4 - Title VI Implementation — Colma City Council, March 11, 2026

STAFF REPORT
TO
: Mayor and Members of the City Council
FROM: Brad Donohue, Director of Public Works and Planning Gelareh Jokar, Project Manager
VIA: Dan Barros, City Manager
MEETING DATE: March 11, 2026
SUBJECT: Study Session – Colma Draft Title VI Implementation Program and Implementation Plan

RECOMMENDATION
This is a study session that will explain why the Council is being asked to adopt this Plan. The study session will have an educational component explaining Title VI policies and the purpose of this federal legislation. The study session will also encourage an open discussion with City Council and public providing a question-and-answer period to go over logistical and cost features that the proposed policies will have upon the Town.

COUNCIL ADOPTED VALUES
Th
is recommendation is consistent with the Council’s adopted values from the Values-Based Code of Conduct for RESPECT. A Title VI Policy will work to build trust with one another and the community, fostering an inclusive, supportive and open environment of communication.

BACKGROUND
Title VI of the Civil Rights Act of 1964 is a federal statute that provides 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 p rogram or activity receiving federal financial assistance. The Town of Colma, because it has applied for and received federal funding, will be required to adopt a plan that encompasses all the programs within Title VI policies and procedures. By having the plan in place, it will assist the Town in future federal funding opportunities as they present themselves. It is important to note that a program and implementation plan such as Title VI of the Civil Rights Act of 1964 is not a requirement of the Town except that if we want to be competitive in pursuing, obtaining and securing federal funding, a plan such as Title VI needs to be in place. The Town does receive federal grants to AGENDA ITEM #4
support many of its transportation projects, and having this policy in place will secure the Towns place in potentially securing current and future federal dollars.

In the 2025- 26 Capital Improvement Program, staff introduced the Title VI Program and Implementation Plan. The Town entered into an agreement with MIG in August of 2025 to develop a plan that which incorporates various policies, procedures and training sessions, so as to meet the Town’s federal grant funding requirements that require that we have a plan in place that is compliant with Title VI of the Civil Rights Act of 1964. Over the past several months , MIG and staff have assembled policies and programs for the Town to be compliant with Title VI.

ANALYSIS/DISCUSSION
The purpose of the Study Session is to review the draft Title VI Program and Implementation Plan, January 2026, (Attachment “A”). The Title VI Program and Implementation Plan will address key components and incorporate features into the plan to ensure the public that the Town is providing strategies to engage low income, minorities and limited English proficiency (LEP) populations in Town events and decision-making opportunities.

The study session will allow us to discuss and ask questions regarding the plan’s key components:
• Non-Discrimination Policy Statement
o Commitment to Title VI Policies
o Framework for administering the Town’s Title VI Plan
• The Town’s Designated Title VI Coordinator
o Designation of a Title VI Coordinator
o Roles and responsibilities
• Limited English Proficiency (LEP) and Language assistance procedures o The Four Factor Analysis
o Safe Harbor Provision
• Filing procedures for complaints as it relates to inefficiencies or inadequacies in the Title VI Program
o Complaint Process and tracking
o Resolution
• Data collection procedures
• Required staff training
o Program topics
o Who needs to attend?
o Frequency
• Annual Accomplishments Report

FISCAL IMPACT
Currently there is not a fiscal impact at this time in reviewing and commenting on the plan. Once the plan is adopted by City C ouncil, future costs will be factored into the T own’s annual budget approval process.

The Town entered into an agreement with MIG in August of 2025 for a not to exceed amount of $69,580.00.

NVIRONMENTAL
The City Council’s discussion of the Draft Title VI Program and Imp lementation Plan is exempt from environmental review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guideline 15306- Information Collection. This specific CEQA exemption consists of basic data collection, research, experimental management, and resource evaluation activities which do not result in a serious or major disturbance to an environmental resource. These may be strictly for information gathering purposes, or as part of a study leading to an action which a public agency has not yet approved, adopted, or funded.

NEXT STEPS
St
aff will take the Council’s direction and feedback. It is anticipated to bring the Draft Title VI Program and Implementation Plan in early Spring of 2026.

TTACHMENTS
A. Draft Title VI Program and Implementation Plan, January 2026

Town of Colma
Title VI Program and Implementation Plan
March 2026

ATTACHMENT A

TITLE VI PROGRAM AND IMPLEMENTATION PLAN

SUBMITTED FOR APPROVAL BY: ________________________
Gelareh Jokar, PMP , LEED AP
Project Manager
(or Nathan)

RECOMMENDED FOR APPROVAL BY: _______________________________________ Nathan Bassett, Administrative Services Director
Title VI Program Coordinator
Town of Colma

APPROVED AS TO FORM BY: ____________________________________________________ Town Attorney
Town Attorney’s Oﬃce

COUNCIL APPROVAL DATE:

RESOLUTION NO.:

Acknowledgements
[TBD}

TABLE OF CONTENTS
I. Introduction ............................................................................................................... 1 II. Title VI Non-Discrimination Policy Statement .............................................................. 2 III. Title VI Program Administration .................................................................................. 3 Town Vision Statement ....................................................................................................... 3 Department Function and Responsibilities ......................................................................... 3 Organizational Chart by Department .................................................................................. 7 IV. Title VI Program Coordinator and Staﬃng Plan ........................................................... 8 V. Key Title VI Program Requirements ............................................................................. 9 VI. Title VI Program Monitoring ..................................................................................... 11 VII. Public Information Requirements ............................................................................. 12 EXHIBIT 1 – WEBSITE POSTING ......................................................................................... 13 EXHIBITS 2, 3, 4 – TITLE VI POSTER – ENGLISH, SPANISH, TAGALOG / FILIPINO ............... 15 VIII. Limited English Proﬁciency Four Factor Analysis ........................................................ 18 Introduction ...................................................................................................................... 18 Factor 1: The Proportion, Numbers and Distribution of LEP Persons ............................... 19 Factor 2: Frequency of Contact with LEP Individuals ........................................................ 20 Factor 3: The Nature and Importance of the Program, Activity or Service to LEP Individuals ........ 21 Factor 4: The Resources Available to the Town and Overall Cost ..................................... 21 Safe Harbor Provision ........................................................................................................ 22 Language Assistance Measures......................................................................................... 23 Staﬀ Training, LEP Plan Monitoring ................................................................................... 24 IX. Complaint Procedure ................................................................................................ 26 Title VI Complaint Timeline ............................................................................................... 30 X. Data Collection Procedures ....................................................................................... 31 XI. Title VI Training ........................................................................................................ 32 XII. Annual Accomplishments Report .............................................................................. 34

XIII. Attachments
ATTACHMENT A – U.S. DOT TITLE VI ASSURANCES A-E ............................................................... A-1 ATTACHMENT B – LIMITED ENGLISH PROFICIENCY DATA COLLECTION FORM ............................ A-9

ATTACHMENT C - LIMITED ENGLISH PROFICIENCY (LEP) STAFF SURVEY FOR LEP FOUR -FACTOR ANALYSIS .................................................................................................................................... A-11 ATTACHMENT D – TITLE VI INFORMATION POSTERS ................................................................. A-14 ATTACHMENT E – EMPLOYMENT NOTICES ................................................................................ A-15 ATTACHMENT F – WRITTEN TRANSLATION OF VITAL DOCUMENTS .......................................... A-16 ATTACHMENTS G1, G2, G3 – EXAMPLE PUBLIC NOTICES IN ENGLISH, SPANISH, AND TAGALOG / FILIPINO ...................................................................................................................................... A-18 ATTACHMENTS H1, H2, H3 – TITLE VI COMPLAINT FORMS IN ENGLISH, SPANISH, AND TAGALOG / FILIPINO ...................................................................................................................................... A-27 ATTACHMENT I – TITLE VI DISCRIMINATION COMPLAINT LOG .................................................. A-30 ATTACHMENT J – TITLE VI TRAINING LOG .................................................................................. A-31

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Town of Colma Title VI Program and Implementation Plan
I. Introduction
The Town of Colma (Town) is a recipient of federal funds from the Federal Highway Administration (FHWA). Recipients of federal funds are required to comply with various federal nondiscrimination laws and regulations, including Title VI of the Civil Rights Act of 1964 (Title VI).

Title VI prohibits discrimination, exclusion from participation, or the denial of beneﬁts against anyone in the United States on the basis of race, color, or national origin in the programs and activities of an agency receiving federal ﬁnancial assistanc e. In addition to Title VI, the other nondiscrimination statutes that aﬀord legal protection are: Section 162 (a) of the Federal -Aid Highway Act of 1973 (23 USC 324) (sex), Age Discrimination Act of 1975 (age), and Section 504 of the Rehabilitation Act of 1973/Americans with Disabilities Act of 1990 (disability). Together, these requirements deﬁne the over-arching Title VI Program.

Recipients of federal funds are required to prepare a plan to clarify roles, responsibilities, and procedures to ensure compliance with Title VI and related non-discrimination statutes. The Town of Colma is committed to ensuring that no person is excluded from participation in, denied the beneﬁts of, or subjected to discrimination under its services on the basis of race, color, or national origin, as protected by Title VI of the Civil Rights Act of 1964.

The Town, through the approval and implementation of the Title VI Program and Implementation Plan (Plan) will ensure compliance with the Title VI of the Civil Rights Act of 1964. The Town expects every manager, supervisor, employee, and sub -recipient of fe deral-aid funds administered by the Town to be aware of and apply the intent of Plan and related nondiscrimination statutes in performing assigned duties.

It is important to also understand that Title VI and the additional nondiscrimination requirements apply to all Town of Colma programs even when only one program receives federal funds. The Civil Rights Restoration Act of 1987 deﬁned the word “program” to make clear that discrimination is prohibited throughout an entire agency if any part of the agency receives federal funds. Simply stated, the Town of Colma is to ensure that none of its activities or programs treats any part of a community any diﬀerently than another.

The Plan is implemented under the designated Title VI Coordinator who works with Directors in every department to implement and monitor compliance with the Plan. The designated Title VI Coordinator is currently the Administrative Services Director or their designee.

The Title VI Program Coordinator is responsible for developing procedures, reporting data, conducting assessments, providing training resources, and tracking complaint resolution, etc. The Title VI Program and Implementation Plan focuses on the functional areas with signiﬁcant public contact responsibilities and provides the policy direction necessary to ensure compliance with Title VI and related nondiscrimination statutes.

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Town of Colma Title VI Program and Implementation Plan
II. Title VI Non-Discrimination Policy Statement
Deﬁnition of Title VI of the Civil Rights Act of 1964
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).

Commitment to Title VI Compliance
The Town of Colma (Town) is committed to ensuring that no person shall on the grounds of race, color, national origin, sex, disability, age, or other protected status be excluded from participation in, be denied the beneﬁts of, or be subjected to discrimi nation in any operation of the T own of Colma as provided by Title VI of the Civil Rights Act of 1964 and related statutes. This plan was developed to guide the Town in its administration and management of Title VI related activities for the public and vendors.

This policy applies to all operations of the Town of Colma, including its contractors and anyone who acts on behalf of the Town of Colma.

Examples of prohibited types of discrimination based on race, color, national origin, sex, disability, age, or other protected status include: denial to an individual any service, ﬁnancial aid, or other beneﬁt; distinctions in the quality, quantity, or manner in which a beneﬁt is provided; segregation or separate treatment; restriction in the enjoyment of any advantages, privileges, or other beneﬁts provided; discrimination in any activities related to highway and infrastructure or facility built or rep aired; and discrimination in employment. Harassment and retaliation are also prohibited forms of discrimination.

Title VI compliance is a condition of receipt of federal funds. The Title VI Coordinator and other Town staﬀ as described in this Plan are authorized to ensure compliance with this policy, Title VI of the Civil Rights Act of 1964, 42 U.S.C § 2000d and related statutes, and the requirements of 23 Code of Federal Regulation (CFR) pt. 200 and 49 CFR pt. 21.

City Manager Date
__________________________________ __________________________

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Town of Colma Title VI Program and Implementation Plan
III. Title VI Program Administration
Town Vision Statement
Colma will be a thriving, inclusive, and sustainable community that fosters economic growth, preserves its cultural heritage, and enhances the quality of life for all residents.

Department Function and Responsibilities

CITY COUNCIL
The City Council is the legislative body and makes laws and policy decisions through the enactment of ordinances and resolutions. The City Council consists of ﬁve members: a Mayor, Vice Mayor, and three Council Members. The City Council guides the City on policies and programs to implement. To promote Title VI and to ensure equity, the City Council will support strategies to improve the participation of under-represented groups in the planning and decision- making process.

CITY ATTORNEY
The City Attorney provides in-house legal counsel and advisory services to the City Council, City Manager, and Town staﬀ. The City Attorney’s oﬃce works closely with other departments to ensure procurements and contracts are consistent with federal, state and local contract laws and regulations. The Attorney’s oﬃce also oversees the application of State Mandates and laws as it aﬀects the Town, including Title VI requirements. Dissemination of vital documents will be in English, Spanish and Tagalog. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

CITY MANAGER
The City Manager’ s Oﬃce provides executive leadership and strategic direction for the T own of Colma, working in partnership with the City Council, staﬀ, and community to implement policies, deliver services, and achieve long-term goals. The Oﬃce is responsible for overseeing day-to-day municipal operations, fostering organizational excellence, Human resource services and promoting ﬁscal sustainability and community engagement. The City Manager’s Oﬃce includes the following divisions: City Clerk, the Administrative Services Director, Public Works Maintenance, and Human Resources . The City manager will work with the designated Title VI Program Manager, currently the Administrative Services Director or their designee and Department Heads and Grant Managers in every department to implement and monitor compliance with the Title VI Prog ram and Implementation Plan. Regarding Public outreach the Dissemination of current events and vital documents will be in English, Spanish, and Tagalog. If language assistanc e is requested, assistance will be provided by in -house bilingual staﬀ or language line service.

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Town of Colma Title VI Program and Implementation Plan

ADMINISTRATIVE SERVICES DEPARTMENT/FINANCE/GENERAL SERVICES/RISK MANAGEMENT Risk Management and General Services: The Administrative Services Director is the Town’s ADA Coordinator responsible for administering ADA requests for reasonable accommodation. Other responsibilities include Risk Manager, chairing the Safety Committee and ensuring the implementation of risk management activities; and General Services function. The Administration Service Director or their designee also serves as the Title VI Program Manager. The Title VI Manager will work with Title VI Liaison Managers and Grant Managers in every department to implement and monitor compliance with the Title VI Program and Implementation Plan.

Dissemination of vital documents will be in English, Spanish, and Tagalog. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

CITY CLERK
The City Clerk’s Oﬃce, a division of the City Manager’s Oﬃce, serves as the custodian of oﬃcial Town records and the facilitator of transparent legislative processes. The Oﬃce prepares and distributes agendas and minutes for Town Council meetings, maintains the Town’s Municipal Code and legislative history, and manages the records retention and destruction program. It ensures compliance with the Brown Act, the Public Records Act, and the Political Reform Act, and administers municipal elections in collaboration with the San Mateo County Elections Oﬃce. The City Clerk will ensure compliance with the Title VI program regarding vital document translation in English, Spanish and Tagalog. The City Clerk will also support the services of the Title VI Program Manager in the Title VI Manager’s absence.

HUMAN RESOURCES
The Human Resources Division is responsible for personnel functions including policy development and compliance, recruitment and retention, compensation and beneﬁts administration. The Division’s budget contains program expenses for the annual employee recognition event, citywide training, safety committee activities and professional consulting services including labor negotiations. Human Resources is responsible for providing translated employment documents for staﬀ that require them.

FINANCE DIVISION
The Finance Division is responsible for paying the Town’s bills, maintaining and reconciling accounts, payroll, ﬁnancial reporting, responding within one business day to vendor and employee inquiries and maintaining related records. The Finance Division is overseen by the Administrative Services Director. The Finance Division will work closely with other departments to ensure procurements and contracts, and dissemination of vital documents are consistent with federal and state laws and regulations, includi ng Title VI requirements. Dissemination of vital documents will be in English, Spanish, and Tagalog.

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Town of Colma Title VI Program and Implementation Plan

POLICE DEPARTMENT
The Police Department provides public safety and crime prevention services with a problem- solving, community policing philosophy while working collaboratively with the City Council, and includes Administration, Patrol, Communications, and Community Service s functions. Grant managers will ensure that procurements and contracts are consistent with federal and state contracting laws and regulations, including Title VI requirements. Dissemination of vital notices regarding services will be in English, Spanish, and Tagalog. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

PUBLIC WORKS & ENGINEERING /PLANNING/ BUILDING DEPARTMENT Public Works consists of the Engineering & Building Division and the Public Works Maintenance Division. The Engineering Division is responsible for the Town’s Capital Improvement Program (CIP), Countywide Storm Water program and maintenance program, Grant Administration, and a variety of other Public Works programs. The Engineering department provides technical oversight to the Maintenance Division which is supervised by the City Manager. The Public Works Maintenance division is responsible for the upkeep and maintenance of public streets, sidewalks, traﬃc signals, streetlights and public facilities, and manages roadway weed and litter control, graﬃti abatement, and sanitary sewer overﬂow response. Public Works Grant Managers will ensure that procurements and contracts are consistent with federal and state contracting laws and regulations, including Title VI requirements. Dissemination of vital notices regarding services will be in English and Spanish. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

The Planning Division is responsible for Advanced (long range) Planning, Current Planning (application processing), Climate Action, Economic Development and Neighborhood Services. The Planning staﬀ, in partnership with other Town staﬀ, residents and the business community, implements the community vision for the physical development of Colma, as described in the General Plan. Speciﬁc activities include: preparing planning studies to update policies and regulations in light of changing laws and conditions to ensure Colma continues to be a desirable community in which to live, work, visit and recreate; coordination with or participation in County and regional planning eﬀorts to represent Colma’s interests; reviewing development proposals to ensure high quality and compatible development; reviewing all building permits for compliance with zoning requirements; enforcing codes and promoting property maintenance; and providing public information about planning and development. Division and Grant managers will e nsure that procurements for construction contracts, Architectural & Engineering services and other professional services contracts are consistent with federal and state contracting laws and regulations, including Title VI requirements. Dissemination of key notices regarding projects will be in English, Spanish, and Tagalog. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

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Town of Colma Title VI Program and Implementation Plan
The Building Division is responsible for facility and building plan approvals, permitting and inspection for code compliance on all building activity. Division and Grant managers will ensure that procurements for construction contracts, Architectural & Engineering services and other professional services contracts are consistent with federal and state contracting laws and regulations, including Title VI requirements. Dissemination of key notices regarding projects will be in English, Spanish, and Tagalog. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

RECREATION
The Recreation Services Department oﬀers a variety of programs, activities, and events for Colma residents of all ages, from youth to seniors, at two park facilities: Colma Historical Park & Community Center and Sterling Park. These programs include Fitness, Enrichment, Special Events, Cultural Activities, Sporting Events, Trips, and Community Gatherings. The department strives to provide a well- rounded selection of oﬀerings that cater to all age groups throughout the ﬁscal year. Division Manager will en sure that procurements for professional services contracts are consistent with federal and state contracting laws and regulations, including Title VI requirements. Dissemination of key notices regarding programs will be in English, Spanish, and Tagalog. If language assistance is requested, assistance will be provided by in-house bilingual staﬀ or language line service.

PUBLIC WORKS MAINTENANCE
Included in the Public Work/ Engineering and Planning Section.

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Town of Colma Title VI Program and Implementation Plan
Organizational Chart by Department

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Town of Colma Title VI Program and Implementation Plan
IV. Title VI Program Coordinator and Staﬃng Plan
Title VI Program Coordinator Identiﬁcation and Contact
The Town Administrator’s Oﬃce is ultimately responsible for assuring full compliance with the pr ovisions of Title VI of the Civil Rights Act of 1964 and relat ed st atut es within the T own. The Town has identiﬁed the Title VI Coordinator to ensure implemen tation of the Town’s Title VI Program and Implementation Plan (Plan). The Title VI Coordinator is:

Nathan Bassett
Title VI Coordinator
Town of Colma
1198 El Camino Real
Colma, CA 94014
[email protected]

Responsibilities of Title VI Coordinator and Title VI Staﬃng Plan The Title VI Program Coordinator is responsible for coordinating the eﬀorts of the Town to comply with Title VI and to investigate any concerns, complaints, or requests regarding access to Town programs, services, and activities.

The Plan focuses on the functional areas with signiﬁcant public contact responsibilities and provides the policy direction necessary to ensure compliance with Title VI and related nondiscrimination statutes. The Department Directors are responsible for the application of Title VI in their respective program areas and are responsible for ensuring Title VI compliance in their respective divisions through policy development, procedures, and monitoring. These individuals work closely with the Title VI Program Coordinator .

Department Directors have the responsibility to implement and monitor the Plan in their functional areas and provide input for program updates, elevate unresolved complaints, ensure that staﬀ have received Title VI training during onboarding and every two years as required and manage program speciﬁc reporting and audits, etc.

Title 23 of the Code of Federal Regulations (CFR) 200.9(b)(11) requires an annual review of the Plan to determine the eﬀectiveness of program areas. The Title VI Program Coordinator and Department Directors will be responsible for the annual review and the update of the Plan.

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Town of Colma Title VI Program and Implementation Plan
V. Key Title VI Program Requirements
The Title VI Program Coordinator in collaboration with Department Directors provides leadership and guidance on the implementation of the Plan. These staﬀ also prepare implementation plans, conduct annual assessments of pertinent program areas, make recommendations to enhance compliance, investigate and resolve Title VI complaints and prepare all necessary reports.

In accordance with 23 CFR Section 200.9(b), the Town is obligated to:
• Develop procedures for prompt processing and disposition of Title VI complaints received directly by the Town.
• Develop procedures for the collection of statistical data (race, color, religion, sex, and national origin) of participants in, and beneﬁciaries of Town’s programs, i.e., relocatees, impacted citizens, and aﬀected communities.
• Develop a program to conduct Title VI reviews of program areas. • Conduct annual reviews of special emphasis program areas to determine the eﬀectiveness of program area activities at all levels.
• Conduct training programs on Title VI and related statutes for Town’s personnel. • Prepare a yearly report of Title VI accomplishments for the past year and goals for the next year.
• Submit annually an updated Title VI Program Implementation Plan to State or Regional Federal Highway Administrator for approval or disapproval (if requested). • Develop Title VI information for dissemination to the general public and, where appropriate, in languages other than English.
• Establish procedures to identify and eliminate discrimination when it is found to exist. • Establish procedures for promptly resolving deﬁciency status and writing the remedial action agreed to be necessary, all within a period not to exceed 90 days.

The Title VI Program Coordinator will assist the Department Directors in meeting the above stated mandates by:
• Providing technical assistance to department liaison managers and grant managers. • Assisting department managers in correcting discriminatory practices or policies. • Reviewing documents as needed for compliance with Title VI to ensure that procedures used have safeguards to prevent discrimination.
• Conducting Title VI compliance reviews.

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Town of Colma Title VI Program and Implementation Plan
• Coordinating the development and implementation of a training program. • Ensuring that Title VI training is provided to staﬀ and material and resources for conducting training sessions and workshops are available. • Developing Title VI information for dissemination to the public and, where appropriate, in languages other than English.
• Processing Title VI external complaints of discrimination. • Collection of statistical data (race, color, national origin, sex, disability, and age) on participants in, and beneﬁciaries of Town’s’ programs, activities, and services. • Identifying and eliminating discrimination when found to exist. • Ensuring Title VI requirements are included in procedure manuals or handbooks. • Preparing and submitting (if requested by State or Federal agencies) the PLAN and the Title VI Accomplishments and Goals Report.
• Assisting department personnel to correct Title VI problems or discriminatory practices or policies found when conducting self-monitoring and/or compliance review activities.

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Town of Colma Title VI Program and Implementation Plan
VI. Title VI Program Monitoring
Title VI Assurances
In addition to self-monitoring and ensuring compliance, the Town is also required to monitor and ensure that contractors and consultants hired for Town projects or programs agree to comply with Title VI of the Civil Rights Act of 1964. This is accomplished by including Title VI Assurance clauses in the contract documents.

Example contract compliance requirements for FHWA Title VI compliance are included as Attachment A.

Annual Update
Title 23 of the Code of Federal Regulations (CFR) 200.9(b) (11) requires an annual review of the Plan to determine the eﬀectiveness of program areas. The Title VI Program Coordinator and the Department Directors will be responsible for the annual review and update of the Plan.

Data collection (Attachment B - Limited English Proﬁciency Data Collection Form) and survey (Attachment C - LEP Staﬀ Survey) will be completed for the annual review and the information will be used to complete the Annual Goals and Accomplishment Report in Section XII and for the Plan update.

The Plan must be submitted to Federal Agencies when a Title VI Compliance Review is initiated.

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Town of Colma Title VI Program and Implementation Plan
VII. Public Information Requirements
To ensure transparency and accessibility, the Town must create a Title VI website page. The dedicated Title VI website (Exhibit 1) will have the Plan, the contact information of the Title VI Program Coordinator, the complaint forms and other related information at https://www.colma.ca.gov/Title-VI-Program/. This information can be accessed in Spanish and Tagalog/Filipino through the Google Translation service available on the website.

In addition, the Town must post Title VI information posters publicly at all Town facilities. The posters in English (Exhibit 2) , Spanish (Exhibit 3) , and Tagalog/Filipino Exhibit 4) will include a person’s rights under the Title VI of the Civil Rights Act of 1964 statement, the contact information of the Title VI Program Coordinator, and the link to the Title VI website. Documentation of this posting is included as Attachment D.

The Town must also post current California and Federal Employment Notices pertaining to employee rights. Documentation of this posting is included as Attachment E.

An additional resource for staﬀ and the public on Title VI is provided at the link below:

FHWA Title VI of the Civil Rights Act and Additional Non-Discrimination Requirements https://highways.dot.gov/civil-rights/title-vi-civil-rights-act-1964-and-additional- nondiscrimination-requirements

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Town of Colma Title VI Program and Implementation Plan
EXHIBIT 1 – WEBSITE POSTING
Title VI
Notice under Title VI of the Civil Rights Act of 1964
In accordance with the requirements of Title VI of the Civil Rights Act of 1964 (“Title VI”), the Town of Colma will not discriminate against, exclude from participation in, or deny the beneﬁts of any person under its services, programs, and activities on the ground of race, color, national origin, or English language proﬁciency.

Eﬀective Communication: The Town of Colma will generally, upon request, provide appropriate aids and services leading to eﬀective communication for persons who are protected under Title VI so they can participate equally in the Town of Colma’s services, programs, and activities , including qualiﬁed interpreters, translated documents, and other ways of making information and communications accessible to individuals who have a limited ability to read, write, speak, or understand English (Limited English Proﬁciency, or LEP).

Modiﬁcations to Policies and Procedures: The Town of Colma will make all reasonable modiﬁcations to policies and programs to ensure that eligible LEP individuals have an equal opportunity to enjoy all of its services, programs, and activities.

Anyone who requires interpretation or translation services for eﬀective communication, or a modiﬁcation of policies or procedures to participate in a service, program, or activity of the Town of Colma should contact the Town’s Title VI Program Coordinator at [email protected] as soon as possible but no later than three (3) business days before the scheduled event.

Complaint Process: Title VI does not require the Town of Colma to take any action that would fundamentally alter the nature of its services, programs, and activities, or impose an undue ﬁnancial or administrative burden. If a person believes they have been discriminated ag ainst or that any service, program, or activity of the Town of Colma is not accessible to LEP individuals, they should submit a complaint to the Title VI Coordinator at (650) 997 -8300, or [email protected]. A signed and dated complaint can be submitted by mail, email, facsimile, or in-person to the Title VI Coordinator as soon as possible, but no later than one hundred and eighty (180) days from the alleged date of discrimination.

The Town of Colma Title VI Complaint process and Complaint Forms in English , Spanish, and Tagalog/Filipino can be found at https://www.colma.ca.gov/Title-VI-Program/.

If an individual is unable to produce a written complaint, the complaint can be taken over the phone. Town staﬀ will assist the individual. If requested, the Town will provide a language or sign interpreter. The Town of Colma will not place a surcharge on a particular LEP individual or any group of LEP individuals to cover the cost of providing interpretation or translation or reasonable modiﬁcations of policy.

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Town of Colma Title VI Program and Implementation Plan
Title VI Coordinator
The Title VI Coordinator is responsible for coordinating the eﬀorts of the Town of Colma to comply with Title VI of the Civil Rights Act of 1964 (“Title VI”) and to investigate any concerns, complaints, or requests regarding access to Town programs, services, and activities.

Nathan Basset
Title VI Coordinator
Town of Colma
1198 El Camino Real
Colma, CA 94014
[email protected]
(650) 997-8300
Fax: (650) 997-8308

Documents
Title VI Complaint Form
Title VI Program and Implementation Plan

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Town of Colma Title VI Program and Implementation Plan
EXHIBIT 2 – TITLE VI POSTER – ENGLISH

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Town of Colma Title VI Program and Implementation Plan
EXHIBIT 3 – TITLE VI POSTER – SPANISH

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Town of Colma Title VI Program and Implementation Plan
EXHIBIT 4 – TITLE VI POSTER -TAGALOG / FILIPINO

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Town of Colma Title VI Program and Implementation Plan
VIII. Limited English Proﬁciency Four Factor Analysis
Introduction
A key provision of Title VI is ensuring that members of the public with Limited English Proﬁciency (LEP) have access to interpretation services and translated materials to support their ability to access Town programs, services, and amenities. This provision is the primary way that recipients of federal funding implement Title VI’s prohibition of discrimination based on a person’s national origin. An LEP person is someone who:
1) Has a primary language other than English
2) Has a limited ability to speak, read, write, or understand English Not only do all federal agencies have to develop LEP plans as a condition of receiving federal ﬁnancial assistance, recipients must comply with Title VI and LEP guidelines of the federal agency from which funds are provided as well. Federal ﬁnancial assistance includes grants, training, and use of equipment, donations of surplus property, and other assistance. Title VI applies to a recipient’s entire program or activity. This means all parts of a recipient’s operations are covered, even if only one part o f a recipient’s organization receives the federal assistance. The Town of Colma receives funds from the U.S. Department of Transportation (U.S. DOT) via the Federal Highway Administration (FHWA) for its roads, as well as additional funding from FHWA under the Congressionally Directed Spending program for its participation in the San Mateo County Sustainable Streets Pilot Project. This section of the Plan is designed to inform the FHWA and the U.S. DOT of our eﬀorts to comply with the laws and regulations speciﬁcally regarding Limited English Proﬁciency (“LEP”) and , to inform the general public of California of the beneﬁts and services available to them regarding LEP through the Town of Colma.

The U.S. DOT published Policy Guidance Concerning Recipients’ responsibilities towards Limited English Proﬁcient individuals in the Federal Register of December 14th, 2005. This guidance applies to all U.S. DOT funding recipients, which include state departments of transportation, state motor vehicle administrations, airport operators, metropolitan planning organizations, and regional, state, and local transit operators, among many others.

However, the Executive Order did not require or direct any change in the services provided by a Federal agency, and left any respective decision -making to Federal-agency heads. The U.S. DOT has not directed any change in federally funded programs or activities in regards to LEP , and the T own of Colma continues to operate its activities and programs in accordance with the U.S. DOT guidance. These recommended plan elements have been incorporated into this LEP Plan.

Methodology for Assessing Language Needs and Reasonable Steps to Respond:

The U.S. DOT guidance outlines four factors that should be analyzed in order to assess the recipient agency’s language needs. The objective of this Four-Factor Analysis is to determine the

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r e a s o n a b l e s t e p s t h e r e c i p i e n t s h o u l d t a k e t o e n s u r e m e a n i n g f u l a c c e s s t o s e r v i c e s f o r L E P persons. The four factors include:

1. The number or proportion of LEP persons eligible to be served or likely to be encountered by a program, activity, or service of the recipient or grantee.

2. The frequency with which LEP individuals come in contact with the program.

3. The nature and importance of the program, activity, or service provided by the recipient to the LEP Community.

4. The resources available to the Town of Colma and overall cost.

The greater the number or proportion of eligible LEP persons, the greater the frequency with which they have contact with a program, activity, or service and the greater the importance of that program, activity, or service, the more likely enhanced language services will be needed. The intent of the U.S. DOT’s guidance is to suggest a balance that ensures meaningful access by LEP persons to critical services while not imposing undue burdens on small organizations and local governments. Smaller recipients with more limited budgets are typically not expected to provide the same level of language service as larger recipients with larger budgets.

In order to assess the needs of the Town in terms of language assistance to LEP individuals, the plan analyzed a variety of data sources. Census data was consulted to determine the languages spoken by LEP individuals. The plan was also informed by a survey completed by a sampling of Town staﬀ from the diﬀerent departments who interact with the community as part of their job.

The Four-Factor Analysis:

This plan uses the recommended four -factor analysis as outlined above. Each of the following factors is examined to determine the level and extent of language assistance measures required to suﬃciently ensure meaningful access to Town of Colma services for LEP individuals.

Recommendations are then based on the results of the analysis.

Factor 1: The Proportion, Numbers and Distribution of LEP Persons The Census Bureau has a range for four classiﬁcations of how well people speak English, these include: ‘very well,’ ‘well,’ ‘not well,’ and ‘not at all.’ For the purposes of this plan, Limited English Proﬁcient persons are considered people that speak English less than ‘very well’.

To determine which languages the Town prioritizes for translation of vital documents, including public-facing Title VI information posters, we assessed the number (≥5,000) and proportion (≥5%) of LEP persons served and/or within the eligible service population.

The 2024 American Community Survey Data for the Town of Colma indicates that 767 (55.9%) of individuals in the Town speak a language other than English. Of those individuals, 318 have identiﬁed themselves as speaking English less than ‘very well’, which r epresents 23.2% of the

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Town of Colma Title VI Program and Implementation Plan
Town’s population 5 years and older. Of the individuals that speak English less than very well, 161 speak Spanish (or 50.6% of the total population that speaks English less than very well), 93 (or 20/2% of the total population that speaks English less than very well) speak Tagalog/Filipino, and 64 speak other languages.

Table #1: Language Spoken at Home

Total Number
of Speakers
Speak English
Less than
"very well"
Speak English
Less than “Very
Well” as Percent
of total
population 5
years old and
over
Population 5 years and over 1,372 318 23.2%
Speak a language other than English 767 318 23.2%
Spanish 445 161 11.7%
Tagalog (incl. Filipino) 172 93 6.8%
Other languages 150 64 42.6%

Source: U.S. Census Bureau, 2023 American Community Survey

Factor 2: Frequency of Contact with LEP Individuals
The Town of Colma conducted an online staff survey to help estimate the frequency with which the Town interacts with LEP individuals. The survey was completed by Town staff from a variety of service areas, including the Police and Recreation departments, considered key service areas due to the nature of their work which involves frequent interactions with the public and which provide services that impact residents’ health, safety and quality of life (as detailed under “Factor 3,” below).

Employees were asked about the frequency of their interactions with the general public and what languages they encounter most frequently. They were also asked if they had ever had to delay and/or modify service delivery for an LEP individual, and if so, to provide details, including steps they took to be responsive to language needs. Those who responded “yes” to a question of whether they had interacted with LEP individuals in the past year were asked to identify how frequently they did so and the mode of t hose interactions (e.g., in-person in the oﬃce or in the ﬁeld, on the telephone, etc.). Finally, all respondents were asked to deﬁne how important eﬀective communication with LEP individuals is to successful delivery of services in their role;

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identify what forms of language assistance they utilized; to provide any additional questions, concerns or comments; and to identify what division / department they work in.

The majority of respondents (77.8%) had interacted with an LEP individual in the past year as part of their job. At least half of these had interacted with LEP individuals in person, in a Town oﬃce (66.7%); in person, out in the ﬁeld (52.4%) and on the telephone (66.7%). Just over three-quarters of these respondents (76.1%) identiﬁed that they interacted with LEP persons at least once a week. The languages other than English most frequently encountered were Spanish and Tagalog.

Factor 3: The Nature and Importance of the Program, Activity or Service to LEP Individuals The Town of Colma provides a variety of essential services to its residents. The inability of an LEP individual to receive services or be delayed in their access to services could have serious implications on an LEP individual. Services that provide for basic needs and that impact residents’ health, safety and quality of life are of particular importance, such as safe and aﬀordable housing, water resources, public facilities operation and maintenance, building safety and accessibility, police / ﬁre and other emergency services, and library services.

The Staﬀ LEP survey included questions about whether staﬀ members have had to delay and/or modify service delivery for an individual with Limited English Proﬁciency, and if they had, to explain / describe the delay and/or modiﬁed service delivery, including any steps they took to be r e s p o n s i v e t o l a n g u a g e n e e d s . T h e y w e r e a l s o a s k e d t o r a t e t h e i m p o r t a n c e o f e ﬀ e c ti v e communication with LEP individuals in the successful delivery of services within their role.

Delays or modiﬁcation of service have been necessary due to language barriers for a little more than a third of survey respondents overall. This was particularly common for respondents who are members of the Police department; all but one had experienced delays of service due to language barriers. The majority of staﬀ responding to the survey, including all but one of the respondents from the Police department, were of the opinion that eﬀective communication with LEP persons was either “extremely important” (59.3%) or “important” (22.2%). It can therefore be determined that it is important that the Town is prepared to serve LEP individuals to avoid any detrimental eﬀects that could occur.

Factor 4: The Resources Available to the Town and Overall Cost The U.S. DOT Guidance Concerning Recipients’ Responsibilities to LEP Persons published in the Federal Register, December 14, 2005, states:
“A recipient’s level of resources and the costs imposed may have an impact on the nature of the steps it should take in providing meaningful access for LEP persons. Smaller recipients with more limited budgets are not expected to provide the same level of language services as larger recipients with larger budgets. In addition, “reasonable steps” may cease to be reasonable where the costs imposed substantially exceed the beneﬁts.

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Recipients should carefully explore the most cost-eﬀective means of delivering competent and accurate language services before limiting services due to resource concerns.” Based on this guidance, the Town of Colma has reviewed the resources it has available to provide language resources in order to estimate the level of language services it can provide. Given the concentration of LEP individuals in the Town, the Town has determined that it has the resources to translate its vital documents into the two languages which fall under the “Safe Harbor” provision (as discussed below):
• Spanish, which is spoken by 50.6% of LEP individuals in the Town, representing 11.7% of the total population 5 years and over; and
• Tagalog/Filipino, which is spoken by 29.2% of LEP individuals in the Town, representing

6.8% of the total population 5 years and over.

Other languages will be provided translation services upon request. The cost associated with the necessary translation of documents will be allocated on an as -needed basis and charged to the program that is responsible for the information being requested.

SAFE HARBOR PROVISION
Because the Department of Transportation (DOT) guidelines regarding “Safe Harbor Provision” for translation of written materials requires the identiﬁcation of “Safe Harbor Languages”, careful attention must be paid to the absolute numbers as well as the percentage of the population that do not speak English in the development of the LEP Plan. FTA Circular 4702.1B states the following with respect to the Safe Harbor Provision:

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. 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 t o receive competent oral interpretation of those written materials, free of cost.

The “Safe Harbor” provision applies to the translation of vital written documents only. Based on sources using U.S. Census data, people in the T own who speak English "less than very well" and meeting the 1,000-person or 5% threshold are Spanish and Tagalog/Filipino speaking people. Per the federal Safe Harbor Provision, the Town has a responsibility to translate vital documents for the department into Spanish and Tagalog/Filipino.

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Determining whether a document is “vital” and therefore requires translation depends on the seriousness of consequences that the LEP individual may face if the information in question is not provided accurately or in a timely manner. The following are examples of written materials that may be considered vital:
• Applications
• Consent forms
• Complaint forms
• Intake forms with potential for health consequences,
• Letters/notices pertaining to eligibility for beneﬁts; rights; the reduction, denial, or termination of services or beneﬁts; that require a response; or that are part of emergency preparedness or risk communications
• Documents that must be provided by law
• Notices regarding the availability of free language assistance services If the document does not fall into one of the above categories, or if its status is unclear, consider whether a member of the public could fail to access or participate in, or be terminated from, a program, service or activity, or suﬀer signiﬁcant ﬁnanc ial, physical, or other harm if they are unable to complete and/or understand the information in that document. If the answer to any of those questions is “Yes,” the document should be considered vital. 1 Language Assistance Measures:

The T own provides notice to LEP persons in a variety of ways. These activities and notiﬁcations include:
• Signage and posters in Spanish and Tagalog/Filipino and notiﬁcation that free language assistance is available.
2 • Verbal communications with bi- lingual staﬀ inform respondents that free language assistance is available including translation of important documents.

The Town has several methods for providing language assistance to LEP person. These activities and notiﬁcations include:

1 For more information, see “Written Translation of Vital Documents,” Attachment F. Source: Health Resources and Services Administration.
2 See Attachment G2 for sample public notices translated into Spanish and Tagalog/Filipino, Exhibit 3 for Title VI informational poster translated into Spanish, and Exhibit 4 for Title VI informational poster translated into Tagalog/Filipino.

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• Town maintains a list of staﬀ with multiple language skills to provide basic language assistance.St a ﬀ w ho ar e eng aging w it h t he p ubli c ma y be assis t ed b y a bi-lingual staﬀ person to address the needs of a LEP-person.
• Bi-lingual Town staﬀ may provide an initial assessment of the level of language assistance support needed and work to schedule the participation of an interpreter or arrange for translations of important documents needs to support the LEP person’s inquiry.

Staﬀ Training:

Town staﬀ will receive training regarding the Plan requirements. New staﬀ will receive training within six months of onboarding. The training will include how to be responsive to a LEP person and the tools available to them. The program also will include potential scenarios where they might encounter an LEP person. Staﬀ are provided strategies to help them respond eﬀectively , regardless of their personal language capabilities.

LEP Plan Monitoring:

At regular intervals, the Title VI Program Manager will conduct a survey of employees from diﬀerent departments to collect information about the number and types of interactions they have with LEP persons to determine if updates or revisions are needed to this plan and related staﬀ training. Census data will also be reviewed as updates are available every ﬁve to ten years.

The plan will also be reviewed and updated as necessary when census data or other information identiﬁes that a higher concentration of LEP individuals are present in the Town.

Review and updates may include the following:
• Determination of the current LEP population in the service area. • Surveying of staﬀ to learn:
 The number and frequency of documented LEP person contacts experienced during the period under review.
 The locations and modes of interaction with LEP persons.  How the needs of LEP persons have been addressed.
• Determination as to whether the need for language assistance services has changed. • Determination as to whether the Town’s language assistance programs have been eﬀective and suﬃcient to meet the need.
• Determination as to whether complaints have been received concerning the Town of Colma’s failure to meet the needs of LEP individuals.
• Determination as to suﬃciency of staﬀ training to meet the needs of LEP individuals.

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Town of Colma Title VI Program and Implementation Plan
• Determination as to whether ﬁnancial resources are suﬃcient to fund the language assistance services needed.
• Determination as to whether the Town of Colma fully complies with the goals of this LEP Plan.

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Town of Colma Title VI Program and Implementation Plan
VIII. Complaint Procedure
General Overview of Title VI Rights
• What are Title VI rights?
Title VI of the Civil Rights Act of 1964 (Title VI) forbids discrimination against anyone in the United States on the basis of race, color, or national origin in the programs and activities of an agency receiving federal ﬁnancial assistance. In addition t o Title VI, other nondiscrimination statutes forbid discrimination based on sex, age, and disability.

Recipients of federal funds are required to prepare a plan to clarify roles, responsibilities, and procedures to ensure compliance with Title VI and relat ed non- discrimination statutes. In accordance with 23 CFR Section 200.9(b)11, the Town is obligated to develop procedures for prompt processing and disposition of Title VI complaints received directly by the Town.
• What is discrimination under Title VI?
Discrimination under Title VI of the Civil Rights Act of 1964, as amended, is an act (action or inaction), whether intentional or unintentional, through which a person, solely because of race, color, national origin, creed, sex, or age, has been otherwise subjected to unequal treatment or impact under any program or activity receiving Federal ﬁnancial assistance from the U.S. Department of Transportation Federal Highway Administration (FHWA). • Who may ﬁle a Title VI complaint?
A complaint may be ﬁled by any person that they, or any speciﬁc class of persons, have been subjected to discrimination by the Town of Colma based on race, color, sex, disability, age, or national origin.

How to ﬁle a Title VI Complaint?
Any person who believes that they have been subjected to discrimination by the Town of Colma based on race, color, or national origin may ﬁle a signed, written complaint up to one hundred and eighty (180) days from the date of the alleged discrimination by completing and submitting the Town’s Title VI Complaint Form.

T h e C o m p l a i n t F o r m c a n b e o b t a i n e d o n t h e T o w n o f C o l m a ’ s w e b s i t e a t https://www.colma.ca.gov/Title-VI-Program/.
• Complainants must include the following information:

1. Name and contact information (e.g., telephone number, email address, mailing address, etc.).

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2. Dates of the following: alleged act of discrimination, when the complainant became aware of the alleged discrimination (if applicable), and when the conduct occurred, the latest instance of conduct, and contact information of any witnesses.

3. Location of the alleged discrimination.

4. Contact information of any witnesses (if applicable) (e.g., telephone number, email address, mailing address, etc.).

5. A detailed description of the issues, including names and job titles of those individuals perceived as parties to the discriminatory activity.

6. Signature and date that the complaint form is being submitted. • Methods for submitting a complaint:

A signed and dated complaint can be submitted by mail, email, facsimile, or in-person to:

Nathan Bassett
Title VI Coordinator
Town of Colma

Email: [email protected]
Mailing Address: 1198 El Camino Real, Colma, CA 94014
Fax: (650) 997-8308
For all complaints sent via the U.S. Postal Service or other delivery service, the Town encourages all complainants to certify mailings to ensure that all written correspondence can be tracked.

If an individual is unable to produce a written complaint, the complaint can be taken over the phone; Town staﬀ will assist the individual. If requested, the Town will provide a language or sign interpreter.

An individual also has the right to ﬁle a complaint directly with the federal or other agency supplying funding for any particular program or service. For the Town of Colma, when the alleged discrimination has taken place in association with a program or service funded by the FHWA, a person may ﬁle a complaint directly with:

Federal Highway Administration
U.S. Department of Transportation
Oﬃce of Civil Rights

Mailing Address: 8th Floor E81-105, 1200 New Jersey Avenue, SE, Washington, DC 20590
Email: [email protected] – or – [email protected] Fax: 202-366-1599

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Town of Colma Title VI Program and Implementation Plan
More information can be found at the following link: https://highways.dot.gov/civil- rights/title-vi-complaint
What happens to the complaint after it is submitted?
• Initial Receipt and Tracking
All Title VI complaints received by the Town should be forwarded directly to the Title VI Coordinator. The Title VI Coordinator will promptly enter the complaint into the log of all Title VI complaints identifying complainant’s name, factual allegations, alleged harm, and basis for the discrimination complaint based on a protected class, and will assign a formal complaint number. The Town of Colma complaint log will be kept by the Town Administrator’s oﬃce.

Within one (1) business day of receiving the formal complaint, The Title VI Coordinator will determine jurisdiction, suﬃciency, and any need for additional information , and forward the complaint to the funding agency for review and investigation. The coordinator will attempt to contact the complainant if additional information is needed. The complainant will have 60 days from the date of the letter to send the requested information to the Title VI Coordinator. If the complainant fails to respond as reques ted, the Town may terminate the investigation and close the complaint. • Forwarding and Investigation
The appropriate authority for investigation diﬀers depending on the federal or other agency supplying funding for the particular program or service that is the source of the complaint. Per the FHWA Guidance Memorandum, Processing of Title VI Complaints, dated June 13, 2018, all Title VI complaints that result from a program or service funded by FHWA are to be forwarded to Caltrans to be submitted to the FHWA Division Oﬃce.

Other agencies may allow the Town to investigate the complaint, although some may request that a copy of the complaint be forwarded to the funding agency. If any funding a g e n c y w i s h e s t o i n v e s ti g a t e a c o m p l a i n t d i r e c t l y i n p l a c e o f t h e T o w n d o i n g s o , t h e process will be similar to that required by FHWA.

If more information is needed to resolve the case, the FHWA investigator may contact the Complainant.

A person may ﬁle a complaint directly with:

Federal Highway Administration
U.S. Department of Transportation
Oﬃce of Civil Rights

Mailing Address: 8th Floor E81-105, 1200 New Jersey Avenue, SE, Washington, DC 20590 Email: [email protected] – or – [email protected]

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Town of Colma Title VI Program and Implementation Plan
Fax: 202-366-1599
If the Town of Colma is to investigate the complaint, the Title VI Coordinator will be responsible for routing it to the Department Director in the appropriate Department. The Department Director will be responsible for ensuring that the complaint is addressed and resolved at department level or, if not possible at the department level, elevating the complaint to the Title VI Coordinator level. The Town shall also provide appropriate assistance to complainants, including those persons with disabilities, or those who are limited in their ability to communicate in English. Additionally, the Town shall make every eﬀort to address all complaints in an expeditious and thorough manner. Town will promptly resolve deﬁciencies and prepare the necessary remedial action within 90 days. • Notiﬁcation
Within 90 calendar days of receipt of the complaint or requested additional information, the appropriate federal agency, Department Director, or Title VI Coordinator will issue either: 1) a closure letter or 2) a Notice of Determination. A closure letter summarizes the allegations and states that there was not a Title VI violation or there was insuﬃcient evidence to substantiate the alleged violation and that the complaint will be closed. A Notice of Determination summarizes the allegations and informs th e complainant whether the complaint was found to have merit and it will take appropriate corrective action to remedy the matter. The Notice of Determination shall include information regarding appeal rights, including:
 Town of Colma will reconsider this determination if new facts come to light; and  If a Complainant is dissatisﬁed with the determination and/or resolution set forth, the Complainant has the right to appeal.

If the Complainant disagrees with the response set forth in the Notice of Determination, they may appeal by submitting a written request to the Title VI Coordinator within 10 calendar days after receipt of the Notice of Determination. The appeal shall be suﬃciently detailed and contain any items the Complainant feels were not fully understood. The Title VI Coordinator will notify the Complainant of their decision to accept or reject the appeal within 10 calendar days of receipt. In cases where the Title V I Coordinator agrees to reconsider, the matter shall be reviewed in accordance with the Town’s referral to review process. The complainant also has the right to appeal the Town’s decision to the appropriate federal agency, by ﬁling a request for an appeal no later than 180 days after the date of the ﬁnal decision.
• Dismissal
A complaint may be recommended for dismissal for the following reasons:
 The complainant requests withdrawal of the complaint.

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Town of Colma Title VI Program and Implementation Plan
 The complainant fails to respond to repeated requests for additional information needed to process the complaint.
 The complainant cannot be located after reasonable attempts to contact them.

Title VI Complaint Timeline
Schedule for Completion Action
Within 180 days from the date of the alleged
discrimination
Complainant must send Complaint Form via
mail, email, facsimile, or direct delivery.

Within one business day of receipt of
complaint
Title VI Coordinator:
• Enters complaint into log
• Determines jurisdiction, suﬃciency,
and need for additional information
• Sends complaint to appropriate
authority
Within 60 days of receiving request for
additional information
Complainant must send requested
information to the Title VI Coordinator or
requesting agency
Within 90 days of receiving complaint or
requested additional information
Appropriate authority (federal agency, Title VI
Coordinator, or Department Director) will
investigate complaint, ensure that
deﬁciencies are resolved and necessary
remedial action prepared, and issue a Notice
of Determination or closure letter.

Within 10 days of receipt of notiﬁcation
directly from the Town of Colma
If Complainant disagrees with ﬁnding in a
complaint investigated by the Town,
Complainant may submit a written request to
the Title VI Coordinator to appeal the ﬁnding.

Within 10 days of receipt of a letter of appeal
received by the Town of Colma
The Title VI Coordinator will notify the
Complainant of their decision to accept or
reject the appeal.

Within 180 days of receipt of notiﬁcation
from a federal agency
If Complainant disagrees with ﬁnding in a
complaint investigated by a federal agency,
Complainant may submit a written request to
the investigating agency to appeal the
ﬁnding.

The Town will regularly review and update the Plan to reﬂect any changes to requirements regarding Title VI complaints for funding agencies.

Complaints Forms and Example Complaint Log can be found in Attachments H1, H2, H3, and I.

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Town of Colma Title VI Program and Implementation Plan
IX. Data Collection Procedures
The purpose of data collection and analysis is to identify beneﬁts and burdens of the planned project on the surrounding communities as well as identifying any disproportionate or disparate impact or burden on the minority populations. Town will perform most of the data collection and analysis as projects are planned in the Town.

Data collection eﬀorts speciﬁc to each department and division will be established and carried out as required by each speciﬁc federal funding agency. Data collection may include activities such the following:
• Public Outreach: A review of U.S. census tract data to determine the demographics of the area where a project is proposed. The demographics will guide outreach activities and required services. If the information yields people residing in the project area speak a language other than English, the Town would make provisions to have translation/interpretation services available if requested. • Complaint Tracking: Tracking discrimination complaints and monitoring their status and resolution.
• Limited English Proﬁciency (LEP): Tracking requests received from LEP persons for inquiries and services, as well as interpretation or translation services provided. A survey is conducted annually to learn the frequency and nature of staﬀ interactions with LEP individuals. (See Attachment B for LEP Data Collection Form and Attachment C for LEP Staﬀ Survey.)
• Contracts and Awards: On federally funded projects the Town may have to establish Disadvantaged Business Enterprise (DBE)
3 goals and include the speciﬁc Good Faith Eﬀort
requirements in the procurement.

The Town may also be required to post the procurement in DBE websites such as DBE GoodFaith ( https://www.dbegoodfaith.com/) and small business enterprise websites s u c h a s S B A (https://eweb.sba.gov/gls/dsp_sbabanner.cfm). Town departments collect demographic data on contract bidders and awardees for all projects and programs receiving federal funding. The data collected is analyzed to ensure non -discrimination in the bidding and award processes. The data is collected using the Disadvantaged Business Enterprise Form.

3 As of October 3, 2025, the U.S. Department of Transportation published an Interim Final Rule which updates 49 CFR Part 23 governing the DBE Program. The California Unified Certification Program (CUCP) must reevaluate all DBE firms under the new criteria before their eligibility can be confirmed. Until the reevaluation is complete, DBE goals cannot be set on contracts, and no DBE participation may be counted toward any DBE goal. Overall DBE goal submissions for FY 2026 and beyond will be developed under the revised § 26.45 requirements once re- evaluations are complete. Until then, no new DBE contract goals are to be established on federally funded projects.

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Town of Colma Title VI Program and Implementation Plan
X. Title VI Training
The Title VI Coordinator is responsible for scheduling and conducting a training every two years so that T own staﬀ stay up to date with program requirements. The Title VI T raining Program is designed to ensure that Town staﬀ fully understand their responsibilities regarding the requirements outlined in this Plan, including the requirement that all community members must receive equal treatment and access to Town activities and programs. The training includes strategies and procedures to help ensure this happens, with particular emphasis on supporting staﬀ in understanding their responsibilities and improving their ability to respond eﬀectively to a LEP person or an individual who may have a concern about being treated unfairly. A typical time allotted for the training is 1 -1.5 hours. The training should include the topics described below.

The order and time allocation for the topics may vary depending on the audience, time available, and other factors.

Training Program Topics

1. Introduction to the Town’s Plan
Participants are introduced to the Plan and be given an orientation to the Plan components and the laws and regulations that direct these programs.

2. Review of the Town’s programs and activities
P a r ti c i p a n t s r e v i e w t h e T o w n ’ s p r o g r a m s a n d a c ti v i ti e s a n d d i s c u s s h o w t h e T i t l e V I requirements might apply to their job. Participants identify potential circumstances for interaction with LEP persons or individual who may have concerns about the response or treatment they are experiencing.

3. Review of outreach materials and complaint reporting procedures Participants receive information about how the Town publicizes its responsibilities and complaint procedures.

4. Discussion of potential responses
Participants will review potential complaint responses to learn how to respond eﬀectively to an LEP person or an individual with concerns.

5. Review of data collection and reporting procedures
Participants are introduced to Town data collection procedures to help support the Title VI Program Manager’s ability to meet the requirements.

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Town of Colma Title VI Program and Implementation Plan
Training Program Participants:

It is essential that Town staﬀ are aware of their responsibilities and receive training on a regular cycle. All Civil Rights oﬃcials and Town staﬀ who have public contact must be aware of and comply with the intent of Title VI and related nondiscrimination statutes.

Training Program Schedule:

The goal is to complete the initial training within 6 months of Plan approval. Subsequent trainings will be provided every two years, with an emphasis on any updates to the federal requirements.

New employees must complete the training within 6 months of hire.

A Training Log is included as Attachment J.

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Town of Colma Title VI Program and Implementation Plan
XI. Annual Accomplishments Report
Goals – 2026 Accomplishments Status
1 Conduct outreach activities to Town staﬀ and public to ensure broad awareness of Title VI Program requirements

• Place posters (English and Spanish) in prominent
locations in Town offices and public areas of buildings

• Post the Plan, Complaint Procedures and Form and
posters on Town website (English and Spanish)

• Use regular meetings of staﬀ and management on a
quarterly basis to refresh staﬀ awareness of Title VI
program requirements

• Reach out to community partners and share posters
and information

• Conduct outreach to contractors and consultants
regarding Title VI assurance contracting requirements
for: Compliance with regulations, non-discrimination,
solicitations for sub-agreements and information and
reports

• Respond to inquiries as needed
2 Conduct training activities for Town Staﬀ and Leadership • Conduct training for Town staﬀ on a two-year cycle
• Work with consultant to ﬁnalize training materials and program

• Conduct training on a regular schedule with Town
leadership

• Provide web-based training platform to train new staff as part of their on-boarding process

• Provide general handout to contractors and
consultants and program requirements

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Town of Colma Title VI Program and Implementation Plan
Goals – 2026 Accomplishments Status
3 Provide translation/interpretation services
• Translate Title VI information into Spanish
• Translate vital documents into Spanish
• Provide translation and interpretation services as
requested

4 Complete documentation of complaints and resolution as needed

• Document complaints and resolution as needed
• Document any program enhancements and adjust
training program as needed

XII. Attachments
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ATTACHMENT A – U.S. DOT TITLE VI ASSURANCES A-E
Appendix A
During the performance of this contract, the contractor, for itself, its assignees, and successors in interest (hereinafter referred to as the “contractor”) agrees as follows:

1. Compliance with Regulations: The contractor (hereinafter includes consultants) will comply with the Acts and the Regulations relative to Nondiscrimination in federally-assisted programs of the U.S. Department of Transportation, Federal Highway Administration, as they may be amended from time to time, which are herein incorporated by reference and made a part of this contract.

2. Non-discrimination: The contractor, with regard to the work performed by it during the contract, will not discriminate on the grounds of race, color, national origin, age, sex, or disability in the selection and retention of subcontractors, including procurements of materials and leases of equipment. The contractor will not participate directly or indirectly in the discrimination prohibited by the Acts and the Regulations, including employment practices when the contract covers any activity, project, or program set forth in Appendix B of 49 CFR Part 21.

3. Solicitation for Subcontracts, Including Procurements of Materials and Equipment: In all solicitations, either by competitive bidding, or negotiation made by the contractor for work to be performed under a subcontract, including procurements of materials, or leases of equipment, each potential subcontractor or supplier will be notiﬁed by the contractor of the contractor’s obligations under this contract and the Acts and the Regulations relative to Non- discrimination on the grounds of race, color, national origin, age, sex, or disability.

4. Information and Reports: The contractor will provide all information and reports required by the Acts, the Regulations, and directives issued pursuant thereto and will permit access to its books, records, accounts, other sources of information, and its facilities as may be determined by the Recipient or the FHWA to be pertinent to ascertain compliance with such Acts, Regulations, and instructions. Where any information required of a contractor is in the exclusive possession of another who fails or refuse s to furnish the information, the contractor will so certify to the Recipient or the FHWA, as appropriate, and will set forth what eﬀorts it has made to obtain the information.

5. Sanctions for Noncompliance: In the event of a contractor’s noncompliance with the Non - discrimination provisions of this contract, the Recipient will impose such contract sanctions as it or the FHWA may determine to be appropriate, including, but not limited to:

1. withholding payments to the contractor under the contract until the contractor complies; and/or

2. cancelling, terminating, or suspending a contract, in whole or in part.

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6. Incorporation of Provisions: The contractor will include the provisions of paragraphs one through six in every subcontract, including procurements of materials and leases of equipment, unless exempt by the Acts, the Regulations and directives issued pursuant thereto. The contractor will take action with respect to any subcontract or procurement as the Recipient or the FHWA may direct as a means of enforcing such provisions including sanctions for noncompliance.

Provided, that if the contractor becomes in volved in, or threatened with litigation by a subcontractor, or supplier because of such direction, the contractor may request the Recipient to enter into any litigation to protect the interests of the Recipient. In addition, the contractor may request the United States to enter into the litigation to protect the interests of the United States.

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Appendix B

CLAUSES FOR DEEDS TRANSFERRING UNITED STATES PROPERTY
The following clauses will be included in deeds eﬀecting or recording the transfer of real property, structures, or improvements thereon, or granting interest therein from the United States pursuant to the provisions of Assurance 4:

NOW THEREFORE, the U.S. Department of Transportation as authorized by law and upon the condition that the California Department of Transportation will accept title to the lands and maintain the project constructed thereon in accordance with Title 23 U.S.C. , the regulations for the administration of the preceding statute, and the policies and procedures prescribed by the FHWA of the U.S. Department of Transportation in accordance and in compliance with all requirements imposed by Title 49, Code of Federal Re gulations, U.S. Department of Transportation, Subtitle A, Oﬃce of the Secretary, Part 21, Non - discrimination in Federally - assisted programs of the U.S. Department of Transportation pertaining to and eﬀectuating the provisions of Title VI of the Civil Rights Act of 1964 (78 Stat. 252; 42 U.S.C. § 2000d to 2000d- 4), does hereby remise, release, quitclaim and convey unto the California Department of Transportation all the right, title and interest of the U.S. Department of Transportation in and to said lands described in Exhibit A attached hereto and made a part hereof. (HABENDUM CLAUSE)
T O H A V E A N D T O H O L D s a i d l a n d s a n d i n t e r e s t s t h e r e i n u n t o t h e C a l i f o r n i a D e p a r t m e n t o f Transportation and its successors forever, subject, however, to the covenants, conditions, restrictions and reservations herein contained as follows, which will remain i n eﬀect for the period during which the real property or structures are used for a purpose for which Federal ﬁnancial assistance is extended or for another purpose involving the provision of similar services or beneﬁts and will be binding on the California Department of Transportation, its successors and assigns.

The California Department of Transportation, in consideration of the conveyance of said lands and interest in lands, does hereby covenant and agree as a covenant running with the land for itself, its successors and assigns, that (1) no person will on the grounds of race, color, or national origin, be excluded from participation in, be denied the beneﬁts of, or be otherwise subjected to discrimination with regard to any facility located wholly or in part on, over, or under such lands hereby conveyed [,] [and]* (2) that the California Department of Transportation will use the lands and interests in lands and interest in lands so conveyed, in compliance with all requirements imposed by or pursuant to Title 49, Code of Federal Regulations, U.S. Department of Transportation, Subtitle A, Oﬃce of the Secretary, Part 21, Non - discrimination in Federally - assisted programs of the

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U.S. Department of Transportation, Eﬀectuation of Title VI of the Civil Rights Act of 1964, and as said Regulations and Acts may be amended[, and (3) that in the event of breach of any of the above-mentioned non-discrimination conditions, the Department w ill have a right to enter or re¬enter said lands and facilities on said lands, and that above described land and facilities will thereon revert to and vest in and become the absolute property of the U.S. Department of Transportation and its assigns as such interest existed prior to this instruction].* (*Reverter clause and related language to be used only when it is determined that such a clause is necessary in order to make clear the purpose of Title VI.)

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Appendix C

CLAUSES FOR TRANSFER OF REAL PROPERTY ACQUIRED OR IMPROVED UNDER THE ACTIVITY ,

FACILITY , OR PROGRAM
The following clauses will be included in deeds, licenses, leases, permits, or similar instruments entered into by the California Department of Transportation pursuant to the provisions of Assurance 7(a):

A. The (grantee, lessee, permittee, etc. as appropriate) for himself/herself, his/her heirs, personal representatives, successors in interest, and assigns, as a part of the consideration hereof, does hereby covenant and agree [in the case of deeds and leases add “as a covenant running with the land”] that:

1. In the event facilities are constructed, maintained, or otherwise operated on the property described in this (deed, license, lease, permit, etc.) for a purpose for which a U.S. Department of Transportation activity, facility, or program is extended or for another purpose involving the provision of similar services or beneﬁts, the (grantee, licensee, lessee, permittee, etc.) will maintain and operate such facilities and services in compliance with all requirements imposed by the Acts and Regulations (as may be amended) such that no person on the grounds of race, color, or national origin, will be excluded from participation in, denied the beneﬁts of, or be otherwise subjected to discrimination in the use of said facilities.

B. With respect to licenses, leases, permits, etc., in the event of breach of any of the above Non- discrimination covenants, the California Department of Transportation will have the right to terminate the (lease, license, permit, etc.) and to enter, re -enter, and repossess said lands and facilities thereon, and hold the same as if the (lease, lice nse, permit, etc.) had never been made or issued.*
C. With respect to a deed, in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will have the right to enter or re -enter the lands and facilities thereon, and the above described lands and facilities will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns. *
(*Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)

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Appendix D

CLAUSES FOR CONSTRUCTION/USE/ACCESS TO REAL PROPERTY ACQUIRED UNDER THE

ACTIVITY , FACILITY OR PROGRAM

The following clauses will be included in deeds, licenses, permits, or similar instruments/agreements entered into by the California Department of Transportation pursuant to the provisions of Assurance 7(b):

A. The (grantee, licensee, permittee, etc., as appropriate) for himself/herself, his/her heirs, personal representatives, successors in interest ,and assigns, as a part of the consideration hereof, does hereby covenant and agree (in the case of deeds and lea ses add, “as a covenant running with the land”) that (1) no person on the ground of race, color, or national origin, will be excluded from participation in, denied the beneﬁts of, or be otherwise subjected to discrimination in the use of said facilities , (2) that in the construction of any improvements on, over, or under such land, and the furnishings of services thereon, no person on the ground of race, color, or national origin, will be excluded from participation in, denied the beneﬁts or, or otherwise be subjected to discrimination, (3) that the (grantee, licensee, lessee, permittee, etc.) will use the premises in compliance with all other requirements imposed by or pursuant to the Acts and Regulations, as amended, set forth in this Assurance.

B. With respect to (licenses, leases, permits, etc.) in the event of breach of any of the above of the above Non-discrimination covenants, the California Department of Transportation will have the right to terminate the (license, permits, etc., as appropriat e) and to enter or re -enter and repossess said land and the facilities thereon, and hold the same as if said (license, permit, etc., as appropriate) had never been made or issued.*
C. With respect to deeds, in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns. (*Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)

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Appendix E
During the performance of this contract, the contractor, for itself, its assignees, and successors in interest (hereinafter referred to as the “contractor”) agrees to comply with the following non¬discrimination statutes and authorities, including, but not limited to: Pertinent Non - Discrimination Authorities:
• Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq., 78 stat. 252), prohibits discrimination on the basis of race, color, national origin); and 49 CFR Part 21. • The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, (42 U.S.C.§ 4601), (prohibits unfair treatment of persons displaced or whose property has been acquired because of Federal or Federal-aid programs and projects); • Federal-Aid Highway Act of 1973, (23 U.S.C. § 324 et seq.), prohibits discrimination on the basis of sex;
• Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794 et seq.), as amended, (prohibits discrimination on the basis of disability); and 49 CR Part 27; • The Age Discrimination Act of 1975, as amended, (42 U.S.C. § 6101 et seq.), prohibits discrimination on the basis of age);
• Airport and Airway Improvement Act of 1982, (49 U.S.C. § 471, Section 47123), as amended, (prohibits discrimination based on race, creed, color, national origin, or sex); • The Civil Rights Restoration Act of 1987, (PL 100- 209), (Broadened the scope, coverage and applicability of Title VI of the Civil Rights Act of 1964, The Age Discrimination Act of 1975 and Section 504 of the Rehabilitation Act of 1973, by expanding the deﬁnition of the terms “programs or activities” to include all of the programs or activities of the Federal - aid recipients, sub -recipients and contractors, whether such programs or activities are Federally funded or not);
• Titles II and III of the Americans with Disabilities Act, which prohibit discrimination of the basis of disability in the operation of public entities, public and private transportation systems, places of public accommodation, and certain testing entities (42 U.S.C. §§ 12131 – 12189) as implemented by Department of Transportation regulations 49 C.F.R. parts 37 and 38;
• The Federal Aviation Administration’s Non -discrimination statute (49 U.S.C. § 47123) (prohibits discrimination on the basis of race, color, national origin, and sex); • Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, which ensures discrimination against minority populations by discouraging programs, policies, and activities with disproportionately Page A-8
Town of Colma Title VI Program and Implementation Plan
high and adverse human health or environmental eﬀects on minority and low -income populations;
• T o ensur e compliance w ith Title VI, you must t ak e reasonable st eps t o ensure that LEP persons have meaningful access to your programs;Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating because of sex in education programs or activities (20 U.S.C. 1681 et seq).

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ATTACHMENT B – LIMITED ENGLISH PROFICIENCY DATA COLLECTION FORM

Town of Colma
TITLE VI Limited English Proﬁciency Data Collection Form The purpose of this form is to collect translation (written) and interpretation (oral) data regarding LEP (Limited English Proficiency) services provided by the Town of Colma.

These services can be provided at the request of a customer or provided proactively for the benefit of the customer. Multiple services can be reported on a single form given those services were all provided / initiated on the same day.

1. What type of service was provided? (select all that apply)  Translation (written)
 Interpretation (oral)

2. If a document was translated (written), what is the name of the document translated?

______________________________________________________________________________

3. Language translated / interpreted (select all that apply)  Spanish
 Tagalog (incl. Filipino)
 Chinese (incl. Mandarin, Cantonese)
 Vietnamese
 Korean
 Armenian
 Persian (incl. Farsi, Dari)
 Russian
 Arabic
 Japanese
 Punjabi

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 Thai, Lao or other Tai-Kodai languages
 Other (please specify which language or languages):

______________________________________________________________________

4. What was the nature of the interpretation / translation? (select one)  Public Outreach Event
 Public Counter Interaction
 Phone call from customer
 Email from customer
 Mail from customer
 Other (please explain)

______________________________________________________________________

5. How was the service provided? (select all that apply)  City Employee
 Telephone Interpreting Service or Other Vendor

6. Date the translation / interpretation was completed (estimate if unknown)

______________________________________________________________________________

7. Department providing the service:

______________________________________________________________________________

8. Employee Name:

______________________________________________________________________________ Please email this completed form to [email protected].

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ATTACHMENT C - LIMITED ENGLISH PROFICIENCY (LEP) STAFF SURVEY

FOR LEP FOUR-FACTOR ANALYSIS

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The purpose of this survey is to understand how the Town of Colma can better support members of the public in knowing and exercising their rights under Title VI of the federal Civil Rights Act of 1964, which establishes 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).

Survey participation is voluntary and is estimated to take ≤15 minutes.

Thank you very much for your participation!

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Q1: In the context of your work for the Town of Colma, how often do you interact with the public? This includes in-person, phone, and email / letters.
 More than once every day.
 About once a day.
 About once a week.
 About once a month.
 A few times a year.
 Other. Please explain: __________________________________________

Q2: Which languages do you most frequently encounter? Please select all that apply:
 English
 Spanish
 Tagalog
 Chinese
 Korean
 Other. Please specify:
 Other. Please specify:

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Q3: In the past year , have you interacted with a person with Limited English Proﬁciency (LEP) as part of your job? An LEP individual speaks English “less than very well. ” LEP also includes individuals who do not speak English and may have communicated with you in another language.
 YES (proceed to question 3b)
 NO (proceed to question 5)

Q3b: On average, how frequently do you encounter LEP individuals as part of your job?  More than once every day.
 About once a day.
 About once a week.
 About once a month.
 A few times a year.
 Other. Please explain: __________________________________________

Q3c: Where and/or how do you interact with LEP individuals? (check all that apply)  In person, in a City oﬃce
 In person, out in the ﬁeld
 On the telephone
 In writing (email, letters, etc.)
 At a public workshop or meeting
 Other (please specify)

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Q5: Have you ever had to delay and/or modify service delivery for an individual with Limited English Proﬁciency (LEP?
 Yes.

Q5a: Please explain / describe the delay and/or modiﬁed service delivery, including any steps you took to be responsive to language needs:
 No

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Q7: In your role, how important to the successful delivery of services is eﬀective communication with individuals who have Limited English Proﬁciency?
[LIKERT SCALE]
5- Extremely important.
4- Important.
3- Somewhat important
2- Minimally important.
1 - Not important at all.

Unsure

Q8: What forms of language assistance do you utilize when serving individuals with Limited English Proﬁciency? (select all that apply)
 Online translator
 Staﬀ translator
 Hand gestures
 None
 Other. Please specify: __________________________________________

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Q9: What questions or concerns do you have, if any, about serving LEP individuals in your professional role?
Q10: Is there anything else you would like to share about your experience serving LEP individuals?

Q11: What is your name? [OPTIONAL]
Q12: What is your title? [OPTIONAL]
Q13: What is your division?

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ATTACHMENT D – TITLE VI INFORMATION POSTERS
[to be added once posters are posted in Town facilities and photos with each location identiﬁed by facility name and address are provided.]
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ATTACHMENT E – EMPLOYMENT NOTICES

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ATTACHMENT F – WRITTEN TRANSLATION OF VITAL DOCUMENTS

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ATTACHMENT G1 – EXAMPLE PUBLIC NOTICES (ENGLISH)

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ATTACHMENT G2 – EXAMPLE PUBLIC NOTICES (SPANISH)

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ATTACHMENT G3 – EXAMPLE PUBLIC NOTICES (TAGALOG/FILIPINO)

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ATTACHMENT H1 – TITLE VI COMPLAINT FORM (ENGLISH)

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ATTACHMENT H2 – TITLE VI COMPLAINT FORM (SPANISH)

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ATTACHMENT H3 – TITLE VI COMPLAINT FORM (TAGALOG/FILIPINO)

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ATTACHMENT I – TITLE VI DISCRIMINATION COMPLAINT LOG

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ATTACHMENT J – TITLE VI TRAINING LOG

Colma City CouncilMarch 11, 2026

Colma City Council
March 11, 2026