HomeMy WebLinkAboutAgenda - 03-10-20; 8-n Attachment 2 - OCTS Draft Title VI Plan soap
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Orange County Public
Transportation Title VI Plan
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TITLE VI PLAN REVIEW AND ADOPTION
On behalf of the Orange County Board of County Commissioners, I hereby acknowledge receipt of the Title VI
Nondiscrimination Plan. We, the Board, have reviewed and hereby adopt this Plan. We are committed to ensuring
that all decisions are made in accordance with the nondiscrimination guidelines of this Plan, to the end the no person
is excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any Orange
County Public Transportation(OCPT) services and activities on the basis of race, color, national origin, sex, age,
creed (religion), or disability, as protected by Title VI of the Civil Rights Act of 1964 and the nondiscrimination
provisions of the Federal Transit Administration.
Signature of Authorizing Official DATE
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Table of Contents
Title VI Nondiscrimination Agreement................................................................................................................6
1.0 Introduction...................................................................................................................................................7
2.0 Description of Programs and Services..........................................................................................................7
2.1 Program(s) and Services Administered......................................................................................................7
2.2 Funding Sources/Tables...........................................................................................................................7
2.3 Decision-Making Process...........................................................................................................................8
2.4 Title VI Coordinator....................................................................................................................................9
2.5 Change of Title VI Coordinator and/or Head of Decision-making Body....................................................9
2.6 Organizational Chart..................................................................................................................................9
2.7 Subrecipients .............................................................................................................................................9
3.0 Title VI Nondiscrimination Policy Statement.............................................................................................10
4.0 Notice of Nondiscrimination.......................................................................................................................11
5.0 Procedures to Ensure Nondiscriminatory Administration of Programs and Services..............................12
6.0 Contract Administration .............................................................................................................................13
6.1 Contract Language...................................................................................................................................13
6.2 Nondiscrimination Notice to Prospective Bidders...................................................................................14
7.0 External Discrimination Complaint Procedures.........................................................................................15
Discrimination Complaint Form......................................................................................................................17
Discrimination Complaints Log.......................................................................................................................19
InvestigativeGuidance....................................................................................................................................20
SAMPLE Investigative Report Template .........................................................................................................21
8.0 Service Area Population Characteristics.....................................................................................................22
8.1 Race and Ethnicity....................................................................................................................................22
8.2 Age&Sex.................................................................................................................................................22
8.3 Disability...................................................................................................................................................23
8.4 Poverty.....................................................................................................................................................24
8.5 Household Income...................................................................................................................................24
8.6 Limited English Proficiency Populations..................................................................................................25
8.7 Population Locations ...............................................................................................................................25
9.0 Title VI Equity Analyses(and Environmental Justice Assessments)..........................................................25
10.0 Public Involvement....................................................................................................................................26
10.1 Introduction...........................................................................................................................................26
10.2 Public Notification..................................................................................................................................26
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10.3 Dissemination of Information................................................................................................................26
10.4 Meetings and Outreach.........................................................................................................................27
10.5 Limited English Proficiency....................................................................................................................28
10.6 Demographic Requests..........................................................................................................................31
10.7 Key Community Contacts.......................................................................................................................32
10.8 Summary of Outreach Efforts Since the Last Title VI Program Submission...........................................32
11.0 Staff Training.............................................................................................................................................32
12.0 Nonelected Boards and Committees—By Race and Gender...................................................................33
13.0 Record-Keeping and Reports....................................................................................................................33
14.0 Transit Providers.......................................................................................................................................34
14.1 Service Standards...................................................................................................................................34
14.2 Service Policies.......................................................................................................................................34
Appendices.........................................................................................................................................................36
Appendix A—Applicable Nondiscrimination Authorities
Appendix B—Organizational Chart
Appendix C—NCDOT's Transit Review Checklist
Appendix D—Orange County LEP Demographics
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TITLE VI NONDISCRIMINATION AGREEMENT
BETWEEN
THE NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
AND
ORANGE COUNTY PUBLIC TRANSPORTATION
In accordance with DOT Order 1050.2A, Orange County Public Transportation assures the North Carolina Department of
Transportation (NCDOT) that no person shall, on the ground of race, color, national origin, sex, creed, age, or
disability, as provided by Title VI of the Civil Rights Act of 1964, the Civil Rights Restoration Act of 1987 and related
nondiscrimination authorities, be excluded from participation in, be denied the benefits of, or be otherwise subjected to
discrimination or retaliation under any program or activity undertaken by Orange County Public Transportation .
Further,Orange County Public Transportation hereby agrees to:
1. Designate a Title VI Coordinator that has a responsible position within the organization and easy access to the
Transportation Services Director of the organization.
2. Issue a policy statement, signed by the Transportation Services Director of the organization, which expresses a
commitment to the nondiscrimination provisions of Title VI and related applicable statutes. The signed policy
statement shall be posted and circulated throughout the organization and to the general public and published
where appropriate in languages other than English. The policy statement will be re-signed when there is a
change of Transportation Services Director.
3. Insert the clauses of the contract language from Section 6.1 in every contract awarded by the organization.
Ensure that every contract awarded by the organization's contractors or consultants also includes the contract
language.
4. Process all and,when required, investigate complaints of discrimination consistent with the procedures contained
within this Plan. Log all complaints for the administrative record.
5. Collect statistical data (race, color, national origin, sex, age, disability) on participants in, and beneficiaries of,
programs and activities carried out by the organization.
6. Participate in training offered on Title VI and other nondiscrimination requirements. Conduct or request training
for employees or the organization's subrecipients.
7. Take affirmative action, if reviewed or investigated by NCDOT, to correct any deficiencies found within a
reasonable time period, not to exceed 90 calendar days, unless reasonable provisions are granted by NCDOT.
8. Document all Title VI nondiscrimination-related activities as evidence of compliance. Submit information and
reports to NCDOT on a schedule outlined by NCDOT.
THIS AGREEMENT 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 assi artaII programs and activities and is binding.
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Authorized Signature
2/14/2020
Date
Theo Letman
Transportation Services Director
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1.0 INTRODUCTION
Title VI of the 1964 Civil Rights Act, 42 U.S.C. 2000d 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."
The broader application of nondiscrimination law is found in other statutes, executive orders, and
regulations, which provide additional protections based on age, sex, creed (religion), and disability,
including the 1987 Civil Rights Restoration Act, which extended nondiscrimination coverage to all
programs and activities of federal-aid recipients, subrecipients, and contractors, including those that are
not federally-funded (see Appendix A—Applicable Nondiscrimination Authorities).
Orange County Public Transportation is a recipient of Federal Transit Administration (FTA)funds from the
North Carolina Department of Transportation (NCDOT). Orange County Public Transportation establishes
this Title VI Nondiscrimination Plan for the purpose of complying with Title VI of the Civil Rights Act of
1964, as required by FTA Circular 4702.1 B, and related requirements outlined within the FTA
Certifications &Assurances, "Nondiscrimination Assurance."This document details the nondiscrimination
program, policies, and practices administered by Orange County Public Transportation, and will be
updated periodically to incorporate changes and additional responsibilities as they are made. This Plan
will be submitted to NCDOT or FTA, upon request.
2.0 DESCRIPTION OF PROGRAMS AND SERVICES
2.1 PROGRAM(S)AND SERVICES ADMINISTERED
Orange County Public Transportation provides public transportation options to its customers within county
limits of Orange County, North Carolina. Orange County Public Transportation provides both demand
response service and fixed route service. Our demand response service includes transportation provided
by Rural Operating Assistance Program (ROAP), Non-Emergency Medical Transportation (Medicaid), and
Americans with Disabilities Act. Our fixed route service is comprised of four buses. The Hillsborough
Circulator which circulates the town of Hillsborough from 8am —5pm Monday through Friday which is fare
free. Then there is the Orange- Chapel Hill Connector which has two buses one that starts in Cedar
Grove, NC and the other that starts in Chapel Hill, NC, fare for this route is two dollars one-way or four
dollars round trip. The Orange—Chapel Hill Connector is in service from 9:45am -3:50pm Monday through
Friday. Lastly there is the Orange — Alamance Connector this routes services the Town of Hillsborough
and City of Mebane from 10:00am — 3:00pm Monday through Friday, fare for this route is two dollars one
way or four dollars round trip. Following the Orange County Holiday Schedule, Orange County Public
Transportation's Administrative Office and Fixed Route Services are closed the following days in 2020:
• New Year's Day:January 1,2020
• Martin Luther King.Jr's Birthday:January 20,2020
• Good Friday:April 10,2020
• Memorial Day: May 25,2020
• Independence Day:July 3,2020
• Labor Day: September 7, 2020
• Thanksgiving: November 26-27,2020
• Christmas: December 24,25,28,2020
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Orange County Public Transportation Staff is comprised of:
• Transit Director(1);Transit Administrator(1);Operations Manager; (1)Transportation Services Manager(1)
Transportation Operations Supervisor(1);Transit Dispatch Supervisor(1);Transportation Demand Management
Coordinator(1); Operations Office Assistant(1);Transit Asset Technician (1); Full Time Public Transportation
Drivers(16);and(5) Part Time Public Transportation Drivers.
Type of Service Days of week Times Fare if applicable
Fixed Route Monday—Friday 8am—5pm $2 one —way* Hillsborough
Circulator is fare free
Elderly/Disabled Monday—Friday 8am-5pm $3 one-way
Transportation Assistance
Program
Rural General Public Monday—Friday 8am—5pm $12.74 one-way
?.2 FUNDING SOURCES/TABLE'
For the purpose of federally assisted programs, "federal assistance" shall include:
1. grants and loans of Federal funds;
2. the grant or donation of Federal property and interest in property;
3. the detail of Federal personnel;
4. the sale and lease of, and the permission to use (on other than a casual or transient basis),
Federal property or any interest in such property without consideration or at a nominal
consideration, or at a consideration which is reduced for the purpose of assisting the recipient, or
in recognition of the public interest to be served by such sale or lease to the recipient; and
5. any Federal agreement, arrangement, or other contract which has, as one of its purposes, the
provision of assistance.
Each FTA Formula Grant received by our system during the past year, and whether the funds were
received through NCDOT or directly from FTA, is checked below.
Grant Title NCDOT FTA Details
(i.e.,purpose,frequency,and duration of receipt)
5307(Urbanized Area Formula) ® ❑ Annually
5310(Transportation for Elderly Persons and ® ❑ Annually
Persons with Disabilities)
5311 (Formula Grants for Other than
Urbanized Areas) ® ❑ Annually
5311(b)(3)(Rural Transit Assistance) ® ❑ Annually
5339(Bus and Bus Facilities Formula) ® ❑ Annually
2.3 DECISION-MAKING PROCESS
Board or Committee Name Appointed Elected #of Members
Transit Advisory Board ® ❑ 14
Board of County Commissioners ❑ ® 7
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2.4 TITLE VI COORDINATOR
The individual below has been designated as the Title VI Coordinator for Orange County Public
Transportation, and is empowered with enough authority and responsibility to implement the Title VI
Nondiscrimination Program:
TeLeishia Holloway
Transportation Administrator
600 NC Highway 86 N Hillsborough, NC 27278
919-245-2007
tholloway@orangecountync.gov
Key responsibilities of the Coordinator include:
• Maintaining knowledge of Title VI and related requirements.
• Attending civil rights training when offered by NCDOT or any other regulatory agency.
• Administering the Title VI Nondiscrimination Program and coordinating implementation of this Plan.
• Training internal staff and officials on their Title VI nondiscrimination obligations.
• Disseminating Title VI information internally and to the general public, including in languages other
than English.
• Presenting Title VI-related information to decision-making bodies for input and approval.
• Ensuring Title VI-related posters are prominently and publicly displayed.
• Developing a process to collect data related to race, national origin, sex, age, and disability to ensure
minority, low-income, and other underserved groups are included and not discriminated against.
• Ensuring that non-elected boards and committees reflect the service area and minorities are
represented.
• Implementing procedures for prompt processing (receiving, logging, investigating and/or forwarding)of
discrimination complaints.
• Coordinating with, and providing information to, NCDOT and other regulatory agencies during
compliance reviews or complaint investigations.
• Promptly resolving areas of deficiency to ensure compliance with Title VI nondiscrimination
requirements.
2.5 CHANGE OF TITLE VI COORDINATOR AND/OR HEAD OF DECISION-MAKING BODY'S TITLE OR"CAO"
If Title VI Coordinator or Transportation Services Director changes, this document and all other
documents that name the Coordinator, will immediately be updated, and an updated policy statement
(and nondiscrimination agreement, if standalone)will be signed by the new Transportation Services
Director.
2.6 ORGANIZATIONAL CHART
An organizational chart showing the Title VI Coordinator's place within the organization is in
Appendix B.
2.7 SUBRECIPIENTS
Orange County Public Transportation does not have pass through funds to any other organizations and,
therefore, does not have any subrecipients.
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3.0 TITLE VI NONDISCRIMINATION POLICY STATEMENT
It is the policy of Orange County Public Transportation, as a federal-aid recipient, to
ensure that no person shall, on the ground of race, color, national origin, sex, creed
(religion), age or disability,be excluded from participation in,be denied the benefits
of, or be otherwise subjected to discrimination under any of our programs and
activities, as provided by Title VI of the Civil Rights Act of 1964, the Civil Rights
Restoration Act of 1987, and all other related nondiscrimination laws and
requirements. r ooeustnea by:
TeLeishia Holloway,Transportation
Administrator
2/18/2020
Date
Title VI and Related Authorities
Title VI of the Civil Rights Act of 1964 (42 U.S.C. Section 2000d) 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." The 1987 Civil Rights Restoration Act (P.L. 100-259) clarified and restored the original intent of
Title VI by expanding the definition of "programs and activities" to include all programs and activities of
federal-aid recipients,subrecipients,and contractors,whether such programs and activities are federally assisted
or not.
Related nondiscrimination authorities include, but are not limited to: U.S. DOT regulation, 49 CFR part 21,
"Nondiscrimination in Federally-assisted Programs of the Department of Transportation—Effectuation of Title
VI of the Civil Rights Act"; 49 U.S.C. 5332, "Nondiscrimination (Public Transportation)"; FTA Circular
4702.1B - Title VI Requirements and Guidelines for Federal Transit Administration Recipients; DOT Order
5610.2a, "Actions to Address Environmental Justice in Minority Populations and Low-Income Populations";
FTA C 4703.1 -Environmental Justice Policy Guidance For Federal Transit Administration Recipients; Policy
Guidance Concerning (DOT) Recipient's Responsibilities to Limited English Proficient (LEP) Persons, 74 FR
74087; The Americans with Disabilities Act of 1990, as amended, P.L. 101-336; Section 504 of the
Rehabilitation Act of 1973,29 U.S.C. 790; Age Discrimination Act of 1975,as amended 42 U.S.C. 6101; Title
IX of the Education Amendments of 1972, 20 U.S.C. 1681; Uniform Relocation Assistance and Real Property
Acquisition Policies Act of 1970, 42 U.S.C. 4601; Section 508 of the Rehabilitation Act of 1973, 29 U.S.C.
794d
Implementation
• This statement will be signed by the Transportation Services Director of Orange County Public
Transportation and re-signed whenever a new person assumes that position.
• The signed statement will be posted on office bulletin boards, near the receptionist's desk, in
meeting rooms, at transit stops, inside vehicles, and disseminated within brochures and other
written materials.
• The core of the statement(signature excluded)will circulate internally within annual
acknowledgement forms.
• The statement will be posted or provided in languages other than English, when appropriate.
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4.0 NOTICE OF NONDISCRIMINATION
➢ Orange County Public Transportation operates its programs and services without regard to race,
color, national origin, sex, creed (religion), age, and disability in accordance with Title VI of the
Civil Rights Act and related statutes. Any person who believes she or he has been aggrieved by any
unlawful discriminatory practice may file a complaint with Orange County Public Transportation.
➢ For more information on Orange County Public Transportation's civil rights program, and the
procedures to file a complaint, contact 919-245-2008, (TTY 919-644-3045); email
octransportationservices@orangecountync.gov, (TTY 919-644-3045); or visit our administrative
office at 600 NC Highway 86 N Hillsborough, NC 278278. For more information, visit
orangecounync.gov.
➢ If information is needed in another language, contact 919-245-2498.
➢ A complainant may file a complaint directly with the North Carolina Department of Transportation by
filing with the Office of Civil Rights, External Civil Rights Section, 1511 Mail Service Center, Raleigh,
NC 27699-1511, Attention: Title VI Nondiscrimination Program; phone: 919-508-1808 or 800-522-
0453, or TDD/TTY: 800-735-2962.
➢ 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, 5th
Floor-TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.
Implementation
• The notice will be posted in its entirety on our website and in any documents and reports we
distribute.
• The notice will be posted in our offices and inside/on our vehicles.
• Ads in newspapers and other publications shall include the following: "Orange County Public
Transportation operates without regard to race, color, national origin, sex, creed (religion), age
or disability. For more information on Orange County Public Transportation Title VI program or
how to file a discrimination complaint, please contact 919-245-2008;
octransportationservices@orangecountync.gov."
• The statement will be posted or provided in languages other than English, when appropriate.
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5.0 PROCEDURES TO ENSURE NONDISCRIMINATORY ADMINISTRATION OF
PROGRAMS AND SERVICES
We are committed to nondiscriminatory administration of our programs and services, organization wide.
Orange County Public Transportation will remind employees of Title VI nondiscrimination obligations
through staff training and use of the Annual Education and Acknowledgment Form below. The Title VI
Coordinator will periodically assess program operations to ensure this policy is being followed.
Annual Education and Acknowledgement Form
Title VI Nondiscrimination Policy
(Title VI and related nondiscrimination authorities)
No person shall, on the grounds of race, color,national origin, sex,age, creed,or disability,be
excluded from participation in,be denied the benefits of,or be subjected to discrimination under any
program or activity of a Federal-aid recipient.
All employees and representatives of Orange County Public Transportation are expected to consider,
respect, and observe this policy in their daily work and duties.If any person approaches you with a
civil rights-related question or complaint,please direct him or her to TeLeishia Holloway at 919-245-
2002.
In all dealings with the public,use courtesy titles(e.g.,Mr.,Mrs.,Miss,Dr.)to address or refer to them
without regard to their race,color,national origin, sex, age or disability.
Acknowledgement of Receipt of Title VI Program
I hereby acknowledge receipt of Orange County Public Transportation Title VI Program and other
nondiscrimination guidelines. I have read the Title VI Program and I am committed to ensuring that no
person is excluded from participation in or denied the benefits of Orange County Public Transportation
programs, policies, services and activities on the basis of race, color, national origin, sex, age, creed
(religion), or disability, as provided by Title VI of the Civil Rights Act of 1964 and related
nondiscrimination statutes.
Signature Date
Implementation
• Periodically, but not more than once a year, employees and representatives will receive, review
and certify commitment to the Title VI Program.
• New employees shall be informed of Title VI provisions and expectations to perform their duties,
accordingly, asked to review the Title VI Program, and required to sign the acknowledgement
form.
• Periodic review of operational practices and guidelines by the Title VI Coordinator to verify
compliance with the Title VI Program. Maintain documents of each review on file.
• Signed acknowledgement forms and records of internal assessments will remain on file for at least
three years.
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6.0 CONTRACT ADMINISTRATION
Orange County Public Transportation ensures all contractors will fulfill their contracts in a
nondiscriminatory manner. While contractors are not required to prepare a Title VI Program, they must
comply with the nondiscrimination requirements of the organization to which they are contracted. Orange
County Public Transportation and its contractors will not discriminate in the selection and retention of
contractors (at any level)or discriminate in employment practices in connection with any of our projects.
i.1 CONTRACT LANGUAGI
I. During the performance of this contract, the contractor, for itself, its assignees, and successors in interest
(hereinafter referred to as the"contractor")agrees as follows:
(1) Compliance with Regulations: The contractor Recipient or the FTA, as appropriate, and will set forth
(hereinafter includes consultants)will comply with the what efforts it has made to obtain the information.
Acts and the Regulations relative to Nondiscrimination
in Federally-assisted programs of the U.S. (5) Sanctions for Noncompliance: In the event of a
Department of Transportation, Federal Transit contractor's noncompliance with the Non-
Administration (FTA), as they may be amended from discrimination provisions of this contract, the
time to time, which are herein incorporated by Recipient will impose such contract sanctions as it or
reference and made a part of this contract. the FTA may determine to be appropriate, including,
but not limited to:
(2) Nondiscrimination:The contractor,with regard to (a)withholding payments to the contractor under
the work performed by it during the contract, will not the contract until the contractor complies;
discriminate on the grounds of race, color, national and/or
origin, sex, age, creed (religion), low-income, limited (b)cancelling, terminating, or suspending a
English proficiency, or disability in the selection and contract, in whole or in part.
retention of subcontractors, including procurements of
materials and leases of equipment.The contractor will (6) Incorporation of Provisions: The contractor will
not participate directly or indirectly in the include the provisions of paragraphs one through six
discrimination prohibited by the Acts and the in every subcontract, including procurements of
Regulations, including employment practices when materials and leases of equipment, unless exempt by
the contract covers any activity, project, or program the Acts, the Regulations and directives issued
set forth in Appendix B of 49 CFR Part 21. pursuant thereto. The contractor will take action with
(3) Solicitations for Subcontractors, Including respect to any subcontract or procurement as the
Procurements of Materials and Equipment: In all Recipient or the FTA may direct as a means of
enforcing such provisions including sanctions for
solicitations, either by competitive bidding, or noncompliance. Provided, that if the contractor
negotiation made the contractor for work to be becomes involved in, or is threatened with litigation by
performed under
a subcontract, including a subcontractor, or supplier because of such
procurements materials, or leases of equipment, direction, the contractor may request the Recipient to
each potentiall subcontractor supplier will b enter into any litigation to protect the interests of the
notified by the contractor off the contractor'ss Recipient. In addition, the contractor may request the
obligations under this contract and the Acts and the Regulations relative to Nondiscrimination on the United States to enter into the litigation to protect the
grounds of race, color, or national origin. interests aof the United States.
(4) Information and Reports: The contractor will Il. During the performance of this contract, the
provide all information and reports required by the contractor, for itself, its assignees, and
Acts, the Regulations, and directives issued pursuant successors in interest (hereinafter referred to as
thereto and will permit access to its books, records, the "contractor") agrees to comply with the
accounts, other sources of information, and its following nondiscrimination statutes and
facilities as may be determined by the Recipient or authorities; including but not limited to:
the FTA to be pertinent to ascertain compliance with
such Acts, Regulations, and instructions. Where any Pertinent Nondiscrimination Authorities
information required of a contractor is in the exclusive . Title VI of the Civil Rights Act of 1964 (42 U.S.C.
possession of another who fails or refuses to furnish § 2000d et seq., 78 stat. 252), (prohibits
the information, the contractor will so certify to the discrimination on the basis of race, color, national
origin); and 49 CFR Part 21.
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• The Uniform Relocation Assistance and Real implemented by Department of Transportation
Property Acquisition Policies Act of 1970, (42 regulations at 49 C.F.R. parts 37 and 38;
U.S.C. § 4601), (prohibits unfair treatment of • The Federal Aviation Administration's
persons displaced or whose property has been Nondiscrimination statute (49 U.S.C. § 47123)
acquired because of Federal or Federal-aid (prohibits discrimination on the basis of race,
programs and projects); color, national origin, and sex);
• Federal-Aid Highway Act of 1973, (23 U.S.C. § • Executive Order 12898, Federal Actions to
324 et seq.), (prohibits discrimination on the Address Environmental Justice in Minority
basis of sex); Populations and Low-Income Populations, which
• Section 504 of the Rehabilitation Act of 1973, (29 ensures Nondiscrimination against minority
U.S.C. § 794 et seq.), as amended, (prohibits populations by discouraging programs, policies,
discrimination on the basis of disability); and 49 and activities with disproportionately high and
CFR Part 27; adverse human health or environmental effects
• The Age Discrimination Act of 1975, as on minority and low-income populations;
amended, (42 U.S.C. § 6101 et seq.), (prohibits Executive Order 13166, Improving Access to
discrimination on the basis of age); Services for Persons with Limited English
• Airport and Airway Improvement Act of 1982, (49 Proficiency, and resulting agency guidance,
USC § 471, Section 47123), as amended, national origin discrimination includes
(prohibits discrimination based on race, creed, discrimination because of Limited English
color, national origin, or sex); proficiency (LEP). To ensure compliance with
• The Civil Rights Restoration Act of 1987, (PL Title VI, you must take reasonable steps to
100-209), (Broadened the scope, coverage and ensure that LEP persons have meaningful
applicability of Title VI of the Civil Rights Act of access to your programs (70 Fed. Reg. at 74087
1964, The Age Discrimination Act of 1975 and to 74100);
Section 504 of the Rehabilitation Act of 1973, by • Title IX of the Education Amendments of 1972,
expanding the definition of the terms "programs as amended, which prohibits you from
or activities" to include all of the programs or discriminating because of sex in education
activities of the Federal-aid recipients, sub- programs or activities(20 U.S.C. 1681 et seq);
recipients and contractors, whether such • Federal transit laws, specifically 49 U.S.C. §
programs or activities are Federally funded or 5332 (prohibiting discrimination based on race,
not); color, religion, national origin, sex (including
• Titles II and III of the Americans with Disabilities gender identity), disability, age, employment, or
Act, which prohibit discrimination on the basis of business opportunity).
disability in the operation of public entities, public
and private transportation systems, places of *The Contractor has read and is familiar with the
public accommodation, and certain testing terms above:
entities (42 U.S.C. §§ 12131-12189) as Contractor's Initials
Date
Implementation
• The nondiscrimination language above (with initials line)will be appended to any existing contracts,
purchase orders, and agreements that do not include it, and initialed by the responsible official of
the other organization.
• The nondiscrimination language above (without initials line)will be incorporated as standard
language before the signature page of our standard contracts, purchase orders, and agreements.
• The Title VI Coordinator will review existing contracts to ensure the language has been added.
6.2 NONDISCRIMINATION NOTICE TO PROSPECTIVE BIDDERS
The Orange County Public Transportation, in accordance with Title VI of the Civil Rights
Act of 1964 and related nondiscrimination authorities, and Title 49 Code of Federal
Regulations, Parts 21 and 26, hereby notifies all bidders that it will affirmatively insure that
in any contact entered into pursuant to this advertisement, minority and women business
enterprises will be afforded full opportunity to submit bids in response to this invitation and
will not be discriminated against on the grounds of race, color, national origin, sex, age,
creed, limited English proficiency, low-income, or disability in consideration for an award.
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Implementation
• The nondiscrimination language above will be included in all solicitations for bids for work or
material and proposals for negotiated agreements to assure interested firms that we provide equal
opportunity and do not discriminate.
• Outreach efforts will be made to minority and women-owned firms that work in requested fields and
documented.
• Unless specifically required under Disadvantaged Business Enterprise (DBE) or Affirmative Action
programs, all contractors will be selected without regard to their race, color, national origin, or sex.
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7.0 EXTERNAL DISCRIMINATION COMPLAINT PROCEDURES
These discrimination complaint procedures outline the process used by Orange County Public
Transportation to process complaints of alleged discrimination filed under Title VI of the Civil Rights Act of
1964 and related nondiscrimination laws that are applicable to Orange County Public Transportation
programs, services, and activities. Complaints will be investigated by the appropriate authority. Upon
completion of an investigation, the complainant will be informed of all avenues of appeal. Every effort will
be made to obtain early resolution of complaints at the lowest level possible by informal means.
FILING OF COMPLAINTS
1. Applicability—These procedures apply to the beneficiaries of our programs, activities, and services,
such as the members of the public and any consultants/contractors we hire.
2. Eligibility—Any person or class of persons who believes that he/she has been subjected to
discrimination or retaliation prohibited by any of the Civil Rights authorities based upon race, color,
sex, age, national origin, creed (religion)or disability, may file a written complaint. The law prohibits
intimidation or retaliation of any sort. The complaint may be filed by the affected individual or a
representative and must be in writing.
3. Time Limits and Filing Options—A complaint must be filed no later than 180 calendar days after
the following:
➢ The date of the alleged act of discrimination; or
➢ The date when the person(s) became aware of the alleged discrimination; or
➢ Where there has been a continuing course of conduct, the date on which that conduct was
discontinued or the latest instance of the conduct.
Complaints may be submitted to the following entities:
➢ Orange County Public Transportation, Administration Office, 600 NC 86 N Hillsborough, NC
27278, PO BOX 818 Hillsborough, NC 27278 ;919-245-2008
➢ North Carolina Department of Transportation, Office of Civil Rights, External Civil Rights
Section, 1511 Mail Service Center, Raleigh, NC 27699-1511; 919-508-1830 or toll free 800-522-
0453
➢ US Department of Transportation, Departmental Office of Civil Rights, External Civil Rights
Programs Division, 1200 New Jersey Avenue, SE,Washington, DC 20590; 202-366-4070
Federal Transit Administration, Office of Civil Rights, ATTN: Title VI Program Coordinator, East
Bldg. 51" Floor—TCR, 1200 New Jersey Avenue, SE, Washington, DC 20590
➢ US Department of Justice, Special Litigation Section, Civil Rights Division, 950 Pennsylvania
Avenue, NW, Washington, DC 20530, 202-514-6255 or toll free 877-218-5228
4. Format for Complaints—Complaints shall be in writing and signed by the complainant(s)or a
representative and include the complainant's name, address, and telephone number. Complaints
received by fax or e-mail will be acknowledged and processed. Allegations received by telephone or
in person will be reduced to writing, may be recorded and will be provided to the complainant for
confirmation or revision before processing. Complaints will be accepted in other languages, including
Braille.
5. Discrimination Complaint Form—The Discrimination Complaint Form is consistent with the FTA
Certifications &Assurances, "Nondiscrimination Assurance."
6. Complaint Basis—Allegations must be based on issues involving race, color, national origin, sex,
age, creed (religion) or disability. The term "basis" refers to the complainant's membership in a
protected group category.
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Protected Definition Examples Applicable Statutes and
Categories Regulations
FTA
Race An individual belonging to one of the accepted Black/African American, Title VI of the Civil Rights Act of
racial groups;or the perception,based usually on Hispanic/Latino,Asian, 1964;
physical characteristics that a person is a member American Indian/Alaska 49 CFR Part 21;
of a racial group Native,Native 49 U.S.C.5332(b);
Hawaiian/Pacific Islander, FTA Circular 4702.1 B
White
Color Color of skin,including shade of skin within a Black,White,brown,yellow,
racial group etc.
National Place of birth.Citizenship is not a factor. Mexican,Cuban,Japanese,
Origin Discrimination based on language or a person's Vietnamese,Chinese
accent is also covered.
Sex Gender Women and Men 49 U.S.C.5332(b);Title IX of the
Education Amendments of 1972
Age Persons of any age 21 year old person Age Discrimination Act of 1975
Disability Physical or mental impairment,permanent or Blind,alcoholic,para- Section 504 of the Rehabilitation
temporary,or perceived. amputee,epileptic,diabetic, Act of 1973;Americans with
arthritic Disabilities Act of 1990
Creed Religion. Muslim,Christian, Hindu, 49 U.S.C.5332(b)
Atheist
Complaint Processing
1. When a complaint is received, an Acknowledgment Letter and a Complainant Consent/Release Form
will be mailed to the complainant within ten (10) business days by registered mail.
2. We will consult with the NCDOT Title VI Program to determine the acceptability and jurisdiction of all
complaints received. (Note: If NCDOT will investigate, the Title VI Program will be responsible for the
remainder of this process. We will record the transfer of responsibility in our complaints log).
3. Additional information will be requested if the complaint is incomplete. The complainant will be
provided 15 business days to submit any requested information and the signed Consent Release
form. Failure to do so may be considered good cause for a determination of no investigative merit.
4. Upon receipt of the requested information and determination of jurisdiction, we will notify the
complainant and respondent of whether the complaint has enough merit to warrant investigation.
5. If the complaint is investigated, the notification shall state the grounds of our jurisdiction, while
informing the parties that their full cooperation will be required in gathering additional information and
assisting the investigator.
6. If the complaint does not warrant investigation, the notification to the complainant shall specifically
state the reason for the decision.
Complaint Log
1. When a complaint is received, the complaint will be entered into the Discrimination Complaints Log
with other pertinent information and assigned a Case Number. (Note: All complaints must be logged).
2. The complaints log will be submitted to the NCDOT's Civil Rights office during Title VI compliance
reviews. (Note: NCDOT may also be request the complaints log during pre-grant approval
processes).
3. The Log Year(s) since the last submittal will be entered (e.g., 2015-2018, 2017-2018, IFFY 2018, or
2018) and the complaints log will be signed before submitting the log to NCDOT.
4. When reporting no complaints, check the No Complaints or Lawsuits box and sign the log.
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Orange County Public Transportation
DISCRIMINATION COMPLAINT FORM
Any person who believes that he/she has been subjected to discrimination based upon race,color,creed,sex,age,national origin,or disability
may file a written complaint with Orange County Public Transportation,within 180 days after the discrimination occurred.
Last Name: First Name: ❑ Male
❑ Female
Mailing Address: City State Zip
Home Telephone: Work Telephone: E-mail Address
Identify the Category of Discrimination:
❑ RACE ❑ COLOR ❑ NATIONAL ORIGIN ❑SEX
❑ CREED(RELIGION) ❑ DISABILITY ❑ LIMITED ENGLISH PROFICIENCY ❑AGE
'NOTE:Title VI bases are race,color,national origin.All other bases are found in the"Nondiscrimination Assurance"of the FTA Certifications&Assurances.
Identify the Race of the Complainant
❑ Black ❑White ❑ Hispanic ❑Asian American
❑American Indian ❑Alaskan Native ❑ Pacific Islander ❑ Other
Date and place of alleged discriminatory action(s).Please include earliest date of discrimination and most recent date of discrimination.
Names of individuals responsible for the discriminatory action(s):
How were you discriminated against?Describe the nature of the action,decision,or conditions of the alleged discrimination. Explain as clearly
as possible what happened and why you believe your protected status(basis)was a factor in the discrimination. Include how other persons
were treated differently from you.(Attach additional page(s),if necessary).
The law prohibits intimidation or retaliation against anyone because he/she has either taken action,or participated in action,to secure rights
protected by these laws. If you feel that you have been retaliated against,separate from the discrimination alleged above, please explain the
circumstances below. Explain what action you took which you believe was the cause for the alleged retaliation.
Names of persons(witnesses,fellow employees,supervisors,or others)whom we may contact for additional information to support or clarify
your complaint: (Attached additional page(s),if necessary).
Name Address Telephone
1.
2.
3.
4.
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DISCRIMINATION COMPLAINT FORM
Have you filed,or intend to file,a complaint regarding the matter raised with any of the following?If yes, please provide the filing dates.Check
all that apply.
❑ NC Department of Transportation
❑ Federal Transit Administration
❑ US Department of Transportation
❑ US Department of Justice
❑ Federal or State Court
❑Other
Have you discussed the complaint with any Orange County Public Transportation representative?If yes, provide the name, position,and date
of discussion.
Please provide any additional information that you believe would assist with an investigation.
Briefly explain what remedy,or action,are you seeking for the alleged discrimination.
**WE CANNOT ACCEPT AN UNSIGNED COMPLAINT. PLEASE SIGN AND DATE THE COMPLAINT FORM BELOW.
COMPLAINANT'S SIGNATURE DATE
MAIL COMPLAINT FORM TO:
Orange County Public Transportation
600 NC Highway 86 North
Hillsborough, NC 27278
OCTransportationServices@orangecountync.gov
919-245-2008
FOR OFFICE USE ONLY
Date Complaint Received:
Processed by:
Case#:
Referred to: ❑NCDOT ❑FTA Date Referred:
18
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INVESTIGATIVE GUIDANCE
A. Scope of Investigation —An investigation should be confined to the issues and facts relevant to the
allegations in the complaint, unless evidence shows the need to extend the issues.
B. Developing an Investigative Plan— It is recommended that the investigator prepares an Investigative
Plan (IP)to define the issues and lay out the blueprint to complete the investigation. The IP should
follow the outline below:
1. Complainant(s) Name and Address (Attorney name and address if applicable)
2. Respondent(s) Name and Address (Attorney for the Respondent(s) name and address)
3. Applicable Law(s)
4. Basis/(es)
5. Allegation(s)/Issue(s)
6. Background
7. Name of Persons to be interviewed
a. Questions for the complainant(s)
b. Questions for the respondent(s)
c. Questions for witness(es)
8. Evidence to be obtained during the investigation
a. Issue—e.g., Complainant alleges his predominantly African American community was
excluded from a meeting concerning a future project which could affect the community.
i. Documents needed: e.g., mailing list which shows all physical addresses, P.O. Box
numbers, property owner names, and dates when the meeting notification was mailed;
other methods used by the RPO to advertise the meeting.
C. Request for Information—The investigator should gather data and information pertinent to the issues
raised in the complaint.
D. Interviews— Interviews should be conducted with the complainant, respondent, and appropriate
witnesses during the investigative process. Interviews are conducted to gain a better understanding of
the situation outlined in the complaint of discrimination. The main objective during the interview is to
obtain information that will either support or refute the allegations.
E. Developing an Investigative Report—The investigator should prepare an investigative report setting
forth all relevant facts obtained during the investigation. The report should include a finding for each
issue. A sample investigative report is provided below.
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Investigative Report
I. COMPLAINANT(S)NAME(or attorney for the complainant(s)—name and address if applicable
Name,Address,Phone: 999-999-9999
II. RESPONDENT(S)(or attorney for the respondent(s)—name and address if applicable)
Name,Address,Phone: 999-999-9999
III. APPLICABLE LAW/REGULATION
IV. COMPLAINT BASIS/(ES)
V. ISSUES/ALLEGATIONS
VI. BACKGROUND
VII. INVESTIGATIVE PROCEDURE
VIII. ISSUES/FINDINGS OF FACT
IX. CONCLUSION
X. RECOMMENDED ACTIONS
APPENDIX
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8.0 SERVICE AREA POPULATION CHARACTERISTICS
To ensure that Title VI reporting requirements are met, Orange County Public Transportation will collect and maintain
population data on potential and actual beneficiaries of our programs and services.This section is intended as a compilation
of relevant population characteristics from our overall service area.This data will provide context to the Title VI
Nondiscrimination Program and be used to ensure nondiscrimination and improve public outreach initiatives and delivery of
ongoing programs.
8.1 RACE AND ETHNICITY
The following table was completed using data from Census Table QT-P3, Race and Hispanic or Latino Origin: 2010:
Race and Ethnicity Number Percent
Total Population 133,801 100
White 99,495 74.4
Black or African American 15,928 11.9
American Indian or Alaska Native 570 0.4
Asian 9,023 6.7
Native Hawaiian and Other Pacific Islander 41 0.0
Some other Race 5,341 4.0
Two or More Races 3,403 2.5
HISPANIC OR LATINO(of any race) 11,017 8.2
Mexican 6,860 5.1
Puerto Rican 669 0.5
Cuban 333 0.2
Other Hispanic or Latino 3,155 2.4
8.2 AGE&SEX
The following table was completed using data from Census Table QT-P1,Age Groups and Sex:2010:
Number Percent
Age Both sexes Male Female Both sexes Male Female
Total Population 133,801 63,954 69,847 100% 100% 100%
Under 5 years 6,890 3,496 3,394 5.1 5.5 4.9
Under 18 years 27,969 14,288 13,681 20.9 22.3 19.6
18 to 64 years 92,943 44,117 48,826 69.5 69.0 69.9
65 years and over 12,889 5,549 7,340 8.6 8.7 10.5
Median Age 31.1 32.5 33.8
8.3 DISABILITY
The following table was completed using data from Census Table S1810, Disability Characteristics:
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Total With a Disability Percent with a Disability
Margin of Margin of Margin of
Subject Estimate Error+1- Estimate Error+1- Estimate Error+/-
Total civilian noninstitutionalized population 139,617 -528 12,55 2,114 9.0 1.5
Population under 5 years 6,699 678 85 129 1.3 2.0
Population 5 to 17 years 21,853 680 789 573 3.6 2.6
Population 18 to 64 years 96,059 669 7,651 1,673 8.0 1.7
Population 65 years and over 15,006 561 4030 851 26.9 5.4
SEX
Male 65,398 866 6,080 1,402 9.3 2.1
Female 84,219 674 6,475 1,400 8.7 1.9
RACE AND HISPANIC OR LATINO ORIGIN
White 104,956 1,762 8,717 1,151 8.3 1.1
Black or African American 16,027 926 2621 1,517 16.4 9.4
American Indian and Alaska Native N N N N N N
Asian 10,149 602 769 711 7.6 7.0
Native American and Other Pacific Islander N N N N N N
Some other Race N N N N N N
Two or more races N N N N N N
Hispanic or Latino 11,699 4 565 396 4.8 3.4
V., ,--� fy
The following table was completed using data from Census Table S1701, Poverty Status in the Past 12 Months:
Total Below poverty level Percent below poverty
level
Margin of Margin of Margin of
Subject Estimate Error+I- Estimate Error+l- Estimate Error+I
Population for whom poverty status is 130,094 1,895 20,787 3,082 16.0 2.3
determined
AGE
Under 18 27,683 751 3,246 1,188 11.7 4.2
18 to 64 84,405 1,835 16,633 2,304 19.0 2.4
65 years and over 15,006 561 908 446 6.1 2.9
SEX
Male 61,513 1153 9132 1,474 14.8 2.3
Female 68,581 1546 11655 2,121 17.0 2.9
RACE AND HISPANIC OR LATINO ORIGIN
White 98,098 2,563 14,261 2,582 14.4 2.4
Black or African American 15,428 957 3,520 1,490 22.8 9.4
American Indian and Alaska Native
Asian 9,363 726 1,197 1091 12.8 11.5
Native American and Other Pacific Islander N N N N N N
Some other Race N N N N N N
Two or more races N N N N N N
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Hispanic or Latino
RACE AND HISPANIC OR LATINO ORIGIN 11,024 321 2,746 1,750 24.9 16.1
All individuals below:
50 percent of poverty level 10,987 2,041
125 percent of poverty level 24,991 3,825
150 percent of poverty level 30,565 3,949
185 percent of poverty level 35,658 4,326
200 percent of poverty level 10,259 4,399
8.5 HOUSEHOLD INCOKR�
Households
Subject Estimate Margin of Error+I-
Total 51,867 1,745
Less than$10,000 8.7 1.8
$10,000 to$14,999 3.1 1.2
$15,000 to$24,999 8.5 1.8
$25,000 to$34,999 6.7 1.7
$35,000 to$49,999 14.1 2.1
$50,000 to$74,999 18.9 2.8
$75,000 to$99,999 9.7 2.1
$100,000 to$149,999 13.9 2.1
$150,000 to$199,999 6.4 1.4
$200,000 or more 9.9 1.8
Median income(dollars) 59,409 3,364
Mean income(dollars) 92,061 6,209
8.6 LIMITED ENGLISH PROFICIENCY POPULATIONS
Speak English Less Estimate Margin of Error Percentage of
Than "Very Well" Population
Total Population 129,155 +/-61 100%
Spanish or Spanish 9,392 +/-461 7.2%
Creole
Chinese 2,533 +/-490 2%
Korean 1,209 +/-364 0.09%
Other Asian 1,522 +/-546 1.2%
Languages
Please see Appendix D for a complete list of LEP Population Statistics in Orange County.
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8.7 POPULATION LOCATIONS
Federal-aid recipients are required to identify the characteristics and locations of populations they serve,
particularly by race/ethnicity, poverty and limited English proficiency. We will document this narratively or
through maps that overlay boundaries and demographic features on specific communities, and provide this
information to NCDOT, upon request.
9.0 TITLE VI EQUITY ANALYSES (AND ENVIRONMENTAL JUSTICE ASSESSMENTS)
Title VI Equity Analyses. In accordance with FTA Circular 4702.1 B, a Title VI equity analysis will be
conducted whenever we construct a facility, such as a vehicle storage facility, maintenance facility, or
operation center. The equity analysis will be conducted during the planning stage, with regard to the
location of the facility, to determine if the project could result in a disparate impact to minority communities
based on race, color or national origin. Accordingly, we will look at various alternatives before selecting a
site for the facility. Project-specific demographic data on potentially affected communities and their
involvement in decision-making activities will be documented. Title VI Equity Analyses will remain on file
indefinitely, and copies will be provided to NCDOT, upon request, during compliance reviews or complaint
investigations.
Environmental Justice Analyses. As required by FTA C 4703.1, environmental justice (EJ) analyses will
be conducted to determine if our programs, policies, or activities will result in disproportionately high and
adverse human health and environmental effects on minority populations and low-income populations. EJ
applies to our projects, such as when we construct or modify a facility, and our policies, such as when
there will be a change in service, amenities or fares. Thus, we will look at various alternatives and seek
input from potentially affected communities before making a final decision. Demographic data will be
collected to document their involvement in the decision-making process. EJ analyses will remain on file
indefinitely, and copies will be provided to NCDOT, upon request, during compliance reviews or complaint
investigations.
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10.0 PUBLIC INVOLVEMENT
10.1 INTRODUCTION
Effective public involvement is a key element in addressing Title VI in decision-making. This Public
Participation Plan describes how Orange County Public Transportation will disseminate vital agency
information and engage the public. We will seek out and consider the input and needs of interested parties
and groups traditionally underserved by transportation systems who may face challenges accessing our
services, such as minority and limited English proficient(LEP) persons. Underlying these efforts is our
commitment to determining the most effective outreach methods for a given project or population.
General public involvement practices will include:
• Expanding traditional outreach methods. Think outside the box: Go to hair salons, barbershops, street
fairs, etc.
• Providing for early, frequent and continuous engagement by the public.
• Use of social media and other resources as a way to gain public involvement.
• Coordinating with community- and faith-based organizations such as the Hispanic Liaison, educational
institutions, and other entities to implement public engagement strategies that reach out specifically to
members of affected minority and/or LEP communities.
• Providing opportunities for public participation through means other than written communication, such
as personal interviews or use of audio or video recording devices to capture oral comments.
• Considering radio, television, or newspaper ads on stations and in publications that serve LEP
populations. Outreach to LEP persons could also include audio programming available on podcasts.
10.2 PUBLIC NOTIFICATION
Passengers and other interested persons will be informed of their rights under Title VI and related
authorities with regard to our program. The primary means of achieving this will be posting and
disseminating the policy statement and notice as stipulated in Sections 3.0 and 4.0, respectively.
Additional measures may include verbally announcing our obligations and the public's rights at meetings,
placing flyers at places frequented by targeted populations, and an equal opportunity tag-on at the end of
radio announcements. The method of notification will be determined through an initial screening of the
area.
1U.3 UISSEMINAiwry ur ujrurcrviHiiui.
Information on Title VI and other programs will be crafted and disseminated to employees, contractors and
subrecipients, stakeholders, and the general public. Public dissemination efforts may vary depending on
factors present, but will generally include: posting public statements setting forth our nondiscrimination
policy in eye-catching designs and locations; placing brochures in public places, such as government
offices, transit facilities, and libraries; having nondiscrimination language within contracts; including
nondiscrimination notices in meeting announcements and handouts; and displaying our Notice of
Nondiscrimination at all our public meetings.
At a minimum, nondiscrimination information will be disseminated on our website and on posters in
conspicuous areas at our office(s). Project-related information and our most current Title VI-related
information will be maintained online.
10.4 MEETINGS AND OUTREACH
There is no one-size-fits-all approach to public involvement. A variety of comprehensive and targeted
public participation methods will be used to facilitate meaningful public involvement. Methods for engaging
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stakeholders and target audiences, including traditionally underserved and excluded populations (i.e.,
minorities, youth, low-income, the disabled, etc.)will include the following:
Public Relations and Outreach
Public relations and outreach (PRO) strategies aim to conduct well-planned, inclusive and meaningful
public participation events that foster good relations and mutual trust through shared decision-making with
the communities we serve.
• We will seek out and facilitate the involvement of those potentially affected.
• Public events will aim to be collaborative, fun, and educational for all, rather than confrontational and
prescriptive.
• Media plans will typically involve multiple channels of communication like mailings, radio, TV, and
newspaper ads.
• Abstract objectives will be avoided in meeting announcements. Specific"attention-grabbing" reasons
to attend will be used, such as "Help us figure out how to relieve congestion on [corridor name]" or
"How much should it cost to ride the bus? Let us know on [date]."
• Efforts will be made to show how the input of participants can, or did, influence final decisions.
• We will do our best to form decision-making committees that look like and relate to the populations we
serve.
• We will seek out and identify community contacts and partner with local community- and faith-based
organizations that can represent, and help us disseminate information to, target constituencies.
• Demographic data will be requested during public meetings, surveys, and from community contacts
and committee members.
Public Meetings
"Public meeting" refers to any meeting open to the public, such as hearings, charrettes, open house and
board meetings.
• Public meetings will be conducted at times, locations, and facilities that are convenient and accessible.
• Meeting materials will be available in a variety of predetermined formats to serve diverse audiences.
• An assortment of advertising means may be employed to inform the community of public meetings.
• Assistance to persons with disabilities or limited English proficiency will be provided, as required.
Small Group Meetings
A small group meeting is a targeted measure where a meeting is held with a specific group, usually at their
request or consent. These are often closed meetings, as they will typically occur on private property at the
owner's request.
• If it is determined that a targeted group has not been afforded adequate opportunities to participate,
the group will be contacted to inquire about possible participation methods, including a group meeting
with them individually.
• Unless unusual circumstances or safety concerns exist, hold the meeting at a location of the target
group's choosing.
• Share facilitation duties or relinquish them to members of the target group.
• Small group discussion formats may be integrated into larger group public meetings and workshops.
When this occurs, the smaller groups will be as diverse as the participants in the room.
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Community Surveying
• Opinion surveys will occasionally be used to obtain input from targeted groups or the general public on
their transportation needs, the quality or costs of our services, and feedback on our public outreach
efforts.
• Surveys may be conducted via telephone, door-to-door canvassing, at community fairs, by placing
drop boxes in ideal locations, or with assistance from other local agencies like social services.
• Surveys will be translated into languages other than English, when appropriate.
10.5 LIMITED ENGLISH PROFICIENCY
Limited English Proficient(LEP) persons are individuals for whom English is not their primary language
and who have a limited ability to read, write, speak, or understand English. These individuals reported to
the U.S. Census Bureau that they speak English less than very well.
To comply with USDOT's LEP Policy Guidance and Executive Order 13166, this section of our Title VI
Plan outlines the steps we will take to ensure meaningful access by LEP persons to all benefits, services
and information provided under our programs and activities. A four-factor analysis was conducted to
determine the LEP language groups present in our planning area and the specific language services that
are needed.
Four Factor Analysis
This Four Factor Analysis is an individualized assessment that balances the following four factors:
(1) The number or proportion of LEP persons eligible to be served or likely to be encountered by a
program, activity, or service of the recipient or grantee;
(2) The frequency with which LEP individuals come in contact with the program;
(3) The nature and importance of the program, activity, or service provided by the recipient to people's
lives; and
(4) The resources available to the recipient and costs.
Factor#1: The number or proportion of LEP persons eligible to be served or likely to be
encountered by the program, activity, or service of the recipient.
Orange County, North Carolina
Estimate Margin of Error
Total: 129.1 i 5 +1-61
Speak only English 108.532 +1-854
Spanish or Spanish Creole: 9.392 +1461
Speak English"very well" 4.604 +1-599
Speak English less than "very well" 4.788 +1-644
French(incl. Patois, Cajun): r89 +1-270
Speak English"very well" 76C +1-266
Speak English less than "very well" 129 +1-K
This Title VI update requires that Orange County Public Transportation recognize the sub-populations of
languages that have either more than 5 % or 1,000 people that speak English less than "very well"
including numbers in the Margin of Error. In the Orange County Public Transportation service area, the
largest language subpopulation within the LEP population was that of Spanish speakers who speak
English less than "very well." Referencing estimates from the 2015 5-year American Community Survey
(ACS), our area has a total of 129,155 people. There are 9,932 Spanish speakers, of whom 4,788 speak
English less than "very well", or just over 3% of the total population.
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Factor#2: The frequency with which LEP individuals come in contact with the program.
Orange County Public Transportation assesses the frequency at which staff has or could possibly have
contact with LEP persons. This includes documenting phone inquiries and surveying public meeting
attendees. No previous LEP requests have been received thus far. Documentation of LEP requests will be
done annually upon implementation of the LEP plan. Orange County Public Transportation transit
operators also provide outreach to the Spanish population. Orange County Public Transportation provides
Spanish translation for public meetings and outreach materials. Arrangements are made to provide
translation when requested.
Factor#3: The nature and importance of the program, activity, or service provided by the recipient
to people's lives.
Orange County is a growing region within the Triangle. OCPT recognizes that public outreach to all groups
within the community is important and will continue to reach out to persons with limited English
proficiencies. OCPT critical service to LEP is scheduling transit services from the general public and the
agency contracts through Department of Social Services and other human service agencies within Orange
County.
Mobility for all Orange County residents is the driving force behind OCPT. This mobility allows access to
medical services, employment, education, human service agencies, recreational activities, etc. thereby
improving the quality of life for Orange County residents.
Other forms of transportation are available in Orange County. Taxi services local to the area are available
but and do not have ADA accessible vehicles. Most often these services are also cost prohibitive to those
seeking affordable transportation. Chapel Hill Transit provides a fixed route service in the City limits of
Chapel Hill but that service is only available to those who live in that specific service area.
Factor#4: The resources available to the recipient and costs.
Orange County Public Transportation (OCPT)will provide translation of materials for all information
regarding our services through third party translators at a cost of$12 center per word or$40.00 an hour for
in-person translation. OCPT will also work with community based organization such as the Family Success
Alliance that helps at risk families and families that speak limited English. Additionally, we will work with
Orange County's Human Rights and Relations department to decimate information to the limited English
speaking populations within Orange County
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Orange County Public Transportation
LANGUAGE ACCESS PLAN
Title: Title VI of the Civil Rights Act of 1964; Policy on the Prohibition Against
National Origin Discrimination as it Affects Persons with Limited English
Proficiency
Authority: Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et.seq.
Section 601 of Title VI of the Civil Rights Act of 1964, 42 U.S.C. Section 2000d et. seq.
states: "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."
Regulations implementing Title VI, provide in part at 45 C.F.R. Section 80.3 (b):
"(1)A recipient under any program to which this part applies may not, directly or
through contractual or other arrangements, on ground of race, or color, or national
origin:
(i) Deny an individual any service, financial aid, or other benefit
provided under the program:
(ii) Provide any service, financial aid, or other benefit to an individual
which is different, or is provided in a different manner, from that
provided to others in the program;
(2)A recipient, in determining the types of services, financial aid, or other
benefits, or facilities which will be provided under any such program or the class
of individuals to whom, or the situations in which such services, financial aid or
other benefits, or facilities will be provided... may not directly, or through
contractual or other arrangements, utilize criteria or methods of administration
which have the effect of subjecting individuals to discrimination, because of their
race, color or national origin, or have the effect of defeating or substantially
impairing accomplishments of the objectives of the program with respect to
individuals of a particular race, color, or national origin. " (emphasis added)
I. Purpose
The purpose of this Policy is to ensure compliance with Title VI of the Civil
Rights Act of 1964, and other applicable federal and state laws and their
implementing regulations with respect to persons with limited English proficiency
(LEP). Title VI of the Civil Rights Act of 1964 prohibits discrimination based on
the ground of race, color or national origin by any entity receiving federal
financial assistance. Administrative methods or procedures, which have the effect
of subjecting individuals to discrimination or defeating the objectives of these
regulations, are prohibited.
In order to avoid discrimination on the grounds of national origin, all programs or
activities administered by the Orange County Public Transportation must take
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adequate steps to ensure that their policies and procedures do not deny or have the
effect of denying LEP individuals with equal access to benefits and services for
which such persons qualify. This Policy defines the responsibilities the agency
has to ensure LEP individuals can communicate effectively.
IL Scope of Policy
These requirements will apply to the Orange County Public Transportation
including subcontractors, vendors, and subrecipients.
The agency will ensure that LEP individuals are provided meaningful access to
benefits and services provided through contractors or service providers receiving
subgrants from the agency.
M. Definitions
A. Limited English Proficient(LEP) individual—Any prospective,potential,
or actual recipient of benefits or services from the agency who cannot
speak, read, write or understand the English language at a level that
permits them to interact effectively with health care providers and social
service agencies.
B. Vital Documents—These forms include, but are not limited to,
applications, consent forms, letters containing important information
regarding participation in a program; notices pertaining to the reduction,
denial, or termination of services or benefits, the right to appeal such
actions, or that require a response from beneficiary notices advising LEP
persons of the availability of free language assistance, and other outreach
materials.
C. Title VI Compliance Officer: The person or persons responsible for
compliance with the Title VI LEP policies.
D. Substantial number of LEP: 5% or 1,000 people, whichever is smaller, are
potential applicants or recipients of the agency and speak a primary
language other than English and have limited English proficiency.
IV. Providing Notice to LEP Individuals
A. The agency will take appropriate steps to inform all applicants, recipients,
community organizations, and other interested persons, including those
whose primary language is other than English, of the provisions of this
policy. Such notification will also identify the name, office telephone
number, and office address of the Title VI compliance officer(s).
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List the current name, office telephone number and office address of the
Title VI compliance officers
TeLeishia Holloway, Transportation Administrator
600 NC Highway 86 North
Hillsborough,NC 27278
919-245-2002
(Note: the agency will notify the DHHS compliance attorney of changes
in name or contact information for the Title VI compliance officer.
B. The agency will post and maintain signs in regularly encountered
languages other than English in waiting rooms, reception areas and other
initial points of contact. These signs will inform applicants and
beneficiaries of their right to free language assistance services and invite
them to identify themselves as persons needing such services.
Identify areas within the agency where these signs will be posted:
Signage will be posted at the Orange County Public Transportation's
Entry way/lobby and breakroom.
C. The agency will include statements of the right to free language assistance
in Spanish and other significant languages in all outreach material that is
routinely disseminated to the public (including electronic text).
D. The agency will also disseminate information in the following manner:
Contacting translators for the all public outreach events and printing
material.
V. Provision of Services to LEP Applicants/Recipients
A. Assessing Linguistic Needs of Potential Applicants and Recipients
I. The agency will assess the language needs of the population to be
served, by identifying:
a. the language needs of each LEP applicant/recipient
b. the points of contact where language assistance is needed;
C. the resources needed to provide effective language
assistance, including location, availability and
arrangements necessary for timely use.
2. Determining the Language Needs of the Population to be Served
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The agency is responsible for assessing the needs of the population
to be served. Such assessment will include,but not be limited to
the following:
a. The non-English languages that are likely to be
encountered in its program will be identified.
b. An estimate of the number of people in the community for
who English is not the primary language used for
communication will be completed and updated annually.
To identify the languages and number of LEP individuals
local entities should review:
i. census data
ii. school system data
iii. reports from federal, state, and local governments
iv. community agencies' information, and
V. data from client files
C. The points of contact in the program or activity where
language assistance is likely to be needed will be identified.
3. Determining the Language Needs of Each Applicant/Recipient
The agency will determine the language needs of each
applicant/recipient. Such assessment will include,but not be
limited to the following:
a. At the first point of contact, each applicant/recipient will be
assessed to determine the individual's primary language.
Check all methods that will be used:
❑ Multi-language identification cards, a poster-size
language list, or the use of"I speak"peel-off language
identification cards for indicating preferred languages
❑ English proficiency assessment tools, provided they can
be administered in a manner that is sensitive to and
respectful of individual dignity and privacy
® Other
b. If the LEP person does not speak or read any of these
languages, the agency will use a telephone interpreting
service to identify the client's primary language
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C. Staff will not solely rely on their own assessment of the
applicant or recipient's English proficiency in determining
the need for an interpreter. If an individual requests an
interpreter, an interpreter will be provided free of charge.
A declaration of the client will be used to establish the
client's primary language.
d. W en staff place or receive a telephone call and cannot
determine what language the other person on the line is
speaking, a telephone interpreting service will be utilized in
making the determination.
e. If any applicant/recipient is assessed as LEP, they will be
informed of interpreter availability and their right to have a
language interpreter at no cost to them with a notice in
writing in the languages identified in Section C. Provisions
of Written Translations.
B. Provision of Bilingual/Interpretive Services
1. The agency will ensure that effective bilingual/interpretive services
are provided to serve the needs of the non-English speaking
population. The provision of bilingual/interpretive services will be
prompt without undue delays. In most circumstances, this requires
language services to be available during all operating hours.
This requirement will be met by: Orange County Public
Transportation will utilize paid interpreter, qualified bilingual
employees, and qualified employees of other agencies.
(Describe whether the agency has bilingual staff, and if so, how
many and in what Sections/Programs/Divisions, whether the
agency uses contractual services to meet this requirement, whether
the agency relies on telephone interpreter services, etc.)
2. The agency will provide language assistance at all level of
interaction with LEP individuals, including telephone interactions.
Describe how this requirement will be met: Orange County Public
Transportation will utilize paid interpreters, qualified bilingual
employees, and qualified employees of other agencies.
(Note: The agency may use paid interpreters, qualified bilingual
employees, qualified employees of other agencies or community
resources. Telephone interpreter services should only be utilized
as a back-up system or where other language assistance options
are unavailable.)
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3. Interpreter Standards
a. Those providing bilingual/interpretive services will meet
the linguistic and cultural competency standards set forth
below. The agency will ensure that interpreters and self-
identified bilingual staff, have first been screened to ensure
that the following standards are met before being used for
interpreter services:
i. Can fluently and effectively communicate in both
English and the primary language of the LEP
individual
ii. Can accurately and impartially interpret to and from
such languages and English
iii. Has a basic knowledge of specialized terms and
concepts used frequently in the provision of the
agency's services
iv. Demonstrates cultural competency
V. Understands the obligation to maintain confidently
vi. Understands the roles of interpreters and the ethics
associated with being an interpreter
Describe how the agency ensures the competency of
bilingual staff and interpreters:
Orange County Public Transportation utilizes the services
of the Orange County Human Rights and Relations.
Additionally, the County contracts with translators for both
in-person services and print materials.
b. When staff members have reason to believe that an
interpreter is not qualified or properly trained to serve as an
interpreter, the staff member will request another
interpreter.
4. Using Family Members or Friends as Interpreters
a. Applicants/recipients may provide their own interpreter;
however the agency will not require them to do so.
b. The agency will first inform an LEP person, in the primary
language of the LEP person, of the right to free interpreter
services and the potential problems for ineffective
communication. If the LEP person declines such services
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and requests the use of a family member or friend, the
agency may utilize the family member or friend to interpret
only if the use of such person would not compromise the
effectiveness or services or violate the LEP person's
confidentiality. The agency will monitor these interactions
and again offer interpreter services, if it appears there are
problems with this arrangement.
C. The agency will indicate in the LEP individual's file that an
offer of interpreter services was made and rejected; that the
individual was informed of potential problems associated
with using friends or family members and the name of the
person serving as an interpreter at the LEP individual's
request.
d. Only under extenuating circumstances shall the agency
allow a minor(under the age of 18 years)to temporarily act
as an interpreter. The agency will keep a written record of
when it has used a minor as an interpreter, and this
information will be shared with the DHHS upon request.
5. The agency will not require the applicant/recipient to pay for
bilingual/interpretive services
6. Use of Interpreters at Hearings
a. An interpreter will be provided for all hearings if a party
requests an interpreter or if the Hearing Officer determines
that an interpreter is necessary.
b. A separate oath or affirmation to translate accurately shall
be administered to all interpreters.
C. Provision of Written Translations
1. The agency must provide written materials in languages other than
English where a substantial number or percentage of the
population eligible to be served or likely to be directly affected by
the program needs services or information in a language other than
English to communicate effectively.
2. Translation of Vital Documents
a. The agency will ensure that vital documents for locally
designed programs are translated into Spanish.
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b. When state DHHS forms and other written material contain
spaces in which the local entity is to insert information, this
inserted information will also be in the individual's primary
language. When such forms are completed by
applicants/recipients in their primary language, the
information must be accepted.
C. If, as a result of the local language assessment, it appears
there are a substantial number of potential applicants or
recipients of the agency(defined as 5% or 1,000 people
whichever is less)who are LEP and speak a language other
than Spanish, the agency will translate and provide vital
documents in the appropriate language. (We prefer counties
do not translate DHHS forms. Please notify DHHS and
DHHS will translate or verify county translation)
d. The agency will keep a record of all vital documents
translated, and will submit this information to DHHS at
their request.
3. If the primary language of an LEP applicant or recipient is a
language other than Spanish AND the language does not meet the
threshold for translation as defined in the preceding paragraph, the
LEP individual will be informed in their own language of the right
to oral translation of written notices. The notification will include,
in the primary language of the applicant/recipient, the following
language: IMPORTANT: IF YOU NEED HELP IN READING
THIS, ASK THE AGENCY FOR AN INTERPRETER TO HELP.
AN INTERPRETER IS AVAILABLE FREE OF CHARGE.
D. Documentation of Applicant/Recipient Case Records
1. The agency will maintain case record documentation in sufficient
detail to permit a reviewer to determine the agency's compliance
with this policy.
2. The agency will ensure that case record documentation, including
computerized records if appropriate, identifies the
applicant's/recipient's ethnic origin and primary language. In
those cases where the applicant/recipient is non-English speaking,
the agency will:
a. Document the individual's acceptance or refusal of forms
or other written materials offered in the individual's
primary language.
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b. Document the method used to provide bilingual services,
e.g., assigned worker is bilingual, other bilingual employee
acted as interpreter, volunteer interpreter was used, or client
provided interpreter. When a minor is used as interpreter,
the agency will document the circumstances requiring
temporary use of a minor and will provide this information
to NC DHHS upon request.
3. Consent for the release of information will be obtained from
applicants/recipients when individuals other than agency
employees are used as interpreters and the case record will be so
documented.
E. Staff Development and Training
1. The agency will provide staff training at new employee orientation
and continuing training programs. The training will include, but
not be limited to:
a. Language assistance policies and procedures, resources
available to support such procedures, methods of effective use
of interpreters, and familiarization with the discrimination
complaint process.
b. Cultural awareness information, including specific cultural
characteristics of the groups served by the agency to provide a
better understanding of, and sensitivity to, the various cultural
groups to ensure equal delivery of services.
2. The agency will provide or ensure training is provided for bilingual
staff and interpreters employed or utilized by the agency. This
includes the ethics of interpreting, including confidentiality;
methods of interpreting; orientation to the organization; specialized
terminology used by the agency; and cultural competency.
3. The agency will ensure that applicable grantees, contractors,
cooperative agreement recipients and other entities receiving state
or federal dollars are trained in the requirements of this policy.
Describe how this provision will be met: Orange County Public
Transportation will utilize paid interpreters, qualified bilingual
employees, qualified employees of other agencies
4. The agency will collect and maintain the following information
about training provided to staff. the date(s) of such training, the
content of such training, the number and types of credit hours
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awarded; and the names and identifying information of each
attendee at the training. The agency will ensure that grantees,
contractors, cooperative agreement recipients and other applicable
funded entities collect and maintain such information as well.
VL Compliance Procedures, Reporting and Monitoring
A. Reporting
I. The agency will complete an annual compliance report and send
this report to the appropriate agency within the Department.
(Format will be supplied by DHHS)
B. Monitoring
I. The agency will complete a self-monitoring report on a quarterly
basis,using a standardized reporting system providing by the
Department. These reports will be maintained and stored by the
Title VI compliance officer and will be provided to the Department
upon request.
2. The agency will cooperate, when requested, with special review by
the Department.
V11. Applicant/Recipient Complaints of Discriminatory Treatment
A. Complaints
1. The agency will provide assistance to LEP individuals who do not
speak or write in English if they indicate that they would like to
file a complaint. A complaint will be filed in writing, contain the
name and address of the person filing it or his/her designee and
briefly describe the alleged violation of this policy.
2. The agency will maintain records of any complaints filed, the date
of filing, actions taken and resolution.
3. The agency will notify the appropriate agency or Division within
DHHS of complaints filed the date of filing, actions taken and
resolution. This information will be provided within 30 days of
resolution.
B. Investigation
1. The Title VI compliance officer will conduct an investigation of
the allegations of the complaint. The investigation will afford all
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interested persons and their representatives, if any, an opportunity
to submit evidence relevant to the complaint.
2. The investigation will not exceed 30 days, absent a 15-day
extension for extenuating circumstances.
C. Resolution of Matters
I. If the investigation indicates a failure to comply with the Act, the
agency Director or his/her designee will so inform the recipient
and the matter will be resolved by informal means whenever
possible within 60 days.
2. If the matter cannot be resolved by informal means, then the
individual will be informed of his or her right to appeal further to
the Office of General Counsel within DHHS. This notice will be
provided in the primary language of the individual with Limited
English Proficiency.
3. If not resolved by DHHS, then complaint will be forwarded to
OCR, USDHHS, and Region IV.
Submitted
Director
Date:
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Lanpuape Assistance Measures
The following general language assistance measures are reasonable and achievable for our organization
at this time:
• Translating public notices posted in the local paper and at stations, stops, and in vehicles into any
languages that meet the safe harbor threshold in Factor 1.
• Vital documents—such as brochures with service times and routes—are translated into Spanish
across the entire service area, and available in our facilities, doctor's offices and shopping centers.
• Making a concerted effort to inform LEP persons of available language assistance via staff, broadcast
media, relationship-building with organizations, and our website.
• Posting vital bulletin board information and disseminating community surveys in various languages.
• Providing translation and interpretive services when appropriate (upon request or predetermined)at
meetings.
• Determining how best to take public involvement to LEP groups directly, including through small group
meetings.
• Language line translation services at our call center.
• Where possible, utilizing or hiring staff who speak a language other than English and can provide
competent language assistance.
o Note: We will not ask community-based organizations (CBO)to provide, or serve as,
interpreters at our meetings. Relying upon CBOs in that capacity could raise ethical concerns.
If a CBO decides (on its own)to translate any materials for its constituents, or bring
interpreters it trusts to our meetings, we will not object. That is their right.
• Using language identification flashcards to determine appropriate services.
• Establishing a process to obtain feedback on our language assistance measures.
Specific Measures by Language Group:
• Spanish :
o Orange County Public Transportation will utilize paid interpreter, qualified bilingual
employees, and qualified employees of other agencies
• Chinese:
o Orange County Public Transportation will utilize paid interpreter, qualified bilingual
employees, and qualified employees of other agencies
• Korean:
o Orange County Public Transportation will utilize paid interpreter, qualified bilingual
employees, and qualified employees of other agencies
Written Translation and Oral Interpretation
Vital documents will be translated for each eligible LEP language group in our service area that constitutes
5% or 1,000, whichever is less, of the population of persons eligible to be served or likely to be
encountered. Translated materials will be placed online and in appropriate public (or private) places
accessible to LEP persons. The safe harbor provisions apply to the translation of written documents only,
and 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. When appropriate, translation
of any document will be communicated orally in the appropriate language.
In the event that the 5% trigger is reached for a LEP language group that is fewer than 50 persons, written
notice will be provided in the primary language of that group of the right to receive competent oral
interpretation of vital written materials, free of cost. The most effective method of notice, which could be an
ad in the local newspaper or other publication, a radio commercial, or door hangers, will be determined in
consideration of the circumstances on the ground and in coordination with LEP community contacts.
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Staff Support for Language Assistance
• Agency staff will be provided a list of referral resources that can assist LEP persons with written
translation and oral interpretation, including the Title VI Officer and any outside consultant contracted
to provide language services. This list will be updated as needed to remain current.
• All main offices and vehicles will have on hand a supply of language assistance flashcards and
materials translated into the languages of the largest LEP language groups. When encountered by an
LEP person, staff(including drivers) should present the individual with an iSpeak flashcard and let
them choose the language. Do not assume you know their preferred language. Drivers are permitted
to seek volunteer assistance from other passengers before contacting a referral resource. Document
the encounter and report it to the Title VI Coordinator.
• Training: All employees will be instructed on our procedures for providing timely and reasonable
assistance to LEP persons. New employee orientation will also explain these procedures to new hires.
Staff routinely encountering LEP persons by telephone or in person will receive annual refresher
training. All other employees will be reminded of LEP through annual Title VI program
acknowledgements (Section 5.0) and basic Title VI trainings (Section 11.0).
Protect-Specific LEP Outreach
A project-specific four factor analysis will be conducted for any project or outreach event limited to a
specific geographical area (i.e., the project study area or outreach area, respectively). Language
assistance will be provided in accordance with the measures already outlined, including translating written
materials for each LEP language group that is 5% or 1,000, whichever is less, of the project or outreach
area population.
Monitoring and Updating the LAP
Monitoring of daily interactions with LEP persons will be continuous, thus language assistance techniques
may be refined at any time. This Plan will be periodically reviewed—at least annually—to determine if our
assistance measures and staff training are working. Resource availability and feedback from agency staff
and the general public will be factors in the evaluation and any proposed updates. Among other practices,
this process will include working with LEP community contacts to determine if our employees are
responding appropriately to requests made with limited English or in languages other than English, and
observing how agency staff responds to requests, including observing drivers or surveying riders. To the
best of our ability, we will attempt to never eliminate a successful existing LEP service. Significant LEP
program revisions will be approved or adopted by our board or designated official and dated accordingly.
LEP data and procedures will be reviewed and updated at least once every three years.
8.1 DEMOGRAPHIC REOUFST
The following form was used to collect required data on Key Community Contacts and nonelected
committee members.
Orange County Public Transportation is required by Title A of the Civil Rights Act of 1964 and related authorities to
record demographic information on members of its boards and committees. Please provide the following
information:
Race/Ethnicity: National Origin:(if born outside the U.S.)
❑White ❑Mexican
❑Black/African American ❑Central American:
❑Asian ❑South American:
❑American Indian/Alaskan Native ❑Puerto Rican
❑Native Hawaiian/Pacific Islander ❑Chinese
❑Hispanic/Latino ❑Vietnamese
❑Other(please specify): ❑Korean
❑Other(please specify):
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Gender: Age.
❑Male ❑Female
❑Less than 18 ❑45-64
❑ 18-29 ❑65 and older
Disability: ❑Yes ❑No
❑30-44
I choose not to provide any of the information requested above: ❑
Completed forms will remain on file as part of the public record. For more information regarding Title VI or this
request, please contact the Orange County Public Transportation at 919-245-2008 or by email at
octransportationservices@orangecountync.gov.
Please sign below acknowledging that you have completed this form.
Thank you for your participation!
Name(print):
Signature:
Implementation
• Forms will be completed prior to NCDOT Title VI reviews and remain on file for three years.
• All new and existing members of appointed decision-making boards or committees will be required
to complete this form for reporting purposes.
• If a member, for whatever reason, selects `Y choose not to provide any of the information requested
above,"this will be accepted as a completed form.
• If a member chooses not to provide any of the information on the form, the Title VI Coordinator will
be permitted to indicate that member's race and gender, based on the Coordinator's best guess.
• Data from these forms will be used to complete the Demographic Request Table.
• Once a new member submits this form, the Demographic Request Table for the associated
committee will be updated.
8.2 KEY COMMUNITY CONTACTS
Contact Name Community Name Interest or Affiliation Also a Committee
Member? YIN
Shannan Barnes Orange County Family Success Alliance N
Marlyn Valeiko Orange County LEP Specialist/Outreach N
Contact information for key community contacts is not public information and is maintained outside of this
document. Any staff member who wishes to contact any individual listed above must request that
information from the Title VI Coordinator.
8.3 5UMMARY OF OUTREACH EFFORTS MADE SINCE THE LAST TITLE VI PROGRAM SUBMISSION
The following format is used to document URTS outreach efforts in reports to NCDOT. All meetings and
disseminations of information capture information for the table below:
Meeting Date Meeting Time Meeting Purpose Target Audience Information Disseminated
9/19/2020 11am Transit Services in General Public Brochures, Bus Rider 101, Bike on Bus
Orange County Information
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9/20/2020 11am Transit Services in General Public Brochures, Bus Rider 101, Bike on Bus
Orange County Information
9.0 STAFF TRAINING
All employees will receive basic Title VI training at least once every three years. New hires will receive this
training within 15 days of their start date. Basic training will cover all sections of this Plan and our overall
Title VI obligations. Staff may receive specialized training on how Title VI applies to their specific work
areas. Those who routinely encounter the public, such as office personnel, call center staff, and vehicle
drivers, will receive annual refresher training. Trainings will be provided or organized by the Title VI
Coordinator and will often coincide with updates to our nondiscrimination policies and procedures. Records
of staff trainings, such as agendas, sign-in sheets, copies of calendars, and certificates, will remain on file
for at least three years (and in personnel files).
10.ONONELECTED BOARDS AND COMMITTEES — BY RACE AND GENDER
The table below depicts race and gender compositions for each of our nonelected (appointed) decision-
making bodies. Member names and full demographics for each committee are available, upon request.
Male% Female Caucasian African Asian Native Other% Hispanic
Body % % American American American %
Service Area Population
Orange Unified Transportation 34% 66% 79% 16% 5%
Board(Transit Advisory Board)
Strategies for Representative Committees
Diversification goals will be provided to our nonelected boards and committees to help ensure that their
membership mirrors our service area demographics, as adequately as possible. We will provide periodic
updates on our outreach efforts at meetings. When there is an opening on a board or committee, we will
ensure the following:
• Current members will be made aware of diversity goals and polled for nominees.
• Officials from local minority groups will be made aware of the diversity goals and polled for nominees.
• Key Contacts from LEP groups will be contacted and polled for nominees.
• A recruitment notice for a Board Member opening will be posted on our website.
• An advertisement of recruitment notice for a Board Member will be placed with the local newspaper
and other publications popular with minorities and other protected groups.
11.0 RECORD-KEEPING AND REPORTS
As a subrecipient of FTA funds through NCDOT, we are required to submit a Title VI Program update to
NCDOT every three years, on a schedule determined by NCDOT. Records will be kept to document
compliance with the requirements of the Title VI Program. Unless otherwise specified, Title VI-related
records shall be retained indefinitely. These records will made available for inspection by authorized
officials of the NCDOT and/or FTA. Reports on Title VI-related activities and progress to address findings
identified during Title VI compliance reviews may also be provided, upon request. It will occasionally be
necessary to update this Title VI Plan or any of its components (e.g., complaints, Public Involvement, and
LEP). Updates will be submitted to NCDOT for review and approval and adopted by our Board when
required.
DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
In addition to items documented throughout this Plan, records and reports due at the time of compliance
reviews or investigations may include:
Compliance Reviews
• Title VI Program Plan 0 Findings from reviews by any other external
• List of civil rights trainings provided or agencies
received • Title VI equity analyses and EJ assessments
• Summaries from any internal reviews 0 Discrimination Complaints Log
conducted
• Ads and notices for specific meetings
Complaint Investigations
• Investigative Reports 0 Supporting Documentation (e.g., requested
• Discrimination complaint, as filed items, photos taken, dates and methods of
• List of interviewees (names and affiliations) contact, etc.)
DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
Appendix A
Applicable Nondiscrimination Authorities
During the implementation of this Title VI Program, the organization, for itself, its assignees and
successors in interest, is reminded that it has agreed to comply with the following non-discrimination
statutes and authorities, including but not limited to:
• Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq., 78 stat. 252), (prohibits
discrimination on the basis of race, color, national origin); and 49 CFR Part 21.
• The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, (42 U.S.C. §
4601), (prohibits unfair treatment of persons displaced or whose property has been acquired because
of Federal or Federal-aid programs and projects);
• Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794 et seq.), as amended, (prohibits
discrimination on the basis of disability); and 49 CFR Part 27;
• The Age Discrimination Act of 1975, as amended, (42 U.S.C. § 6101 et seq.), (prohibits discrimination
on the basis of age);
• The Civil Rights Restoration Act of 1987, (PL 100-209), (Broadened the scope, coverage and
applicability of Title VI of the Civil Rights Act of 1964, The Age Discrimination Act of 1975 and Section
504 of the Rehabilitation Act of 1973, by expanding the definition of the terms "programs or activities"
to include all of the programs or activities of the Federal-aid recipients, sub-recipients and
contractors, whether such programs or activities are Federally funded or not);
• Titles II and III of the Americans with Disabilities Act, which prohibit discrimination on the basis of
disability in the operation of public entities, public and private transportation systems, places of public
accommodation, and certain testing entities (42 U.S.C. §§ 12131-12189) as implemented by
Department of Transportation regulations at 49 C.P.R. parts 37 and 38;
• Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating
because of sex in education programs or activities (20 U.S.C. 1681 et seq).
• Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e et seq., Pub. L. 88-352), (prohibits
employment discrimination on the basis of race, color, creed (religion), sex, or national origin);
• 49 CFR Part 26, regulation to ensure nondiscrimination in the award and administration of DOT-
assisted contracts in the Department's highway, transit, and airport financial assistance programs;
• Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations
and Low-Income Populations, which ensures discrimination against minority populations by
discouraging programs, policies, and activities with disproportionately high and adverse human health
or environmental effects on minority and low-income populations;
• Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency,
and resulting agency guidance, national origin discrimination includes discrimination because of
limited English proficiency (LEP). To ensure compliance with Title VI, you must take reasonable steps
to ensure that LEP persons have meaningful access to your programs (70 Fed. Reg. at 74087 to
74100);
• Federal-Aid Highway Act of 1973, (23 U.S.C. § 324 et seq.), (prohibits discrimination on the basis of
sex);
• Airport and Airway Improvement Act of 1982, (49 USC § 4 71, Section 4 7123), as amended,
(prohibits discrimination based on race, creed (religion), color, national origin, or sex);
• The Federal Aviation Administration's Non-discrimination statute (49 U.S.C. § 47123) (prohibits
discrimination on the basis of race, color, national origin, and sex);
• Federal transit laws, specifically 49 U.S.C. § 5332 (prohibiting discrimination based on race, color,
religion, national origin, sex (including gender identity), disability, age, employment, or business
opportunity).
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DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
Appendix C
NCDOT's Compliance Review Checklist for Transit
I. Program Administration(General Requirements)
Requirement.FTA C 47021B—Title VI Requirements and Guidelines for FTA Recipients,Chapter III—General Requirements and Guidelines.
Note: Every NCDOT subrecipient receiving any of the FTA Formula Grants listed above must complete this section.
Requested Items
(Please attach electronic documents(.pdf,.doe,etc.)or provide links to online versions) Completed
1. A copy of the recipient's signed NCDOT's Title VI Nondiscrimination Agreement ❑
2. Title VI Policy Statement(signed) ❑
3. Title VI Notice to the Public,including a list of locations where the notice is posted ❑
4. Type the name and title of your Title VI Coordinator and attach a list of their Title VI duties ❑
Name/Title:
5. Title VI Complaint Procedures(i.e.,instructions to the public regarding how to file a Title VI ❑
discrimination complaint)
6. Title VI Complaint Form ❑
7. List of transit-related Title VI investigations,complaints, and lawsuits(i.e., discrimination ❑
complaints log)
8. Public Participation Plan, including information about outreach methods to engage traditionally
underserved constituencies(e.g.,minorities, limited English proficient populations(LEP),low- ❑
income, disabled),as well as a summary of outreach efforts made since the last Title VI Program
submission
9. Language Assistance Plan for providing language assistance to persons with limited English
proficiency(LEP),based on the DOT LEP Guidance,which requires conducting four-factor ❑
analyses
10. 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
11. 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
12. A description of the procedures the agency uses to ensure nondiscriminatory administration of ❑
programs and services
13. If you pass through FTA funds to other organizations, include a description of how you
monitor your subrecipients for compliance with Title VI,and a schedule for your subrecipients' ❑
Title VI Program submissions.
➢ No Subrecipients ❑
14. A Title VI equity analysis if you have constructed or conducted planning for a facility, such
as a vehicle storage facility,maintenance facility, operation center, etc. ❑
➢ No Facilities Planned or Constructed❑
15. Copies of environmental justice assessments conducted for any construction projects during
the past three years and, if needed based on the results, a description of the program or other
measures used or planned to mitigate any identified adverse impact on the minority or low- ❑
income communities
➢ No Construction Projects❑
DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
16. If the recipient has undergone a Title VI Compliance Review in the last 3 years,please indicate ❑
the year of the last review and who conducted it.Year/Agency:
IL Transit Providers
Requirement:FTA C 4702.IB, Chapter IV—Requirements and Guidelines for Fixed Route Transit Providers.
Note: All NCDOT subrecipients that provide fixed route public transportation services (e.g., local, express or commuter bus; bus rapid
transit;commuter rail;passenger ferry)must complete this section.
➢ Not Applicable ❑ (Check this box if you do not provide fixed route services, and skip questions 17 and 18.This section
does not apply to you if you only provide demand response services.)
Requested Items
(Please attach electronic documents(.pdf,.doc,etc.)or provide links to online versions) Completed
17. Service standards(quantitative measures)developed for each specific fixed route mode that the
recipient provides (standards may vary by mode)must be submitted for each of the following
indicators:
• Vehicle load for each mode (Can be expressed as the ratio of passengers to the total number of seats on a
vehicle.For example,on a 40-seat bus,a vehicle load of 1.3 means all seats are filled and there are approximately 12 ❑
standees.)
• Vehicle headway for each mode (Measured in minutes(e.g.,every 15 minutes),headway refers to the
amount of time between two vehicles traveling in the same direction on a given line or combination of lines.A shorter ❑
headway corresponds to more frequent service.Service frequency is measured in vehicles per hour(e.g.,4 buses per
hour).)
• On time performance for each mode (Expressed as a percentage,this is a measure of runs completed as
scheduled. The recipient must define what is considered to be`on time."Performance can be measured against route ❑
origins and destinations only,or against origins and destinations as well as specified time points along a route.)
• Service availability for each mode (Refers to a general measure of the distribution of routes within a transit
provider's service area,such as setting the maximum distance between bus stops or train stations,or requiring that a ❑
percentage of all residents in the service area be within a one-quarter mile walk of bus service.)
18. Service policies(system-wide policies) adopted to ensure that service design and operations
practices do not result in discrimination on the basis of race, color or national origin,must be
submitted for each of the following:
• Transit amenities for each mode (e.g.,benches,shelters/canopies,printed materials,escalators/elevators,
and waste receptacles.NOTE:Attach this information only if you have decision-making authority over siting transit ❑
amenities or you set policies to determine the siting of amenities.)
• Vehicle assignment for each mode (Refers to the process by which transit vehicles are placed into service
throughout a system.Policies for vehicle assignment may be based on the type or age of the vehicle, where age ❑
would be a proxy for condition,or on the type of service offered.)
DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
Appendix D
Orange County's LEP Demographics
Orange County, North Carolina
Estimate Margin of Error
Total: 129,155 +1-61
Speak only English 108,562 +1-854
Spanish or Spanish Creole: 9,392 +1A61
Speak English"very well" 4,604 +1_599
Speak English less than"very well" 4,7B8 +1-644
.f reach-(inct_Palois,Cajon)-
Speak English"very well" 760 +1-266
Speak English less than"very well" 129 +1-59
French Creole: 55 +1-50
Speak English"very well" 42 +IA1
Speak English less than "very well" 13 +1-24
Italian: 191 +1-99
Speak English"very well" 141 +1-77
Speak English less than"very well" 50 +1-61
Portuguese or Portuguese Creole: B8 +f-B6
Speak English"very well" 68 +1-77
Speak English less than"very well" 20 +1-36
German: 573 +1-164
Speak English"very well" 528 +1-164
Speak English less than"very well" 46 +IA2
Yiddish: 0 +f-2g
Speak English"very well" 0 +f-29
Speak English less than "very well" 0 +f-29
Other West Germanic languages: 80 +IA6
Speak English "very well" BO +1-46
Speak English less than"very well" 0 +1-29
Scandinavian languages: 162 +1-111
Speak English"very well" 146 +1_97
Speak English less than"very well" 16 +1-26
Greek: 176 +1-131
Speak English"very well" 136 +1-114
Speak English less than"very well" 40 +1-56
Russian: 483 +1-248
DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
[}range Counly.North Carolina
Fdia Hargin of Firer
SpeA 1154tsh-my weir 403 #1-23
Speak Erdish less&m'mywei 80 V-W
Polish_ 113 41-82
Speak s4ish'leerywelr 102 V-7�
R End mhTessMm'%wywer 11 -9-19
Sedx.-Croatian_ 32 V45
Spew Endmh-My welt 32 a-45
Speak Erdish less ffm'weryweir 0 V-29
Odw Slavic laiguaWs: 203 -0-150
Speak English'veryweir 283 +l-155
Speak EWtsh kss dun'wYy weff' 10 14-15
Aumenian: 26 V-39
Speak Erkglt!sh r weir 17 -9-21
Speak Er4ish less dian'wrywei 9 +l-13
Persian_ 246 -9-153
Speak Errjish mywelr 163 4-103
Speak Engitshlessdhan'werywer 83 -9-75
Gujarati_ 128 +l-75
Speak Erdish-*my weir 107 -9-W
Speak B4ish less&m'werywEE' 21 433
Ffirdi= 249 -9428
Speak Erdish'vMwelr 249 0-125
SpeakEngltshless&m'weryweF 0 -0-20
Mu: 128 4-109
SpEak B4rsh-*mywelr 128 +d-100
Speak English less dian'werywEff 0 V-29
OUrer Indic 6mVmages: 294 +d-175
Speak English mywelr 274 +l-17d
SpeakErdtshlessdran'mmywer 20 4-25
Odher n urcpaw 186 +l-79
Speak Errgltsh-Very weir 173 -9-74
Speak English less dwn'weryweir 12 +l-19
chirese: 2= -0-40
Speak Endish verywelr 1.5w0 r1371
Speak Eroish less dun'wmywW 893 +d-261
Japanese: 265 +l-100
SPBM B4 173 ff-97
Speak English less dim'werywef 32 930
Y,orsan: 1 M -9304
Speak English'very weir ggp 14300
SpeakErrgltshless&m'werywW 550 41-M
hr xW,hmer.Carnbcdian: 31 V38
Speak Erdish-*my weir 0 -9-20
pe Er4ish less wary weir 31 rl38
Frnnng: 31 -934
Speak Erdish,%wywelr 31 +l3A
Speak Errgltsh less dean'wary wer 0 -0-22
Thai: 83 V-97
Speak B4rsh-my v"r 10 41-Z4
Speak English less dian'weryweir 68 14-92
15 -0-22
Speak Errglish'my welr 15 V-22
Speak End tshlessMm'YuywW 0 -9-2h
VE,tnarnem: 2M 4-160
Speak Errgltsh-WHY weir 202 -9-154
Speak Endish less&m'wYywW 24 V37
OUrer Asian lames_ 1,522 -9-646
Speak 744 V-22!5
SpeAFmdlsh less d-ian'werywer 778 -a-320
DocuSign Envelope ID:3FDDF183-DEOC-45F5-AE17-OB9CF99E613F
Orange County, North Carolina
Estimate Margin of Error
Tagalog: 229 +1.145
Speak English`very well" 152 +1-101
Speak English less than "very well" 77 +1-73
Other Pacific Island languages: 43 +1A3
Speak English"very well" 31 +1-40
Speak English less than"very well" 12 +1-19
Navajo: 6 +1-29
Speak English'"well" o +1-29
Speak English less than "very well" p +1-29
Other Native North American languages: p +1-29
Speak English"very well" p +1-29
Speak English less than"very well" p +1-29
Hungarian: 35 +1-46
Speak English`very well" 35 +IA6
Speak English less than "very well" p +1-29
Arabic: 195 +l-148
Speak English"very well" 161 +1-137
Speak English less than"very well" 34 +IA4
Hebrew: 104 +1-69
Speak English`very well" 85 +1-57
Speak English less than "very well" 19 +1-32
African languages: 331 +f-203
Speak English"very well" 316 +1.201
Speak English less than"very well" 15 +1-20
Other and unspecified languages: 18 +1-26
Speak English`very well" 6 -"-1p
Speak English less than "very well" 12 +1-17