City of Camarillo
Camarillo Area Transit
TITLE VI PLAN
Title VI of the Civil Rights Act of 1964
Adopted: December 11, 2024
December 11, 2024 – May 31, 20271
Contact Information:
Lydia Salas, Management Assistant
Camarillo Area Transit
601 Carmen Drive
Camarillo, CA 93010
Office: 805-388-5341
Email: [email protected]
1 Expiration date matches VCTC’s date. Sections of VCTC’s Title VI Program are incorporated into the City’s Title VI Program.
TITLE VI PLAN
I. Plan Statement
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving federal financial assistance.
Specifically, Title VI provides that “no person in the United States shall, on the ground of race, color or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance” (42 U.S.C. Section 2000d).
The City of Camarillo /Camarillo Area Transit (City) is committed to ensuring that no person is excluded from participation in, or denied the benefits of, its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1.B.
As sub -recipient to the regional grantee, Ventura County Transportation Commission (VCTC), the City is eligible to adopt certain elements of the VCTC Title VI Program per FTA Circular 2702.1B, dated October 1, 2012. Appropriate, adoptable elements include the following:
• Notice to Beneficiaries
• Title VI Complaint Procedures
• Language Assistance Plan (LEP Plan)
• Public Participation Plan
The City has elected to adopt eligible elements of the VCTC Title VI Program, in order to satisfy federally -mandated Title VI requirements; adopted elements are noted accordingly.
This plan was developed to guide the City in the administration and management of Title VI-related activities
Title VI Coordinator
Public Works
City of Camarillo
601 Carmen Drive
Camarillo, CA 93010
II. Title VI Information Dissemination
Title VI information posters shall be prominently and publicly displayed in the City contractor’s transit facility (see Appendix G). The plan information, along with contact information for the City’s Title VI C oordinator is available on the City ’s web page, at www.cityofcamarillo.org
. Additional information relating to nondiscrimination obligation can be obtained from the City’s Title VI Coordinator.
Title VI information shall be disseminated to the City’s public transit contract operator annually via the Employee Education form (see Appendix A) in payroll envelopes. This form reminds employees of their Title VI responsibilities in their daily work and duties.
During new employee orientation, new employees shall be informed of the provisions of Title VI, and the expectations to perform their duties accordingly.
All contractor employees shall be provided a copy of the Title VI Plan and are required to sign the Acknowledgement of Receipt (see Appendix B).
Title VI information shall also be made available in non- English languages, consiste nt with the City’s Language Assistance Plan.
III. Subcontracts and Vendors
All subcontractors and vendors who receive payments from the City where funding originates from any federal assistance are subject to the provisions of Title VI of the Civil Rights Act of 1964 as amended. Written contracts shall contain non- discrimination language, either directly or through the bid specification package which becomes an associated component of the contract.
IV. Record Keeping
The Title VI Coordinator will maintain permanent records, which include, but are not limited to, signed acknowledgements of receipt from the employees indicating the receipt of the Title VI Plan, copies of Title VI complaints or lawsuits and related documentation, and records of correspondence to and from complainants, and Title VI investigations.
V. Title VI Complaint
Procedures Filing a Title VI Complaint
The complainant may file a signed, written complaint up to180 days from the date of the alleged discrimination. The complaint should include the following information:
• Complainant’s name, mailing address, and contact information (i.e., telephone number, email address, etc.)
• How, when, where and why the complainant believes they were discriminated against. Include the location, names and contact information of any witnesses.
• Other information that the complaint deems significant.
The Title VI Complaint Form (see Appendix C) may be used to submit the complaint information. The complaint may be filed in writing with the City of Camarillo at the following address:
Title VI Coordinator
Public Works
City of Camarillo, 601 Carmen Drive
Camarillo, CA 93010
The Complaint Form is also available online at:
https://cityofcamarillo.org/residents/public_transportation/index.php NOTE: The City encourages all complainants to use certified mail through the U.S. Postal Service and/or ensure that all written correspondence can be tracked easily by other means. For complaints originally submitted by facsimile, an original, signed copy of the complaint must be mailed to the Title VI Coordinator as soon as possible, but no later than 30 days from the alleged date of discrimination.
Complaint processing after submission:
All complaints alleging discrimination based on race, color or national origin in a service or benefit will be directly addressed by City. City shall also provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English. Additionally, the City shall make every effort to address all complaints in an expeditious and thorough manner.
A letter acknowledging receipt of complaint will be mailed within thirty (30) days (see Appendix D). Please note that in responding to any requests for additional information, a complainant’s failure to provide the requested information may result in the administrative closure of the complaint.
Notification of complainant of the outcome of the complaint process:
The City will send a final written response letter (see Appendix E and F) to the complainant. In the letter notifying complainant that the complaint is not substantiated (see Appendix F), the complainant is also advised of his or her right to: 1) appeal wi thin seven calendar days of receipt of the final written decision from the City, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration. Every effort will be made to respond to Title VI co mplaints within 60 working days of receipt of such complaints, if not sooner.
In addition to the complaint process described above, a complainant may file a Title VI complaint with the following offices:
Federal Transit Administration Office of Civil Rights
Attn: Title VI Program Coordinator
East Building, 5
th Floor - TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
VI. Language Assistance Plan (LAP)/Limited English Proficiency (LEP) Plan Title VI and its implementing regulations require that FTA recipients take responsible steps to ensure meaningful access to the benefits, services, information, and other important portions of their programs and activities for individuals who are Limited English Proficient (LEP).
In developing a language implementation plan VCTC and sub-recipients can ensure that LEP persons have meaningful access to their programs and activities by developing and carrying out a language implementation plan pursuant to the recommendations in Section VII of the US DOT LEP Guidance.
The VCTC Title VI Program for Language Assistance Plan, Overview of VCTC, Language Assistance Goals, Results of the Four Factor Analysis, Implementation Plan, General Measures or Practices, Monitoring and Updating of the LAP Plan and Staff Training, adopted May 7, 2021, and any future amendments are incorporated into the City’s Title VI Program and included as Appendix I. The VCTC Title VI Program Attachment B is also incorporated by reference to this document.
Additionally, City staff members and contracted service provider ( RTW Management, Inc.) can provide assistance for Spanish speakers in the community.
Description of Subrecipient Monitoring and Schedule of Subrecipient Title VI Program Submissions
The City is considered a subrecipient to VCTC (primary recipient). In accordance with 49 CFR 21.9(b), and to ensure that subrecipients are complying with the DOT Title VI regulations, primary recipients must monitor their subrecipients for compliance with the regulations. Importantly, if a subrecipient is not in compliance with the Title VI requirements, the primary recipient is not in compliance. The VCTC Director of Programming is responsible for all subrecipient monitoring. VCTC monitors its subrecipients by ensuring that each entity meets the criteria outlined in Chapter Ill of Title VI Circular 4702.1 B. VCTC has collected and reviewed the subrecipients' Title VI Programs which were approved by the subrecipients' governing board. VCTC also reviewed the subrecipients' website and confirmed that their Title VI Notice complaint process and Title VI complaint form were available to the public. VCTC's subrecipients must submit a copy of their Title VI Program triennially prior to the due date of VCTC's Title VI Program submission to the FTA. VCTC staff monitors the submissions.
Service Standards for Fixed Route Transit Providers
The City's fixed-route bus service operates two (2) fixed route vehicles in peak service.
Vehicle load for each mode
Vehicle Load or load factor is a ratio of the number of seats on a vehicle to the number of passengers. Load factor is an indicator of the extent of probable overcrowding or the need for additional vehicles. It is also a means to determine whether the level of service on a particular route at a particular time is adequate to assure a level of service deemed appropriate for the transit system. As a service standard, load factor is typically expressed as a ratio (E.g., 1 :1 or 1.25 or 1 seat for every 1.25 passengers). The load factor is determined by taking the number of seats on a specific route which pass the peak point during the peak hour and dividing that into the number of passengers that are actually carried past that point during that hour. Vehicle loads are monitored for all routes to determine if additional vehicles are needed to avoid overcrowding.
Camarillo Area Transit fixed-route vehicle load shall not exceed 1:1 or 1 seat for every 1 passenger.
Camarillo Area Transit trolley bus vehicle load shall not exceed 1:1. 3 or 1 seat for every
1.3 passengers (or a total bus capacity of 29 passengers with 22 seats available).
Camarillo Area Transit dial-a-ride vehicle load shall not exceed 1 :1, or 1 seat for every 1 passenger.
Vehicle headway for each mode
Vehicle headway is a measurement of the time interval between two vehicles traveling in the same direction on the same route. The frequency of service is a general indication of the level of service provided along a route and a factor in the calculation of the amount of travel time expended by a passenger to reach his/her destination. It is generally expressed for peak and off peak service as an increment of time ( e.g. peak: every 15 minutes; and off peak: every 30 minutes).
The goal of Camarillo Area Transit's fixed-route vehicle headways is to be 60 minutes or less, Monday through Friday . Some trips may require approximately 70 minutes due to the need of driver breaks and peak traffic in certain areas of the City . The Trolley Route vehicle headway is to be 30 minutes Monday through Sunday.
On-Time Performance for each mode
A vehicle is considered on time if it arrives at a scheduled timepoint no more than 5 minutes late. No buses shall arrive ahead of schedule. The City’s on- time performance objective for fixed route is 98%.
Service availability for each mode
Camarillo Area Transit operates a fixed-route service that connects Leisure Village to various locations within Camarillo and the Trolley route which connects the Metrolink Station to the Camarillo Town Center, Outlets and Old Town. Local dial -a-ride (DAR) service is available to the general public. In addition, the City participates in Regional DAR services with the East County Transit Alliance Intercity and West County for ADA and seniors.
Service Policies - Transit Amenities
Transit amenities that were added since the last report include: new sign holders and schedule signs replaced on the fixed route, new holders with schedule signs installed at every Trolley stop and new Trolley Bus signs posted at every stop.
Service Policies - Vehicle Assignment
The City’s 18 vehicle fleet consists of 5 minivans, 6 transit vans, 6 cutaways and 1 trolley bus. Currently, one (1) cutaway bus is used daily for the Fixed Route, (1) one trolley bus is used for the Trolley Route and 16 vehicles for DAR service s. All DAR buses are interchangeable; vehicle assignments are done in a manner that ensures rotation of fleet vehicles throughout the City’s system.
VII. Community Outreach
As an agency receiving federal financial assistance, the City has made the following community outreach efforts:
The City holds public meetings, particularly in connection with service changes. At these meetings the public is welcome to attend and share in discussion with a variety of Community Outreach discussions. The City's form of outreach may also include posters/flyers distributed at City Hall, email to stakeholders (City News), media releases, social media posts and website posts. Additionally, the City works with the other transit agencies in the service area and other stakeholder organizations to review and discuss the planning and is involved in the decision-making process.
The City submits to the California Department of Transportation and Federal Transit Administration annually an application for funding through VCTC. The application requests funding for both capital maintenance and operating assistance. Part of the annual application is a public notice, which includes a 30- day public comment period , which is performed through VCTC.
VIII. Active Investigation, Lawsuit or Complaint
To ensure compliance with 49 CFR Section 21.9(b), the City is required to prepare and maintain a list of any active investigations conducted by entities other than FTA, lawsuits, or complaints naming the City that allege discrimination on the basis of race, color, or national origin. This list shall include the date that the investigation, lawsuit, or complaint was filed; a summary of the allegation(s); the status of the investigation, lawsuit, or complaint; and actions taken by the recipient or sub- recipient in response to the investigation, lawsuit, or complaint.
The City has had no active investigations, lawsuits or complaints alleging discrimination on the basis of race, color or national origin. No transit -related Title VI investigations, complaints or Lawsuits have been made.
Public Participation Plan, Public Participation Process, Minimum Outreach Requirements, Outreach Methods to Engage Minority and Limited English Proficient Populations
The VCTC Title VI Program for Public Participation Plan, Public Participation Process, Minimum Outreach Requirements, Outreach Methods to Engage Minority and Limited English Proficient Populations adopted May 7, 2021, and any future amendments are incorporated into the City's Title VI Program and included as Appendix H.
IX. Subrecipient’s Monitoring
The City is considered a subrecipient to VCTC (primary recipient) of federal funds . In accordance with 49 CFR 21.9(b), and to ensure that subrecipients are complying with the DOT Title VI regulations, primary recipients must monitor their subrecipients for compliance with the regulations. Importantly, if a subrecipient is not in compliance with the Title VI requirements, the primary recipient is not in compliance.
The VCTC Director of Programming is responsible for all subrecipient monitoring. VCTC monitors its subrecipients by ensuring that each entity meets the criteria outlined in Chapter III of Title VI Circular 4702.1B. VCTC has collected and reviewed the subrecipients’ Title VI Programs which were approved by the subrecipients’ governing board. VCTC must also review the subrecipients’ website and confirm that their Title VI Notice complaint process and Title VI complaint forms are available to the public.
VCTC’s subrecipients must submit a copy of their Title VI Program triennially prior to the due date of VCTC’s Title VI Program submission to the FTA. VCTC staff monitors the submissions.
Each VCTC subrecipient Title VI Program includes the following:
1. A copy of the Title VI notice to the public that indicates the subrecipients’ compliance with Title VI and informs members of the public of the protections against discrimination afforded to them by Title VI.
2. A copy of the subrecipients’ instructions to the public explaining how to file Title VI discrimination complaints, including a copy of the complaint form.
3. A list of any public transportation- related Title VI investigations, complaints, or lawsuits filed with the subrecipient. The list only contains investigations, complaints, or lawsuits that pertain to allegations of discrimination on the basis of race, color, or national origin.
X. Board Demographic
City of Camarillo, Camarillo Area Transit board of directors (the City Council) consists entirely of elected members. Therefore, this [requirement to provide a table depicting membership of non-elected committees and councils] does not apply to the City.
XI. Facility Construction
No operational or maintenance facilities have been constructed. Therefore, this does not apply to the City.
XII. Resolution Approving Title VI Plan
A copy of this resolution can be found in Appendix J of this Plan. Adoption is expected on December 11, 2024.
APPENDIX A
Employee Annual Education Form
No person shall, on the grounds of race, color or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.
All employees of City of Camarillo are expected to consider, respect, and observe this policy in their daily work and duties. If a citizen approaches you with a question or complaint, direct his or her to the Public Works Management Assistant who is the Title VI Coordinator.
In all dealings with citizens, use courtesy titles (i.e., Mr., Mrs. , Ms., or Miss) to address them without regard to race, color or national origin.
APPENDIX B
Acknowledgement of Receipt of Title VI Plan
I hereby acknowledge the receipt of City of Camarillo Title VI Plan. I have read the plan and am committed to ensuring that no person is excluded from participation in or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1.B.
Signature
Print your Name
Date
APPENDIX C
TITLE VI Complaint Form
Title VI of the 1964 Civil Rights Act requires that “No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.”
The requested information will assist us in processing your complaint. Please let us know if you require any assistance in completing this form.
If you feel you have been discriminated against in transit services, please provide the following information in order to assist us in processing your complaint and send it to:
Title VI Coordinator
Public Works Management Assistant
City of Camarillo
601 Carmen Drive, Camarillo, CA 93010
Please print clearly:
1.Complaintant’s Name:
2. Address:
3.City: State: Zip Code:
4. Telephone (home) ___ (cell) _____ (work)
5. Person discriminated against: (if someone other than the complainant) Name
Address
City: State: Zip Code:
Telephone Number (home) (business)
6. Which of the following best describes the reason you believe the discrimination took place? Was it because of your: Please indicate why you believe the discrimination occurred:
a. Race/Color Yes No
b. National Origin Yes No
7. What date did the alleged discrimination take place?
8. In your own words, describe the alleged discrimination. Explain what happened and whom you believe was responsible. Please use the back of this form if additional space is required.
9. Please list any and all witnesses’ names and phone numbers:
10. Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court? Yes _____ No _____
If yes, check all that apply:
_____ Federal Agency _____ State Agency _____ Local Agency _____ Federal Court _____ State Court
11. Please provide information about a contact person at the agency/court where the complaint was filed.
Name: Title:
Agency:
Address:
Telephone Number:
Resolution No. 2021-4021
Page
15 Titulo VI Forma de Queja
El Titulo VI de los D erechos Civiles de 1964 exije que "Ninguna persona en los Estados Unidos, por motives de raza, color o origen nacional ser excluido de la participacion en, ser negado los beneficios de, o ser objeto de discriminacion bajo cualquier programa o actividad que reciba asistencia financiera federal." La informacion solicitada es necesaria para asistirnos en el procesamiento de su queja. Por favor avisenos si usted requiere ayuda en completar esta forma.
Complete y devuelva esta forma a:
Title VI Coordinator
P
ublic Works/Transportation
City of Camarillo
601 Carmen Drive, Camarillo, CA 93010
1. Nombre del reclamante:
2. Direccion
3. Ciudad Estado Codigo Postal:
4. Numero de telefono (casa) _ (negocio) _
5. Persona de discriminacion (si alguien que no sea el reclamante):
Nombre
Direccion
Ciudad Estado Codigo Postal:
Numero de telefono (casa) ( negocio) _
6. Cual de las siguientes opciones describe mejor la razón que usted cree la discriminacion ocurrio? Fue debido a su?:
c. Raza/Color: Si No
d. Origen Nacional: Si No
Que fecha ocurrio la supuesta discriminacion?
Resolution No. 2021-4021
16 7. En sus propias palabras, describa la supuesta discriminacion. Explique lo que ocurrio y a quien usted cree que fue responsable. Por favor use otra pagina (o atras de esta pagina) si se necesita mas espacio.
8. Ha presentado esta queja con cualquier otra agencia gubernamental, o con algun tribunal federal o estatal? Si No
Si la respuesta es si, marque cada caja que se aplica:
agencia federal □
tribunal estatal □
tribunal federal □
agencia local □
organismo estatal □
9. Por favor proporcione la informacion sobre una persona de contacto en la agencia o tribunal donde la queja fue presentada.
Nombre
Direccion
Ciudad Estado Codigo Postal:
Numero de telefono
10. Por favor firme abajo. Usted puede incluir cualquier material escrito o otra informacion que usted cree es pertinente a su queja.
Firma del Reclamante Fecha
12. Please sign below. You may attach any written materials or other information that you think is relevant to your complaint.
Complainant’s Signature Date
Print your Name
APPENDIX D
Sample Letter Acknowledging Receipt of Complaint
(Date)
Ms. Jo Doe
1234 Main Street
Camarillo, CA 93010
Dear Ms. Doe,
This letter is to acknowledge receipt of your complaint against the City of Camarillo/Camarillo Area Transit alleging
.
An investigation will begin shortly. If you have additional information you wish to convey or questions concerning this matter, please feel free to contact this office by telephoning or write to me at this address.
Sincerely,
Title VI Coordinator
Public Works
City of Camarillo
601 Carmen Drive
Camarillo, CA 93010
Office: 805-388-5341
APPENDIX E
Sample Letter Notifying Complainant that the Complaint Is Substantiated Today’s Date
Ms. Jo Doe
1234 Main Street
Camarillo, CA 93010
Dear Ms. Doe,
The matter referenced in your letter of (date) against City of Camarillo/ Camarillo Area Transit alleging Title VI violation has been investigated.
(An/Several) apparent violation(s) of Title VI of the Civil Rights Act of 1964, including those mentioned in your letter (was/were) identified. Efforts are underway to correct these deficiencies.
Thank you for calling this important matter to our attention. You were extremely helpful during our review of the program . (If a hearing is requested, the following sentence may be appropriate.) You may be hearing from this office, or from federal authorities, if your services should be needed during the administrative hearing process.
Sincerely,
Title VI Coordinator
Public Works
City of Camarillo
601 Carmen Drive
Camarillo, CA 93010
(805) 388-5341
APPENDIX F
Sample Letter Notifying Complainant that the Complaint Is Not Substantiated
Today’s Date
Ms. Jo Doe
1234 Main Street
Camarillo, CA 93010
Dear Ms. Doe,
The matter referenced in your complaint of __ (date) against City of Camarillo/ Camarillo Area Transit (City) alleging has been
investigated.
The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights Act of 1964, had in fact been violated. As you know, Title VI prohibits discrimination based on race, color, or national origin in any program receiving f ederal financial assistance.
The City has analyzed the materials and facts pertaining to your case for evidence of the agency’s failure to comply with any of the civil rights laws. There was no evidence found that any of these laws have been violated.
I therefore advise you that your complaint has not been substantiated, and that I am closing this matter in our files.
You have the right to 1) appeal within seven calendar days of receipt of this final written decision from the City, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration at Federal Transit Administration Office of Civil Rights Attention: Title VI Program Coordinator East Building, 5 th Floor - TCR
1200 New Jersey Avenue, SE Washington, DC 20590.
Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not hesitate to call me.
Sincerely,
Title VI Coordinator
Public Works
City of Camarillo
601 Carmen Drive
Camarillo, CA 93010
(805) 388-5341
APPENDIX G
TITLE VI INFORMATION
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that “no person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance” (42 U.S.C. Section 2000d).
The City is committed to ensuring that no person is excluded from participation in or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1. B. If you feel you are being denied participation in or being denied benefits of the transit services provided by the City, or otherwise being discriminated against because of your race, color, national origin, gender, age, or disability, you may contact our office at:
Title VI Coordinator
Public Works
City of Camarillo
601 Carmen Drive
Camarillo, CA 93010
For more information, visit our website www.cityofcamarillo.org
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.
INFORME SOBRE EL TITULO VI
El Titulo VI de la Ley de los Derechos Civiles de 1964 prohibe la discriminacion sobre la base de raza, color o nacionalidad en programas y actividades que reciben ayuda financiera Federal. Especificamente, el Titulo VI establece que esta prohibido que “ninguna persona en los Estados Unidos debera ser excluida a participar ya sea por su raza, color o nacionalidad y sea negada a recibir beneficios o sea sujeta a discriminacion por ningun programa o actividad que este recibiendo asistancia financiera Federal” (42 U.S.C. Section 2000d).
La Ciudad de Camarillo Transporte Publico esta comprometido a asegurar que ninguna persona sea excluida para participar o sea negado de los beneficios de servicio de transporte public y sea sujeta a discriminacion ya sea por su raza, nacionalidad, y esta protegido por el Titulo VI en la Administracion de la Trasportacion Federal (FTA) Circular 4702.1.B. Si usted siente que le han negado participar o le han negado los beneficios del servicio del transporte public que la ciudad esta proporcionando o esta siendo discriminado por su raza, color, nacionalidad, genero, edad y si esta incapacitado, usted puede comunicarse con nuestras oficinas.
Title VI Coordinator
Public Works
City of Camarillo
601 Carmen Drive
Camarillo, CA 93010
Para mas informacion, visite nuestra pagina www.cityofcamarillo.org Las quejas pueden ser sometidas directamente a las oficinas Federal Transit Administration Administracion de Transporte Federal) mande la queja a las oficinas de los Derechos Civiles (Civil Rights), Attencion: Title VI Program Coordinator, East Building, 5th Floor -TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.
Public Participation Plan
Purposes of This Plan
This Public Participation Plan was created during the development of VCTC ’s Title VI Program. This plan includes strategies for VCTC’s outreach and participation activities. Of particular importance, this plan includes enhancing strategies for engaging minority and Limited English Proficient (LEP) individuals in VCTC’s transportation-related planning efforts to ensure that all groups are represented, and their needs considered.
VCTC serves the c ounty of Ventura consistently and in the most cost-efficient and appropriate manner. Through conversation and collaboration with riders, prospective riders, and the larger community, VCTC assess es the quality of its service, measure s potential impacts to the commu nity from VCTC’s transportat ion-related initiatives or proposed initiatives, and ensure s that it is providing a valuable and accessible service.
Public Participation Process
Approach to Public Participation
The public participation process should be considered at the earliest stage s of any transit project that may impact the community, transit riders, and potential transit riders. The public participation process and extent of pu blic participation varies for each projec t. The following sections outline tools and strategies to ensure that public input is invited and all foreseeable impacts to the community are considered.
At the beginning of a project, staff will identify appropriate and effective strategies and develop an approach. For contracted project s, the Request for Proposal (RFP) requirements and criteria for scoring proposals will include the development of that project’s Public Participation Process.
Outreach Requirements and Activities
The following activities are intended to serve as guidelines for minimum levels of outreach to ensure that all resident s, transit riders , and potential transit riders have equal access and opportunity to participate in transportation planning and decisio n-making. These also provide strategies for soliciting input and engaging various communities , including racial minorities and LEP individuals .
Minimum Outreach Requirements
1. Notices for public events may include posters, email blasts to agency-level stakeholders, media releases to local papers, slides for City TV stations, social media posting, or radio announcements if funding allows.
2. Notices will be posted one week prior to the event.
Ventura County Transportation Commission
Title VI Update
______________________________________________________________________________________________________________
Appendix H
3. Notices will be posted at the VCTC offices, on buses, and major transfer points or stations along affected routes.
4. Notices will be posted on www.goventura.org and may include other online tools such as mobile apps, GTFS Realtime Alerts and other real -time information public systems.
5. Comments will be accepted at public events, by mail, by email, and by phone.
Outreach Methods to Engage Minority and Limited English Proficient Populations
1. VCTC wi ll produce its transit schedules in English and Spanish .
2. VCTC will develop and post notices in English and Spanish.
3. VCTC will c ultivate relationships with c ommunity groups and agencies that serve LEP populations.
4. VCTC will distribute event information to community groups and agencies that work with LEP populations.
5. VCTC will employ bilingual staff who can translate f or LEP individuals tha t speak Spanish.
6. VCTC will ensure that non -English language interpretation is available at public transit meeting s or workshop.
7. VCTC will attend existing community meetings and activities to invite participation from LEP populations who may not attend VCTC hosted public meetings VCTC annually hold s transit listening sessions in the evenings in the Heritage Valley, the cit ies of Moo rpark , Camarillo and Thousand Oaks to receive input from the se communities, in addition to meeting s held at the VCTC meeting site in Camarillo. The Heritage Valley and the City of Oxnard are the two areas in the county with substantial minority and Spanish speaking populations. Bilingual staff participates at all transit related public meetings, and a n announcement is made in Spanish as well as English regarding the availability of staff to translate or interpret for the LEP attendees.
When VCTC considers fare changes, it takes several actions including :
• Issuing press releases to all media outlets in E nglish and Spanish • Advertising in English and Spanish publications
• Survey ing riders in English and Spanish
• Mak ing staff available to community groups and schools Transit staff works with the community groups who represent and coordinate the low -income communities, including CAUSE, and more traditional organizations such as the County Human Services Authority and the Area Agency on Aging
As discussed in the Language Assistance Plan (Table 2 on page 17), 39% of people five years or older in Ventura County speak a language at home other than English. Spanish is the most common language spoken by those who do not speak English very well with 31% of the population speaking Spanish. Twelve percent of the population speaks Spanish at home and ‘Speak English less than “very well ”’.
Ventura County Transportation Commission
Title VI Update
______________________________________________________________________________________________________________
The Sa fe Harbor Provision of Ti tle VI covers languages spoken by over 5% of the popul ation (about 40, 000 people) or 1,000 individuals, whi chever is less. A "safe harbor" means that if a recipient provides written translations for these emerging languages, it will be considered strong evidence of compliance with the recipient's written-translation obligations. The re are fi ve emerging language groups in Ventura County that fall under the Sa fe Harbor Provision. They are Tagalog, spoken by 3,543 individuals (0.4% of the popul ation) , Chinese, spoken by 3, 521 i ndividuals (0.4%) and Kor ean, spoken by 1,556 individuals (0.2%), Vietnamese, spoken by 1,969 individuals (0.3%) and Punjabi, spoken by 992 individuals ( 0.1%).
Ventura County Transportation Commission
Title VI Update
______________________________________________________________________________________________________________
Language Assistance Plan
This Language Assistance Plan was developed during the process of preparing the VCTC Title VI Program to ensure that VCTC services are accessible to Limited English Proficient (LEP) individuals. LEP is defined as having a limited ability to read, write, speak or understand English. In compliance with regulations from the U.S. Department of Transportation, and to avoid discrimination against LEP persons on the grounds of national origin, VCTC will take reasonable steps to ensure that all persons have meaningful access to its programs, services, and information, free of charge.
The plan has been prepared in accordance with:
• Title VI of the Civil Rights Act of 1964, Federal Transit Administration Circular 4702.1B dated October 1, 2012, which prohibits discrimination against individuals based on race, color, and national origin and includes meaningful access to LEP customers.
• Executive Order 13166, titled “Improving Access to Services for Persons with Limited English Proficiency (August 2000)”, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin ’s discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to VCTC as both a recipient of Federal transit funds and as a programming agency responsible to distribute Federal transit funds to the different public and private transportation providers in this region.
VCTC’s Title VI Program was prepared in May 2021 in accordance with FTA Circular 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, October 1, 2012. VCTC Title VI Program Administrator is:
Peter De Haan, Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive #420
Camarillo, CA 93010
805.642.1591
Email: [email protected]
More information about Ventura County Transportation Commission’s Title VI Program is available at:
https://www.goventura.org/vctc-transit/riding-vctc/
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Overview of VCTC
VCTC has evolved to administer and act as:
▪ Regional Transportation Planning Agency (RTPA). VCTC is responsible for multi-modal transportation planning, programming, and fund allocation, as required by the state statutes.
This includes the annual allocation of Transportation Development Act funds, as well as all federal and local funds for highway, transit, rail, bicycle and other transportation projects. ▪ Congestion Management Agency (CMA). The Cities and County have designated VCTC as the CMA for Ventura County. In this capacity, VCTC is responsible for the development and implementation of the countywide Congestion Management System (CMS) required in all urban counties. In the past, the State of California and the federal government required the CMA to prepare a Congestion Management Program (CMP), which provides local agencies and private developers the procedures and tools necessary to manage and decrease traffic congestion in the County. Although this is no longer a state-level requirement, VCTC continues to update and monitor its CMP.
▪ Consolidated Transportation Services Agency (CTSA). VCTC is the state mandated facilitator charged with the development and implementation of regional coordination of transit and paratransit services and improvement of social service transportation to seniors, persons with disabilities, the young and the low-income disadvantaged. ▪ Airport Land Use Commission (ALUC). In this capacity, VCTC is responsible under state law to protect public health, safety, and welfare by ensuring that vacant lands in the vicinity of airports are planned and zoned for uses compatible with airport operations. ▪ Ventura County Service Authority for Freeway Emergencies (SAFE). As the SAFE, VCTC is responsible for the installation, operation, and administration of the system of roadside call boxes in Ventura County that is financed by a $1.00 per year fee on all motor vehicles registered within the county.
▪ County Transportation Commission (CTC). As the CTC, VCTC leverages state and federal transportation dollars and provides assistance during project implementation. VCTC’s responsibilities include preparing the State Transportation Improvement Program (STIP) for submittal to the State, participation in the AB1246 Committee, performing short-range capital and service planning, and preparing long-range expenditure plans for transportation programs in the county.
▪ County Transportation Authority (CTA). VCTC was designated the CTA per California Public Utilities Code 130050.1. In the role as the CTA, VCTC determines the preferred method and distribution of sales tax revenue for transportation improvements, when applicable. ▪ VCTC Intercity. VCTC provides intercity bus service connecting the cities within Ventura county and between neighboring Santa Barbara and Los Angeles counties. With a fleet of 36 over-the- road coach buses, VCTC Intercity operates 1.5 million revenue miles and carries 650,000 passengers annually.1. The cities served are Camarillo, Fillmore, Moorpark, Oxnard, Santa Paula, Simi Valley, Thousand Oaks, and Ventura.
▪ Valley Express Transit Service. VCTC manages and administers the Valley Express Transit Service, which serves the Heritage Valley including Santa Paula, Fillmore and Piru.
1 Pre-Coronavirus numbers from Fiscal Year 2018-19
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The County of Ventura, which VCTC serves, includes a population of about 850,000 persons residing in over 1,845 square miles of land. The county’s make-up ranges from urban and suburban cities to rural towns and farming communities and varies significantly between the eastern and western portions of the county.
Language Assistance Goals
VCTC’s goal is to provide meaningful access for LEP current and potential customers of VCTC services, information and materials by developing a Language Assistance Plan and by regular evaluation of its method and strategies.
Results of the Four Factor Analysis
In order to prepare this plan, VCTC undertook the U.S. Department of Transportation (U.S. DOT) four- factor LEP analysis which considers the following:
Factor 1 - The number or proportion of LEP persons to be served or likely to be encountered in a VCTC program, activity or service.
Factor 2 - The frequency with which LEP persons come in contact with VCTC programs, activities, or services.
Factor 3 - The nature and importance of programs, activities or services provided by VCTC to the LEP population.
Factor 4 - The resources available to VCTC and overall cost to provide LEP assistance.
A summary of the results of the VCTC four-factor analysis is below.
Factor 1: The number or proportion of LEP persons to be served or likely to be encountere d in a VCTC program, activity , or service.
VCTC used American Community Survey (American Community Survey, 2019) and California’s Department of Education (Attachment B) data to identify LEP populations within its service area. The American Community Survey2 provides information on the number of people who ‘Speak English less than “very well”’ also referred to as Limited English Proficient persons. The California Department of Education data compares student ‘English Learners’ populations with ‘Fluent English Proficiency’ populations to determine the number or proportion of LEP persons to be served or likely to be encountered in a VCTC program, activity, or service.
According to the 2019 survey results approximately 39% of the Ventura County population speak a language at home other than English with Spanish being the most common language spoken by those
2 United States Census Bureau , American Communities Survey (ACS ) – https://www.census.gov/programs -surveys/acs Ventura County Transportation Commission
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who ‘Speak English “less than very well”’ (30.4%) (Table 1).
Table 2 shows the languages spoken at home by ability to speak English for persons five years of age and older. Of the 30.4% of the population that speak Spanish, 11.7% ‘Speak English “less than very well”’.
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As mentioned above, VCTC also used data from the California’s Department of Education to identify LEP populations within its service area. The California Department of Education’s survey provides an additional source of data to identify possible LEP populations. While the State’s school data has its shortcomings -- missing households and individuals without school age children; double counting households with two or more children in the schools; and in some cases, missing households where the school children are fluent in English, but other members of the household are not-- it does provide valuable information about minority and immigrant populations.
Looking at the county totals based on data from the California Department of Education’s annual census of students, the most frequently spoken language other than English is Spanish. Ventura County’s 2019 – 2020 school year data show a student population of 135,312. The number of Spanish speaking English Learners is 25,592 (18.9 percent of the total school population). The next largest groups of non-English speakers were Mixteco (which may not have an accepted written form), 939 (0.7%); Filipino, 223 (0.2%); Arabic, 172 (0.13%); and Vietnamese, 158 (0.12%).
Given the very low percentages of people who ‘Speak English less than “very well” other than Spanish language speakers, and the fact that that in the past 18 years, VCTC has reported no phone calls, office walk-ins, or written requests for languages other than English or Spanish, at this time there are no plans to expand the printed materials beyond those two languages. VCTC added Google Translate to its web site to allow visitors to read translations of its web pages. The translation of individual documents will be provided upon request.
Factor 2: The frequency with which LEP persons come in contact with VCTC programs, activities or services.
VCTC works with local advocacy groups such as Central Coast Alliance United for a Sustainable Economy (CAUSE) and One Step A La Vez to inform LEP populations.
Although Title VI regulations for LEP individuals cover only written materials, a Spanish interpreter is available at the annual Unmet Transit Needs community meetings, virtual meetings, and Public Hearings. VCTC’s Regional Transit Information Center (RTIC) employs bilingual staff to field transit- related phone calls within Ventura County. The majority of calls received are in English and 11% of calls received are in Spanish.
VCTC Intercity (contracted with RATP Dev.) dispatch and the Valley Express Bus & Dial-A-Ride (contracted with MV Transportation) reservation center have bilingual staff members. For RATP Dev, Sixty-seven percent (67%) of the drivers, 100% of the dispatchers, and 75% of management are bilingual speaking Spanish, Iranian, and Indian. Valley Express Bus & Dial-A-Ride operates in non-urban portions of the Santa Clara River Valley. The breakdown of Spanish speaking staff: drivers (50%), dispatchers (80%), and management (66.6%).
VCTC prints vital materials in English and Spanish including but not limited to: ADA applications, notices of denial, and complaint forms; photo/media consent forms; rider alerts of decreased service; surveys; and the Unmet Transit Needs process information.
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Vital written documents include, but are not limited to, consent and complaint forms; intake and application forms with the potential for important consequences; written notices of rights; notices of denials, losses, or decreases in benefits or services; and notices advising LEP individuals of free language assistance services. Examples of vital documents include an ADA complementary paratransit eligibility application, a Title VI complaint form, notice of a person’s rights under Title VI, and other documents that provide access to essential services. Failure to translate these vital documents could result in a recipient denying an eligible LEP person access to services and discrimination on the basis of national origin.
The frequency that LEP persons encounter VCTC Intercity transit programs, activities, or services varies by individual circumstances. A very small proportion of the population uses regional or local transit services. According to the American Community Survey 2019 estimates, only about one percent of ‘Workers 16 years or over' use public transportation as a means for workplace travel. Transit is used by people to access medical facilities, shopping centers, educational facilities, government resources, homeless shelters, to visit friends and family however, the number of transit users is still relatively small.
Factor 3: The nature and importance of programs, activities , or services provide d by VCTC to the LEP population .
VCTC understands that its services are used for transportation to work, school, shopping, medical appointments and other quality-of-life activities. For transit-dependent individuals, VCTC transit services are extremely important. For this reason, VCTC is committed to translating vital documents relating to its service. Vital documents are those that demonstrate where and how to use VCTC Intercity bus, how to access services and additional information, and information about VCTC’s Title VI program. At this time VCTC does not have the funds required to translate all written materials -- such an undertaking would incur substantial costs and require substantial resources.
In addition, VCTC will continue to offer language interpretation at public meetings when requested.
Providing interpretation services to allow LEP populations to participate by obtaining information about VCTC services has been a core activity at VCTC since its creation.
Factor 4: The resources available to VCTC and overall cost to provide LEP assistance.
As VCTC serves a vast area, outreach is varied and event specific. VCTC Public Participation Plans for various projects lay out the types of public outreach activities that will be undertaken for the various Ventura County Transportation Commission
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levels of public events. VCTC will continue working with local advocacy groups like CAUSE to ensure contact with LEP populations; there is little to no cost to the agency to do this although it does take time.
Implementation Plan
Language Assistance Measures
VCTC will continue to use a variety of techniques or practices to provide meaningful, early and continuous opportunities for all interested Ventura County residents to participate in the dialogue that informs key decisions, regardless of language barriers. This is done in a number of ways, including:
General Measures or Practices
• Review prior experiences with LEP populations to determine the language services needed. • Robust use of maps, charts, and photographs to illustrate trends, choices being debated, etc. • Translate to Spanish various printed materials for the transit services provided by VCTC including but not limited to VCTC Intercity services; Valley Express Bus & Dial-A-Ride services; fare media and other farebox information; transit seat drops; freeway call box information; ADA certification materials and services; community outreach event notices; and regional Rideshare materials.
• Work to involve non-profit groups that advocate for persons with limited English proficiency. • Identify areas within the service area with high concentrations of LEP individuals. • Include LEP populations in transit rider surveys.
• Translation of vital documents including certain news releases, brochures, fact sheets and Unmet Transit Needs notices.
• All translated documents will be posted onto the VCTC website. • Ensure competency of translators; have interpreters available, if requested 3 days in advance (72 hours) at meetings.
• Employ multi-lingual staff at the VCTC Regional Transit Information Center. • Encourage multi-lingual transit dispatch staff and transit operators (as of March 2021):
• Valley Express: 50% of the drivers and 80% of the dispatchers and are bilingual in English and Spanish.
• VCTC Intercity: 67% of the drivers are bilingual -- Spanish (67%) and Iranian (3%). All VCTC Intercity dispatchers speak Spanish and English.
Local Community Media
• Work with Spanish language media outlets to place articles about VCTC's work or announce participation opportunities.
• Purchase display ads in Spanish language community newspapers to announce public hearings.
Outreach Techniques
When staff prepares a document or schedules a meeting for which the target audience is expected to Ventura County Transportation Commission
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include LEP individuals then documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population. Interpreters may be available as needed.
VCTC will continue to develop relationships with organizations that serve LEP individuals.
Monitoring and Updating of the L anguage Assistance Plan (LAP) VCTC will monitor requests for translations and adjust practices to meet demand while maintaining a basic level of access by LEP populations to key programs and documents. VCTC's Language Assistance Plan (LAP) will be updated periodically as required by U.S. DOT and as needed to reflect significant changes. At minimum, the plan will be reviewed and updated when data from new ACS counts are available, or when it is clear that higher concentrations of LEP individuals are present in Ventura County. Updates will include the following:
• How the needs of LEP persons have been addressed.
• Determination of the current LEP population in the service area per the latest Census reports at the community level.
• Determination as to whether the need for translation services has changed or whether a change in the contractor used for translation services is warranted based on geographical proximity or availability at times needed.
• Determine whether VCTC ’s financial resources are sufficient to fund bilingual or multi-lingual language assistance resources needed.
• Determine whether VCTC has fully complied with the goals of this LAP Plan. • Determine whether complaints have been received concerning VCTC ’s failure to meet the needs of LEP individuals.
• Regularly assess the effectiveness of how VCTC communicates with LEP individuals through use of surveys, conversations with advocacy groups etc.
Staff Training
VCTC works to instill its staff with an awareness of and sensitivity to the needs of LEP residents. The following training will be provided to VCTC staff:
1. Information on the VCTC Title VI Procedures and LEP responsibilities.
2. Description of language assistance services offered to the public.
3. Documentation of language assistance requests
4. How to handle a potential Title VI/LEP complaint
Dissemination of the VCTC L anguage Assistance Plan
A link to the VCTC L AP and the Title VI Procedures is included on the VCTC website at https://www.goventura.org/vctc -transit/riding-vctc/#title-vi Any person or agency may request a copy of the plan via telephone, fax, mail, e-mail or in person and shall be provided a copy of the plan at no cost. LEP individuals may also request translated copies of Ventura County Transportation Commission
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the plan.
Questions or comments regarding the LAP may be submitted to the Ventura County Transportation Commission, Title VI Coordinator:
Attn: Peter De Haan, Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive #420
Camarillo, CA 93010
Office: 805.642.1591
Email: [email protected]
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TITLE VI PROGRAM UPDATE
VENTURA COUNTY TRANSPORTATION COMMISSION
August 1, 2024 – July 31, 2027
ATTACHMENT B
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TABLE OF CONTENTS
INTRODUCTION ___________________________________________________________ 3 VCTC’S VISION STATEMENT ____________________________________________________________ 3 VCTC’S MISSION STATEMENT __________________________________________________________ 3 TITLE VI OF THE CIVIL RIGHTS ACT OF 1964 ______________________________________________ 3 AGENCY OVERVIEW ___________________________________________________________________ 4 GENERAL REQUIREMENTS _________________________________________________ 5 CIVIL RIGHTS NOTICE TO THE PUBLIC __________________________________________________ 5 COMPLAINT PROCEDURES AND COMPLAINT FORMS ____________________________________ 6 TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS _______________________________ 14 PUBLIC PARTICIPATION PLAN _________________________________________________________ 14 LANGUAGE ASSISTANCE PLAN ________________________________________________________ 17 MEMBERSHIP OF NON-ELECTED COMMITTEES & COUNCILS ____________________________ 32 MONITORING SUBRECIPIENTS AND CONTRACTORS ____________________________________ 33 FIXED FACILITY IMPACT ANALYSIS _____________________________________________________ 34 GOVERNING BODY APPROVAL OF TITLE VI PLAN ________________________________________ 34 PROGRAM SPECIFIC REQUIREMENTS ______________________________________ 35 SYSTEM-WIDE SERVICE STANDARDS __________________________________________________ 35 SYSTEM-WIDE SERVICE POLICIES _____________________________________________________ 36 ATTACHMENT A __________________________________________________________ 38
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INTRODUCTION
This VCTC Title VI Program Report provides policies, procedures, and data analysis to comply with guidelines issued by the Federal Transit Administration of the US Department of Transportation to implement Title VI of the 1964 Civil Rights Act regarding transit services and related benefits. The purpose of Title VI is to “assure that no person shall on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.”
Since 1972, the FTA has required applicants for and recipients of Federal assistance to provide assessments of compliance as part of the grant approval process. The FTA has the responsibility to ensure that federally supported transit services and related benefits are distributed in a manner consistent with Title VI including as related to Environmental Justice and access for individuals who have Limited English Proficiency (LEP). This update conforms to the FTA’s Title VI Circular 4702.1B, effective October 2012.
As a federal grant recipient, VCTC is required to maintain and provide to FTA information on its compliance with the Title VI regulations. VCTC is required to perform a self-assessment every three years and to document that service and benefits are provided in a non-discriminatory manner. This Program Update will be for the period of August 1, 2024, through July 31, 2027.
Any questions regarding this Title VI Program Update can be directed to the Peter DeHaan, Director of Programming at [email protected]
or at (805) 642-1591.
VCTC’S VISION STATEMENT
To Keep Ventura County moving.
VCTC’S MISSION STATEMENT
To create a more connected, resilient, equitable and user-friendly transportation system for Ventura County.
TITLE VI OF THE CIVIL RIGHTS ACT OF 1964
Title VI of the Civil Rights Act of 1964 protects people from discrimination based on race, color, and national origin in programs and activities receiving federal financial assistance. The Federal Transit Administration works to ensure nondiscriminatory transportation in support of its mission to enhance the social and economic quality of life for all Americans. The FTA Office of Civil Rights is responsible for monitoring FTA recipients’ Title VI programs and ensuring their compliance with Title VI requirements.
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AGENCY OVERVIEW
The Ventura County Transportation Commission (VCTC) is the regional transportation planning agency responsible for transportation planning efforts in Ventura County. Access to convenient, safe, and affordable multimodal transportation options is a crucial element in maintaining the quality of life for residents, visitors, and the public. The transportation network allows people to access opportunities related to employment, education, shopping, medical, social and recreation. Ensuring the ongoing efficient and effective operation of this network is central to VCTC’s mission to provide accessibility and equity to all.
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GENERAL REQUIREMENTS
This section addresses the General Requirements as described under Chapter III of FTA Circular 4702.1B, dated October 1, 2012. The information is required under U.S. Department of Transportation (DOT) regulations of all Federal Transit Administration (FTA) grantees on a triennial basis.
CIVIL RIGHTS NOTICE TO THE PUBLIC
The Ventura County Transportation Commission (VCTC) is committed to ensuring that the public is aware of the rights and protections afforded to them under Title VI. In accordance with Title 49 CFR Section 21.9(d) and guidance provided in FTA Circular 4702.1B, VCTC’s Civil Rights Policy includes:
• A statement that VCTC operates programs without regard to race, color, or national origin;
• A description of procedures that the public should follow to request additional information regarding VCTC’s Title VI obligations;
• A description of the procedures that the public needs to follow in order to file a Title VI discrimination complaint.
LIST OF LOCATIONS WHERE TITLE VI PUBLIC NOTICE IS POSTED The Ventura County Transportation Commission (VCTC) Title VI notice to the public is currently posted by the VCTC Transit Operations staff at the following locations:
• VCTC, Main Office, 751 E. Daily Dr. #420, Camarillo, CA 93010 • VCTC Intercity, schedule brochures
• Valley Express Bus & Dial-A-Ride, schedule brochures
• On-board all VCTC and Valley Express revenue service fleet vehicles VCTC’s Title VI Policy can be found on VCTC’s website at: https://www.goventura.org/vctc- transit/riding-vctc/#title-vi
For additional information on VCTC’s civil rights program and procedures to file a complaint, call 1-800-438-1112, visit https://www.goventura.org/vctc-transit/riding-vctc/#title-vi or write to:
Attn: Director of Transit
Ventura County Transportation Commission
751 E. Daily Dr., Suite 420
Camarillo, CA 93010
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In addition to the Title VI Complaint process at VCTC, a complainant may file a Title VI complaint with the Federal Transit Administration (FTA), Office of Civil Rights, 1200 New Jersey Avenue, SE Washington, DC 20590.
COMPLAINT PROCEDURES AND COMPLAINT FORMS
As part of VCTC’s commitment to ensuring that no person is discriminated against based on race, color, or national origin. To ensure compliance with 49 CFR Section 21.9 (b), VCTC has developed The Civil Rights Policy which includes procedures for investigation and tracking Title VI complaints. VCTC policy is to investigate complaints that are filed in writing within 180 days from the date of the alleged discrimination in which the complainant alleges discrimination on the basis of race, color, or national origin. Each complaint alleging discrimination based on race, color, or national origin is categorized as a Title VI complaint and investigated according to VCTC’s Title VI Complaint Procedure. Translated versions of the procedure and complaint form can be accessed by clicking the tabs located on the Title VI Program webpage.
TITLE VI POLICY
The Ventura County Transportation Commission (VCTC) is committed to ensuring that no person is excluded from participation in or denied the benefits of its services on the basis of race, color or national origin as protected by Title VI of the Civil Rights Act of 1964, as amended.
No person or group of persons will be discriminated against with regard to fares, routing, scheduling, or quality of transportation service that VCTC furnishes, on the basis of race, color, or national origin. Frequency of service, age and quality of vehicles assigned to routes, and location of routes will not be determined based on race, color or national origin.
HOW TO FILE A COMPLAINT
Any person who believes that they have, individually, or as a member of any specific class of persons, been subjected to discrimination based on their race, color, or national origin may file a Title VI complaint with VCTC. The complaint must be filed within 180 days of the date of the alleged discrimination. Written complaints may be sent to:
Ventura County Transportation Commission
Attn: Director of Transit
751 E. Daily Dr., Suite 420
Camarillo, CA 93010
Or by email to [email protected]
The “Title VI Complaint Form” is available online at
https://www.goventura.org/vctc-
transit/riding-vctc/#title-vi and s hould be used to detail the complaint, but is not mandatory.
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Complaint forms may also be obtained by calling 1- 800-438-1112. In addition to the Title VI complaint process at VCTC, a complainant may file a Title VI complaint with the Federal Transit Administration, Office of Civil Rights, 1200 New Jersey Avenue, SE, Washington, D.C. 20590.
If a complaint is made in a language other than English, VCTC staff will translate the complaint and if staff is unable to perform the translation, VCTC staff have the ability to receive translations through a contracted service, and any response, including requests for additional information and any disposition will be made in both English and the language in which the complaint was made.
HOW COMPLAINTS ARE PROCESSED BY VCTC
All complaints alleging discrimination based on race, color or national origin in a transit service or benefit provided by VCTC and sub-recipients will be recorded by the VCTC Director of Transit by updating the “List of Active Investigations, Lawsuits or Complaints”. This list shall include the date of the investigation, lawsuit, or complaint was filed; a summary of the allegation(s); the status of the investigation, lawsuit, or complaint; and actions taken by the recipient or subrecipient in response to the investigation, lawsuit, or complaint. The list shall be made available to FTA upon request and with every VCTC Title VI Program update.
If additional information is needed for assessment or investigation of the complaint, VCTC staff will contact the complainant in writing within fifteen (15) working days of receiving the complaint. Failure of the complainant to provide the requested information by the requested date may result in the administrative closure of the complaint.
VCTC staff will investigate the complaint and prepare a draft written response. If appropriate, VCTC staff may administratively close the complaint.
VCTC staff will investigate a formal Title VI complaint within thirty (30) working days of receiving the complaint. Based upon all the information received, VCTC staff will prepare a draft written response subject to review by the VCTC Executive Director.
The VCTC Executive Director will determine if the complaint may be administratively closed after the draft is written, or if a final written response is needed. If a final written response is needed, VCTC will send the response to the complainant and advise the complainant of his/her right to file a complaint externally. The complainant also will be notified of the action in writing and advised of their right to appeal the response to federal and state authorities as appropriate.
VCTC will use its best efforts to respond to a Title VI complaint within sixty (60) working days of its receipt. Please see “Attachment A” for draft letters.
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The flowchart below is provided as an overview and visual representation of the internal process for resolving customer complaints. Most complaints are captured by VCTC’s Regional Transit Information Center (RTIC) representatives who provide instructions to the public on how to reach schedules, plan a trip, property board and disembark from a transit vehicle, or purchase a bus pass. RTIC staff also inform riders about their rights and responsibilities and special equipment available.
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COMPLAINT PROCESS FLOWCHART
Complaint Received by RTIC Staff
Email | Telephone | Social Media
Complaint Received by
Transit Director
Title VI or ADA Complaint Form
(Received within 180 days of
alleged discrimination)
RTIC Staff
Forwards Complaint to
Transit Operations Manager
Transit Operations Manager
Complaint recorded to
'List of Active Investigations,
Lawsuits, or Complaints'
Transit Director and/or
Operations Manager
Request Additional Information
from Complainant if Needed
(Within 15 Working Days of
Receiving Complaint)
Transit Director and/or
Operations Manager
Investigate or Recommend to
Administratively Close due to Lack
of Additional Information from
Complainant (Within 30 Working
Days of Receiving Complaint)
Title VI Coordinator /
Programming Manager
Prepare Draft Written Response
Substantiated | Unsubstantiated |
Administratively Close
Executive Director
Administratively Close or
Approve Written Response
(Within 60 Working Days of
Receiving Complaint)
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TITLE VI COMPLAINT FORMS
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TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS
To comply with 49 CRF Section 21.9(b), VCTC maintains a list of all active complaints, investigations, and lawsuits naming VCTC, based on race, color, and/or national origin. This list includes the date of the complaint, investigation of or lawsuit; a summary of the allegations; and the status of the complaint, investigation, or lawsuit; and the actions taken in response to the complaints, investigations, and lawsuits. From May 31, 2021 to April 30, 2024, VCTC has not had any Title VI discrimination complaints filed.
PUBLIC PARTICIPATION PLAN
Pursuant to FTA Title VI regulations and FTA guidance 4702.1B, VCTC’s Public Participation Plan has been updated and assembled to capture the methods, innovations, and measurements of the agency’s commitment to exceed the prescribed requirements of the FTA Circular 4702.1B, citing VCTC’s responsibilities to Limited English Proficient (LEP) persons that are traditionally underserved, such as people with disabilities, low-income populations, minority communities, and other historically disadvantaged groups.
VCTC serves the county of Ventura consistently and in the most cost-efficient and appropriate manner. Through conversation and collaboration with riders, prospective riders, and the larger community, VCTC assesses the quality of its service, measures potential impacts to the community from VCTC’s transportation-related initiatives or proposed initiatives and ensures that it is providing a valuable and accessible service.
PUBLIC PARTICIPATION PROCESS
Approach to Public Participation
The public participation process should be considered at the earliest stages of any transit project that may impact the community, transit riders, and potential transit riders. The public participation process and extent of public participation varies for each project. The following sections outline tools and strategies to ensure that public input is invited and all foreseeable impacts to the community are considered.
At the beginning of a project, staff will identify appropriate and effective strategies and develop an approach. For contracted projects, the Request for Proposal (RFP) requirements and criteria for scoring proposals will include the development of that project’s Public Participation Process.
Outreach Requirements and Activities
The following activities are intended to serve as guidelines for minimum levels of outreach to ensure that all residents, transit riders, and potential transit riders have equal access and opportunity to participate in transit planning and decision-making activities. These also provide
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strategies for soliciting input and engaging various communities, including racial minorities and LEP individuals.
Minimum Outreach Requirements
1. Notices for public outreach events may include posters, email blasts to the public and stakeholders, media releases to local papers, social media postings, and/or radio announcements if funding allows.
2. Notices are posted one week prior to the event.
3. Notices are posted at the VCTC offices, on buses, and major transfer points or stations along affected routes.
4. Notices are posted on www.goventura.org and may include other online tools such as mobile apps, GTFS Realtime Alerts and other available real-time information public notification systems.
5. Comments are accepted in person at public events, by mail, email, social media, and phone.
Outreach Methods to Engage Minority and Limited English Proficient Populations
1. VCTC will produce its transit schedules in English and Spanish.
2. VCTC will develop and post notices in English and Spanish.
3. VCTC will cultivate relationships with community groups and agencies that serve LEP populations.
4. VCTC will distribute event information to community groups and agencies that work with LEP populations.
5. VCTC will employ bilingual staff who can translate for LEP individuals that speak Spanish.
6. VCTC will ensure that non-English language interpretation is available at public transit meetings or workshop.
7. VCTC will attend existing community meetings and activities to invite participation from LEP populations who may not attend VCTC hosted public meetings.
VCTC annually holds transit listening sessions as part of its Unmet Transit Needs process in the evenings in the Heritage Valley and in the cities of Moorpark, Camarillo, and Thousand Oaks to receive input from these communities, in addition to meetings held at the VCTC meeting site in Camarillo. The Heritage Valley and the City of Oxnard are the two areas in the county with substantial minority and Spanish speaking populations. Bilingual staff participates at all transit related public meetings, and an announcement is made in Spanish as well as English regarding the availability of staff to translate or interpret for the LEP attendees.
When VCTC considers fare changes, it takes several actions including:
• Issuing press releases to all media outlets in English and Spanish
pg. 16
• Advertising in English and Spanish publications
• Surveying riders in English and Spanish
• Making staff available to community groups and schools
Transit staff works with the community groups and Neighborhood Community Councils who represent and coordinate the low-income communities, including CAUSE, and more traditional organizations such as the County Human Services Authority and the Area Agency on Aging.
SUMMARY OF OUTREACH EFFORTS
Recurring Outreach Efforts
Unmet Transit Needs – VCTC is required by State statute to conduct a Public Hearing to solicit information on transit needs each year. The annual Unmet Transit Needs survey and comment period is held from mid-December to mid-February, with community meetings generally held in January and the public hearing held on the first Friday in February. VCTC takes comments year- round and greatly encourages feedback from the public to determine if additional areas need to be served by public transit in cities with populations less of less than 100,000.
Recent Project-Related Outreach Efforts
College Ride Free – Purpose of this outreach is to bring awareness to free public transit bus rides for college students in Ventura County as part of the Low Carbon Transit Operations Program (LCTOP).
Youth Ride Free – Purpose of this outreach is to bring awareness to free rides for youth 18 and under and those over 18 enrolled in high school to ride any public transit bus in Ventura County as part of the Low Carbon Transit Operations Program (LCTOP) program.
Free Fare Days – Purpose of this outreach is to bring awareness to free rides for anyone to ride any public transit bus service within Ventura County on select days as part of the Low Carbon Transit Operations Program (LCTOP) program.
Summary Overview of Major Outreach Efforts Made Since 2021 2021
Comprehensive Transportation Plan (CTP) –Between Summer 2021 and Winter 2022, VCTC staff solicited feedback from hundreds of community members for their thoughts on the future of transportation between Summer 2021 and Winter 2022. The CTP was guided by input received from the community and project stakeholders. There were two online surveys that were made available in English and Spanish during the project. Additionally, members of the project also visited community events to connect with community members to get feedback.
pg. 17
Coordinated Public Transit-Human Services Transportation Plan (2022 Update) – The project team conducted outreach between July 2021 and May 2022 using a variety of engagement methods including interviews, affinity group discussions, and surveys to address potential barriers to public transportation.
2022
Ventura County Fair – The purpose of this outreach activity was to showcase VCTC’s services and engage with potential customers face-to-face. By having presence at events like this, VCTC increased brand awareness through brochures, digital advertisements, and organic social media posts.
2023
Transit Integration and Efficiency Study (TIES) – Conducted an online survey to solicit input from the general public about the potential for the TIES study to affect their use of or interest in transit. The survey was targeted to all residents, students, or workers in Ventura County, whether they used transit or not.
VCTC Intercity and Valley Express Rider Survey – VCTC conducted on-board rider surveys to compile passenger information regarding fare payment methods, travel patterns, and customer satisfaction as well as demographic information in support of federal Title VI requirements.
2024 | Plans and Studies in Progress
Short Range Transit Plan (SRTP) – Conducted transit bus onboard and online surveys to solicit feedback to better help VCTC and local bus operators understand the community’s priorities and preferences for public transportation services across the County.
LANGUAGE ASSISTANCE PLAN
This Language Assistance Plan was developed during the process of preparing the VCTC Title VI Program to ensure that VCTC services are accessible to Limited English Proficient (LEP) individuals. LEP is defined as having a limited ability to read, write, speak, or understand English.
In compliance with regulations from the U.S. Department of Transportation, and to avoid discrimination against LEP persons on the grounds of national origin, VCTC will take steps to ensure that all persons have meaningful access to its programs, services, and information.
The plan has been prepared in accordance with:
• Title VI of the Civil Rights Act of 1964, Federal Transit Administration Circular 4702.1B dated October 1, 2012, which prohibits discrimination against individuals based on race, color, and national origin and includes meaningful access to LEP customers.
pg. 18
• Executive Order 13166, titled “Improving Access to Services for Persons with Limited English Proficiency (August 2000)” , indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to VCTC as both a recipient of Federal transit funds and as a programming agency responsible for distributing Federal transit funds to the different public and private transportation providers in this region.
VCTC’s Title VI Program was prepared in May 2024 in accordance with FTA Circular 4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, October 1, 2012. VCTC’s Title VI Program Administrator is:
Peter De Haan, Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive #420 Camarillo, CA 93010
805.642.1591
Email: [email protected]
More information about Ventura County Transportation Commission’s Title VI Program is available at https://www.goventura.org/vctc-transit/riding-vctc/#title-vi.
OVERVIEW OF VCTC
VCTC has evolved to administer and act as the:
• Regional Transportation Planning Agency (RTPA) – VCTC is responsible for multi-modal transportation planning, programming, and fund allocation, as required by the state statutes. This includes the annual allocation of Transportation Development Act funds, as well as all federal and local funds for highway, transit, rail, bicycle and other transportation projects.
• Congestion Management Agency (CMA) – The Cities and County have designated VCTC as the CMA for Ventura County. In this capacity, VCTC is responsible for the development and implementation of the countywide Congestion Management System (CMS) required in all urban counties. In the past, the State of California and the federal government required the CMA to prepare a Congestion Management Program (CMP), which provides local agencies and private developers the procedures and tools necessary to manage and decrease traffic congestion in the County. Although this is no longer a state-level requirement, VCTC continues to update and monitor its CMP. • Consolidated Transportation Services Agency (CTSA) – VCTC is the state mandated facilitator charged with the development and implementation of regional coordination of
pg. 19
transit and paratransit services and improvement of social service transportation to seniors, persons with disabilities, the young and the low-income disadvantaged. • Airport Land Use Commission (ALUC) – In this capacity, VCTC is responsible under state law to protect public health, safety, and welfare by ensuring that vacant lands in the vicinity of airports are planned and zoned for uses compatible with airport operations. • Ventura County Service Authority for Freeway Emergencies (SAFE) – As the SAFE, VCTC is responsible for the installation, operation, and administration of the system of roadside call boxes in Ventura County that is financed by a $1.00 per year fee on all motor vehicles registered within the county.
• County Transportation Commission (CTC) – As the CTC, VCTC leverages state and federal transportation dollars and provides assistance during project implementation.
VCTC’s responsibilities include preparing the State Transportation Improvement Program (STIP) for submittal to the State, participation in the AB1246 Committee, performing short-range capital and service planning, and preparing long-range expenditure plans for transportation programs in the county.
• County Transportation Authority (CTA) – VCTC was designated the CTA per California Public Utilities Code 130050.1. In the role as the CTA, VCTC determines the preferred method and distribution of sales tax revenue for transportation improvements, when applicable.
• VCTC Intercity – VCTC provides intercity bus service connecting the cities within Ventura county and between neighboring Santa Barbara and Los Angeles counties. With a fleet of 36 over-the-road coach buses, VCTC Intercity operates 1.5 million revenue miles and carries 650,000 passengers annually. The cities served are Camarillo, Fillmore, Moorpark, Oxnard, Santa Paula, Simi Valley, Thousand Oaks, and Ventura. • Valley Express Transit Service – VCTC manages and administers the Valley Express Transit Service, which serves the Heritage Valley including Santa Paula, Fillmore and Piru.
The County of Ventura, which VCTC serves, includes a population of about 842,009 1 persons
residing in over 1,845 square miles of land. The county’s make-up ranges from urban and suburban cities to rural towns and farming communities and varies significantly between the eastern and western portions of the county.
1 U.S. Census Bureau – American Community Survey 5-Year Estimates Data Profiles
pg. 20
LANGUAGE ASSISTANCE GOALS
VCTC’s goal is to provide meaningful access for current and potential LEP customers of VCTC services, information and materials by developing a Language Assistance Plan (LAP) and by regular evaluation of its method and strategies.
RESULTS OF THE FOUR FACTOR ANALYSIS
Title VI of the Civil Rights Act of 1964, Federal Executive Order 13166 and the U.S. Department of Transportation's (U.S. DOT) Limited English Proficiency (LEP) Guidelines combine to require agencies which receive Federal funding to make reasonable accommodations for those with limited English proficiency. This analysis describes VCTC’s efforts to comply with these requirements.
Title VI prohibits recipients of Federal funding from discriminating based on national origin, including LEP individuals, defined as those who have a limited ability to read, write, speak, or understand English. Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency” (2000), operationalizes non-discrimination for LEP populations by directing Federal agencies to publish guidance for funding recipients as to how to meet these statutory obligations.
According to U.S. DOT guidance concerning persons with LEP, the extent of Federally funded recipients’ obligations to accommodate LEP populations is determined by undertaking the U.S.
Department of Transportation (U.S. DOT) four-factor LEP analysis which considers the following:
Factor 1 - The number or proportion of LEP persons to be served or likely to be encountered in a VCTC program, activity, or service.
Factor 2 - The frequency with which LEP persons come in contact with VCTC programs, activities, or services.
Factor 3 - The nature and importance of programs, activities or services provided by VCTC to the LEP population.
Factor 4 - The resources available to VCTC and overall cost to provide LEP assistance.
VCTC utilizes the DOJ’s Safe Harbor Provision, which outlines circumstances that can provide a “safe harbor” for recipients regarding translation of written materials for LEP populations. The Safe Harbor Provision stipulates that, if a recipient provides written translation of vital documents for each eligible LEP language group that constitutes five percent (5%) or 1,000 persons, whichever is less, of the total population of persons eligible to be served or likely to be affected or encountered, then such action will be considered strong evidence of compliance with the recipient’s written translation obligations.
pg. 21
Translation of non-vital documents, if needed, can be provided orally. If there are fewer than 50 persons in a language group that reaches the five percent (5%) trigger, the recipient is not required to translate vital written materials but should provide written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of those written materials, free of cost. These safe harbor provisions apply to the translation of written documents only. They do not affect the requirement to provide meaningful access to LEP individuals through competent oral interpreters where oral language services are needed and are reasonable.
A recipient may determine, based on the Four Factor Analysis, that even though a language group meets the threshold specified by the Safe Harbor Provision, written translation may not be an effective means to provide language assistance measures. For example, a recipient may determine that a large number of persons in that language group have low literacy skills in their native language and therefore require oral interpretation. In such cases, background documentation regarding the determination shall be provided to FTA in the Title VI Program.
Factor 1 - The number or proportion of LEP persons to be served or likely to be encountered in a VCTC program, activity, or service.
The USDOT LEP guidance directs recipients of Federal funding to identify the number or proportion of LEP individuals that are likely to come into contact with Federally-funded services and programs. For the purposes of this analysis, those individuals over five years of age who self-identify as speaking English less than well will be considered LEP persons.
Data Sources
The following data sources were used to assess the prevalence of LEP populations in VCTC’s service area:
• 2018-2022 American Community Survey (ACS) 5-year estimates, for large language families and individual languages
• California Department of Education – English Learner (EL) Data, 2022-2023 school year American Community Survey
VCTC used American Community Survey (American Community Survey 5-Year Estimates, 2022) and California’s Department of Education 2022-2023 data to identify LEP populations within its service area. The American Community Survey provides information on the number of people who ‘Speak English less than “very well”’ also referred to as Limited English Proficient persons.
The California Department of Education data compares student ‘English Learners’ populations with ‘Fluent English Proficiency’ populations to determine the number or proportion of LEP persons to be served or likely to be encountered in a VCTC program, activity, or service.
pg. 22
According to Table 1, 38% of the Ventura County population speak a language at home other than English with Spanish being the most common language spoken by those who ‘Speak English “less than very well”’ at 29.8%. Thirty-eight percent of people five years or older in Ventura County speak a language at home other than English. 39.6% of the population speaks Spanish at home and ‘Speak English less than “very well”’.
pg. 23
Table 1 - Language Spoken at Home2
Speak
English
only or
speak
English
"very well"
Percent
speak
English
only or
speak
English
"very
well"
Speak
English
less than
"very well"
Percent
speak
English
less than
"very
well"
Label Estimate Percent Estimate Percent Estimate Percent Population 5
years and over 796,345 - 680,590 85.50% 115,755 14.50%
Speak only
English 493,871 62.00% - - - -
Speak a language
other than
English
302,474 38.00% 186,719 61.70% 115,755 38.30%
SPEAK A LANGUAGE OTHER THAN ENGLISH
Spanish 237,482 29.80% 143,392 60.40% 94,090 39.60%
Other Indo-
European
languages
23,374 2.90% 18,521 79.20% 4,853 20.80%
Asian and Pacific
Island languages 33,247 4.20% 20,162 60.60% 13,085 39.40% Other languages 8,371 1.10% 4,644 55.50% 3,727 44.50%
CITIZENS 18 YEARS AND OLDER
All citizens 18
years old and
over
573,110 - 522,928 91.20% 50,182 8.80%
Speak only
English 399,992 69.80% - - - -
Speak a language
other than
English
173,118 30.20% 122,936 71.00% 50,182 29.00%
Spanish 130,672 22.80% 92,967 71.10% 37,705 28.90%
2 U.S. Census Bureau: S1601 Language Spoken at Home
pg. 24
Other languages 42,446 7.40% 29,969 70.60% 12,477 29.40% Table 2 shows the languages spoken at home by ability to speak English for persons five years of age and older. Of the 29.8% of the population that speak Spanish, 11.8% ‘Speak English “less than very well”’.
Table 2 - California English Learners Data 2022-23
Language
Total
Enrollment
Number
of
English
Learners
(EL)
Number of
Fluent
English
Proficient
(FEP)
Students
Total
Number
of EL and
FEP
Students
Percent of
Total
Enrollment
that is EL
and FEP
Spanish 25,032 20,408 45,440 35.8
Mixteco 1,027 382 1,409 1.11
Mandarin (Putonghua) 113 461 574 0.45
Filipino (Pilipino or Tagalog) 152 392 544 0.43
Other non-English languages 187 348 535 0.42
Vietnamese 134 279 413 0.33
Arabic 136 209 345 0.27
Farsi (Persian) 82 212 294 0.23
Russian 83 190 273 0.22
Hindi 45 180 225 0.18
Korean 40 174 214 0.17
Telugu 37 153 190 0.15
Japanese 37 105 142 0.11
Tamil 27 108 135 0.11
Hebrew 17 117 134 0.11
Punjabi 47 76 123 0.1
German 23 83 106 0.08
Gujarati 22 83 105 0.08
French 26 77 103 0.08
Portuguese 26 62 88 0.07
Cantonese 17 60 77 0.06
Urdu 18 59 77 0.06
Armenian 18 51 69 0.05
Zapoteco 62 3 65 0.05
Marathi 11 38 49 0.04
Bengali 9 39 48 0.04
Thai 20 26 46 0.04
pg. 25
Language
Total
Enrollment
Number
of
English
Learners
(EL)
Number of
Fluent
English
Proficient
(FEP)
Students
Total
Number
of EL and
FEP
Students
Percent of
Total
Enrollment
that is EL
and FEP
Turkish 14 28 42 0.03
Khmer (Cambodian) 10 23 33 0.03
Italian 6 26 32 0.03
Pashto 16 16 32 0.03
Polish 4 28 32 0.03
Kannada 4 22 26 0.02
Ukrainian 15 11 26 0.02
Dutch 6 18 24 0.02
Hungarian 5 18 23 0.02
Rumanian 1 15 16 0.01
Cebuano (Visayan) 4 11 15 0.01
Albanian 5 9 14 0.01
Samoan 5 8 13 0.01
Ilocano 3 10 13 0.01
Indonesian 5 8 13 0.01
Swedish 5 5 10 0.01
Assyrian 3 6 9 0.01
Serbo-Croatian (Bosnian,
Croatian, Serbian) 8 8 0.01
Bulgarian 4 3 7 0.01
Greek 1 5 6 0
Burmese 4 1 5 0
Malayalam 3 2 5 0
Taiwanese 1 3 4 0
Lao 1 3 4 0
Amharic 2 2 4 0
Kurdish (Kurdi, Kurmanji) 3 3 0
Chaozhou (Chiuchow) 2 2 0
Mayan Languages 2 2 0
Kashmiri 1 1 0
Igbo 1 1 0
Mongolian 1 1 0
Somali 1 1 0
Uzbek 1 1 0
pg. 26
Language
Total
Enrollment
Number
of
English
Learners
(EL)
Number of
Fluent
English
Proficient
(FEP)
Students
Total
Number
of EL and
FEP
Students
Percent of
Total
Enrollment
that is EL
and FEP
Khmu 1 1 0
Swahili 1 1 0
Hmong 1 1 0
Tongan 1 1 0
Marshallese 0
Toishanese 0
Lahu 0
Tigrinya 0
Ventura County Total 126,932 27,581 24,674 52,255 41.17 California State Total 5,852,348 1,112,535 1,197,776 2,310,311 39.48
There are six languages that have more than 1,000 persons who speak English less than “Very Well”: Spanish, Tagalog (incl. Filipino), Chinese, Persian, Vietnamese, and Arabic. Thus, per the guidelines, these would qualify as “Safe Harbor” languages requiring the translation of vital documents. According to FTA guidance under C4702.1B, vital written documents include, but are not limited to, consent and complaint forms; intake and application forms with the potential for important consequences; written notices of rights; notices of denials, losses, or decreases in benefits or services; and notices advising LEP individuals of free language assistance services.
LEP populations that qualify as Safe Harbor Languages and their share of the total LEP population is summarized in Table 3.
Table 3 - Language Spoken at Home by Ability to Speak English for the Population 5 Years and Over3 Language Spoken at Home by Ability to Speak English for the Population 5 Years and Over
Estimat
e
% of Total
Populatio
n
Spanish: Speak English less than "very well" 95,158 12.1% Tagalog (incl. Filipino): Speak English less than "very well" 4,550 0.6% Other and unspecified languages: Speak English less than "very well" 4,116 0.5% Chinese (incl. Mandarin, Cantonese): Speak English less than "very well" 2,926 0.4%
Persian (incl. Farsi, Dari): Speak English less than "very well" 2,220 0.3% Vietnamese: Speak English less than "very well" 1,988 0.3%
3 U.S. Census Bureau – B16001: Language Spoken at Home by Ability Speak English for the Population 5 Years and Over
pg. 27
Arabic: Speak English less than "very well" 1,302 0.2%
Korean: Speak English less than "very well" 773 0.1%
Thai, Lao, or other Tai-Kadai languages: Speak English less than "very well" 708 0.1%
Gujarati: Speak English less than "very well" 705 0.1%
Ilocano, Samoan, Hawaiian, or other Austronesian languages: Speak English less than "very well" 659 0.1%
Russian: Speak English less than "very well" 400 0.1%
Ukrainian or other Slavic languages: Speak English less than "very well" 295 0.0%
Other Indo-European languages: Speak English less than "very well" 238 0.0% Armenian: Speak English less than "very well" 226 0.0%
Punjabi: Speak English less than "very well" 200 0.0%
Italian: Speak English less than "very well" 192 0.0%
Greek: Speak English less than "very well" 178 0.0%
Japanese: Speak English less than "very well" 165 0.0%
Hindi: Speak English less than "very well" 159 0.0%
German: Speak English less than "very well" 150 0.0%
French (incl. Cajun): Speak English less than "very well" 136 0.0% Portuguese: Speak English less than "very well" 134 0.0% Yiddish, Pennsylvania Dutch or other West Germanic languages:
Speak English less than "very well" 105 0.0%
Malayalam, Kannada, or other Dravidian languages: Speak English less than "very well" 98 0.0%
Urdu: Speak English less than "very well" 91 0.0%
Nepali, Marathi, or other Indic languages: Speak English less than "very well" 91 0.0%
Tamil: Speak English less than "very well" 47 0.0%
Telugu: Speak English less than "very well" 41 0.0%
Haitian: Speak English less than "very well" 0 0.0%
Polish: Speak English less than "very well" 0 0.0%
Serbo-Croatian: Speak English less than "very well" 0 0.0% Bengali: Speak English less than "very well" 0 0.0%
Hmong: Speak English less than "very well" 0 0.0%
Khmer: Speak English less than "very well" 0 0.0%
Other languages of Asia: Speak English less than "very well" 0 0.0% Hebrew: Speak English less than "very well" 0 0.0%
Amharic, Somali, or other Afro-Asiatic languages: Speak English less than "very well" 0 0.0%
pg. 28
Yoruba, Twi, Igbo, or other languages of Western Africa: Speak English less than "very well" 0 0.0%
Swahili or other languages of Central, Eastern, and Southern Africa:
Speak English less than "very well" 0 0.0%
Navajo: Speak English less than "very well" 0 0.0%
Other Native languages of North America: Speak English less than "very well" 0 0.0%
California Department of Education – English Learner (EL) Data 2022-23 In addition, FTA recommends seeking school enrollment data to verify the languages spoken in the service area. The California Department of Education collects information regarding the number of students who are English learners and the languages that they use at home. An English learner is defined as an individual who lacks the clearly defined English language skills of listening comprehension, speaking, reading, and writing necessary to success in the school’s regular instructional program. VCTC used the latest available data for the 2022-23 school year for this analysis.
California Department of Education’s survey provides an additional source of data to identify possible LEP populations. While the State’s school data has its shortcomings -- missing households and individuals without school age children; double counting households with two or more children in the schools; and in some cases, missing households where the school children are fluent in English, but other members of the household are not-- it does provide valuable information about minority and immigrant populations.
Looking at the county totals based on data from the California Department of Education’s annual census of students, the most frequently spoken language other than English is Spanish.
Ventura County’s 2022 – 2023 school year data show a student population of 126,932. The number of Spanish speaking English Learners is 25,032 (35.8 percent of the total enrollment that is EL and FEP). The next largest groups of non-English speakers were Mixteco (which is only an oral language) at 1,027 (1.11%); Mandarin - Putonghua, 113 (0.45%); Filipino – Pilipino or Tagalog, 152 (0.43%), (0.13%); Vietnamese, 134 (0.33%), and Arabic, 136 (0.27%).
Given the very low percentages of people who ‘Speak English less than “very well” other than Spanish language speakers, and the fact that that in the past 18 years, VCTC has reported no phone calls, office walk-ins, or written requests for languages other than English or Spanish.
VCTC intends to add Chinese (Mandarin) to its’ translated language portfolio due to Thousand Oaks Transit adding the language to their Title VI Program. Although, Google Translate is not perfect, it provides an additional layer for website translations that can supplement translation materials available to the public. The translation of individual documents will be provided upon request.
pg. 29
Factor 2 - The frequency with which LEP persons come in contact with VCTC programs, activities, or services.
VCTC works with local advocacy groups such as Central Coast Alliance United for a Sustainable Economy (CAUSE), One Step A La Vez, as well as Neighborhood Community Councils to inform LEP populations.
Although Title VI regulations for LEP individuals cover only written materials, a Spanish interpreter is available at the annual Unmet Transit Needs community meetings, virtual meetings, and Public Hearings. VCTC’s Regional Transit Information Center (RTIC) employs bilingual staff to field transit-related phone calls within Ventura County.
VCTC Intercity (contracted with RATP Dev) dispatch and the Valley Express Bus & Dial-A-Ride (contracted with MV Transportation) reservation center have bilingual staff members. For RATP Dev, the breakdown of Spanish speaking staff consists of: drivers (83%), dispatchers (60%), and 25% management with 25% also speaking Indian. Valley Express Bus & Dial-A-Ride operates in non-urban portions of the Santa Clara River Valley. The breakdown of Spanish speaking staff consists of: drivers (71%), dispatchers (100%), and management (75%).
VCTC prints vital materials in English and Spanish including but not limited to: ADA applications, notices of denial, and complaint forms; photo/media consent forms; rider alerts of decreased service; surveys; and the Unmet Transit Needs process information (and Chinese – Mandarin as part of the 2024 Assessment).
Vital written documents include, but are not limited to, consent and complaint forms; intake and application forms with the potential for important consequences; written notices of rights; notices of denials, losses, or decreases in benefits or services; and notices advising LEP individuals of free language assistance services. Examples of vital documents include an ADA complementary paratransit eligibility application, a Title VI complaint form, notice of a person’s rights under Title VI, and other documents that provide access to essential services. Failure to translate these vital documents could result in a recipient denying an eligible LEP person access to services and discrimination based on national origin.
The frequency that LEP persons encounter VCTC Intercity transit programs, activities, or services varies by individual circumstances. A very small proportion of the population uses regional or local transit services. According to the American Community Survey 2022 estimates
4, only about 0.5% of ‘Workers 16 years or over' use public transportation as a means for workplace travel. Transit is used by people to access medical facilities, shopping centers, educational facilities, government resources, homeless shelters, to visit friends and family however, the number of transit users is still relatively small.
4 U.S. Census Bureau – S0804: Means of Transportation to Work by Selected Characteristics for Workplace Geography
pg. 30
Factor 3 - The nature and importance of programs, activities or services provided by VCTC to the LEP population.
VCTC understands that its services are used for transportation to work, school, shopping, medical appointments, and other quality-of-life activities. For transit-dependent individuals, VCTC transit services are extremely important. For this reason, VCTC is committed to translating vital documents relating to its service. Vital documents are those that demonstrate where and how to use VCTC Intercity bus, how to access services and additional information, and information about VCTC’s Title VI program. At this time VCTC does not have the funds required to translate all written materials -- such an undertaking would incur substantial costs and require substantial resources.
In addition, VCTC will continue to offer language interpretation at public meetings when requested. Providing interpretation services to allow LEP populations to participate by obtaining information about VCTC services has been a core activity at VCTC since its creation.
Factor 4 - The resources available to VCTC and overall cost to provide LEP assistance.
As VCTC serves a vast area, outreach is varied and event specific. VCTC Public Participation Plans for various projects lay out the types of public outreach activities that will be undertaken for the various levels of public events. VCTC will continue working with local advocacy groups like CAUSE to ensure contact with LEP populations; there is little to no cost to the agency to do this although it does take time.
IMPLEMENTATION PLAN
Language Assistance Measures
VCTC will continue to use a variety of techniques or practices to provide meaningful, early, and continuous opportunities for all interested Ventura County residents to participate in the dialogue that informs key decisions, regardless of language barriers. This is done in several ways, including:
General Measures or Practices
• Review prior experiences with LEP populations to determine the language services needed.
• Robust use of maps, charts, and photographs to illustrate trends, choices being debated, etc.
• Translate to Spanish various printed materials for the transit services provided by VCTC including but not limited to VCTC Intercity services; Valley Express Bus & Dial-A-Ride services; fare media and other farebox information; freeway call box information; ADA certification materials and services; community outreach event notices; and regional Rideshare materials.
pg. 31
• Work to involve non-profit groups that advocate for persons with limited English proficiency.
• Identify areas within the service area with high concentrations of LEP individuals. • Include LEP populations in transit rider surveys.
• Translation of vital documents including certain news releases, brochures, fact sheets and Unmet Transit Needs notices.
• All translated documents will be posted onto the VCTC website. • Contract with a translation service to handle calls in foreign languages on an as-needed basis
• Ensure competency of translators; have interpreters available, if requested 3 days in advance (72 hours) at meetings.
• Employ multi-lingual staff at the VCTC Regional Transit Information Center. • Encourage multi-lingual transit dispatch staff and transit operators.
Local Community Media
• Work with Spanish language media outlets to place articles about VCTC's work or announce participation opportunities.
• Purchase display ads (when cost-effective) in Spanish language community newspapers to announce public hearings.
Outreach Techniques
When staff prepares a document or schedules a meeting for which the target audience is expected to include LEP individuals then documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population. Interpreters may be available as needed. VCTC will continue to develop relationships with organizations that serve LEP individuals.
MONITORING AND UPDATING OF THE LANGUAGE ASSISTANCE
PLAN (LAP)
VCTC will monitor requests for translations and adjust practices to meet demand while maintaining a basic level of access by LEP populations to key programs and documents. VCTC's Language Assistance Plan (LAP) will be updated periodically as required by U.S. DOT and as needed to reflect significant changes. At minimum, the plan will be reviewed and updated when data from new ACS counts are available, or when it is clear that higher concentrations of LEP individuals are present in Ventura County. Updates will include the following:
• How the needs of LEP persons have been addressed
• Determination of the current LEP population in the service area per the latest Census reports at the community level.
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• Determination as to whether the need for translation services has changed or whether a change in the contractor used for translation services is warranted based on geographical proximity or availability at times needed. • Determine whether VCTC’ s financial resources are sufficient to fund bilingual or multi- lingual language assistance resources needed.
• Determine whether VCTC has fully complied with the goals of this LAP Plan. • Determine whether complaints have been received concerning VCTC’ s failure to meet the needs of LEP individuals.
• Regularly assess the effectiveness of how VCTC communicates with LEP individuals through use of surveys, conversations with advocacy groups etc.
Staff Training
VCTC works to instill its staff with an awareness of and sensitivity to the needs of LEP residents.
The following training will be provided to VCTC staff:
1. Information on the VCTC Title VI Procedures and LEP responsibilities
2. Description of language assistance services offered to the public
3. Documentation of language assistance requests
4. How to handle a potential Title VI/LEP complaint
Dissemination of the VCTC Language Assistance Plan
A link to the VCTC LAP and the Title VI Procedures is included on the VCTC website at www.goventura.org/vctc-transit/riding-vctc/#title-vi
Any person or agency may request a copy of the plan via telephone, fax, mail, e-mail or in person and shall be provided a copy of the plan at no cost. LEP individuals may also request translated copies of the plan.
Questions or comments regarding the LAP may be submitted to the Ventura County Transportation Commission, Title VI Coordinator:
Attn: Peter De Haan, Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive #420 Camarillo, CA 93010
Office: 805.642.1591
Email: [email protected]
MEMBERSHIP OF NON-ELECTED COMMITTEES & COUNCILS
While VCTC does have transit-related, non-elected advisory committees, VCTC does not have control on appointing members, therefore, this requirement does not apply to VCTC.
The Commission is established by California State law; 15 of the Commission members are elected members, the remaining two members are appointed by the County Board of Supervisors (1) and the Mayors’ selection committee (1). The one ex-officio board member,
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appointed by the Governor, is usually the California Transportation Department of Transportation District 7 Director.
The VCTC also has monthly meetings of the Transit Operators Advisory Committee (TRANSCOM), which is composed of one representative from each transit service provider operating in Ventura County, one representative from each of the cities in the County, County of Ventura, Ventura County Air Pollution Control District and the California Department of Transportation – District 7.
As required by state law, VCTC has a Citizens Transportation Advisory Committee and Social Services Transportation Advisory Council (CTAC/SSTAC) which meets quarterly. Two members of the CTAC/SSTAC are citizens appointed by the individual jurisdictions in Ventura County.
The Coastal Express Policy Advisory Committee (CEPAC) meets as needed. Its members include representatives of VCTC, Gold Coast Transit District, Santa Barbara County Association of Governments, and Santa Barbara Metropolitan Transit District.
The Heritage Valley Policy Advisory Committee (HVPAC) reviews the Heritage Valley Transit services and budget, determines if any capital expenditures are required, reviews the contract for operation of the service, and discusses methods of expanding or adjusting the service to respond to the transit needs of the region. The HVPAC is composed of the VCTC Executive Director, Commission members from the Cities of Fillmore and Santa Paula, and the County Supervisor whose district represents the Cities of Fillmore and Santa Paula. HVPAC meets twice a year.
The HVTAC advises the Heritage Valley Policy Advisory Committee (HVPAC) on operational elements of the Services including routes, schedules, adjustments to the performance standards in the Heritage Valley Transit Plan, the annual budget, the annual report, and other service details. HVTAC is composed of staff representatives from VCTC, the cities of Fillmore and Santa Paula, and the County, and a member of the contract operator providing the service.
HVTAC meets four times a year.
MONITORING SUBRECIPIENTS AND CONTRACTORS
In accordance with 49 CFR 21.9(b), and to ensure that subrecipients are complying with the DOT Title VI regulations, primary recipients must monitor their subrecipients for compliance with the regulations. Importantly, if a subrecipient is not in compliance with the Title VI requirements, then the primary recipient is not in compliance.
The Director of Programming is responsible for all subrecipient monitoring. VCTC monitors its subrecipients by ensuring that each entity meets the criteria outlined in Chapter III of Title VI Circular 4702.1B. VCTC collects and reviews subrecipients’ Title VI Programs which are
pg. 34
approved by the subrecipients’ governing board. VCTC also reviews the subrecipients’ website and confirms that their Title VI Notice, Title VI complaint process and Title VI complaint form are available to the public.
VCTC’s subrecipients must submit a copy of their Title VI Program triennially prior to the due date of VCTC’s Title VI Program submission to the FTA. VCTC Programming staff monitors the submissions.
Each VCTC subrecipient Title VI Program includes the following:
1. A copy of the Title VI notice to the public that indicates the subrecipients’ compliance with Title VI and informs the public of the protections against discrimination afforded to them by Title VI.
2. A copy of the subrecipients’ instructions to the public explaining how to file Title VI complaints, including a copy of the complaint form.
3. A list of any public transportation-related Title VI investigations, complaints, or lawsuits filed with the subrecipient. The list only contains investigations, complaints, or lawsuits that pertain to allegations of discrimination based on race, color, or national origin.
FIXED FACILITY IMPACT ANALYSIS
Since 2024, no operational or maintenance facilities have been constructed or are planned before the next Title VI cycle in 2027.
GOVERNING BODY APPROVAL OF TITLE VI PLAN
This section will be updated once the Board of Commissioner’s has approved the Title VI Plan.
pg. 35
PROGRAM SPECIFIC REQUIREMENTS
VCTC Intercity bus operates fewer than 50 fixed route vehicles in peak service.
SYSTEM-WIDE SERVICE STANDARDS
To comply with 49 CFR Section 21.5(b)(2) and 49 CFR Section 21.5(b)(7), Appendix C to 49 CFR part 21, VCTC is required to adopt system-wide service policies necessary to guard against service design and operational policies that have disparate impacts. System-wide policies differ from service standards in that they are not necessarily based on a quantitative threshold. Below are the current standards and policies:
VEHICLE LOADS
Vehicle Load or load factor is a ratio of the number of seats on a vehicle to the number of passengers. Load factor is an indicator of the extent of probable overcrowding or the need for additional vehicles. It is also a means to determine whether the level of service on a particular route at a particular time is adequate to assure a level of service deemed appropriate for the transit system. As a service standard, load factor is typically expressed as a ratio (e.g., 1:1 or 1 seat for every 1 passengers). The load factor is determined by taking the number of seats on a specific route which pass the peak point during the peak hour and dividing that into the number of passengers that are carried past that point during that hour. Vehicle loads are monitored for all routes to determine if additional vehicles are needed to avoid overcrowding. If load factors are exceeded on a regular basis, VCTC will consider adjustments to the schedule.
VCTC Intercity: Vehicle load shall not exceed 1:1 for VCTC Intercity service
Valley Express: Vehicle load shall not exceed 1:1 for Valley Express fixed-route vehicles.
VEHICLE HEADWAYS
Vehicle headway is a measurement of the time interval between two vehicles traveling in the same direction on the same route. The frequency of service is a general indication of the level of service provided along a route and a factor in the calculation of the amount of travel time expended by a passenger to reach their destination. It is generally expressed for peak and off- peak service as an increment of time.
Local bus service is usually more frequent than intercity bus service because the travel distance is generally longer on intercity buses. This is the case for VCTC Intercity services that traverse the county and into neighboring counties to connect with other bus operations and commuter rail.
pg. 36
VCTC Intercity: Scheduled VCTC Intercity headways ranged from less than 30 minutes during peak hours to over two hours for the longer limited runs. Because service to both Los Angeles and Santa Barbara counties is limited, the minimum headways standard shall apply only to VCTC Intercity “intra-county” routes operating within Ventura County. The variation in headways between VCTC Intercity routes and time of day is largely based on the travel patterns and needs of commuters in the county matched with available funding to operate the service. For “intra- county” routes, peak period headways will be a maximum 120 minutes (2 hours), Monday through Fridays. Where offered, peak period weekend headways will be maximum 120 minutes (2 hours). Off peak service headways will be maximum 240 minutes (4 hours).
Valley Express: Peak period headways will be a maximum of 120 minutes (2 hours), Monday through Friday. Where offered, peak period weekend headways will be 120 minutes (2 hours).
Off peak service headways will be maximum 240 minutes (4 hours).
ON-TIME PERFORMANCE
VCTC Intercity: 85% of all runs on time (defined as no more than 8 minutes late). No buses shall arrive ahead of schedule.
Valley Express Fixed Route: 95% of all runs on time (defined as no more than 15 minutes late).
No buses shall arrive ahead of schedule.
SERVICE AVAILABILITY
VCTC Intercity: Commuter bus service differs from local transit systems in that intercity buses run longer distances and make fewer stops to pick up passengers. The VCTC Intercity buses run long distances to connect with local transit systems that serve population centers that are geographically distributed throughout the county. All local municipal bus systems (except Ojai Trolley) have access to VCTC Intercity Bus services by connecting at the most convenient locations for patronage while keeping stops to a minimum for quicker cross-county connections. The common standard used by local transit systems -- normally measured in the distance a person must travel to access transit -- does not work for VCTC Intercity services.
Making VCTC Intercity available for connection to local transit systems shall be considered providing reasonable access to the VCTC Intercity bus system.
Valley Express Bus: Operates fixed route, ADA-paratransit, and general public Dial-A-Ride through the Heritage Valley in Ventura County. The service is provided in the communities of Fillmore, Santa Paula, and the unincorporated communities of Piru and Saticoy through a cooperative agreement between the Cities of Fillmore, Santa Paula, the County of Ventura, and the Ventura County Transportation Commission. It is managed and administered by VCTC.
SYSTEM-WIDE SERVICE POLICIES
Transit Amenities
pg. 37
The VCTC Intercity bus system is a regional commuter system and relies on facilities provided by local transit agencies, Cities, the County, and others for bus stop locations. VCTC selects intercity stop locations to ensure equal access to these amenities by the public.
VCTC Intercity has not installed bus stops or shelters at stop locations and has no plans to do so in the future. All bus stop amenities and bus shelter locations are determined by the jurisdictions which own and control the sites. Most VCTC Intercity bus stops are at locations shared with the local transit provider. Working with local agencies, VCTC makes every effort to place an infopost and sign-blade at every stop.
Any benches, shelters and facilities that exist where VCTC Intercity bus provides service have been provided by another entity, except for the Camarillo Transit Station which is owned by VCTC. GOVCbus, the real-time bus locating technology, is available online (www.GOVCbus.com), via text (41411) or app (iOS and Android), and telephone (805.430.0298).
Vehicle Assignment
All 36 of the VCTC Intercity buses are similar, 45’ over-the-road motor coaches and use similar fuel. Because of this, all buses are interchangeable; vehicle assignments are done in a manner that ensures rotation of fleet vehicles throughout all the routes in the VCTC Intercity system.
The Valley Express fleet is made up of five (5) small, five (5) medium, and five (5) large cutaways for a total fleet of 15 cutaway vehicles. Based on capacity, the larger vehicles are assigned to fixed route and the and medium vehicles are assigned to Dial-a-Ride service; vehicle assignments are done in a manner that ensures rotation of fleet vehicles throughout the service area.
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ATTACHMENT A
Sample Letter Acknowledging Receipt of Complaint
Today’ s Date
Jo Doe
1234 Main St.
Ventura, CA 93001
Dear Ms. Doe:
This letter is to acknowledge receipt of your complaint against the Ventura County Transportation Commission alleging ___________________________________ ___________________________________________________.
An investigation will begin shortly. If you have additional information you wish to convey or questions concerning this matter, please feel free to contact this office using the information below.
Sincerely,
Peter DeHaan
Title VI Coordinator
Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive, Suite 420
Camarillo, CA 93010
Office: 805-642-1591
Email: [email protected]
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Sample Letter Notifying Complainant that the Complaint Is Substantiated
Today’ s Date
Jo Doe
1234 Main St.
Ventura, CA 93001
Dear Ms. Doe:
The matter referenced in your letter of ___________________ (date) against the Ventura County Transportation Commission alleging Title VI violation has been investigated.
(An/Several) apparent violation(s) of Title VI of the Civil Rights Act of 1964, including those mentioned in your letter (was/were) identified. Efforts are underway to correct these deficiencies.
Thank you for calling this important matter to our attention. You were extremely helpful during our review of the program. (If a hearing is requested, the following sentence may be appropriate.) You may be hearing from this office, or from federal authorities, if your services should be needed during the administrative hearing process.
Sincerely,
Peter DeHaan
Title VI Coordinator
Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive, Suite 420
Camarillo, CA 93010
Office: 805-642-1591
Email: [email protected]
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Sample Letter Notifying Complainant that the Complaint Is Not Substantiated
Today’ s Date
Jo Doe
1234 Main St.
Ventura, CA 93001
Dear Ms. Doe:
The matter referenced in your complaint of _______________________ (date) against the Ventura County Transportation Commission alleging ______________________has been investigated.
The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights Act of 1964, had in fact been violated. As you know, Title VI prohibits discrimination based on race, color, or national origin in any program receiving federal financial assistance.
The Ventura County Transportation Commission has analyzed the materials and facts pertaining to your case for evidence of the VCTC’s failure to comply with any of the civil rights laws. There was no evidence found that any of these laws have been violated.
I therefore advise you that your complaint has not been substantiated, and that I am closing this matter in our files.
You have the right to 1) appeal within seven (7) calendar days of receipt of this final written decision from Ventura County Transportation Commission, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration at:
Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor - TCR 1200
New Jersey Ave., SE
Washington, DC 20590
Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not hesitate to call me.
Sincerely,
Peter DeHaan
Title VI Coordinator
pg. 41
Director of Programming
Ventura County Transportation Commission
751 E. Daily Drive, Suite 420
Camarillo, CA 93010
Office: 805-642-1591
Email: [email protected]