HomeMy WebLinkAboutAgenda - 03-17-2015 - 7cORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: March 17, 2015
SUBJECT: 2015 Orange Public Transportation Title VI Plan
DEPARTMENT: Planning and Inspections
ATTACHMENT(S):
1. Draft 2015 Title VI Plan
2. Resolution of Adoption
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Action Agenda
Item No. 7 -c
PUBLIC HEARING: (Y /N) No
INFORMATION CONTACT:
Bret Martin, Transportation Planner,
919- 245 -2582
Peter Murphy, Transportation
Administrator, 919 - 245 -2002
Craig Benedict, Planning Director, 919-
245 -2592
PURPOSE: To consider adoption by resolution of the draft 2015 Orange Public Transportation
Title VI Plan.
BACKGROUND: Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of
race, color, or national origin in programs and activities receiving federal financial assistance.
Specifically, Title VI provides 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). The Federal -Aid Highway Act of 1973 added the requirement that
there be no discrimination on the grounds of sex, and the Civil Rights Restoration Act of 1987
defined the word "program" to make clear that discrimination is prohibited through an entire
agency if any part of the agency receives federal financial assistance.
In response to this requirement, public transportation providers making use of federal financial
assistance to provide their services are required to develop a Title VI plan /program to guide their
administration and management of Title VI- related activities. More particularly, the plan must
clarify roles, responsibilities, and procedures established to ensure compliance with Title VI.
Orange County transportation planning staff has developed a plan /program that includes the
required components for a Title VI plan /program as provided in guidance issued by the Federal
Transit Administration (Attachment 1). The plan focuses on Orange Public Transportation
programs with significant public contact responsibilities and provides policy direction necessary
to ensure compliance with Title VI.
Although required for transit provider recipients of federal financial assistance for many years,
this is the first Title VI plan /program developed for OPT. The development of this plan /program is
a corrective action taken by OPT and NCDOT to meet specific federal guidance requirements for
what should be provided and addressed in a Title VI program. The plan /program is necessary for
OPT to continue to receive certain federal grants as a sub - recipient through the State, as well as
for receiving additional grant sources directly from the Federal Transit Administration (FTA) that
transportation planning staff is pursuing or has secured.
The draft Orange Public Transportation Title VI plan contains the following federally required
components:
1) Draft of notice to the public indicating that the agency complies with Title VI and informs
the public of the protections against discrimination afforded to them by Title VI;
2) The agency's instructions to the public regarding how to file a Title VI discrimination
complaint, including a copy of the complaint form;
3) Any public transportation- related Title VI investigations, complaints, or lawsuits filed with
the agency;
4) A public participation plan that includes an outreach plan to engage minority and limited
English proficient populations, as well as a summary of recent outreach efforts;
5) The agency's plan for providing language assistance to persons with limited English
proficiency; and
6) A table depicting the racial breakdown of the membership of the OUTBoard, which
serves as Orange Public Transportation's non - elected advisory board, and a description
of efforts made to encourage the participation of minorities on the OUTBoard.
Next Steps:
Following the BOCC's consideration of approval of the draft Title VI plan, the plan will then be
forwarded for review and approval to agencies that require the plan for grant eligibility, such as
NCDOT and the Federal Transit Administration. Once approved by those agencies, the plan
will be published as OPT's official Title VI plan /program and implemented accordingly before
expansion services begin this spring. To ensure continued compliance with federal
regulations, the plan /program will be updated and reconsidered for adoption every three (3)
years.
FINANCIAL IMPACT: The only financial impact associated with this item is the consequence
of being ineligible for transit grant funding in the absence of an adopted Title VI plan /program.
For FY 2014, OPT received a total of $235,493 from federal sources, which covered
approximately 28.8 percent of OPT's budget expenditures. Orange County transportation
planning staff has worked to secure additional federal funding for OPT in future years that
would range between an additional $250,000 - $432,000 per year.
RECOMMENDATION(S): The Manager recommends the Board:
1) Consider approval of the attached resolution (Attachment 2) approving and authorizing the
plan; and
2) Authorize the Orange County Transportation Planning staff to submit the plan to the North
Carolina Department of Transportation and Federal Transit Administration.
ATTACHMENT 1: DRAFT 2015 TITLE VI PLAN
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Agency Name: Orange County /Orange Public Transportation
Date Adopted: 03/17/2015
Adopted By: Orange County Board of County Commissioners
This plan /policy is hereby adopted and signed by:
Transportation Administrator, Orange Public Transportation
Name
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Date
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Plan /Policy Statement
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Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color,
or national origin in programs and activities receiving Federal financial assistance.
Specifically, Title VI provides 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).
Orange County /Orange Public Transportation (OPT) is committed to ensuring that no
person is excluded from participation in, or denied the benefits of its transit services on
the basis of race, color, or national origin, as protected by Title VI in Federal Transit
Administration (FTA) Circular 4702.1 B. Orange County /OPT as a recipient of FTA grant
funding either directly from FTA or through the North Carolina Department of
Transportation (NCDOT) will comply with the Title VI of the Civil Rights Act of 1964 and
the U.S. Department of Transportation implementing regulations.
This plan was developed to guide Orange County /OPT in its administration and
management of Title VI- related activities.
II. Title VI information Dissemination
Title VI information posters shall be prominently and publicly displayed in the
administrative offices of OPT and on the system's revenue vehicles. The name of the
Title VI coordinator will be displayed on the poster. Additional information related to
nondiscrimination obligation can be obtained from the OPT Title VI Coordinator.
The Title VI Notice to the Public is as follows-
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NOTIFYING THE PUBLIC OF RIGHTS UNDER TITLE VI
Orange Public Transportation
• Orange Public Transportation operates its programs and services without regard
to race, color, and national 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 Orange Public
Transportation.
• For more information on Orange Public Transportation's civil rights program and
the procedures to file a complaint, contact (919) 245 -2008; email
r)murr)hyn,oran ecountync. ov; or visit our administrative offices at 600 NC
Highway 86 North, Hillsborough, NC 27278. For more information, visit
www.co.oranQe.nc.us/traaag2rtation.
• A complainant may file a complaint directly with the Federal Transit
Administration by filing a complaint with the Office of Civil Rights, Attention: Title
VI Program Coordinator, East Building, 5t" Floor -TCR, 1200 New Jersey Avenue,
SE Washington, DC 20590.
• If information is needed in another language, contact 919 - 245 -2008. Si se
necesita information en otro idioms de contacto, 919 - 245 -2008.
Title VI information shall be disseminated to OPT employees annually via the Title VI
Education Notice to OPT employees (Exhibit 1) in payroll envelopes. This notice
reminds employees of the OPT Title VI policy statement and their Title VI
responsibilities in their daily work and duties. This information will also be disseminated
to new OPT employees during new employee orientation. All employees shall be
provided a copy of the Title VI Plan and required to sign the acknowledgement of
receipt (Exhibit 2).
For users of the system requiring registration or enrollment for specialized services,
OPT will ensure that all new riders are provided with a copy of the Title VI Plan during
intake /registration /subscription, and upon approval, it will be distributed to all current
registered /enrolled users of the system. The Title VI Plan will also be located on the
OPT website for public view.
III. Subcontracts and Vendors
All subcontractors and vendors who receive payments from OPT in which funding
originates from any federal assistance are subject to the provisions of Title VI of the
Civil Rights Act of 1964 as amended. Written contracts shall contain non - discrimination
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language, either directly or through the bid specification package, that by extension,
becomes an associated component of the contract.
IV. Record Keeping
The Title VI Coordinator, or his /her designee, will maintain permanent records, which
include but are not limited to, signed acknowledgements of receipt from the employees
indicating the receipt of the OPT Title VI Plan, copies of any Title VI complaints or
lawsuits and related documentation, records of correspondence to and from
complainants, and Title VI investigations.
V. Title VI Complaint Procedures
A complainant may file a signed, written complaint up to one hundred and eighty (180)
days from the date of the alleged discrimination. The complaint should include the
following information:
• Complainant's name, mailing address, and how to contact you (i.e., telephone
number, email address, etc.)
• Description of the incident including how, when, where and why you believe you
discriminated against. Include the location, names and contact information of any
witnesses.
• Other information that you deem significant
The Title VI complaint form (Exhibit 3) may be used to submit the complaint
information. The complaint may be filed in writing with Orange Public
Transportation at the following address:
Orange Public Transportation
PO Box 8181
600 Highway 86 N
Hillsborough, NC 27278
NOTE: OPT encourages all complainants to certify all mail that is sent through
the U.S. Postal Service and /or ensure that all written correspondence can be
tracked easily. For complaints originally submitted by facsimile, an original signed
copy of the complaint must be mailed to the Title VI Coordinator as soon as
possible but not later than 180 days from the alleged date of discrimination.
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Complaint Procedures:
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All complaints alleging discrimination based on race, color or national origin in a service
or benefit provided by OPT will be directly addressed by OPT. OPT shall also provide
appropriate assistance to complainants, including those persons with disabilities or who
are limited in their ability to communicate in English. Additionally, OPT shall make every
effort to address all complaints in an expeditious and thorough manner.
A letter acknowledging receipt of complaint will be mailed within seven (7) days to the
address provided by a complainant (Exhibit 4). Please note that in responding to any
requests for additional information, a complainant's failure to provide the requested
information may result in the administrative closure of the complaint.
Notification of Complaint:
Orange Public Transportation will send a final written response letter to the complainant
(Exhibits 5 and 6). In the letter notifying the complainant that the complaint is not
substantiated (Exhibit 6), the complainant is also advised of his or her right to:
1) Appeal within seven (7) calendar days of receipt of the final written decision from
OPT; and /or
2) File a complaint externally with the U.S. Department of Transportation and /or the
Federal Transit Administration.
Every effort will be made to respond to Title VI complaints within 60 working days of
receipt of such complaints, if not sooner.
In addition to the complaint process described above, a complainant may file a Title VI
complaint with the following office:
Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5t" Floor — TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
OPT History of Transit - Related Title VI Investiaations. Comalaints and Lawsuits
As indicated in Exhibit 7, Orange Public Transportation has no history of any transit -
related Title VI investigations, complaints or lawsuits being conducted, submitted or
filed. However, if investigations, complaints or lawsuits emerge, Orange County /Orange
Public Transportation will track, record and report them to the North Carolina
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Department of Transportation and /or the Federal Transit Administration using the form
provided in Exhibit 7.
VI. Public Participation /Community Outreach
As an agency receiving federal financial assistance, OPT has made and continues to
extend many public participation /community outreach efforts. OPT has engaged the
public in its planning and decision - making processes, as well as in its marketing and
outreach activities. Through 2013 and 2014, the public was invited to participate in the
following activities:
• August 2013 Bus Service Expansion Public Outreach Meetings — Four (4) public
outreach meetings were held at four (4) different locations throughout the OPT
service area to solicit input through surveys, comments and other exercises
regarding where and how within the county existing bus services should be
improved and new bus service should be developed.
• May and June 2014 Bus Service Expansion Public Outreach Meetings — Four (4)
public outreach meetings were held at four (4) different locations throughout the
OPT service area to present information and receive feedback on bus service
improvement and expansion plans developed from prior public input
opportunities. When new service or major service changes are proposed,
information is disseminated to the affected service area, and public meetings are
scheduled and held.
• Orange Unified Transportation Board (OUTBoard) meetings, which are
advertised and open to the public, were held throughout 2013 and 2014 with
multiple agenda discussion and action items involving OPT transit service,
including service change proposals, and will continue to be held on a monthly
basis.
• Americans with Disabilities Act (ADA) Plan public meeting, public hearing and
30 -day public open comment period were held February 2015 to provide the
opportunity for public participation in a major update to OPT's complementary
ADA paratransit service plan and the certification process for eligible users.
• Public hearings held before the County Board of Commissioners in the fall of
2013 and 2014 for OPT's proposed use of federal and state grants for rural
services it provides, as well as administrative and capital projects. These public
hearings will continue each fall and will correspond with federal and state grant
applications.
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• In 2013, the Durham - Chapel Hill - Carrboro Metropolitan Planning Organization
(DCHC MPO), which covers a large portion of the OPT service area, developed
an update to its Coordinated Public Transportation -Human Service
Transportation Plan, which provides a framework for the development of projects
intended to address the transportation needs of persons with disabilities, older
adults, and individuals with lower incomes through a better coordinated
transportation system. Federal transit law (MAP -21) requires that projects
selected for funding under the Elderly and Individuals with Disabilities Program
(Section 5310) be derived from a coordinated plan. The development of the plan
update involved a survey and a stakeholder workshop to assess transportation
needs and develop strategies to address those needs. The plan will be updated
in future years and will involve continued public input.
• In 2013, the Triangle Area Rural Planning Organization (TARPO), which also
covers a large portion of the OPT service area, developed an update to its
Coordinated Public Transportation -Human Service Transportation Plan, which
involved stakeholder workshops. The plan will be updated in future years and will
involve continued public input.
• On its website, Orange Public Transportation solicits feedback and complaints to
be directed to the system's transportation administrator by phone or email.
These efforts are carried out on a continuous basis to involve the public, with particular
emphasis on engaging minority and limited English proficiency (LEP) populations as
much as possible. OPT stresses serving areas of concentrated transit - dependent
populations (i.e., elderly, low- income, no vehicle, disabled, and youth populations) with
its fixed -route transit operation, which by extension also directly involves minority and
limited - English- proficient communities. In doing so, OPT targets communities directly
served by its operations with its public participation and outreach efforts by holding
easily accessible small- format meetings that are squarely located within the heart of the
applicable communities and that are scheduled during times the majority of the public
can attend. OPT also targets specific organizations representing minority, transit -
dependent, and LEP communities when advertising public participation processes and
opportunities. Most notices posted and /or published for public hearings and public
meetings are translated to Spanish to encourage participation from the Spanish -
speaking community, which is the largest LEP population group in Orange County.
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VII. Limited English Proficiency (LEP) Plan
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Individuals with a limited ability to read, write, speak or understand English are
considered limited English proficient, or "LEP." The includes persons who have reported
to the U.S. Census Bureau that they speak English less than very well, not well, or not
at all. U.S. Census Bureau 2013 American Community Survey data indicate that an
estimated 4.8 percent of persons five (5) years of age or older in North Carolina speak
English less than "very well." American Community Survey data for 2013 also indicate
that, in Orange County, an estimated 6.1 percent of persons five (5) years of age or
older speak English less than "very well." In Orange County, an estimated 60.6 percent
of LEP persons speak Spanish as their primary language, and an estimated 28.2
percent of LEP persons in Orange County speak Chinese, Korean or other Asian
languages as their primary language.
As a recipient of U.S. Department of Transportation funding, OPT is required to take
reasonable steps to ensure meaningful access to its programs and activities for LEP
persons. OPT's language assistance plan includes the following elements:
1) The results of the Four Factor Analysis, including a description of the LEP
population(s) served;
2) A description of how language assistance services are provided by language;
3) A description of how LEP persons are informed of the availability of language
assistance service;
4) A description of how the language assistance plan is monitored and updated;
and
5) A description of how employees are trained to provide language assistance to
LEP persons.
Four Factor Analysis
1) The number or proportion of LEP persons in the service area who may be served
or are likely to encounter an OPT program, activity or service.
The OPT service area, or the area containing populations served directly by OPT
operations, includes the entire area of Orange County located outside the Chapel Hill
Transit service area. For the purpose of the Four Factor Analysis, LEP census data for
the Towns of Chapel Hill and Carrboro, which fall within the Chapel Hill Transit service
area, are excluded from the count and proportion of LEP populations represented in the
OPT service area.
According to the American Community Survey 5 -year estimates for 2013, an estimated
2,479 persons in the portion of Orange County outside the Towns of Chapel Hill and
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Carrboro speak English "less than very well," which accounts for 4.5 percent of the
population. The largest LEP group of the total LEP population is Spanish- speaking
persons. A total of 2,301 Spanish- speaking persons in the OPT service area speak
English "less than very well," which accounts for 4.2 percent of the OPT service area
population. Because greater than 1,000 persons within the Spanish- speaking group are
considered LEP, OPT is responsible for providing Spanish translation of vital documents
in written format for these non - English users. Applicable documents include the Title VI
policy statement and /or notice to the public, Title VI complaint procedure, Title VI
complaint form, and ADA paratransit eligibility forms.
2) The frequency with which LEP persons come into contact with OPT programs.
OPT assessed the frequency with which staff and drivers have, or could have, contact
with LEP persons. This includes documenting phone inquiries and surveying vehicle
operators. To date, OPT has had no requests for interpreters and no requests for
translated documents. Although difficult to assess the exact level of English- speaking
proficiency, staff has indicated that it has contact with very few LEP system users per
month. However, if staff encounters an LEP person who requests language translation
assistance, they are instructed to encourage the LEP person to request that documents
such as schedules, route maps, and eligibility certification forms be translated for their
use.
3) The nature and importance of programs, activities or services provided by OPT
to the LEP population.
The overwhelming majority of the OPT service area population speaks only English or
speaks English very well. There are social services, professional and leadership
organizations within the OPT service area that focus on outreach to LEP individuals.
OPT works closely with these organizations to ensure that the programs and activities
administered by these groups that interface with OPT operations work to assist LEP
populations.
4) The resources available to OPT and the overall cost to provide LEP assistance.
OPT has assessed its available resources that could be used to provide LEP
assistance, including determining how much a professional interpreter and translation
service would cost on an as- needed basis, the availability of other County staff qualified
to provide such services, which of its documents would be the most valuable to be
translated if the need should arise, and taking an inventory of available organizations
with which OPT could partner for outreach and translation efforts. While OPT does not
have staff internally that could provide translation services, Orange County has
adequate staff to provide such services should the need be indicated or arise.
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Description of How Language Assistance Services are Provided by Language
OPT has access to Orange County staff members in other County departments with
Spanish- speaking and translation ability. Additionally, OPT works to ensure
mechanisms are in place to reach LEP persons in the service area, such as translating
public notices for public participation that are visibly posted and that are published in the
newspaper. OPT also offers for its vital documents to be translated if requested by an
LEP individual.
Description of How LEP Persons are Informed of the Availability of Language
Assistance Service
OPT does the following to inform LEP persons of the availability of language assistance
services:
• Publish schedules and route maps in languages other than English if requested;
• Provide graphics, visual aids and universal symbols in relevant published
materials that traverse all language abilities;
• Strive to employ multi - lingual staff; and
• Post bilingual announcements, posters and other information.
Description of How the Language Assistance Plan is Monitored and Updated
OPT reviews its plan on an annual basis or more frequently as needed. In particular,
OPT will evaluate the information collected on encounters with LEP persons as well as
public outreach efforts to determine if adjustments should be made to the delivery of
programs and services to ensure meaningful access to minority and LEP persons.
Description of How Employees are Trained to Provide Language Assistance to LEP
Persons
OPT employees are oriented on the principles of Title VI and OPT's Language
Assistance Plan. New employees will be provided guidance on the needs of clients
served and how best to meet their needs. If a driver, dispatcher or other employee
needs further assistance related to LEP program participants, he /she will work with
OPT's Title VI Coordinator to identify strategies to meet the language needs of the
participants of the program or service.
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VIII. Minority Representation of the Orange Unified Transportation Board
The Orange Unified Transportation Board (OUTBoard) serves as OPT's transit services
advisory board and is a non - elected board. The table below depicts the OUTBoard's
racial /ethnic breakdown:
Caucasian
Hi panic(Latiho '
African American
Asian American
Native American
90%
10 %
0%
0%
0%
Efforts to Encourage Minority Participation
Orange County and OPT understand diverse representation on its OUTBoard results in
sound policy reflective of its entire population. As such, Orange County and OPT
encourage participation of all citizens. As of March 2015, one minority ethnicity was
represented on the OUTBoard. As vacancies on the Board become available, OPT will
make efforts to encourage and promote diversity by engaging racial and ethnic minority
communities within the OUTBoard's representative townships to identify persons who
could be recommended for appointment by the Orange County Board of Commissioners
to the OUTBoard. This will involve reaching out to community, ethnic and faith -based
organizations to connect with all populations. Additionally, OPT will create ways to make
participating realistic and reasonable such as scheduling meetings at times best suited
to its members and providing transportation for OUTBoard meetings, if needed.
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Employee Annual Education Form
Title VI Policy
No person shall, on the grounds 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.
All employees of Orange County /Orange Public Transportation are expected to
consider, respect, and observe this policy in their daily work and duties. If a citizen
approaches you with a questions or compliant, direct him or her to the Title VI
Coordinator /Orange Public Transportation Administrator.
In all dealings with citizens, use courtesy titles (i.e. Mr., Mrs., Ms., or Miss) to address
them without regard to race, color or national origin.
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Acknowledgement of Receipt of Title VI Plan /Program
I hereby acknowledge receipt of the Orange Public Transportation Title VI
Plan /Program. I have read the plan and am committed to ensuring that no person is
excluded from participation in or denied the benefits of its transit services on the basis
of race, color or national origin, as protected by Title VI in Federal Transit Administration
(FTA) Circular 4702.1.13.
Your signature
Print your name
Date
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Title VI Complaint Form
Title VI of the 1964 Civil Rights Act requires 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." If you feel you have been discriminated against
in transit services, please provide the following information in order to assist us in
processing your complaint and send it to:
Title VI Coordinator
Orange Public Transportation
PO Box 8181
600 Highway 86 N
Hillsborough, NC 27278
Please print clearly:
Section I:
Name:
Address:
Telephone (Home):
Telephone (Work):
Electronic Mail Address:
Accessible Format
Requirements?
Lar e 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
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 mores ace is needed, please use the back
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of this form.
Section IV
Have you previously filed a Title VI complaint with this agency?
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:
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
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Letter Acknowledging Receipt of Complaint
Date
Ms. Jane Doe
1234 Main Street
Stamping Ground, KY 40379
Dear Ms. Doe,
This letter is to acknowledge receipt of your complaint against Orange Public
Transportation alleging
An investigation will begin shortly. If you have additional information you wish to convey
or questions concerning this matter, please feel free to contact this office by telephoning
(919) 245 -2008, or write to me at P.O. Box 8181, 600 Highway 86 N, Hillsborough, NC
27278.
Sincerely,
Name
Title VI Coordinator
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Letter Notifying Complainant that the Complaint is Substantiated
Date
Ms. Jane Doe
1234 Main Street
Stamping Ground, KY 40379
Dear Ms. Doe,
The matter referenced in your letter of (date) against Orange Public
Transportation alleging Title VI violation has been investigated.
(An /several) violation(s) of Title VI of the Civil Rights Act of 1964, including those
mentioned in your letter (was /were) identified. Efforts are underway to correct these
deficiencies.
Thank you for calling this important matter to our attention. You were extremely helpful
during our review of the program. (If a hearing is requested, the following sentence
may be appropriate.) You may be hearing from this office, or from federal authorities, if
your services should be needed during the administrative hearing process.
Sincerely,
Name
Title VI Coordinator
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Letter Notifying Complainant that the Complaint is Not Substantiated
Date
Ms. Jane Doe
1234 Main Street
Stamping Ground, KY 40379
Dear Ms. Doe,
The matter referenced in your complaint of (date) against Orange Public
Transportation alleging has been investigated.
The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights
Act of 1964 had in fact been violated. As you know, Title VI prohibits discrimination based on
race, color, or national origin in any program receiving federal financial assistance.
Orange Public Transportation has analyzed the materials and fact pertaining to your case for
evidence of the agency's failure to comply with of the civil rights laws. There was no evidence
found that any of these laws have been violated.
I therefore advise that your complaint has not been substantiated and that I am closing this
matter in our files.
You have the right to 1) appeal within seven (7) calendar days of receipt of this final written
decision from Orange Public Transportation, and /or 2) file a complaint externally with the U.S.
Department of Transportation and /or Federal Transit Administration at:
Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor — TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not
hesitate to call me.
Sincerely,
Name
Title VI Coordinator
21
*:/:1l :j Ill t/
a�
List of Transit Related Title VI Investigations, Complaints and Lawsuits
Recipient/
Subrecipient: Orange County /Orange Public Transportation
Contact Person: Signature: Date:
Check One:
X There have been no investigations, complaints and /or lawsuits filed against us
during the reporting period.
There have been investigations, complaints and /or lawsuits filed against us. See
list below. Attach additional information as needed.
Attachment 2: Resolution of Adoption of Orange Public Transportation Title VI Plan / ProgMm
RES- 2015 -017
ORANGE COUNTY BOARD OF COUNTY COMMISSIONERS
A RESOLUTION ADOPTING THE ORANGE PUBLIC TRANSPORTATION TITLE VI
PLAN /PROGRAM
WHEREAS, pursuant to Title VI of the Civil Rights Act of 1964, 42 U.S.C. Section 2000d et seq. and
23 C.F.R. part 21, the U.S. Department of Transportation and the Federal Transit Administration
(FTA) prohibit discrimination on the basis of race, color or national origin; and
WHEREAS, Orange Public Transportation (OPT) operates a public transportation service including
bus and paratransit services; and
WHEREAS, OPT receives FTA funding through the North Carolina Department of Transportation and
will be applying to receive FTA funding directly to operate public transportation services and is,
therefore, required to demonstrate compliance with such federal laws and regulations by submitting a
Title VI program update once every three years; and
WHEREAS, OPT seeks to ensure that the level and quality of public transportation service is provided
in a nondiscriminatory manner; and
WHEREAS, OPT seeks to promote full and fair participation in public transportation decision - making
without regard to race, color or national origin; and
WHEREAS, OPT seeks to ensure meaningful access to transit - related programs and activities by
persons with limited English proficiency; and
WHEREAS, pursuant to federal laws and regulations, the OPT Title VI Plan /Program must be
considered and approved by the governing body of OPT, the Board of County Commissioners; and
NOW, THEREFORE, BE IT RESOLVED by the Orange County Board of Commissioners that the
Board approves and adopts the 2015 Orange Public Transportation Title VI Plan /Program.
BE IT FURTHER RESOLVED that the Orange County Board of Commissioners authorizes the
Orange County Transportation Planner to submit the 2015 Orange Public Transportation Title VI
Plan /Program to the North Carolina Department of Transportation and Federal Transit Administration.
Upon motion of Commissioner , seconded by Commissioner
the foregoing resolution was adopted this the 17th day of March, 2015.
I, Donna Baker, Clerk to the Board of Commissioners for the County of Orange, North Carolina, DO
HEREBY CERTIFY that the foregoing is a true copy of so much of the proceedings of said Board at a
meeting held on March 17, 2015, as relates in any way to the adoption of the foregoing and that said
proceedings are recorded in the minutes of said Board.
WITNESS my hand and the seal of said County, this day of 12015
Clerk to the Board of Commissioners