EASTER SEALS WEST ALABAMA
TRANSPORTATION DEPARTMENT
TITLE VI PROGRAM
TBA
1110 Dr. Edward Hillard Dr,
Tuscaloosa, AL 35401
205-722-1004
www.eastersealswestal.org
This document was prepared in accordance with the FTA Circular 4702.1B, dated October 1, 2012.
TABLE OF CONTENTS
Page
- Policy Statement .............................................................................................................. 1
- Notice to the Public ......................................................................................................... 1
- Complaint Procedures and Form ................................................................................. 1
- Transit-Related Investigations, Complaints, and Lawsuits ...................................... 2
- Public Participation Plan ............................................................................................... 3
- Limited English Proficient Plan .................................................................................... 4
- Minority Representation on Planning and Advisory Bodies ................................... 6
- Guidance on Determining Site or Location of Facilities ........................................... 6
- Additional Title VI Information ........................................................................................ 6
- Board Meeting Resolution of Approved Title VI Program ......................................... 6
APPENDICES
Appendix A – Title VI Notice to the Public ......................................................................... 7
Appendix B – Title VI Complaint Form ................................................................................ 9
Appendix C – List of Transit-Related Investigations, Complaints, and Lawsuits,........ 13
Appendix D – Limited English Proficiency Plan ............................................................... 14
Appendix E – Table Depicting Minority Representation on Planning and Advisory
Bodies ...................................................................................................................................... 27
Appendix F – Title VI Construction Project Analysis ........................................................ 28
Appendix G – Additional Title VI Information .................................................................... 31
Appendix H – Documentation of Title VI Authorization ................................................... 33
- Policy Statement
EASTER SEALS WEST ALABAMA (ESWA) ensures compliance with Title VI of the Civil Rights Act of 1964, 49 CFR, Part 21, and related statutes and regulations to the end that “no person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance” (42 U.S.C. Section 2000d) including the denial of meaning access for Limited English Proficient (LEP) persons. ESWA further grants equal opportunity to all regardless of age, disability, marital status, sexual orientation, pregnancy, or any other legally protected status.
The purpose of this plan is to assist ESWA in its administration and management of Title VI related activities. ESWA’S Title VI Coordinator for Transit is the Transportation Director. The Director can be contacted at 205-722-1004 ext. 269 and/or by email at transportation@eswaweb.org.
- Notice to the Public
ESWA has developed a Title VI Notice to provide information to the public regarding ESWA’s Title VI obligations and to inform the public of the protections against discrimination afforded to them by Title VI. The notice also includes contact information to file a discrimination complaint with ESWA as well as information to file complaint directly with the Federal Transit Administration (FTA).
ESWA has posted the Title VI Notice on the agency’s website and in public areas of the agency’s office(s) including the receptionist area and meeting rooms. The notice is also posted in all transit vehicles. This notice will be translated into languages other than English as needed. A copy of the notice is included as Appendix A.
- Complaint Procedures and Form
A Title VI complaint may be filed by any individual or individuals who allege that he or she has been subjected to discrimination or adverse impact under any FTA funded program or activity based on race, color, or national origin. ESWA has adopted Title VI complaint procedures for investigating and tracking complaints. A formal, signed, written Title VI complaint form must be filed within 180 days of the date of the alleged act of discrimination. A copy of the complaint form is included in Appendix B. The complaint procedures and complaint form is posted on ESWA’s website. Completed forms should be submitted to:
TRANSPORTATION DIRECTOR
Easter Seals West Alabama
P. O. Box 2817
Tuscaloosa, AL 35403
205-759-1211
FAX: 205-722-1008
transportation@eswaweb.org
Once the complaint is received, ESWA will review it to determine who has jurisdiction. The complainant will receive an acknowledgement letter informing her/him whether the complaint will be investigated by ESWA’s office. ESWA will only process complaint forms that are complete.
In a situation where the complainant is unable or incapable of providing a written complaint, a verbal complaint of discrimination may be made to ESWA. Under these circumstances, the complainant will be interviewed and ESWA will assist the complainant in converting the verbal allegations to a formal written complaint.
ESWA has 15 business days to investigate the complaint. If more information is needed to resolve the case, ESWA may contact the complainant. The complainant has 15 business days from the date of this 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 15 business days, ESWA can administratively close the case. A case can also be administratively closed if the complainant no longer wishes to pursue the 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. An LOF summarizes the allegations and the interviews regarding the alleged incident and explains whether any disciplinary action, additional training of the accused staff member or other action will occur. If the complainant wishes to appeal the decision, she/he has 15 days after the date of the closure letter or the LOF to do so.
If the complainant is not satisfied with actions taken locally or if they demand further action, the complaint may also file a complaint directly with the Federal Transit Administration at FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.
*If information is needed in another language, complainant can contact 205-722-1004.
- Transit-Related Investigations, Complaints, and Lawsuits
ESWA shall maintain a log of Title VI complaints received. The log shall include the date the complaint was filed, a summary of the allegations, the status of the complaint, and actions taken in response to the complaint. Any transit related Title VI active investigations and lawsuits shall also be included in this log. This log shall be included in the Title VI Program that is submitted to ALDOT every three years.
There have been no Title VI transit-related investigations, complaints, or lawsuits received by ESWA. A copy of the Title VI Transit Investigations, Complaints, and Lawsuits Form that will be used if a complaint or lawsuit is filed can be found in Appendix C.
- Public Participation Plan
In an effort to more fully integrate the opinions of minority, low-income, and LEP populations into community outreach activities, ESWA’s public participation program will:
- Continue to coordinate with community-based organizations to identify and implement strategies to reach out to members in the affect minority, low income, and LEP communities.
- Reduce barriers to public participation from these segments of the population.
- Place public notices on transit website, in the receptionist areas, and on transit vehicles.
- Utilize the media (newspaper, radio, television, etc.) to notify the minority, low-income, and LEP populations of public involvement efforts
- Provide opportunities for public participation through means other than written communication such as personal interviews or the use of recording devices to capture oral comments.
- Hold public meetings in locations, facilities, and at meeting times that are convenient and accessible to the minority, low-income, and LEP populations.
- Ensure that the decision making process adequately considers the issues and concerns raised by minority, low-income, and LEP populations.
- Develop a Title VI brochure in English and other languages as needed.
- Host a table or both at community events or piggyback engagement efforts onto regularly scheduled community meetings.
- Develop signs, fliers, or other materials to mail or distribute to the general puclic and to post in libraries, community centers, etc.
- Consider non-traditional media outlets such as local neighborhood publications or internet outlets such as You Tube, Twitter, or Facebook.
To date, ESWA has utilized the following public outreach and involvement activities:
- ESWA staff members have participated in and supported Community-Based Transportation programs for disadvantaged communities (i.e. Housing Authority, WARC, Tuscaloosa One).
- Placed public notices and in the receptionist areas.
- Utilized the television local noon show, the local APT network and local newspaper to notify the minority, low-income, and LEP populations of public involvement efforts.
- Conducted public meetings in locations, facilities, and at meeting times that are convenient and accessible to the minority, low-income, and LEP populations.
- Ensured that the decision making process adequately considers the issues and concerns raised by minority, low-income, and LEP populations.
- Provided Title VI brochures in English and Spanish.
- Worked with United Way of West Alabama to promote transportation services available to the disadvantages
- Distributed program brochures to the general public.
- Limited English Proficient Plan
- The number or proportion of LEP persons eligible to be served or likely to be encountered by ESWA’s program. In addition to the number or proportion of LEP persons served, the analysis identified:
- How LEP persons interact with ESWA;
- Where LEP communities are located and the number or proportion of LEP persons from each language group to determine the appropriate language services for each language group;
- The literacy skills of LEP populations in their native languages in order to determine whether document translation will be an effective practice; and
- Whether or not LEP persons are underserved by ESWA due to language barriers.
- The frequency with which LEP persons come into contact with the program. The following areas were evaluated:
- Public meeting participation;
- Customer service interactions;
- Ridership surveys; and
- Operator surveys.
- The nature and importance of ESWA’s program to people’s lives.
- The resources available for LEP outreach and the costs associated with that outreach.
ESWA has developed a Limited English Proficiency Plan which is located in Appendix D. It includes:
- Results of the Four Factor Analysis, including a description of the LEP population(s) served;
- A description of how language assistance services will be provided;
- The methods used by ESWA to provide language assistance services;
- A description of how employees are trained to provide timely and reasonable language assistance to LEP populations;
- A description of how notice is provided to LEP persons about the availability of language assistance; and
- An explanation of how the plan is monitored, evaluated, and updated.
In accordance with the Safe Harbor Provision, Tuscaloosa County has only one language group that exceeds the threshold of 1,000 persons but this group does not exceed the 5% which is less of the total population eligible to be served by the program: Spanish. This language group is listed in Appendix D. ESWA focuses translation efforts in Spanish, which is the largest language group other than English. Vital documents such as public notices, complaint forms, and complaint procedures will be available in Spanish as needed. ESWA also provides free translation services upon request.
- Minority Representation on Planning and Advisory Bodies
ESWA has a transit-related non-elected Board of Directors. A table depicting the racial breakdown of the membership of the Board can be found in Appendix E. ESWA also has an Equal Opportunity Committee.
All committees actively recruit and continue to reach out to community groups to find additional diverse individuals to represent the population and help provide experience and ideas to better transit services.
- Guidance on Determining Site or Location of Facilities
ESWA will complete a Title VI equity analysis during the planning state of any new facility with regard to where it is to be located or sited to ensure the location is selected without regard to race, color, or national origin. Wherever necessary, needed, and/or required, ESWA will engage in outreach to persons potentially impacted by the placement of facilities. The Title VI equity analysis will compare the equity impacts of various alternatives and will occur before the selection of preferred sites. A copy of the Title VI Construction Project Analysis can be found in Appendix F.
- Additional Title VI Information
- Board meeting Resolution of Approved Title VI Program
ESWA Board of Directors approved the Title VI program TBA. A copy of the AUTHORIZING RESOLUTION is included as Appendix H.
Appendix A
TITLE VI NOTICE OF PROTECTION AGAINST DISCRIMINATION
ESWA operates its programs 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 ESWA.
For more information on the civil rights program and the procedures to file a complaint, contact:
ESWA
1110 Dr. Edward Hillard Dr.
Tuscaloosa, AL 35401
205-759-1211
www.eswaweb.org
A complaint may be filed directly with the
Federal Transit Administration by contacting:
Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor-TCR
1200 New Jersey Ave., SE
Washington DC 20590
If information is needed in another language, then contact
205-722-1004 ext. 269
El Apéndice A
TÍTULO VI AVISO DE PROTECCIÓN CONTRA LA DISCRIMINACIÓN
ESWA ejecuta sus programas sin tener en cuenta la raza, color, origen nacional y de conformidad con lo dispuesto en el Título VI de la Ley de Derechos Civiles. Cualquier persona que cree que ella o él ha sido agraviada por cualquier práctica discriminatoria ilegal en virtud del Título VI puede presentar una queja con ESWA.
Para obtener más información sobre el programa de derechos civiles y de los procedimientos para presentar una queja, póngase en contacto con:
ESWA
Dr. Edward 1110 Hillard Dr.
Tuscaloosa, AL 35401
205-759-1211
www.eswaweb.org
Una queja puede ser presentada directamente a la
Administración Federal de Tránsito poniéndose en contacto con:
Oficina de Derechos Civiles
Atención: Título VI Coordinador del Programa
edificio este, 5ª planta-TCR
1200 New Jersey Ave., SE Washington
DC 20590
Appendix B
Title VI Complaint Form
Section I
Name:
Address:
Telephone (Home):
Telephone (Work):
Electronic Mail Address:
Section II
Are you filing this complaint on your own behalf? Circle
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
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? Circle
Yes
No
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: EASTER SEALS WEST ALABAMA TRANSPORTATION
Contact person: Deborah Chandler
Title: Transportation Project Director
Telephone number: 205-722-1004 ext. 269
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:
TRANSPORTATION DIRECTOR
ESWA
P. O. Box 2817
Tuscaloosa, AL 35403
Apéndice B
Itulo VI Formulario de Queja
Sección I
Nombre: ____________________________________________
Dirección: ___________________________________________
Teléfono (Casa): ______________________ Teléfono (trabajo): ____________________________
Dirección de correo electrónico: en la sección ____________________
Sección II
Se puede presentar esta reclamación en su propio nombre? Círculo Sí No
Si usted contestó "sí" a esta pregunta, vaya a la Sección III.
Si no es así, por favor proporcione el nombre y la relación de la persona para la que se quejan:___________________
Por favor, explique por qué se han presentado para una tercera parte: ____________
Por favor, confirme que ha obtenido el permiso de la parte perjudicada si va a presentar en nombre de un tercero. Sí No
Sección III
Creo que la discriminación que he experimentado fue basado en (marque todas las que correspondan):
[ ] raza [ ]color [ ] origen nacional
Fecha de presunta discriminación (Mes, Día, Año): ______________________________
Explicar lo más claramente posible lo que ocurrió y por qué usted cree que son objeto de discriminación. Describir todas las personas que han participado. Incluir el nombre y la información de contacto de la(s) persona(s) que discrimina contra usted (si se conoce) así como los nombres y la información de contacto de los testigos. Si se necesita más espacio, utilice la parte de atrás de este formulario.
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
Sección IV
Anteriormente ha presentado un Título VI queja con esta agencia? Círculo Sí No
Sección V
¿Ha presentado esta queja con cualquier otro local, estatal o federal, o con cualquier tribunal Federal o Estatal?
[ ] Sí [ ] No
Si la respuesta es sí, marque todo lo que aplique:
[ ] Agencia Federal:_________________
[ ] Tribunal Federal [ ] ESWAAgencia Estatal
[ ] Tribunal de Justicia del [ ] Estado Agencia Local
Proporcione información sobre una persona de contacto de la agencia/tribunal, donde se presentó la denuncia.
Nombre:_________________________________
Título: __________________________________
Organismo: ______________________________
Dirección: ________________________________
Teléfono: _________________________________
Sección VI
Nombre de agencia denuncia es contra: EASTER SEALS WEST ALABAMA TRANSPORTE
Persona de contacto: Deborah Chandler
Título: Proyecto de Transporte Director
Número de teléfono: 205-722-1004 ext 269
Adjuntar cualquier material escrito o de otro tipo de información que usted considere relevante para su reclamación.
Firma y fecha requerida a continuación
______________________________ ________________________
Firma Fecha
Envíe este formulario en persona a la dirección que aparece a continuación o por correo el formulario a:
TRANSPORTE
ESWA DIRECTOR
P. O. Box 2817
Tuscaloosa, AL 35403
Appendix C
List of Transit-Related Investigations, Complaints, and Lawsuits
Date
(Month, Day, Year)
Summary
(include basis of complaint: race, color, or national origin)
Status
Pending or Closed
Action(s) Taken
Investigations
1.
2.
Complaints
1.
2.
Lawsuits
1.
2.
Appendix D
LIMITED ENGLISH PROFICIENCY ASSESSMENT
Provider:
Easter Seals West Alabama
Date Completed:
January 22, 2015
Census Data based on Census 2010 Data and 2007-2011 American Community
Survey on pages 16-17.
City/County
Population
Population that Speaks English Less than Very Well (Number)
Population that Speaks English Less than Very Well (as Percent of Total Population)
Language/Languages Spoken by “Speak English Less Than Very Well” Population
Tuscaloosa County
180,060
3,373
1.9%
Spanish or Spanish Creole
Tuscaloosa County
180,060
428
.20%
Indo European
Tuscaloosa County
180,060
988
.50%
Asian Pacific Island
Tuscaloosa County
180,060
136
.10%
Other
- Survey your drivers. Do they indicate that there is a need for language assistance for riders? If so, which languages?
- Survey your receptionist, customer service representative, and schedule/dispatcher. Do they indicate that there is a need for language assistance for riders? If so, which languages?
- Contact major employers. Do they indicate a need for language assistance for potential transit users? If so, which languages?
Employer
Response
- Contact human service agencies. Do they indicate a need for language assistance for potential transit users? If so, which languages?
Agency
Response
- Contact local towns and cities, including the police departments. Do they indicate a need for language assistance for potential transit users? If so, which languages?
Town/City/Department
Response
- Contact the local school systems. Do they indicate a need for language assistance for potential transit users? If so, which languages?
School System
Response
- Contact the local churches. Do they indicate a need for language assistance for potential transit users? If so, which languages?
Church
Response
- Inventory second languages spoken by staff.
- Do the responses indicate a need for language assistance for potential transit users? If so, which languages? If yes, please prepare and submit an LEP plan.
LIMITED ENGLISH PROFICIENCY (LEP) INTERACTIONS STAFF SURVEY
Individuals with Limited English Proficiency do not speak English as their primary language, have a limited ability to read, speak, write, or understand English or are native English speakers with low levels of literacy.
1) In the past six months have you encountered a Limited English Proficiency (LEP) person in your work activities?
2) What language have you encountered in the past six months?
3) How many times have you encountered a LEP person speaking (language selected in Question 2) in the past six months?
4) What type of work activity were you involved in when you encountered this language?
Choose all that apply
- Outreach/Public Meeting
- E‐mail
- Phone Call
- Other, please specify
5) Have you encountered additional languages in the past six months?
EASTER SEALS WEST ALABAMA
LIMITED ENGLISH PROFICIENCY (LEP)
PLAN
1110 Dr. Edward Hillard Dr.
Tuscaloosa, AL 35401
205-759-1211
eswaweb.org
Introduction
This Limited English Proficiency Plan (LEP) has been prepared to address ESWA’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English skills. This plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, et seq. and its implementing regulations, which state that no person shall be subjected to discrimination on the basis of race, color, or national origin.
Plan Summary
ESWA has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access transit services provided by ESWA. As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write, or understand English.
This plan outlines how ESWA identifies a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how LEP persons are notified that assistance is available.
In order to prepare this plan, ESWA undertook the U.S. DOT Four Factor Analysis which considers the following factors:
- The number or proportion of LEP persons in the service area who may be served or are likely to encounter a ESWA program, activity, or service.
- The frequency with which LEP persons come into contact with ESWA’s programs, activities, or services.
- The nature and importance of programs, activities, or services provided by ESWA to the LEP population.
- The resources available to ESWA and the overall cost to provide LEP assistance.
Four Factor Analysis
- The number or proportion of LEP persons in the service area who may be served or are likely to encounter a ESWA program, activity, or service.
ESWA provides Job Access/Reverse Commute transportation to Tuscaloosa County and will likely encounter more Spanish speaking persons that benefit from the transit programs than any other LEP persons. Transportation to and from work and daycare for children is important to LEP persons to help them acclimate to the area and provide income for their families.
ESWA reviewed the 2010 U.S. Census Report and determined that the total population for TUSCALOOSA COUNTY is 180,060 and 4,925 or 2.7% residents report speaking English less than very well. Those persons with limited English proficiency are in the following groups: 3,373 Spanish or Spanish Creole, 428 Indo European languages, 988 speak Asian Pacific Island languages, and 136 other languages. The most popular language spoken at home is Spanish.
- The frequency with which LEP persons come into contact with ESWA’s programs, activities, or services.
ESWA assessed the frequency with which staff and drivers have contact with LEP persons, both presently and in the past. The following contact points and frequencies have been identified:
Public meeting participation Minimum
Customer service interactions Minimum
Ridership surveys Minimum
Operator surveys Minimum
- The nature and importance of programs, activities, or services provided by ESWA to the LEP population.
ESWA’s transportation service provides transportation to low-income persons to and from work in Tuscaloosa County. By providing these services to LEP individual’s ability to obtain employment and provide for their families is enhanced. Working in the community aids in the acclimation of LEP individuals to another language.
The largest geographic concentration of LEP individuals in ESWA’s service area other than English are Spanish speaking residents. These residents are often dependent upon our specialized transportation services. It is also likely that ESWA will encounter LEP individuals at community outreach events. - The resources available to ESWA and the overall cost to provide LEP assistance.
ESWA assessed its resources and determined that funds are available within the current budget for providing LEP assistance. ESWA also determined which documents would be most beneficial if translated into other languages and the cost associated with this effort. An inventory of available organizations with which ESWA could partner for outreach and translation efforts was also identified. In addition, bilingual staff, volunteer community agencies, and web based translation services were identified as ways to reduce the cost of translation services.
Limited English Proficiency (LEP) Plan Outline
There are five areas that comprise ESWA’s LEP PLAN:
1. Identifying LEP Individuals Requiring Language Assistance
2. Providing Language Assistance
3. Training Staff
4. Providing Notice to LEP Persons
5. Monitoring and Updating the LEP Plan
1. Identifying LEP Individuals Requiring Language Assistance
ESWA identifies an LEP person who requires language assistance by:
- Examining customer service records to identify language assistance that has been received in the past, either at meetings or over the phone, to determine whether language assistance might be needed for similar future situations.
- Regularly surveying drivers and other first line staff who have direct or indirect contact with LEP individuals.
- Providing Language Identification Flash Cards at public meetings.
2. Providing Language Assistance
ESWA assists an LEP person who requires language assistance by:
- Networking with local human service organizations that provide service to LEP individuals and seeking opportunities to provide information on ESWA’s programs and services through these organizations.
- Posting ESWA’s Title VI Notice, Complaint Procedures, Complaint Form, and LEP Plan on the agency’s website.
- Providing travel training to LEP persons.
- Identifying in-house staff with other language abilities to assist with translation services.
- Making public notices, publications, and other printed materials (including webpage content) available in other languages.
- Placing statements in notices and publications to notify LEP persons that free language interpreter services are available for meetings with a seven day advance notice.
- Providing Language Identification Flash Cards onboard ESWA’s fleet and at the Administrative Office.
- Utilizing a web-based translation service application such as Google Translate.
3. Training Staff
ESWA will train staff members on their role and responsibilities in providing meaningful access to services for LEP persons by:
- Developing a curriculum and corresponding PowerPoint to educate staff on the Title VI requirements for providing meaningful access to services for LEP persons.
- Providing staff with a description of language assistance services offered by ESWA.
- Providing staff with specific procedures to be followed when encountering a LEP person, including how to handle a potential Title VI / LEP complaint.
- Instructing staff on the use of Language Identification Flash Cards.
4. Providing Notice to LEP Persons
ESWA will provide notice to LEP persons in both oral and written communications by:
- Providing the following written communications in English and Spanish as needed:
- Onboard fliers containing information about public hearings;
- Interior bus signage that displays safety or system policy information; and
- Title VI Notice, Complaint Procedures, and Complaint Form.
5. Monitoring and Updating the LEP Plan
This plan is designed to be flexible and should be viewed as a work in progress. As such, it is important to consider whether new documents and services should be made accessible for LEP persons and to monitor changes in demographics and types of services.
ESWA will update the LEP Plan as required by the U.S. DOT. At a minimum, the plan will be reviewed and updated when data from the most recent U.S. Census is made available, when clear and higher concentrations of LEP individuals are present in ESWA’s service area, and/or during the process of updating Title VI Program.
ESWA will monitor and update its LEP Plan by:
- Determining how the needs of LEP persons have been addressed.
- Determining the current LEP population in the service area and whether the needfor translation services has changed.
- Determining whether local language assistance programs have been effective and sufficient to meet the need.
- Determining whether ESWA’s financial resources are sufficient to fund the needed language assistance efforts.
- Determining whether ESWA has fully complied with the goals of the LEP Plan.
- Determining whether complaints have been received concerning ESWA’s failure to meet the needs of LEP individuals.
Dissemination of ESWA’s LEP Plan
The LEP Plan will be disseminated to customers and the community by:
- Publishing the LEP Plan and the Title VI Plan on ESWA’s website so that any person or agency with internet access can view and download these plans. Alternatively, any person or agency may also request a copy of the plan at no cost via telephone, fax, mail, or in person. LEP individuals may request that these plans be translated into various languages. If feasible, ESWA will accommodate such requests.
- Distributing the LEP Plan to human service organizations in the service area.
Questions or comments regarding the LEP Plan may be submitted to ESWA at the following address:
TRANSPORTATION DIRECTOR
P.O.BOX 2817
Tuscaloosa, AL 35403
205-722-1004 ext. 269
www.eswaweb.org
Appendix E
Table Depicting Minority Representation on Planning and Advisory Bodies
Body
Caucasian
Latino
African American
Asian American
Native American
Population
130,790
3,421
58,564
2,493
1,175
Board of Directors
25
0
6
0
0
Name of Committee
Name of Committee
Appendix F
Title VI Construction Project Analysis
Name of Agency_____________________________________________________________
Contact Person:_____________________________________________________________
Mailing Address:_____________________________________________________________
City/State/Zip Code:_______________ __________________________________________
Contact Person:______________________________Title____________________________
Phone: ____________________________ Fax ____________________________________
E-Mail Address: _____________________________________________________________
1. Describe the low-income and minority populations within the area affected by the construction project and the method used to identify these populations.
2. Describe the adverse effects of the project both during and after construction that would affect the identified minority and low-income populations and minority-owned businesses.
3. Provide a detailed list of all minority-owned businesses and households that will be affected by the construction project.
4. Describe the potential negative environmental impact, such as noise, air, or water pollution.
- Describe the relocation program and/or other measures adopted by the subrecipient that will be used to mitigate any identified adverse social, economic, or environmental effect of the proposed construction project.
- For each of the identified low income or minority communities, discuss the positive effects such as an improvement in transit service, mobility, or accessibility.
7. Describe all mitigation and environment enhancement actions incorporated into the project to address the adverse effects, including any special features of the relocation program that go beyond the requirements of the Uniform Relocation Act and address adverse community effects such as separation or cohesion issues, and replacement of community resources destroyed by the project.
- Describe the remaining effects, if any, and why further mitigation is not proposed.
- For projects that traverse predominantly minority and low-income and predominantly non-minority and non-low-income areas, provide a comparison of mitigation and environmental enhancement actions that affect predominantly low-income and minority areas with mitigation implemented in predominantly non-minority or non-low-income areas.If there is no basis for such a comparison, describe why that is so.
Appendix G
Additional Title VI Information
All subrecipients must address each of the following:
1. Describe all pending applications for financial assistance currently provided by other Federal agencies to the applicant.
N/A
- Summarize all civil rights compliance reviews conducted by other local, state or federal agencies during the last three years. (Include the reason for review, name of agency performed the review, and report on the status of findings or recommendations.)
N/A
- Is your agency considered a minority organization:____Yes__X__No
If yes, check the category(ies) that apply.
___ Black American ___ Sub-Continent Asian-American
___ Hispanic American ___ Asian-Pacific American
___ Native American ___ Other
- Does your agency provide transportation services to minority communities?
_X__Yes ___ No
If yes, check the category(ies) that apply.
_X_ Black American ___ Sub-Continent Asian-American
_X_ Hispanic American ___ Asian-Pacific American
___ Native American ___ Other
- Has your Title VI Coordinator/EEO Officer changed during the reporting period or since your last Title VI Plan was approved?If yes, please provide the name and contact information for the new coordinator/EEO Office.
Transportation Director
Easter Seals West Alabama
1110 Dr. Edward Drive
Tuscaloosa, AL 35401
205-722-1004 ext. 269
- Has your organization had any projects and/or service changes that have Title VI, Limited English Proficiency (LEP), or Environmental Justice (EJ) impacts?
N/A
If yes, please complete the following items:
- Provide a brief description of these projects/service changes.
- What did you do to ensure that populations affected by the project and/or service change had meaningful access to and involvement in the development process?
- What is the number of percentage of LEP or EJ populations affected by the project and/or service change?
Appendix H
EASTER SEALS WEST ALABAMA
BOARD OF DIRECTORS’
TITLE VI PLAN RESOLUTION
WHEREAS, Easter Seals West Alabama is a recipient of federal financial assistance from the Alabama Department of Transportation in support of transit services which imposes certain obligations upon the recipient, including complying with the Title VI federal requirements; and
WHEREAS, Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and national origin in programs and activities receiving federal financial assistance; and
WHEREAS, Easter Seals West Alabama commits to assure that no person shall, on the grounds of race, color, national origin, religion, creed, age, disability, marital status, veteran status, sex, sexual orientation, or pregnancy as provided by Title VI of the Civil Rights Act of 1964 and the Civil Rights Restoration Act of 1987 (PL 100.259), be excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination under any program or activity regardless of the funding source;
NOW, THEREFORE, be it resolved by the Board of Directors of Easter Seals West Alabama as follows:
The Board approves the proposed Title VI Program in order to comply with the Title VI federal requirements.
The TRANSPORTATION DIRECTOR in his/her capacity will serve as the Title VI Officer and is authorized to revise and update the plan as necessary.
Adopted this______day of____________.
Signature: _______________________ Attest: _________________________
Typed Name: ___SAMMY WATSON _ Typed Name: ROSALIND HOLLOMAN_
Title: _CHAIRPERSON_____________ Title: __SECRETARY_________
