needed in another language, contact [PHONE REDACTED]  You may also file your complaint directly with the FTA at: Federal Transit Administration Office of Civil Rights Attention: Title VI Program Coordinator, East Building, 5th Floor - TCR 1200 New Jersey Ave., SE, Washington, DC 20590 ---PAGE BREAK--- Title VI Plan Jefferson County Transit E-1 Appendix E Title VI Complaint Form ---PAGE BREAK--- Title VI Plan Jefferson County Transit E-2 Jefferson County Transit Title VI 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 [ ] Age [ ] Disability [ ] Family or Religious Status [ ] 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 complaint with this agency? Yes No ---PAGE BREAK--- Title VI Plan Jefferson County Transit 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: Teresa C. Snider P.O. Box 658 Louisville, GA 30434 ---PAGE BREAK--- Title VI Plan Jefferson County Transit F-1 Appendix F Public Participation Plan (PPP) ---PAGE BREAK--- Title VI Plan Jefferson County Transit F-2 Introduction The Public Participation Plan (PPP) for Jefferson County Transit 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 Jefferson County Transit. 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 Jefferson County Transit services and to provide a variety of efficient and convenient methods for receiving and considering public comment prior to implementing changes to services. Jefferson County Transit 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 Jefferson County Transit and its operations. The goals for this PPP include:  Inclusion and Diversity: Jefferson County Transit will proactively reach out and engage low-income, minority, and LEP populations for the Jefferson County Transit 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: Proposed adjustments to fares or services will be described in language that is clear and easy to understand.  Responsive: Jefferson County Transit 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 Jefferson County Transit. Jefferson County Transit 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 Jefferson County Transit F-3 The public will be invited to provide feedback on Jefferson County’s website www.jeffersoncountyga.gov and all feedback on the site will be recorded and passed on to Jefferson County Transit management. The public will also be able to call the Jefferson County Transit office at [PHONE REDACTED] during its hours of operation. Feedback collected over the phone will be recorded and passed on to Jefferson County Transit 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. For all public meetings, the venue will be a facility that is accessible for persons with disabilities and, preferably, is served by public transit. For community meetings and other important information, Jefferson County Transit will use a variety of means to make riders and citizens aware, including some or 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, particularly those that target LEP population  Flyers and information distribution through various libraries and other civic locations that currently help distribute timetables and other information  Communications to relevant elected officials  Other methods required by local or state laws or agreements All information and materials communicating proposed and actual service adjustments will be provided in English. Public Hearing Jefferson County Transit is required to perform public hearings for any construction projects, relocation of transit facilities, and major fare or service changes above 25%. LCB Meetings Jefferson County Transit does not have a Local Coordinating Board. ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-1 Appendix G Language Assistance Plan (LAP) ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-2 I. Introduction Jefferson County Transit operates a transit system within Jefferson County. The Language Assistance Plan (LAP) has been prepared to address Jefferson County Transit’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 Jefferson County Transit service area there are 180 residents or 1.18% who describe themselves as not able to communicate in English “very well” (Source: US Census). Jefferson County Transit 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. Jefferson County Transit 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 Jefferson County Transit be able to communicate effectively with all of its riders. When Jefferson County Transit 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. Jefferson County Transit 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 Jefferson County Transit 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 ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-3  Translation: Providing timely translation of important documents  Staffing: Identifying Jefferson County Transit 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 Jefferson County Transit 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 Jefferson County Transit program, activity or service. 2. The frequency with which LEP persons come in contact with Jefferson County Transit programs, activities or services. 3. The nature and importance of programs, activities or services provided by Jefferson County Transit to the LEP population. 4. The resources available to Jefferson County Transit 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 15,267 residents in the Jefferson County Transit service area 180 residents describe themselves as speaking English less than “very well”. People of Spanish descent are the primary LEP persons likely to utilize Jefferson County Transit services. For the Jefferson County Transit service area, the American Community Survey of the U.S. Census Bureau shows that among the area’s population 98.82% speak English “very well”. For groups who speak English “less than very well”, 99.44% speak Spanish and 0.00% speak Portuguese or Portuguese Creole. Appendix H contains a table which lists the languages spoken at home by the ability to speak English for the population within the Jefferson County Transit 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. Jefferson County Transit 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. ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-4 As discussed above, Census data indicates the lack of prominent LEP group. Phone inquiries and staff survey feedback indicated that Jefferson County Transit dispatchers and drivers interact infrequently with LEP persons. The majority of these interactions have occurred with LEP persons who mainly spoke Spanish. Over the past 20 years, Jefferson County Transit has had no requests for translated documents. 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. Jefferson County Transit is available to all residents of Jefferson County. d. Factor 4: The Resources Available to the Recipient and Costs Jefferson County Transit 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: copies of flyers in Spanish. 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. Jefferson County Transit has identified the number and proportion of LEP individuals within its service area using United States Census data (see Appendix As presented earlier, 97.12% of the service area population speaks English only. The largest non-English spoken language in the service area is Spanish Of those who primary spoken language is Spanish, approximately 1.17% identify themselves as speaking less than “very well”. Those residents whose primary language is not English or Spanish and who identify themselves as speaking English less than “very well” account for 0% of the service area population. ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-5 Jefferson County Transit 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. 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. Jefferson County Transit has undertaken the following actions to improve access to information and services for LEP individuals: 1. Survey transit drivers and other front-line staff annually on their experience concerning any contacts with LEP persons during the previous year. 2. Include statements clarifying that being bilingual is preferred on bus driver recruitment flyers and onboard recruitment posters. 3. 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. [PHONE REDACTED] 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 Jefferson County Transit, the most important staff training is for Customer Service Representatives and staff. ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-6 The following training will be provided to Customer Service Representative and staff: 1. Information on Title VI Procedures and LEP responsibilities 2. Documentation of language assistance requests 3. How to handle a potential Title VI/LEP complaint d. Element 4: Providing Note to LEP Persons Jefferson County Transit will make Title VI information available in English on the Agency’s website. Key documents are written in English. Notices are also posted in Jefferson County Transit office lobby, on buses, and facilities. 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 Jefferson County Transit’s financial resources are sufficient to fund language assistance resources needed Jefferson County Transit 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. Jefferson County Transit is open to suggestions from all sources, including customers, Jefferson County Transit staff, other transportation agencies with similar experiences with LEP 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. ---PAGE BREAK--- Title VI Plan Jefferson County Transit G-7 Jefferson County Transit service area does not have LEP populations which qualify for the Safe Harbor Provision. As shown in Appendix H, Jefferson County Transit does not 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. Jefferson County Transit 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 Jefferson County Transit J-1 Appendix H Operating Area Language Data: Jefferson County Transit Service Area ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-2 Language County Percent of Population Total 15,267 100 Speak only English 14,827 97.12 Spanish or Spanish Creole 342 2.24 Speak English “very well” 163 1.07 Speak English less than “very well” 179 1.17 French (incl. Patois, Cajun) 25 .16 Speak English “very well” 25 .16 Speak English less than “very well” 0 0 French Creole 1 0 Speak English “very well” 1 0 Speak English less than “very well” 0 0 Italian 1 0 Speak English “very well” 1 0 Speak English less than “very well” 0 0 Portuguese or Portuguese Creole 37 .24 Speak English “very well” 37 .24 Speak English less than “very well” 0 0 German 4 .03 Speak English “very well” 4 .03 Speak English less than “very well” 0 0 Yiddish 0 0 Speak English very well 0 0 Speak English less than “very well” 0 0 Other West Germanic languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Scandinavian languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Greek 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Russian 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Polish 6 .04 Speak English “very well” 6 .04 Speak English less than “very well” 0 0 Serbo-Croatian 0 0 Speak English “very well” 0 0 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-3 Language County Percent of Population Speak English less than “very well” 0 0 Other Slavic Languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Armenian 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Persian 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Gujarati 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Hindi 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Urdu 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Other Indic languages 5 .03 Speak English “very well” 5 .03 Speak English less than “very well” 0 0 Other Indo-European Languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Chinese 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Japanese 14 .09 Speak English “very well” 14 .09 Speak English less than “very well” 0 0 Korean 1 .01 Speak English “very well” 0 0 Speak English less than “very well” 1 .01 Mon-Khmer, Cambodian 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Hmong 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Thai 0 0 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-4 Language County Percent of Population Speak English “very well” 0 0 Speak English less than “very well” 0 0 Laotian 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Vietnamese 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Other Asian languages 4 .03 Speak English “very well” 4 .03 Speak English less than “very well” 0 0 Tagalog 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Other Pacific Island languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Navajo 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Other Native American languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Hungarian 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Arabic 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Hebrew 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 African languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 Other and unspecified languages 0 0 Speak English “very well” 0 0 Speak English less than “very well” 0 0 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-5 Appendix I Demographic Maps ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-6 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-7 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-8 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-9 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-10 ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-11 Appendix J Title VI Equity Analysis ---PAGE BREAK--- Title VI Plan Jefferson County Transit J-12 This Does not apply to Jefferson County ---PAGE BREAK---